| Comment Number: | 522418-00323 |
| Received: | 6/1/2006 3:03:18 PM |
| Organization: | Rainbow Health |
| Commenter: | Renee Lubbers |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam, I am writing this letter in strong opposition to the proposed B.O. Rule R511993. I understand it is the responsiblity of the FTC to protect the public, but the rule as propsed would make it very difficult for me to operate my business as a Shaklee Distributor. The most confusing and burdensome section is the 7 day waiting period. Most of the people who sign up do so to buy products at wholsale and if they wish to become involved in the business all we need is a Tax ID or SS number. Shaklee also has a 90% buy back policy which includes the membership for up to 2 years. I am very uneasy about the rule of disclosing a minimun of 10 purchasesers near the prospective purchaser. Everyone is concerned about identity theft, and if I tell a prospect if they get involved with the business that I may have to disclose some personal information, do you think they would want to get involved? I think not. Providing the 10 references could also damage the business of numerous of our distributors. Some people who would do this part time may feel that the list would be a means to solicit existing distributors. It is also a astronamical administrative burden. I would need to provide Shaklee with the prospects address, and then wait to receive the list of 10 of the nearest distriubtors for the past 3 years. Each prospect will need a customized disclosure statement. In view of the fact that most people get into the direct selling part-time to earn extra income the extra work will make it seem impossible to do what they need to do. The proposed rule calls for the release of any information regarding lawsuits that allege mistrpresentation even if the company was found innocent or not liable. It does not make sence to me to me that I would have to disclose these lawsuits unless Shaklee or its officers, directors or sales deparment had been found guilty or liable. Myself and my business partner have been Shaklee consumers and Distributors for 3 years and the reason we got involved is because we love the products and wanted to earn extra income. We now are working on the time when we will depend on it as sole incomes. While I appreciate the FTC's work to protect the consumers, I believe this proposed rule has many uninteded consequences for direct sellers and that there are less burdensome alternatives available to the agency to achieve its goals. Thank you for your time in considering my comments. Sincerely, Renee Lubbers