| Comment Number: | 522418-01867 |
| Received: | 6/12/2006 4:30:48 PM |
| Organization: | Mannatech |
| Commenter: | Kevin Page |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am very concerned about the negative impact that the proposed rule in its present form could have on my direct selling business. I have been recommending and educating the public about the benefits of Mannatech’s wellness products and the associated business opportunity for the last 10 years. I have recently sold a business to focus my full time efforts on building my direct selling business. I understand the need to protect the public unfair and deceptive business practices, however, this rule will make it very difficult if not impossible for me to sell Mannatech products. The 7 day waiting period gives the impression that there might be something wrong with the plan plus the consumer should not be forced to wait 7 days. In addition, Mannatech already has a 90% buyback policy for all products including sales kits purchased within the last 12 months. The proposed rule requires notification of all litigation. This is unfair in that it does not distinguish between winning and losing lawsuits. In today’s world, anyone can sue for almost any reason and I should not have to disclose any lawsuits unless the company is found guilty. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective buyer. I have no problem providing references, but I am not comfortable giving out the personal information of individuals without there prior approval to strangers. Today, people are very concerned about their privacy and identity theft and so may be unwilling to become involved knowing that there personal contact information will be shared. Like in all other businesses, this should be left to the individual purchaser and seller relationship. I became involved with Mannatech because of the results and benefits my family received from the products. I know feel compelled to share the information with others who are interested in the benefits as well as the opportunity to earn additional income based on helping others. I appreciate the work of the FTC, but I believe this proposed new rule has many unintended consequences and that there are much less burdensome alternatives available in achieving its goals. Thank you for considering my comments.