Comment Number: 522418-05326
Received: 6/30/2006 5:14:45 PM
Organization: Larsen Global Alliance, Inc.
Commenter: Collette Larsen
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

RE: Business Opportunity Rule, R511993 Dear Sir or Madam: Thank you for taking the time to consider my serious concerns over the FTC’s proposed Business Opportunity Rule (R511993). As presently drafted, I believe the rule would negatively impact my successful USANA business – a business I have poured my heart and soul into for the past twelve years. I am an independent distributor with USANA Health Sciences, Inc. – a company that strictly adheres to all laws, rules and regulations in the thirteen countries in which we operate. It is my understanding that the FTC is attempting to protect the public from deception and I appreciate that. However, having been contacted by representatives from dozens of direct selling companies over the past twelve years; I can honestly say there was very little hype, let alone deception. And even if there was, I don’t need a government agency telling me who is acting with integrity and who isn’t. Frankly, it is my responsibility to make that determination for myself. The requirements outlined in the proposed rule go too far in trying to protect the public. In fact, I believe the requirements proposed would have a detrimental impact on my ability to run my business. One requirement that would be devastating is the seven-day waiting period to enroll new Associates. The starter kit for USANA associates is either $19.95 (electronic version) or $49.95. Can you imagine being required to wait seven days before purchasing a kit to help you get started in business? When I prospect someone, one of their first questions is, “how soon can I get my products?” They are anxious to get started! If I were to go online or to a store or to an agent to purchase anything…and I was told I would have to wait seven days to process my order, I’d forget the whole thing. Please don’t hinder our business in this way! I also don’t understand the references clause in the proposed rule. I keep my customer’s and distributor’s information absolutely confidential. I promise them their information will go no further than me – and that I’ll shred any sensitive information I acquired from them in the sign-up process. It seems to me that passing along personal information would be a violation of rights as well as providing an open door to identity theft. I certainly wouldn’t want someone passing my personal information along. I originally became involved with USANA in 1994 because I was looking for some high-quality nutritional products that would benefit my family. I was a single mother trying my best to keep my head above water. As I learned about USANA’s business opportunity, I saw some potential for me – an opportunity to work from home to support my five children. Mine is one of those “only in America” stories. The small home-based USANA business I started in 1994 has grown into an organization that spans the globe. I have personally seen thousands of lives enhanced through better health and additional income. If your proposed Business Opportunity Rule had been in place in 1994, my life and the lives of all I’ve introduced to USANA would be completely different today. I don’t believe I would have gotten involved in an industry that had so many governmental hurdles and consequently, I would probably be on welfare! I implore you to consider the hundreds of thousands of Americans who operate their direct selling businesses with the utmost integrity. Please don’t stifle our entrepreneurial spirit. There are millions more “only in America” stories out there waiting to be born. Again, thank you for your time and consideration. I appreciate your intent but believe there are far better alternatives for achieving your purpose. Sincerely, Collette Larsen