Comment Number: 522418-06792
Received: 7/7/2006 1:57:59 PM
Organization: Melaleuca
Commenter: Chris Brown
State: CO
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: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as a Marketing Executive with Melaleuca and destroy my small business. I have been an independent Contractor with Melaleuca for more than 3 years. Originally, I started my Network Marketing because of the products I loved them and wanted to earn some additional money. Now my family depends on this extra income to supplement our budget. Please don’t destroy my small business we need it! Some of the sections in the proposed rule would make it hard or almost impossible for me to find new customers. This waiting period will give the public the idea that there’s something wrong with me or our plan and also reflects badly on me. I also think this seven-day waiting period is unnecessary, because Melaleuca already has a 100% 60 day empty bottle, buyback policy for all products including sales kits purchased by a salesperson. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new customer Melaleuca’s membership (like a Sam’s Club or a CostCo membership) only costs $_29 and is also 100% refundable in first 4 months... People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone a prospect and will then have to send in reports to my company. I am a small home business and this burden hurt or destroy my business. This proposed rule is bad. Yes I search for both new Melaleuca customers who just want to take advantage of our products at wholesale price and those who wish to build a business by helping us find new customers. We already have a full discloser income statistic fact sheet that shows real incomes earned by those building a business along with the % of those at what income level and the time it took them to get to that level. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Women in my organization may be subject to sexual or racial harassment so this part can’t go in at all, unless the FTC passes an addition to this rule Prohibiting sexual or racial attacks related to this disclosure. In the end the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. I have seen many scams on the Internet and been approached by many crooks because of my success. This rule will do nothing to stop them. They hurt my business! This rule will not stop Crooks – they violate the current rule all the time. But I am a good American citizen and it will hurt me. Thank you and please help me. Sincerely, Chris Brown