| Comment Number: | 522418-01165 |
| Received: | 6/6/2006 5:39:20 PM |
| Organization: | Signature HomeStyles |
| Commenter: | KIMBERLY ROBERTSON |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. In its present form, it will prevent me from continuing 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. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new Representatives. The Signature HomeStyles Starter Case only costs $100-$175. People buy TVs, cars, and other items that cost much more than that and they do not have to wait seven-days. This waiting period gives the impression that there might be something wrong with the plan. 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. Under 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 rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today, anyone or any company can be sued for almost anything. 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. Finally, the proposed rule requires the disclosure of a minimum of 10 Representatives nearest to the prospective Representative. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, giving away this information could damage the business relationship of the references that may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 Representatives, I will need to send the address of the prospective Representative to Signature HomeStyles Home Office and then wait for the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” 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 just started my business as a Signature HomeStyles Representative. I have done direct sales before and really appreciate the opportunity to be able to earn based on what I put in and the flexability. My husband and I share 8 children together and feel it is our responsability to raise our children without the help of state assistance and daycare. It is Independant sales that will allow us to do just that. If you enact this proposal you will not be protecting consumers you will be taking away from families who need this great opportunity. As a consumer I appreciate the work you do to protect me. I agree that some proposed businesses are less than fair but there is a way to weed them out without punishing everybody else. Why the wait period? Why not allow the 48 hours to change their mind like anybody commiting to a sale at their door? Just one option. Please thoughtfully consider these points. We are not just reps. We too are consumers. Respectfully,