| Comment Number: | 522418-00457 |
| Received: | 6/2/2006 1:09:23 AM |
| Organization: | |
| Commenter: | Jenny Williams |
| State: | AR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opportunity Rule R511993 Dear Sirs: I wish to express my STRONG OPPOSITION to the above rule. It is the responsibility of the FTC to protect the public from unfair and deceptive acts or practices, but this rule wuld make it very difficult for me to operate my Shaklee business. The 7 day waiting period to enroll new distributors is extremely confusing and burdensome. Most of the people who sign an application do so for the purpose of buying Shaklee products at wholesale. They are solely consumers of the products. Later if they decide to build a business all they must do is supply Shaklee with their SSN or Tax ID No. There is no additional kit, fee or application required. The Member Kit costs only $19.95. This is far less than many if not most consumer purchases, from TV's to household appliances, none of which reuire a 7 day waiting period. Also the 7 day waiting period is unnecessary because Shaklee already has a 90% buyback policy for products, including Member Kit, purchased within the last 2 years. The proposed rule requires disclosure of 10 prior purchasers nearest to the prospective buyer. There are many problems with this. In this day of identity theft, I am uncomfortable giving out personal infomation of others to strangers without their knowledge or consent. I understand that those who sign up after the rule takes effect would be told in writing that their contact information could be disclosed to other buyers int he future. This would dissuade new people from signing up as distributors as they are concerned not only about identity theft but privacy issues. People don't want to share their personal information to people they haven't met. Providing the 10 references could also damage the businesses of numerous Shaklee distributors. Lower ranking distributors are often involved in more than one direct selling company. Providing a lsit to a potential recruit, who may be in a competitive company, may be an invitation to solicit existing distributors for such other opportunity. The 10 reference requirement is also an administrative burden. To obtain the lsit of 10 prior purchasers, I will have to provide Shaklee with the prospective distributor's address and wait to receive the lsit of the 10 nearest distributors who became distributors within the past three years. Each recruit will need a customized disclosure statement. This will result in additional delay before my person can sign an application. Since many join to earn extra income for a specific purpose, vacation or holiday purchases, the long wait the rule will entail may make their goal unattainable. The rule calls for release of any information regarding lawsuits over a 10 year period...no matter whether the company was found innocent or not liable. It makes no sense that I would have to disclose lawsuits unless there was guilt or liability involved. A 50 year old company such as Shaklee would be at a disadvantage compared to start-up DS companies which may not yet have experienced litigation but are far more likely to have legal issues surrounding their opportunities. I have been a Shaklee Distributor for 30 years. I began because I loved the company's nutritional products and needed to earn additional income working from home. Now my family depends upon this income for our livelihood. While I appreciate the work of the FTC to protect consumers, I believe this proposed new rule has many unintended 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, Jenny Williams