Comment Number: 522418-03058
Received: 6/17/2006 12:24:09 AM
Organization:
Commenter: Alvin Bergh
State: IL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

To Whom It May Concern: I am 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 an Associate with Mannatech, Incorporated. The seven day waiting period puts a tremendous burden on sales associates as it will demand much follow-up time with customers. It also is putting a selected restriction on direct sales while this restriction is not placed on other kinds of sales such as that of cars, television sets and appliances. The litagation reporting requirement seems totally unfair and predatory. I know of no businesses that are required to state to their customers the lawsuits that their company has had to deal with. What would happen to a medical doctor's practice if he/she had to declare all his/her previous lawsuits to patients? I served as Executive Director of a Social Service Agency which endured many frivolous lawsuits and it would serve no positive purpose for me or the agency to publicize to supporters or clients the existence of these frivolous lawsuits that were all won by the agency. In respect to the proposal on references, it seems that this is a proposal that is not required of other kinds of businesses. For example, the people who recently painted our house, supplied us with references that they selected, not that which was proposed by Federal Law. I believe that Direct Marketing should have the same privilege. We are appreciative of the FTC efforts to fight fraudulent groups but these regulations would severely impare our ability to market the Mannatech products. Thank you for giving attention to our concerns. Alvin Bergh