| Comment Number: | 522418-07739 |
| Received: | 7/11/2006 4:12:37 PM |
| Organization: | |
| Commenter: | José Bernabel |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To FTC Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Ave, NW Washington, DC 20580. Re: Business Opportunity Rule, R511993 Dear Sir or Madam: The reason of this letter, is to express strong opposition to the proposed Business Opportunity Rule R511993. I do understand that the FTC must protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. A confising and burdensome section of the peoposed rule is the seven day waiting period to enroll new distributors. Most of the people who sign a Shaklee application are consumersof the products. If they later wis to build a business, all they must do is supply Shaklee Corporation with their Social Security Number or Tax Identification Number. No additional kit, fee or application is required.The Shaklee Member Kit cost only $ 19.95. This is far less than most consumer purchases, from TVs to all manner of household appliances, non of which require a wai ting period is also unnecessary in that Shaklee Corporation already has 90% buy back policy for products, including the member Kit, purchased by a distributor within the last two years. The proposed rule requires of a minimum of 10 prior purchasers n earest to the prospective purchaser. In this day of identity theft, I am uncomfortable giving out the personal information of other Shaklee Distributors, without their knowledge or consent. I unders tand that those who sign up after the rule takes effect would be told in writing "if you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers." This would dissuade new people fron signing up as distri butors as they are concerned not only about identity deft, but also about their privacy. Provaiding the 10 references also could dema ge the business of Shaklee distributors. Lower ranking distributors often are involved in more than one direct selling company. Provi ding a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for such other opportunity. There are others reasons why I do strongly opposed to the proposed Business Opportunity Rule R511993. I had been a Shaklee Independent Distributor for more than 22 years. Originaly, I becaame a Shaklee Distributor because the company's products lines are the best in the Industry. (Nutritional, personal, household, Water Treatment and Air Source). Thenafter I wanted to earn additional income and very soon I started to do so, working from home and for past 22 years my family had been and is depending upon this income. I just want to thank you for considering my coments. Sincerely, José Bernabel