| Comment Number: | 522418-03071 |
| Received: | 6/17/2006 3:44:50 AM |
| Organization: | PartyLite Gifts |
| Commenter: | Melody Pobuda |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern I would like to comment on the proposed Business Opportunity Rule by stating first that I agree with the core intent of the rule which is to protect & further assist consumers to identify fraudulent businesses & business practices. However, from what I understand from my sources, this rule is written such that it would make a major portion of my job much more difficult to perform. That job function is sponsoring new consultants when they decide they would like to start their own PartyLite home based business. The seven day waiting period for new consultants I do not see as necessary & can significantly take the excitment & momentum away from someone who, often with the support & excitment of their friends & family, has made the choice to begin selling PartyLite products. As you may or may not know, the PartyLite home based business of selling and promoting PartyLite candles & accessories through giving parties at the homes of our hosts/hostesses, thrives on excitment. If the consultants are excited, their hosts will be excited, if the hosts are excited their guests will be excited & when the guests are excited about the products they are more comfortable & secure in making their purchases thus resulting in a very successful show for everyone. Take away or even greatly slow down that momentum and excitement in a new consultant and their would-be-hosts & hostesses then it is harder for them to have a strong start. A strong start that they can currently take advantage of from the moment they decide to start this business. The other problematic aspect of this new rule is the requirement of 10 references to be provided to any new consultant. In the case of PartyLite consultants, this is the information of 10 other consultants and leaders in the area. This is an inconvenience and a violation of privacy. In order to provide this you would need to get the permission of all 10. This is a huge inconvenience & unnecessary. When a new consultant is sponsored they are encouraged to join their sponsoring consultant at the unit meetings & to attend the regional meetings which are important activities for consultants to perform, especially when they just start. At these meetings they are encouraged to interact & meet not only other members of their unit but also members from other units w/in the region. By providing as many as 10 references up front could cause some new consultants to feel that they do not need to attend these meetings & activities to meet other consultants & network; they already have been given 10 local contacts w/out lifting a figure. PartyLite is completely an at-will business; consultants can start & stop their employement with PartyLite any time they want. The same goes for the hosts/hostesses; they can choose to have a party or not have a party. PartyLite has always followed thru with their promises to hosts & consultants alike and has proven over the years to be a very accountable company. I can not see how these requirements help confirm to consumers that PartyLite is not a fraudulent company. If you are worried about people pretending to be consultants and fraudulently taking consumers' money and information, then impose that consultants, when sponsoring new consultants & when giving shows for hosts, to provide their consultant ID # and one or two references before any personal information or money is exchanged. Every consultant, when registered thru the PL home office, is given a unique ID#. The references should be the consultant (or leader) that sponsored the consultant in question and the regional leader. I realize that this rule was not written specifically for regulating the PartyLite home based businesses but to apply to a broad scope of business types. My purpose here is to explain how I believe it would affect my business and the business of any potential new consultants. However, If I'm not mistaken, these rules will affect and adversely limit many other businesses also