| Comment Number: | 522418-06919 |
| Received: | 7/7/2006 11:43:26 PM |
| Organization: | |
| Commenter: | Janet Kuester |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Madam or Sir, I am writing regarding # 178 FTC Matter No.: R511993 16 CFR Part 437 Notice of Proposed Rulemaking: Business Opportunity Rule. I am very much opposed to this rule because of the direct impact it would have upon the ability of my husband to continue to conduct our very legitimate and ethical business which is our source of income. We are the founding distributors with Scent-Sations, Inc. and rely upon our income from our home based business to support us. I appreciate that it is the responsibility of the Federal Trade Commission to protect the public from unfair and deceptive acts or practices, but the rule as proposed would make it very difficult for me to operate my business. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll as a member of our candle of the month club. Most of the people who join our "candle of the month club" do so strictly to receive their candle package at a wholesale price. In other words, they are the sole consumers of the products. If they later wish to build a business, all they must do is supply the corporation with their Social Security Number or Tax Identification Number. There is no additional kit, fee or application required. A second facet of the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. In this day of identity theft, a governmental mandate to distribute the personal information of other distributors to strangers is more than unsettling. I believe that this would be a significant hurdle in maintaining any business growth and would cause MANY current distributors to quit. Additionally, providing a list of names of competitors to a potential recruit? How can anybody realistically expect that would be fair or beneficial to my business? The proposed rule also calls for the release of any information regarding lawsuits that allege misrepresentation, or unfair or deceptive practices over a ten-year period. It does not matter if the company was found innocent or guilty. How equitable is that? Thank you for your time in considering my remarks and concerns. Sincerely Janet Kuester