| Comment Number: | 522418-00621 |
| Received: | 6/3/2006 11:08:13 AM |
| Organization: | Signature HomeStyles |
| Commenter: | Rebecca Klompstra |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-00621.pdf Download Adobe Reader |
Comments:
Rebecca Klompstra Independent Team Leader Signature HomeStyles June 3, 2006 FTC: I am very concerned about the proposed Business Opportunity Rule R511993. I feel this could be very damaging to my career as a Signature HomeStyles Representative. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will make it very difficult if not impossible for me to sell Signature HomeStyles products and recruit others to do so. I feel the seven-day waiting period to enroll new Representatives is the most damaging. With our company, a new representative can start her business for only $100-$175. This isn’t a large investment. Everyday people make much larger investments into home improvement projects, health & wellness items & even cosmetic surgeries & there is not a seven-day waiting period. With our business, a recruit can earn back her investment very quickly. This waiting period gives the impression that there might be something wrong with the plan or the program. I also think this seven-day waiting period is unnecessary, because Signature HomeStyles already has a 90% buy-back policy for all products including Starter Cases purchased by a salesperson within the last 12 months. With this waiting period requirement, I will need to keep very detailed records when I first speak to someone about Signature HomeStyles and will then have to send in many reports to the Signature HomeStyles Home Office. The proposed law to disclose lawsuit information is hideous. Doctors aren’t even made to do this & they hold our lives in their hands. I do not feel the proposed law to disclose lawsuit information is fair. This should only be done if the company has been found guilty in a lawsuit. It does not make sense to me that I would have to disclose these lawsuits unless Signature HomeStyles is found guilty. Otherwise, Signature HomeStyles and I are put at an unfair advantage even though Signature HomeStyles has done nothing wrong. The proposed rule requires the disclosure of a minimum of 10 Representatives nearest to the prospective Representative. I would be greatly opposed to my name & contact information being given out without having known the person it is being distributed to. In this day of identity theft, this would be a golden ticket for criminals. He or she could simply inquire on the business opportunity & in return receive a list of 10 local representatives who work evenings. I see this as a breach of privacy for the representatives. Many evenings, my teenage child is home alone for a few hours while I work my shows. How troubling this will be for me if my contact information is given out to strangers who know I will not be home. I am eager to provide references to inquiring prospects, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. And in turn, I do not want my information handed out to strangers either. There’s too much at risk for my family’s safety. I also feel that someone in a competing business could simply inquire on the business opportunity & in turn, receive a list of our local representatives & ultimately use the list to recruit those people into their own business. I just don’t see a good outcome with disclosing this information. People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. I have been a Signature HomeStyles Representative for more than 5 years. This is my primary income. I invested the $100 into my business knowing that if I was not successful within 1 year, I could return the case for a 90% buy-back. Signature HomeStyles is very upfront about that information. Working in this business is my way of buying & selling locally. In Michigan, the economy has had its hardships with big companies moving out of the country & factories closing down. When I can serve as a local vendor to our community & help other woman to do the same in their community, I’m doing my part in keeping the local economy thriving. I help many other women start their own businesses. I invest my time into helping them start a business and maintain a business. This isn’t about “signing someone up”. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are other alternatives available in achieving its goals. Thank you for your time in considering my comments. Sincerely, Rebecca Klompstra Signature HomeStyles Team Leader