| Comment Number: | 522418-01925 |
| Received: | 6/12/2006 9:04:23 PM |
| Organization: | Work At Home Mother |
| Commenter: | Angie Thornton |
| State: | MS |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-01925.pdf Download Adobe Reader |
Comments:
I am writing this letter because 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 work at home mom in the direct selling industry. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” yet some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell my products and/or invite others to join my team. I have been a direct sales consultant for the past 2 years. Direct Sales has offered me the opportunity to earn a much better income working from home than what my education and skills would offer me if I were to get a job working for some one else. I work from home in order to be able to raise my children myself instead of paying some stranger to do so. My husband works outside the home and he works hard and long hours. Yet, we still need a second income in order to meet our financial needs. The future of my family is dependent on the stability of the direct selling industry. In addition to my home business contributing to my families financial well being, I have also gained a real sense of worth. My self-esteem has improved and I have developed leadership skills through working with my team as we build our businesses together. Also, I have made many new friends that I would not have been blessed with had it not been for my business. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new consultants. If I were applying for a job, would you tell me I can’t agree to work for at least seven days? NO! This waiting period gives the impression that there might be something wrong with the company or the compensation plan. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about joining me in working from home and will then need to send in many reports to my company headquarters. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to the company 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 salesperson - “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may 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, Angie Thornton