| Comment Number: | 522418-01714 |
| Received: | 6/10/2006 3:58:47 PM |
| Organization: | The Traveling Vineyard |
| Commenter: | Kimberly Douthit |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am a concerned “distributor” with The Traveling Vineyard, a direct sales company which is the arm of a larger company that has been around for more than twenty years. I have read enough of the FTC’s proposed Business Opportunity Rule to realize that it will do more harm than good in my case and the case of many friends/colleagues/acquaintances who are also involved in Direct Sales Business opportunities. I am a veteran of the U.S. Coast Guard (honorably discharged), married to an active duty member of the U.S. Navy who is trying to earn some extra income to support my household. As a military spouse, I find it difficult to stay employed with any one company for more than a few years due to the “nomadic” nature of the Navy (i.e. being relocated every 2-4 years to a new city). This prohibits me (and other military spouses) from earning seniority, raises or promotions within a company. When I found The Traveling Vineyard, I found an opportunity to earn income, promotions and seniority and not have to start over every time I am forced to relocate. I know of several other military spouses who have found the same opportunity with other Direct Sales Companies (such as Mary Kaye, Avon, PartyLite, Pampered Chef…) I can honestly say that The Traveling Vineyard has never misrepresented income potential, expense, the amount of work involved, etc. The “distributors” that I spoke with before signing up to become a consultant were very up-front and honest. I have also found the training materials to be tremendously helpful and the customer service provided by the company has been nothing short of excellent. I feel that it is unfair to lump legitimate Direct Sales companies (some of which have been around since the 1950’s…) in with “Fly-By-Night” companies that sell vending machines or franchises. It punishes the hard-working, honest individuals (like myself and several of my close friends) by chipping away at our income and potential business. Essentially, you are taking food out of the mouths of our children and forcing us into foreclosure on our mortgages by cutting our income potential. In order to achieve the same income we are used to earning, we will have to work longer hours, which cuts into the precious time with our families - time that most of us were hoping to increase by working from home. The costs associated with complying with these proposed regulations will also force our company to raise the cost of our product. This is harmful to our consumers who rely on many of the products available exclusively through the various Direct Sales companies in this country. They enjoy the convenience of shopping from home with their friends and not being forced out onto the roads to pay exorbitant gas prices and shop in over-crowded stores. By passing this piece of legislation, you will only bring harm to what has been a wonderful way to earn income (both full and part-time) for thousands of citizens of this country for at least the last 30 years. You will be punishing the masses for the sins of a few. The companies should not be punished for the individuals who initially thought direct sales was a great opportunity, but later discovered that it was not for them. May I suggest re-writing the legislation to exclude Direct Sales companies that have sterling reputations and targeting those companies which have a history of harmful or fraudulent practices? Perhaps only requiring companies with a history of bankruptcy, fraud, etc. to disclose such to the individuals and comply with the “seven day waiting period”? After reading the proposed legislation, it is obvious to me that no one involved in writing the proposal understands Direct Sales. Just as it is with any business, some employees are a great fit and stay with the company for a long time, and some do not find a match and leave to seek out other employment. I hope you will seriously consider involving actual Direct Sales associates when writing or re-writing legislation that involves this type of opportunity. Thank you for your attention. Sincerely, Kimberly Kolibab Douthit