Comment Number: 522418-00090
Received: 5/25/2006 4:40:16 PM
Organization:
Commenter: Claire Jenkins
State: PA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear FTC, It has come to my attention that you are proposing to make some changes in the laws that govern multi-level marketing and the process for enrolling new people into the network. I certainly support the requirement that the cancellation or refund policy must be disclosed before the person signs up. However, I believe that creating a seven-day waiting period would add to costs and hassle without really helping protect anyone from fraud. Requiring contact information for a minimum of 10 prior purchasers is an especially bad idea. If nothing else, this would violate the privacy of the purchasers! And can you imagine placing such a burden on other businesses? I urge you instead, to do all in your power to encourage this kind of business. My experience is that MLM companies provide efficient access to quality products that would not otherwise be readily available to consumers. The two nutritional products companies that I have been associated with for years are Shaklee and Mannatech. Both of them supply much needed opportunities for consumers to educate themselves about issues vital to our health. Simplistic, Madison Avenue hype is completely inappropriate in the area of helping people make decisions about how to maintain their health. The information oriented, person-to-person aspects of MLMs has helped me become interested in doing research and changing my lifestyle to such an extent that if everyone in my age bracket were as healthy as I am, there would be no health care crisis! In both cases, I was enrolled by people who were basically housewives, wanting to help their friends and to make some money doing so. Please do not put stumbling blocks in front of such people. Keep the difficult process of finding and enrolling new purchasers as simple as possible. I am also in complete disagreement with the idea that every legal action against a company must be disclosed to potential purchasers. This should only happen after a company or representative is found guilty. Thank you for your attention to these issues, Claire Jenkins