| Comment Number: | 522418-03056 |
| Received: | 6/17/2006 12:07:38 AM |
| Organization: | Mannatech |
| Commenter: | Richard Gaffney |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I'm writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a direct selling distributor of Mannatech products. I understand that part of the FTC's responsibility is to protect the public from "unfair and deceptive acts or practices," but some of the sections in the proposed rule will make it very difficult in not impossible for me to market my products. Of greatest concern is the 7-day waiting period to enroll new distributors. Sale kits only cost around $1000. People buy TVs, cars, and other items that cost much more and they do not have to wait 7 days. This waiting period gives the impression that there may be something wrong with the plan or products. I also think this 7 day waiting period is unnecessary, because Mannatech already has a 90 % buyback policy for all products including sales kits purchased by a salesperson within the last 12 months. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about Mannatech. This is an unfair and costly rule. It gets worse when one considers the reporting requirements that are associated with it. Thanks you for your time. Richard S.Gaffney