Comment Number: 522418-06950
Received: 7/8/2006 5:02:32 AM
Organization: Stampin' Up
Commenter: kristin gerber
State: Not in the US
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been a demonstrator with Stampin' Up for 2 years. I sell about $1200 worth of merchandise every year and make about $1200, which I spend on more stamps for myself. I'm a stay-at-home mom with 5 children. I enjoy selling stamps and craft supplies to my friends and neighbors, but it's more a hobby than a business. I have 3 recruits now, all friends or neighbors. (1) The proposed new rules would involve excessive record-keeping for me. This is not a full-time business with a separate office. It's run out of my dining room, personal computer, and one file drawer. If more record-keeping were required, it would be a burden on my and off-putting to potential recruits. One of the main selling points for new demonstrators is how it doesn't take lots of time away from their families. (2) It would invade my privacy. Would I have to tell everyone about the lawsuit against us arising from my daughter's car accident? That took years to resolve and we were not found to be at fault. Potential recruits like their privacy, too, expecially since personal lawsuits likely have no bearing on Stampin' Up. (3) A seven day period before applying would be very harmful to recruiting. When a recruit fills out an application, it takes at least 2 weeks before it's processed and her supplies are shipped and even longer for us because we're with the Army in Europe. One of my recruits does't want to sell at all, she only wanted the demonstrator supply kit. There is plenty of time built into the process for the recruit to continue collecting information and change her mind. But requiring waiting 7 days before even applying would seriously harm my recruiting efforts. Americans want it and they want it now! I have other concerns about the rules changes, but these are the main ones. Sincerely, Kristin Gerber