| Comment Number: | 522418-00428 |
| Received: | 6/1/2006 10:23:15 PM |
| Organization: | Stampin' Up (Independent Demonstrator) |
| Commenter: | Heather Tierney |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing to express my dismay and displeasure at the proposed Business Opportunity Rule. As a direct sales professional, I find certain aspects of the proposal to be evidence of a serious attempt to quash the business of direct sellers. As one example, my understanding of the rule is that it would require direct sellers to furnish prospective "recruits" with the names of as many as 10 other members of the organization in the area as "references." I'm sure you can understand why I, as a sales professional, find this proposal to be extremely offensive: For one thing, Wal-mart isn't required to give me the names and addresses of the local Kmart and Target stores. In most cases, people who sign up to join my organization with me are current and former customers of MINE. Being forced to give these customers the contact information for my competitors (other direct sellers within my organization) as "references" is tantamount to sending them elsewhere for business information and advice. I want my propspective recruits to rely on me, because I take pride and pleasure in providing members of my downline with the best advice I can. That is a major part of the direct-selling relationship. Instead of taking aim at the reliable, well-known and highly placed direct sales organizations, why not go after the less reputable ones? Surely a direct seller with a membership in the Direct Sales Assocation (a large trade industry group with standards for ethical and profesional conduct) is not the intended target of these proposed "reforms." Instead, please seek ways to make it more difficult for scam artists to stay in business. Please don't damage our reputable businesses, in the guise of "improvements." One suggestion: Please find a way to limit the advertising of scam artists. Just this afternoon, I saw a television commercial that promised HUGE, impossible returns in very short periods of time. The commercial touted a sales manual for real estate ventures. I'm sure you are aware that the only venture being sold here is the manual itself, and any other so-called business materials. Before you enact these changes, please seek other comments from high-ranking, reputable direct sellers. Stampin' Up, Creative Memories, Pampered Chef, Usborne Books, Tupperware, etc. -- these are reputable businesses. Granted, direct sales is not for everyone, but for many of us, our businesses are a cornerstone of our daily lives, which we live with integrity and ethics. Thank you for your consideration of these comments. -- Heather Tierney