|Received:||6/4/2006 7:07:44 PM|
|Organization:||Shaklee Independent Distributor|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I strongly oppose the proposed Business Opportunity Rule R511993. I appreciate the resopnsiblity of the FTC to protect us from unfair and deceptive practices, but I believe this rule would, in fact, penalize honest and fair business people and unfairly aid irresponsible ones. The 7-day waiting period to enroll new distributors will be a detriment to my business. Most of the people who enroll with Shaklee, and all people who enroll with my Shaklee business do so for the sole purpose of buying products at a savings. If they later wish to earn by working with Shaklee products, they may do so with no additional requiremen, but the vast majority stay as simple wholesale consumers. The cost of enrolling as a Shaklee member is $19.95, a very small expenditure, fully covered by Shaklee's buyback policy and customer satisfaction guarantee for every thing purchased from Shaklee within the last 2 years. I personally check on my members to be sure that they are happy with the value of all their purchases. What would happen to WalMart business if everyone had to wait 7 days to make their first consumer purchase? The disclosure of at least 10 prior purchasers nearest the prospective purchaser is an administrative nightmare, an invasion of privacy and an identity theft threat. I would not ever want to tell my new customers that their personal information may be disclosed to unknown strangers in the future! The requirement to tell of all lawsuits, regardless of whether the company was found innocent or liable is greatly unjust to ethical, honest companies like Shaklee that have stood the test of time. At the same time, it could make new companies with no track record look good, even if they use unfair or deceptive practices. In fact, unscrupulous individuals do start companies and close them down, only to start other companies in order to avoid responsibility for their deceptive practices. This rule will not catch them, but it would penalize honest ones. I have been a Shaklee Distributor for more than 35 years. Originally, I became a distributor strictly to save money on Shaklee's nutritional, personal care and household products. I loved them and shared my enthusiasm with family and friends even before I recognized that I could earn additional income working from home with Shaklee. Shaklee has treated my customers and me with consideration well above the requirements of fairness for the entire 36+ years. In addition, my family now depends on my Shaklee income to completer our budget as we near retirement. I know of no fairer, more just way to contribute to the welfare of the world while contributing to the welfare of my family. While I appreciate the work of the FTC to protect consumers, I believe that R511993 will have many unintended consequence for direct sellers and consumers alike. Less burdensome, more effective alternatives must be found. Thank you for your time in considering my concerns.