| Comment Number: | 522418-02237 |
| Received: | 6/15/2006 12:10:57 AM |
| Organization: | vicki thom |
| Commenter: | vicki thom |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Hello: I am writing this letter to oppose the proposed Business Opportunity Rule R511993. I understand that it is the responsibility of the Federal Trade Commission to protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Scent-Sations Inc Independent Distributor. One part that seems hard and confusing are sections of the proposed rule is the seven-day waiting period to enroll new distributors.. If anyone wishes to become a Scent-Sations Distributor they simply fill out an application which is free to do. In our case there is no additional kit or fee required. This is far less than many, if not most, consumer purchases, from TVs to all manner of household appliances, none of which require a seven-day waiting period. This places an unfair burden on companies like the one I represent. In addition, the seven-day waiting period is unnecessary in that Scent-Sations Inc already has a 90% buyback policy for products! The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. There are many problems with this proposed requirement. In this day of identity theft, I am uncomfortable giving out the personal information of other Scent-Sations distributors, without their knowledge or consent, to strangers. I understand that those who sign up after the rule takes effect would be told in writing "If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers." I believe that this would dissuade new people from signing up as distributors as they are concerned not only about identity theft, but also about their privacy. People today are understandably reluctant to share their personal information with individuals they may never have met. Providing the ten references also could damage the businesses of numerous Scent-Sations distributors. Lower ranking distributors often are involved in more than one direct selling company. Providing a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for such other opportunity. The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentation, or unfair or deceptive practices over a ten-year period. It does not matter if the company was found innocent or not liable. Today, almost all business lawsuits contain claims of misrepresentation or unfair competition. It does not make sense to me that I would have to disclose these lawsuits unless Scent-Sations Corporation, or its officers, directors or sales department employees, had been found guilty or liable. I have been a Scent-Sations Distributor for about 1 year. There are many scams out there I agree, but after searching a lot I have found Scent-Sations to be a great company and one I'm proud to promote. People are invited to check out the company, training sessions etc. to make an educated decision. This bill puts unfair burdens upon the good companies and those that are trying to sell them. Sincerely, Vicki Thom