Comment Number: 522418-04883
Received: 6/28/2006 5:17:30 PM
Organization: arbonne international
Commenter: loraine grover
State: WA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear FTC: 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 Arbonne Independent Consultant. I understand that part of the FTC’s responsibility is to protect the public from “unfair and deceptive acts or practices,” but some areas of the proposed rule will make it very difficult, if not impossible, for me to sell Arbonne products and sponsor people into the business. I have sold Arbonne products for 9 years. It is my only source of income for my family. Previously I had to work outside my home. This has allowed me to be at home with my daughter through her teen years. I am a better person from my affiliation with Arbonne. My public speaking skills, my ability to give more to my community financially, training skills, etc. I am concerned that a 7 day waiting period sheds an unnecessary negative light on my business, my character and on my company. I don’t have to wait 7 days to purchase from Costco or Sam’s Club or Nordstrom! I find that once people try my products, they want to place their order right away! And if they want to have an income with Arbonne, they can’t wait to get started. A 7 day waiting period would create undue stress upon my family income generated through having a home based business with Arbonne. The record keeping alone would be a nightmare for me, a small business owner. I don’t have the resources of a chain store at my disposal. As far as litigation goes, we live in a litigious society. I don’t see where the litigation information would state the difference between legitimate lawsuits that are won and those that are lost. That seems highly unfair to me. I don’t see a sign posted at Nordstrom how many lawsuits there have been, nor do I see that at the doors of the hospital where I had my surgery. I do not want to have to continually find 10 consultants near my potential consultant to refer them to. If someone asks me, I happily do that for them. But many people do not care about that. We have quality products, they know me and trust me and want to do business with me. Please do not take away my livelihood!! I understand completely that there are fraudulent groups out there, I’ve come across some of them, but the FTC’s proposed rule would unfairly target legitimate direct selling businesses. Why not spend your time eliminating the unlawful people and leave those of us who are hard working, trustworthy and legitimate alone? Please work on my behalf. Don’t destroy my families income possibility. Sincerely, Loraine Grover