| Comment Number: | 522418-05074 |
| Received: | 6/29/2006 3:15:48 PM |
| Organization: | Arbonne International |
| Commenter: | Jessica Thompson |
| State: | TX |
| 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 an Independent Consultant with Arbonne International and I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its current form, it could inhibit me from continuing as an Arbonne Independent Consultant. I understand and am thankful 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. The most confusing and restrictive section of the proposed rule is the 7-day waiting period to sign up new Consultants. This waiting period gives the impression that there might be something wrong with the Arbonne opportunity. When, in fact, it is the most exciting opportunity for anyone to be a part of. It has meant the world to me and my family. Under this waiting period requirement, I would need to keep very detailed records when I first speak to someone about Arbonne and keep track of when to follow up. One of the key elements to my success in this business has been capturing the enthusiasm and immediate results prospects experience with the Arbonne products. This proposed waiting period would potentially limit my ability to grow my business. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. This does not seem fair because there could have been some lawsuits where the company was found innocent. The fact that there even was a lawsuit could incorrectly imply wrongdoing. I don't want to be penalized by even the impression of a lawsuit, especially when I have done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior Independent Consultants nearest to the prospective Consultant. I am glad to provide references, but identity theft is a reality we live with in today's world and I am very uncomfortable with giving out personal information about individuals, without their permission or knowledge, to complete strangers. Also, sharing this information could damage the business relationship of references with those involved in other companies or businesses, or provide an unfair advantage to competitors. People are already leary of giving out personal information when they know and trust me. I would find it an invasion of privacy and a lack of integrity on my part to disclose personal data, for my business purposes. I have been an Arbonne Independent Consultant for over a year and it has truly changed my family's life. I became a Consultant because I love the products and our family was in need of a second source of income for our financial dreams to be attained. Since starting my business I have developed an incredible team of over 200 Independent Consultants all across the country and together we are helping our families enjoy better lives. I am so thankful for the work that the FTC is doing in their attempt to protect consumers, but I truly believe that this proposed new rule would have many detrimental and unintentional consequences. I believe that there is an alternative means to resolving the outstanding issues at hand that do not involve harming the livlihood of so many successful network marketers, like me. Please, please, please realize how this would affect millions of people's financial security. It would be detrimental to the blood, sweat and tears that they have poured in to their business. Thank you for taking the time to listen. I pray for your understanding. Sincerely, Jessica L. Thompson Independent Consultant Regional Vice President Arbonne International