| Comment Number: | 522418-03740 |
| Received: | 6/21/2006 8:12:31 PM |
| Organization: | |
| Commenter: | Robert E Polster |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in it,s present form it could prevent me from continuing as a 4Life Research distributor. I understand that part of the FTC,s responsibility is to protect the public from " unfair and deceptive acts and practices, " but some sections in the proposed rules will make it almost impossible for me to continue to sell 4Life Research products. One of the most burdensome sections of the proposed rule is the 7 day waiting period to enroll new distributors. 4 Life Research's sales kit only costs $29.95. People buy TVs, Cars, and many items which coetmuch more than that and they do not have to wait seven days. This waiting period makes it look like there may be something wrong with the plan. I also think the seven day waiting period is unnecessary, since 4Life Researh already has a 90% buy back policyfor all products including sales kitspurchased by a salesperson within the last 12 months. this waiting period will require me to keep very detailed records of when first speak to someone about 4Life Research and I will have to send in many reports to 4Life Research headquarters. the proposed law also calls for the release of any information regardinglawsuits involving misrepresentation,or unfair or deceptive practices. it doesn't matter if the company was found innocent. Today any company or person can be sued for almost anything. It does not make sense to have to disclose these lawsuits unless 4Life research is found guilty, otherwise 4Life research and myself are put at an unfair advantage even though 4Life Research has done nothing wrong. Finally the proposed rule requires the disclosure of a mininum of 10 prior purchasers nearset the prospective purchaser. I am happy to provide references, but in this day of identity theft, I am extremely uncomfortable giving out the personal information of individuls (without their approval) to strangers.Besides, giving away this information could damage the business relationship of the references who may be involved in other companies, or businesses including those of competitors. In order toget the list of 10 prior purchasers,I would have to send the address of the prospective purchaser to 4Life Research headquarters and then wait for the list. I also believe the following sentence required by the proposed rule willprevent many people from wanting to sign up as a salesperson "If you buy a business opportuniy from the seller,your contact informationcan be disclosedin the future to other buyers." People are very concerned aboutidntity theft and their privacy. They will be reluctant to share their personal information with individuals they may have never met. I have been a Distributor for 4Life Research for more than 5 months. Originally I became a 4Life Research Distributor because of the quality of their products, which have greatly enhanced my family,s health, and has given me the opportunity to earn extra income which my family needs. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended and detrimental consequences and that there are less burdensomemeans available to achieve its goals. Thank you for your time in considering my comments. Sincerely, Robert E Polster