Comment Number: 522418-00116
Received: 5/31/2006 2:41:39 PM
Organization: Mannatech Independent Associate
Commenter: Therese Alme
State: AZ
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing because I am concerned about the proposed Business Opportunity Rule R511993. If this rule, in it's current written form, is passed, it would have a devastating impact on my home based business. I am an Independent Associate with Mannatech, Inc. I know that it is your role to protect the public from unfair and deceptive acts or practices but some of the sections in the rule would paralyze my business developement. Having my home based business allows me to work from home, take care of my family and take care of my health. If I was unable to stay at home, I would not be able to work a full time job due to my physical illness and limitations. I am happy, my family is happy and I am producing business and income opportunities to other people just like me. In the proposed rule, there is a section that specifies a 7 day waiting period to enroll new associates and customers. The Mannatech associate enrollment packs cost between $99 and $1100. We just bought a couch for less than $1000 and didn't have to wait 7 days. If I was told I had to wait 7 days to "think about it", not only would I wonder about that, but I would be offended that some entity is suggesting that I have not thought it over enough or well enough myself. That is just wrong. Additionally, Mannatech Inc., already has a return policy and cancellation policy for all it's products including the sales kits. My business would be overly burdened and my growth would be dramatically impacted if, as a small business owner, had to take my valuable time to keep detailed reports and records and then submit it to the corporate office. Regarding litigation information. In this country's current business environment there is an out of control climate of litigation. Anyone or any company can be sued for almost anything! It does not make any sense that I would have to disclose these lawsuits unless Mannatech is found guilty. Otherwise, Mannatech and I are put at an unfair advantage even though Mannatech has done nothing wrong. Lastly, another section of the rule would require the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I would provide those references, however, due to the major concerns with IDENTITY THEFT, I would be uncomfortable giving out personal information of purchasers (without their approval) to strangers (prospective buyers). That is WRONG and dangerous. ALSO, in order to get a list of 10 prior purchasers, I would need to send his/her address to the corporate office and wait for the list to be sent. And to have this specific sentence, as proposed in the rule, "If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers". People will not sign on to that...not in this time of privacy and identity theft concerns. Why would anyone agree to share their personal information with someone they have never met? That statement alone, could kill my business. I have been involved with Mannatech for nearly 2 years. I purchased the "associate" sales kit, primarily for the best price for the excellent products that I needed, and secondly for the business benefits. Through Mannatech I have been able to recover my health and build an income that my family relies on. Your proposed rule would most likely take that away from us. I appreciate all the efforts of the FTC to protect consumers, but I believe this rule would have a tremendous negative impact on endless numbers of individuals. I hope you consider alternatives to the rule that would meet your goals and continue to allow for productive and honest business development and financial success. Thank you for your consideration. Sincerely, Therese Alme