Comment Number: 522418-02064
Received: 6/13/2006 10:59:17 PM
Organization:
Commenter: Kathy Sammons
State: MO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Kathy Sammons  June 12, 2006 FTC Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 Dear Sir or Madam: I am writing this letter because of my concern about the proposed Business Opportunity Rule R511993. I believe that in its present form that it would make it very difficult, if not impossible to continue as a Mannatech Associate. I understand that it is your responsibility to protect the general public and I am thankful for your efforts, however in this case it would prevent me from selling Mannatech products. One of the sections that I am most concerned about is the stipulation of the seven day waiting period. There are many businesses that sell products for a lot more money than ours, that do not have this burden, such as car dealers, home appliance dealers etc. The waiting period makes it look like there is something wrong with our products or our company. We already have a policy that states that the company will buy back products and materials at 90% of the purchase price. The logistics of this rule are just mind boggling, it would cause a lot of lost time and effort to comply. The rule also asks that companies disclose any lawsuits that are brought again the company. We live in a culture the does not think twice about suing any company for just about anything. I think that that is just too great of a burden, to be held by the throat over a fiery pit of greed. We should not have to disclose these suits unless we are found guilty. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchases nearest to the prospective purchaser. This is really not feasible, for a lot of reasons. One of them and the most pressing is privacy. The nature of our products could imply that the purchaser has a health concern. This is not a good way to do business. Consumer privacy is on the top of most peoples’ mind these days and I think that they would have a problem with me giving out their names to others. I have been an associate with Mannatech for about 2 years. I love their products and several people in my family consume them. I am trying to build a business where I can work out of my home and I feel that this rule would take that all away from me. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving its goals. Thank You for your consideration, Kathy Sammons