|Received:||6/16/2006 12:28:13 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I've been with PartyLite for 13 years, While I can appreciate the need to protect people from scams, the proposed 7-day waiting period, and 10-name reference list would have a chilling effect on our business. I hold 150 shows a year, sponsor and train new consultants, and have a $750,000 a year business. It ALL was built by sponsoring, which by the way is the hardest part of our business. Make sponsoring harder, and anyone who comes into a DSA businesses AFTER these regulations go into effect will be seriously disadvantaged. My business is in-home presentations -- a candle party. Guests know that they can buy products, or host their own show & shop for free. If they don't like candles (or attending home parties), usually they don't come. We also offer people the opportunity to start their own businesses. With PartyLite there is NO investment. Really. Last night's show had 6 guests with 2 days notice; one didn't buy anything, another spent $117. The hostess had $330 in orders; with another $350, she could have started PartyLite for free. (With $330, it would have cost her $10 to join.) I could have sent in the show to PartyLite today, and she'd be ready to get started. She could even be holding shows this weekend, (perhaps inviting folks who couldn't come last night.) PartyLite ships its orders within 2 weeks. So her guests from last night's show will have their products in about 21 - 25 days. (It takes a week for orders to reach CA.) However, if she had to wait 7 days, then her guests will have to wait 28 to 32 days: a month. Delivery time from 3 - 4 weeks, up 25% a drawback to customers. A 7-day wait would hurt a new consultant's fledgling business. Her guests' orders delayed, AND she has now has to wait an entire week before getting started. Does this mean she'd have to wait 7 days before she starts calling potential hostesses? Wait 7 days to talk to friends who might be interested in joining her in the business? Wait 7 days to call friend who didn't come, and invite them to another show? (Is that 7 business days? or 7 days?) Wait a week to THINK about the business? How is this going to be enforced? How could a week's wait possibly help someone have a stronger business? The reality is, many people will decide not to even give it a try, if they can't start right away. And that hurts everyone's bottom line. About the 10 references. . How would I even know who the 10 PartyLite people who are geographically closest to the potential new consultant? Aren't there privacy issues involved? How would I know if they were active, or would be able references? What if they decided to talk the consultant into to starting with them? I've actually had that happen to one of my consultants. When I started with PartyLite (I was the 18th person to start in Nebraska -- I wonder who I would have called for references?), I sponsored Jodi in California. She wanted to grow her business, and Anna, who lived near her summer home in Utah, was ready to start. Jodi was thrilled. Well, Anna met a Partylite consultant in Utah who basically told her not sign up with a friend (in California), when she was local. So Anna joined with the consultant in Utah, (this is TOTALLY unethical, by the way....but what's to prevent this from happening?), and Jodi was crushed. It had a chilling effect on her business. Just because someone is or has been a consultant with a company, doesn't mean they (1) are ethical themselves, (2) have had the training to intelligently answer questions, or (3) will see any benefit in encouraging the prospect to sign up under someone else. Over the years, I've had 4 potential consultants steal kits from me (at $175 a pop). Maybe I need protection from them! These regulations would have the unintended consequence of making it harder for future consultants with a DSA company to build a strong business.