| Comment Number: | 522418-02834 |
| Received: | 6/16/2006 2:52:40 PM |
| Organization: | Mannatech, Inc. |
| Commenter: | Nathan East |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am concerned about the proposed Business Opportunity Rule R511993. This rule could disrupt my business and prevent me from continuing as an Associate for Mannatech, Inc. Although I know that the FTC is responsible for protecting the public from “unfair or deceptive trade practices”, this rule will make it very difficult, if not impossible, for me to continue to sell Mannatech products. Mannatech, Inc., is a company with integrity, an excellent marketing plan, and superior nutrition products. This would not be fair to the company nor any of its over one million Associates. I am concerned with the proposed 7-day waiting period before signing a new Associate. Mannatech, Inc., does not charge a fee for signing new customers as Mannatech Associates, and becoming an Associate allows the customer to purchase their products at wholesale cost, directly from the company. A 7-day waiting period would require extra time and paper-work for me, as well as for Mannatech, and most new Associates would not want to wait 7 days before enrolling as a new Associate or ordering their products. The law does not require such a waiting period for purchases made in retail stores. Why should purchases made from a direct marketing company be any different? This casts our company in a negative light, as if our marketing plan or products are defective or not above-board. If the Associate feels he or she has made a mistake by signing as an Associate, he/she can always terminate his/her position by contacting the company directly, with no problems or hassles. Another concern about this proposed law is the requirement that prospective Associates be given a list of 10 prior purchasers nearest their location. Besides the impracticality of obtaining such a list, disclosing this information can be a breach of privacy to my current customers and fellow Associates. Also, knowing that personal contact information can be disclosed to others would be a deterrent, possibly preventing a prospective client from signing with Mannatech as an Associate. I have only been a Mannatech Associate for a year, but the products are top-quality and the company is outstanding. I am looking forward to a long and continuous relationship with this company. However, this rule could dramatically put a damper upon my personal success and limit the unlimited possibilities I could have with this company. Please do not put Business Opportunity Rule R511993 into effect. Thank you for your consideration.