| Comment Number: | 522418-01533 |
| Received: | 6/9/2006 2:41:50 AM |
| Organization: | Young Living Essential Oils |
| Commenter: | E. Shields |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opportunity Rule R51193 being considered for adoption. I am very concerned & believe that it could prevent me from continuing as a Distributor for Young Living Essential Oil Company. I know you wish to protect fraudulent groups from entering our wonderful industry, but it would also unfairly target legitimate direct selling businesses such as mine. I know there are less burdensome alternatives available to achieving your goals. I have been in the therapeutic grade essential oil business since 1997. The money I receive from selling Young Living’s products is used to purchase oils for family and clients. Without the use of the oils that I use on my housemate who is disabled, his pain threshold would be unbearable (8 to 9 level). Before discovering the value of the oils, he had attempted suicide 5 times because of severe spinal nerve pain for over 14 years. (Other company's oils are not affective) Since 1997, his pain level is now 6 to 7. Currently I use up to 30 different essential oils for him alone, and have a total of 90 different oils which I use at different times on my clients. I’ve worked hard for years as a Health Professional. If I had to go through the ‘red tape’ such as the Seven Day Waiting Period, no one could have convinced me to wait 7 days. I would have let it go, and would have lost out on a fantastic treatment that really works for all sorts of issues (mind, body, and emotions). Not only is the 7-day waiting period confusing and burdensome, but it gives the impression that the company I’m working with is questionable and the compensation plan should be judged inadequate or fraudulent. Needing to keep very detailed records when I first speak to someone about Young Living oils will be terribly burdensome and the necessity of mailing in reports to my company headquarters is just adding more red tape. Sending reports to the company is completely stress producing and burdensome and inappropriate for the protection of prospective customers. The record keeping, if this bill is passed, is simply not fair. It is as if we are all being treated as culprits or dishonest people under suspect. Litigation Reporting doesn’t seem reasonable, nor does it create a realistic picture as the reporting does not distinguish between winning and losing lawsuits.. It says “any” and doesn’t even say anything about whether the company was innocent. It should not even be mentioned if the party is considered innocent. Most companies already have a buyback policy for all products and the consumer is already protected. Regarding the Reference portion of the ruling, Privacy issues are being infringed upon. I know that most of my clients would be appalled if they knew I was giving out their personal information to complete strangers. The time spent in waiting for the list of prior purchasers from the company is time consuming also. People don’t wish to give out their personal information as they are concerned with privacy and identity theft. Even getting a person to give their master card online is still ‘iffy’ as trust levels are very low even now…before the proposed Rule. I would not want someone calling me asking me how I liked the oil before I purchased it. It’s like getting a ‘cold call’ or a “telephone solicitor." Your paragraph that says ...if you buy a bus. opp from the seller, your contact info can be disclosed in the future to other buyers' will prevent people from signing as distributors... is outrageous. It is essentially firing all the people who are currently working independently and forcing them to go work for someone else. I've been able to stay at home, raise my kids, care of a disabled housemate, and not have to work for anyone else but myself. I've benefited from direct sales as being a distributor lets me purchase the necessary oils that I know heal our bodies. Please don't force me to get on welfare. Thank you for considerating my comments.