Comment Number: 522418-02410
Received: 6/15/2006 6:02:15 PM
Organization: Harry & Barbara Evans - Mannatech Associates
Commenter: Harry Evans II
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

To Whom It May Concern: I believe the function of the FTC is not only to protect consumers against Fraud, "unfair and deceptive acts or practices", but to judiciously establish rules that don't adversely impact legitimate businesses involved with direct selling of products to the general public. The Business Opportunity Rule R511993 in its present form with a mandatory seven day waiting period will seriously impair our ability to continue in our legitimate business as a distributor of products that are sold worldwide. An integral part of our business is to enroll new Consultants (Distributors) for the purpose of expanding our own business. Since people are FREE to buy items costing much more than products we sell, such as automobiles, TV's, computers, etc, we find this proposed rule discriminatory in that its very nature (imposing a waiting period to do business) leads the prospective buyer to think there must be something wrong with conducting this particular legitimate business as compared to other legitimate businesses. The products we sell to others are products we use on a daily basis ourselves. This contributes to our financial well being as well as personal satisfaction gained by helping others help themselves. We've been involved with our business for over two years now. We sell quality products! The proposed Seven Day Waiting Period casts our direct selling business in a negative light. Since our business is LEGITIMATE, your agency proposes to discriminate, unfairly targeting direct selling businesses. In addition, the nature of this proposed rule would create record keeping and administrative problems as well as cause unnecessary delays in the daily conduct of our business. This rule does not distinguish between those winning and loosing lawsuits that may arise through FTC actions. The nature of this proposed rule also compromises privacy laws (due to ID theft and safety) in requiring references be given to prospective distributors of 10 or so of the nearest current distributors. We understand there is a small percentage of fraudulent groups of people in every walk of life. We even see some of our elected officials convicted of fraud occasionally. I think you need to evaluate how to best NOT unfairly target the vast majority of direct selling businesses, while at the same time providing severe penalties for the small percentage of fraudulent businesses. Sincerely, Harry and Barbara Evans Mannatech Associates 3204 Summit Court Grapevine, Texas 76051