Comment Number: 522418-00442
Received: 6/1/2006 11:11:42 PM
Organization: Springanew
Commenter: Leslie Baldwin
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear FTC, Having been a content Independent Distributor of Nature's Sunshine Products and Business Owner for over 6 years I am appalled at this Business Opportunity Rule. You cannot pass such proposals that dramatically penalize thousands, if not hundreds of thousands of small businesses. If a person wishes to break the law to conduct a scam they are going to falsify the proposed data too. Thus causing legitimate businesses to spend dramatically more time on record keeping - for little, if any, positive gain. If an individual is going to spend hundreds to thousands of dollars on a business opportunity they should be doing the proposed research anyway. Rather than researching and publishing proposals as this which strike at the heart of free enterprise, you should be spending the money on education. There is no glory or victory in passing such a proposal when it will shut down thousands of independent distributorships. Only those business opportunities such as restaurant franchises will be able to afford the cost burden and as stated before - purchasers of these opportunities should be doing their own research. If I am an Independent Distributor and thus my own company, how can I legally obligate other Independent Distributors to provide references? How am I to legally receive law suit information if I am not a party? If the manufacturer is obligated to do this - and I doubt the legality of forcing Independent Distributors to provide personal data for public distribution (can we say identity theft?), the increased cost will be reflected in higher product and business costs - ultimately passed on to the customer. Plus who is going to enter into a business with such burdensome obligations? Since many small direct sales businesses are run by women, you not only run the risk of discrimination but also harming the American Family by reducing the opportunity to earn money and yet structure the business around family. I vote no for this proposal. Sincerely, Leslie Baldwin Springanew leslie@springanew.com Independent Nature's Sunshine Distributor Wellness Educator