Comment Number: 522418-07094
Received: 7/9/2006 10:20:37 AM
Organization: Discovery Toys, Inc.
Commenter: Laurie Harmon
State: SC
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 its present form, it could prevent me from successfully operating my business as a direct seller of Discovery Toys products. I understand that the FTC's mission is to protect the public from unfair and deceptive acts or practices. However, some of the sections in the proposed rule will make it very difficult for me to sell Discovery Toys products and help others start Discovery Toys businesses of their own. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period for new consultants. Our new consultant startup kit costs only $99. People buy TVs, cars and other items that cost much more than that, and they don't have to wait seven days. This waiting period gives the impression that there might be something wrong with our business. Under this waiting period requirement, I will also need to keep very detailed records when I first speak to someone about Discovery Toys, and I will then have to spend much of my time preparing and sending in reports to Discovery Toys headquarters. This will be a major burden for me, and it doesn't help to protect the public in any way. When I became a Discovery Toys independent consultant 2 years ago, I did it primarily because I wanted to earn some additional money. My family now depends on this extra income, and I'm very concerned about the proposed Business Opportunity Rule, because I believe it will jeopardize my business. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving the FTC's goals. Thank you for your time and for taking my comments into consideration.