|Received:||6/10/2006 3:41:04 PM|
|Organization:||Shaklee Independent Distributors|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear Sir, Madam: I am writing this letter to express my opposition to the proposed Business Opportunity Rule R511993. Although the responsibility of the FTC is to protect the public from "unfair and deceptive acts or practices" I do believe the rule as proposed will hinder honest business operators such as the Shaklee Independent Distributors. Many of these operators work on a part-time/seasonal basis. The restrictions and requirements proposed would make such a venture very difficult or maybe even impossible should this bill pass. By the time these independents fulfill their obligations to the FTC (such as the seven day waiting period; disclosure of 10 prior purchasers; 10 references) the season (ie, Christmas) would be over before they even begin. While I appreciate the work of the FTC to protect consumers, I believe this proposal has many unintended negative consequences for direct sellers. I am sure the FTC could find some less burdensome alternatives to achieve their goals. Thank you for your attention to this matter.