| Comment Number: | 522418-07339 |
| Received: | 7/10/2006 2:59:44 PM |
| Organization: | Advocare |
| Commenter: | John Duran |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-07339.pdf Download Adobe Reader |
Comments:
Please see the attached letter. I have worked with Advocare for the past 2 and a half years. I have found the company and all of those members I have dealt with, to be extremely credible and interested in the good of their customers and members. This organization offers and fully supports a money back offer. It is a core part of their philosopy that they only want satisfied customers and members. Please reconsider the Business Opportunity Rule that enforces a 7 day cooling off period, this rule is decidely hurtful to the business development activities of legitimate distributors and is prejudicial against direct sales. Imagine forcing car dealerships to wait a full week before they could close a sale. The idea is ridiculous yet the size permanency and financial impact of that investment is far greater than the one an Advocare member makes when they decide to join Advocare. Further, by not protecting consumers from ALL financial decisions through similarly enforcing a 7 day cooling off period, you are in effect saying consumers are intelligent enough to spend their money wisely, EXCEPT when it comes to membership in direct sales companies. These are not firearms, they are largely legitimate business with people like you and me trying to work with others for the common good. An alternative to the 7 day cooling off period is the proper structuring and enforcement of a refund policy with appropriate labeling and simple processing for members who choose not to remain with the company. Thank you for consideration of my comments and the comments of other legitimate responsible members of the direct sales industry