| Comment Number: | 522418-02192 |
| Received: | 6/14/2006 8:22:11 PM |
| Organization: | Sunrider International, Inc. |
| Commenter: | Jim & Sandy Caves |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Subject: Business Opportunity Rule, R 511993 Dear FTC: We want to encourage you toward modifying the proposed Business Opportunity Rule R511993. The proposal, we believe, goes beyond basic consumer protection, and would create a hardship for us in conducting business. Our business is of benefit to the community. The seven-day waiting period before enrolling new distributors would essentially double our administrative work in signing them up. There is no need for it, because of our low cost and guarantees. Our maximum start-up cost is only $140, and it is not a mandatory purchase in order to become an Independent Sunrider Distributor. We have a sixty-day return policy. Sunrider also has a 90% buyback policy for former distributors applicable for twelve months. Many, many more expensive items are sold by other businesses without a waiting period. A mandatory waiting period implies that there is a significant risk in becoming a distributor, and there is not. The proposal for disclosure of any information about lawsuits involving misrepresentation or unfair or deceptive practices does not take into consideration the merits of any such lawsuit. This does not seem equitable unless a judgment was issued. Other sales organizations are not burdened with this requirement. Most importantly, a requirement to provide references of prior purchasers would be a serious setback to our business. Citizens are so concerned about their privacy these days that our business would be very negatively affected by a requirement that buyers’ contact information be disclosed to future buyers. We have happily been Independent Sunrider Distributors for more than two years, and are very favorably impressed with the products. Sharing the business has enabled us to supplement our retirement income, and we depend on it for our budget. We are grateful for the zealousness of the FTC. We hope and trust that the Commission will find suitable alternatives that will not impose a great onus on small business people like us. Thank you for your consideration. Respectfully submitted.