Comment Number: 522418-00524
Received: 6/2/2006 12:33:50 PM
Organization: Mannatech, Inc.
Commenter: Sue Robinson
State: NC
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

RE: Business Opportunity Rule - R 511993 Concerning the proposed Business Opportunity Rule - R 511993; my efforts to build a small business as a Mannatech, Inc. Independent Associate would suffer to the point of extinction. I know that the FTC is trying to guard against businesses with “unfair and deceptive acts or practices”. However, the proposed rule will make it impossible for me to continue in business. One of the most devastating aspects of the proposed rule is the seven day waiting period to enroll new Mannatech, Inc. associates or members. There is no additional charge for a sales kits…it’s all product cost (from $35 to the Family Value Pack at $1,099). This waiting period gives the impression that there is something shady about our activities. What if I purchased something from Wal-Mart and was told I’d have to wait seven days for the merchandise? Also, this proposed seven day waiting period is not needed since Mannatech, Inc.—a company which belongs to the Council for Responsible Nutrition and helps set standards for the industry—already has a 90% buyback policy for all products/sales kits. I have been consuming Mannatech, Inc. glyconutritional products since 1997. Four years ago I became involved with marketing since there is so much evidence-based science to validate what I knew to be true…the products really do work. My husband is wanting to fully retire and I’m counting on commission income from Mannatech, Inc. to allow him to do so. The work that the FTC undertakes to protect consumers is very much appreciated. However, I feel certain that this proposed new rule would put me out of business. Please, please, consider other alternatives to this proposed rule. And, thank you in advance for your consideration.