| Comment Number: | 522418-07035 |
| Received: | 7/8/2006 6:22:29 PM |
| Organization: | |
| Commenter: | LaVonne Klimek |
| State: | WI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in it's present form, it could prevent me from continuing as a Market America Independent Distributor. I understand that part of the FTC's responsibilities is to protect the public but some of the sections of the proposed rule will make it very difficult if not impossible for me to sell Market America products and services. I have been an Independent Distributor for a couple years now. I became an Independent Distributor to have a backup plan to my employment because rumors of downsizing were coming from management. Ultimately, a year after I started with my backup plan (Market America) it became my ONLY plan as I was unemployed. This was not the first time I was victim to this lawful change in the corporate world. In the 1980's I was also victim of losing two career jobs to mergers in the food distribution and airline industries. The trend to part-time jobs with no benefits brings us to where we are today. My Market America business has given me a way to pay my bills, while working jobs paying less than what I made 10 years ago, and I'm not getting any younger! I am also on my way to replacing the income from these jobs with goals to go beyond what appears to be in reach currently in the low economic area I currently live in. One of the most confusing and burdensome sections of the proposed rule is the seven day waiting period to enroll new distributors. Market America's subscription (sales) kit costs under one hundred dollars. This is an unheard of low risk endeavor! We do not tie other much more expense purchases to this kind of requirement and I feel it is totally unnecessary. One of the greatest benefits to working with Market America is that they have ensured a system that is not overwhelming with paperwork and inventory, and I feel the detailed records and their submissions will be overwhelming, burdensome and would be of little value to the public. The proposed rule requiring disclosure of prior purchasers may be in violation of my state's laws regulating referrals, testimonials and advertising. In addition, people are very protective and apprehensive about disclosings and use of their personal information and requesting and giving out this kind of information could damage the business relationships I have. There are no assurrances these days of absolute protections! The proposed rule calling for the release of any information regarding lawsuits without the disclosure of an innocent judgement would also be unfair. Since people will sue for just about anything this would unfairly represent Market America and I'm sure other companies or businesses. I believe this proposed new rule has damaging consequences for small business owners like me. A less burdensome alternative would be desirable in achieving your goal to protect consumers.