| Comment Number: | 522418-02255 |
| Received: | 6/15/2006 4:31:20 AM |
| Organization: | Maximum Progress Services |
| Commenter: | Laury Orndorff |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 15, 2006 To Whom It May Concern: I am sending this communication because I am deeply bothered by the proposed Business Opportunity Rule R511993. In its present form, it could prevent our business from continuing as an Independent Sunrider Distributor. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will make it nearly impossible for our business to succeed, selling Sunrider® products. One of the most damaging sections of the proposed rule is the seven-day waiting period to enroll new Distributors. Sunrider’s Starter Pack costs only $140, and is not required in order to become an Independent Distributor. That idea is unrealistic, as people buy TVs, cars, and other items that cost much more and have no seven day wait. This waiting period gives the impression that our business is bogus and fly-by-night. I also think this seven-day waiting period is completely unnecessary because Sunrider already has a 60-day return policy for existing Distributors that is applicable to all products, and a 90% buyback policy for former Distributors applicable to all products purchased within the past year. Another problem is the administrative task of keeping complicated records when I first present Sunrider to a potential client, and then having to send numerous reports to our headquarters. The proposed rule also insinuates that our business has a shaded history and a checkered past to new clients. It calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if our company was found innocent. Our courts are filled with gold diggers, wanting millions for nothing. It does not make sense to me that I would have to disclose these ridiculous lawsuits unless Sunrider has been found guilty. This puts our business at an unfair advantage up front, even though Sunrider has an impeccable record. How about making this rule pertain to every medical doctor in practice and pharmaceutical companies? Last, this rule requires us to list a minimum of 10 prior purchasers nearest to the prospective purchaser. References are one thing, but these days, identity theft is real and I am very appalled at the suggestion to give out the personal information of my clients to strangers. What ever happened for respect for people’s privacy? In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to Sunrider 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.” THAT IS REDICULOUS. People are still concerned about their privacy and identity theft. Who in their right mind would want to do that? Sunrider is not only a business to me; it is a way of life. It has changed the horizon of thousands of quality people. Originally, I became a Distributor of Sunrider’s products because I loved them and wanted others to get the benefits as well. It is a very powerful, positive force in our lives. I appreciate the commitment of the FTC to help protect the public, but this proposed new rule has many disastrous negatives and there are better ways to achieve its goals. Sincerely, Laury A. Orndorff