| Comment Number: | 522418-06069 |
| Received: | 7/5/2006 10:01:49 AM |
| Organization: | Law Enforcement Officer |
| Commenter: | Hebert |
| State: | LA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I, being in law enforcement, have been approached by several persons being solicited by Arbonne International consultants. These consultants are using tactics to sign up people in the classic pyramid form of promising such things as $30,000.00 a month. They are also leading people to unreal expectations of income at any level and are pushing recruitment of 4 people under you, then 4 people under them, and on and on, instead of pushing the sale of their goods. This is getting extremely out of hand and will result in a large finanical loss to numerous people across the U.S. Although the product may be excellent their marketing scheme is a pyramid scheme for the people at the upper levels to make the money and the other 99% to think they will make the money. They also have clauses in their terms and conditions where any consultant, and on up the line, cannot hold them civily liable for any loss of income. Some questions one might ask is what is the total amount of employees, consultants all the way to president, in the company to date? What is the total sales of the product to date not including consultant purchases? What is the total sales to date of the company from a consultant purchasing the RE9 kits, that is now theirs, or other kits to bring to people for three days to try? This information should be available for viewing by employees from the company, it is not. If the company disclosed this information it would show that their consultants, their own employees, provide their highest profit margins and are their best customers. Think about it. People need help to wake up from this dillusion and I beleive the only way to do this is for the FTC to take action with this new rule to at least make a dent in these MLM's that are taking advantage of U.S. citizens. I have been in law enforcement for over twenty years working scams similar to this on a smaller scale. I have seen people manipulted over and over and want law enforcement to arrest these people once the victims have lost their money. Well without the proper laws, law enforcement is unable to arrest and prosecute these people and civil action is necessary. Thats why the FTC must enact more aggressive rules to deal with these companies. Thank you