| Comment Number: | 522418-00398 |
| Received: | 6/1/2006 8:01:55 PM |
| Organization: | TruHealth, Inc. |
| Commenter: | Kasara Delene |
| State: | WA |
| 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 because I am concerned that if proposed Business Opportunity Rule R511993 is adopted in its present form, my livelihood as a Nature's Sunshine distributor and small business owner will be significantly undermined. I will basically have to shut my store down and prevent my over 1000 customers from having access to information to help them affordably make choices for their health. The very thought of governmental interference in the free enterprise process strikes fear in the hearts of Americans everywhere. Cherished values are a stake, and the FTC needs to be aware of the dangers of ill considered action. The public is not well served by the FTC's over regulation of an industry that is causing absolutely no harm and more than adequately polices itself by remedying any and all complaints by members of the public. Nature's Sunshine complies with all applicable buy back requirements and always makes it easy for individuals to exit the Company, if the business opportunity is not right for them. While the FTC needs to protect the public where necessary, this proposed rule is hopelessly overbroad and misguided. The seven-day waiting period is unnecessary and will interfere with my ability to enter into lawful transactions and enroll new people that wish to purchase products at a discount for their families. People buy TV's, cars, and other much more costly items without such a waiting period. This proposed waiting period gives the impression that something is wrong with the plan. And, the burdensome paperwork, which will not even be read by the public, makes it extremely difficult for the individual participant to fully comply, thereby risking fines and other penalties for such failures, however innocent. By these actions, the FTC does a disservice to the consuming public and Americans everywhere who are trying to get ahead by starting their own business, or earning necessary supplemental income to help support their family. I am also concerned because this raises privacy issues due to ID theft and safety. While I appreciate the work of the FTC in protecting consumers, I believe this proposed new rule has many unintended consequences that could be avoided by a less burdensome approach. I understand there may be fraudulent groups out there, but the FTC's proposed rule would unfairly target legitimate direct selling businesses. It is hard to imagine all Tupperware, Mary Kay, Longaberger, Avon and Amway direct selling representatives having to follow these rules. All of these home businesses would basically be put out of business. So much for mom’s across America trying to make an extra income for their families. I have been selling Nature’s Sunshine products since 1993, originally from my home, and from 2 different store locations since then. I currently have a 4-year-old sun and this is my only source of income. I love my job, love providing for my family by myself, and love being able to help people help themselves both from the Nature’s Sunshine Products and also the opportunity it offers them to help their families with health and financially. I know we are an integral part of this community helping to empower people to help themselves in a positive way. I can’t imagine going back to a job I hate, that doesn’t help me, my family or the community as a whole. If this passes, this is most likely what will happen. Thank you for your time in considering my comments. Sincerely yours, Kasara D'Elene, B.Sc., C.N.H.P., M.H. Traditional Naturopath President of TruHealth, Inc. Member of National Nutritional Foods Association www.nnfa.org Certified Member of IIPA (International Iridology Practitioners Association)