| Comment Number: | 522418-08161 |
| Received: | 7/12/2006 1:01:35 PM |
| Organization: | |
| Commenter: | John Tartol |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
TARTOL ENTERPRISES July 12, 2006 Federal Trade Commission: I am writing to express my concerns with the FTC's proposed Business Opportunity Rule R511993. I became an Herbalife distributor after getting fantastic product results - lost 12 pounds in 10 days and never felt better. I wanted to help people get the same positive results I received and also wanted to help people with the opportunity side of the business. I was very enthusiastic that everyone won - customers with their results, distributors making money and Herbalife flourishing. I have now used the product and worked the opportunity for almost 25 years. My whole family - parents, in-laws, brother, sisters -2 and their children have all benefited from the products and the opportunity. This company brought our family together in helping people around the entire world, having incredible life experiences while bringing up our children with good health and showing them the American dream can be a reality. The proposed rule would be an unnecessary and substantial burden in building our business. We would have to obtain the written disclosure statement from Herbalife which I feel is discriminatory. If Herbalife must do this then every college and university in the USA should gather data on how many students get a job with their degree, at what pay ranges, longevity, cost of education, how long to get advanced in their companies, pay raises, do they have to travel, child care expenses…Ridiculous right? Each individual's circumstances, motivation, work habits, etc. would be too hard to balance in fairly. The same is true here. Also I would have to send 10 prior purchasers names and contact info living closely to the prospective purchaser. This would inhibit people from buying as they would be asked to discuss very personal health and image issues with strangers who also would be put into a very awkward situation. If we must do this then so should doctors, chiropractors, beauticians, contractors, insurance agents, lawyers, pharmacies or anyone else offering a service or product to the public. I would also have to send the disclosure statement signed by the prospect to Herbalife who would keep the data for 3 years - again Why us and not every other business person? I would have to wait 7 days before a prospect could sign the application or make any partial payment. When people decide to make a life changing decision they want to act now. Our enrollment fee is as low as $55. Again with this logic then anyone buying a car, appliance, home, or a myriad of other products costing MUCH more should be forced to wait 7 days - this would stop the economy. 2. I absolutely believe in the FTC's goal of preventing consumer fraud but the burdens being proposed here are discriminatory, unbalanced compared to our competitors, and a significant unfair burden to honest, hard working direct sellers as me and my family are. Sincerely, John Tartol