| Comment Number: | 522418-02507 |
| Received: | 6/16/2006 12:22:11 AM |
| Organization: | Cookie Lee Jewelry |
| Commenter: | Wendy Campbell |
| 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) Re. Business Opportunity Rule R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 To Who It May Concern; This letter is being submitted due to a concern about the proposed Business Opportunity Rule R%11993. I believe in its present form, it could be detrimental to my business and even prevent me from continuing as a Cookie Lee Consultant. I understand that the FTC’s responsibility is to protect the public from "unfair and deceptive acts or practices," however some of the sections of the proposed rule will hinder the ability of direct sales consultants to sell their products and share their business opportunities. One of the most concerning sections is the proposed rule that an individual should wait seven days to enroll as a new consultant. Our initial business start-up costs are between $300 and $600 which is a considerably reasonable amount to start a small business. Individuals purchase televisions, cars, and other items that cost a great deal more than our start up costs and they do not have to wait 7 days to take ownership of those large ticket items. This proposed waiting period gives the impression that there may be a defect with our products or with our company. In addition, this waiting process would hugely impact record-keeping processes and would cause an individual who is ready to begin their business venture to wait unnecessarily to get started making extra money for their families. I have been selling our jewelry for two years. This business has made my family much more financially sound. I am able to contribute to our family income as I would never have been able to in corporate America including paying for my daughter's first year of college. Through Cookie Lee I was given the opportunity to succeed in my own business. My family depends on this income and this proposal would negatively affect that income and therefore affect the impact on our community economics. By initiating this proposal you are taking dollars out of the pockets of our economy. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. In today's society, any person or any company can be sued for very trivial occurances, such as having hot coffee spilled on a customer. It is not a fair business practice that we be required to disclose any unfounded lawsuits unless Cookie Lee is found guilty of some sort of crime or illegal practices. Given this proposal takes affect, Cookie Lee and Cookie Lee Consultants are put at an unfair advantage even though no unfair or deceptive acts were committed. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchase. If I am in a department store I do not request the personal information on the last 10 consumers that were in line, nor do I ask for the 10 consumers living closest to the store who last purchased. This cannot be considered fair for the self-employed direct seller? This could be detrimental to anyone supplying this information to their customers considering that identity theft is rampant throughout our country today. Additionally this proposal would interfere with my relationship with my customer which could in turn force me to discontinue my business. I appreciate and respect the work of the FTC to protect consumers, however this proposed rule has many unintended consequences. There has to be an alternative available that would protect the consumer as well as the direct selling consultant. Thank you for your time and consideration regarding the above comments. Sincerely, Wendy Campbell Unit Manager, Cookie Lee Jewelry