|Received:||6/2/2006 10:26:24 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I strongly oppose the Business Opportunity Rule R511993 as it would make it very diffficult for me to operate my business as a Shaklee Distributor. The seven-day waiting period to enroll new distributors would be very burdensome. Most of the people that sign an application do so to purchase products at a discount - they are soley consumers. If they later wish to build a business, all they must do is supply Shaklee Corporation with their SS number or Tax ID number. There is no additional kit, fee or application required. The Shaklee Membership Kit costs only $19.95. This is far less than many, if not most consumer purchases, from tvs to household appliances, none of which require a seven-day waiting period. I feel it is unnnecessary in that Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. I especially don't like the disclosure of 10 prior purchasers in their area. I would not feel comfortable giving out information to others. It would definitely hurt my business as people are concerned about privacy and identity theft. It would also present an administrative burden. The rule to release information regarding lawsuits is unfair also. It doesn't make sense to disclose this unless the company were found guilty as there are so many frivolous lawsuits now days. Fifty-year old companies like Shaklee will be at a disadvantage compared to start-up companies. There are certainly other ways to check out a company and I encourage my prospects to do so. While I appreciate the work of the FTC to protect consumers, I believe the proposed new rule has many unintended consequences for direct sellers and that there are less burdensome alternative available to the agency to achieve its goals. Thank you for considering my comments.