Comment Number: 522418-03980
Received: 6/23/2006 7:46:10 PM
Organization: AdvoCare International, L.P.
Commenter: Keith Warford
State: AR
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

The Federal Trade Commission (FTC) has proposed a Business Opportunity Rule that would unfairly restrict and burden the legitimate direct selling industry and Members of companies like AdvoCare. The intent is to protect consumers from fraudulent businesses, which AdvoCare supports, but the Rule has many sections that would make it especially burdensome and difficult for a legitimate company like AdvoCare and our Members to operate a business. AdvoCare opposes this Rule in its current form. This Rule proposes a seven-day waiting period from the time a Member speaks to someone about AdvoCare until you can sign them up as a Member. AdvoCare already has a buyback policy on all products and sales kits purchased by a Member within 12 months. This Rule casts the direct selling plan in a negative light and prevents momentum with enrolling new members. Please reject these new rules in their current form. Thank you, Keith Warford