| Comment Number: | 522418-02126 |
| Received: | 6/14/2006 12:30:36 PM |
| Organization: | Mary Kay Cosmetics |
| Commenter: | Gerry Jones |
| State: | NM |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 14, 2006 Federal Trade Commission/Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Ave. NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: I write this to voice my opposition to the present form of the proposed Business Opportunity Rule R511993. For 25 years I have worked as an Independent Beauty Consultant for Mary Kay Cosmetics, developing honest relationships in a business situation while representing and selling products from this reputable company. As I understand the proposed Rule, my government through the FTC would impose very unfair and unrealistic obligations upon me and upon similar companies in order to meet the law’s obligations. I acknowledge the FTC’s role in protecting the public from unfair business practices, but I think this Rule goes too far in its requirements of documenting and reporting business contacts. The proposed seven-day waiting period would cause many problems in record keeping and create delays that are completely unnecessary. I have introduced many women to this business opportunity in direct sales, and the timing decision has always been their own, with no pressure from myself or the company. I understand that the Rule would make litigation reporting mandatory, but would not distinguish between winning and losing lawsuits. That is so impractical in this day of so many frivolous legal suits. I think the media is doing a good enough job of educating the public. In regard to requiring references, it would be unfair to the ‘10 nearest purchasers’ of my product to have their personal information distributed to other potential buyers as a routine matter. I would not feel comfortable doing that during this time of so many identity thefts and security threats, nor do I believe that my customers would agree to having their information given so freely. Of course I do provide references when requested. Certainly, I commend the FTC for its work to ensure fair trade practices, but I believe this Rule goes too far in creating unnecessary paperwork, requiring established reputable companies to do excessive reporting, and promoting even more government beaurocracy. Thank you for your consideration . Geraldine M. Jones (Gerry Jones) Independent Beauty Consultant/Team Leader, Mary Kay Cosmetics