| Comment Number: | 522418-07365 |
| Received: | 7/10/2006 4:05:51 PM |
| Organization: | Stampin' Up! |
| Commenter: | Elizabeth Saccocia |
| State: | MA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
While I appreciate the intent of the work that the FTC does, I believe that in this case Rule R511993 will do harm to legitimate direct sales organizations such as Stampin' Up! I have been with the company as an independent demonstrator for over 5 years now. My family now counts on the time that I can be available for them in addition to the extra income I can provide working around all of our schedules. When I first got involved with Stampin' Up!, it was strictly a hobby. I have been able to grow my business at my pace over the last 5 years due to the support of my uplines and company. If the rule changes go into effect, I am certain that it will negatively impact my business. A 7-day waiting period sheads a negative light on the business in addtion to causing administrative headaches and unneccessary delays. Litigation reporting would require providing information that is not related to my business venture and is riduculous to go back 10 years. It is not practical to find the 10 closest distributors and there are privacy issues to contend with in this day in age. Asking for all purchasers of demonstrotorships over the past 3 years is absurd! That information is effected by each individuals circumstances and goals and a simple number cannot reflect anything meanful here. It appears that while the goal may be to protect consumers from fraudulent enterprises, I think think more research needs to go into understanding the workings of the direct sales industry. There are plenty of legitimate companies run through direct sales that will definately be adversely affected if this ruling goes into effect. I, for one, know that the company I represent, Stampin' Up! is legitimate and has their demonstrators best interest in mind. I know that they are not the only company like this. Please reconsider this ruling after researching HOW direct sales companies conduct their business. Certainly, people have the right to spend much more than $195 (the price of Stampin' Up!'s starter kit) without a second thought let alone a wait period, personal information about the seller for the past 10 years and references for 10 local sellers!! When you look at how the companies run, you can see that it clearly is not in anyone's best interest to adhere to the proposed rulings. Thank you for your consideration. Elizabeth Saccocia