| Comment Number: | 522418-01518 |
| Received: | 6/8/2006 11:33:41 PM |
| Organization: | Scentelligence |
| Commenter: | Tamalu Watkins |
| State: | WY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 8, 2006 Dear Sir or Madam, I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form it could prevent me from continuing as a Young Living Essential Oils Independent Distributor. I appreciate the FTC's obligation to protect the public from deceptive practices, but some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell Young Living products. I have been an Independent Distributor for Young Living Essential Oils for more than 6 years. Prior to that time, I was a loyal customer for 4 years, and I became a Distributor for Young Living because of the high quality of their products and the business opportunity. My income now provides a large portion of my family's income, and my husband (a construction contractor) and 7 children depend on the consistency and dependability of those funds. The stability of the direct selling industry is vital for our family's well-being. One of the most confusing and burdensome sections of the proposed rule is the 7-day waiting period to enroll new distributors. Young Living's most expensive business kit only costs $150. Anyone can buy things which cost much more without waiting 7 days. The waiting perion implies that there might be something wrong with the company or the compensation plan. The waiting period is also unnecessary in this instance because Young Living also has a satisfaction guarantee on all products. Under this waiting period requirement, I will need to spend much of my working time writing and submitting reports instead of otherwise building my business and maintaining my family's livelihood. The proposed rule also calls for the release of ANY information regarding lawsuits involving misrepresentation, or unfair or deceptive practices, regardless of whether or not the company was found innocent. Today, anyone can be sued for anything, yet the implication has been made that the company may be guilty because someone is disgruntled. It is illogical to me to disclse these unless Young Living is found guilty. Otherwise, Young Living and I are put at an unfair advantage even though Young Living has done nothing wrong. Finally, the proposed rule requires a disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but I am very uncomfortable giving out the erpsonal information of individuals to strangers. Also, giving out this information could damage the business relationship of the references who may be involved with other companies or businesses, including those of competitors. In order to get the list of 10 prior purchasers, I will need to send the list of the 10 prior purchasers to Young Living's headquarters 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 distributor - "If you buy a business opportunity from a seller, your contact information can be disclosed in the future to other buyers." People are very concerned about their privacy and identity theft, and will be reluctant to share their personal information with individuals they have never met. I appreciate the work that the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences and there are less burdensome alternatives available to achieving your goals. Thank you for your time in considering my comments. Respectfully, Tamalu Watkins