| Comment Number: | 522418-08375 |
| Received: | 7/12/2006 5:38:54 PM |
| Organization: | |
| Commenter: | Gary Lyle |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
07-12-06 Re: Business Opporltunity RUle R511993 Dear Representative Greg Walden, Chairman Stearns or Secretary: I am writing this letter because I am concerned about hte proposed BUsiness Opportunity Rule R511993. While I understand the responsibilities of the FTC to protect the public from "unfair and deceptive acts or practices," I believe that this proposed rule coulde prevent me from continuing as a distributor for Young Living Essential Oils. There are specific sections in the proposed rule that will make it very difficult, if not impossible, for me to sell (PURCHASE) Young Living's products. I became involved with this company becasue I felt the products were exceptional and still do. Later on, I became further involved by offering the products for sale (both retail and wholesale) so that I could earn additional income (or to help pay for the products I use). Through Young Living I have developed leadership skills, cultivated many meaningful relationships and have begun to build a retirement fund for myself. My family members enjoy the health benefits of using the Young Living products daily, and we are thrilled to be part of this company.. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new distributors. Young Living's new distributor Starter Kits cost only $50.00, and each kit contains products, samples, training materials, etc., worth far more than the sale price. When a Starter Kit is purchased, the purchaser becomes a distributor and is granted special discounted pricing on all orders. No commissions or other compensation is paid on these kits, and the company just covers its production costs. Having the proposed waiting period gives the impression that there might be something wrong with the company or the compensation plan. I also think the seven day waiting period is unnecessary because Young Living fully refunds the $50 cost if the customer decides to send it back. Requiring a seven-day waiting period before a distributor is allowed to even place an order would be destructive to the businesses of thousands of distributors who are building a business around Young Living's products. IT would also be quite burdensome for us to keep such detailed records of when we spoke with every single person about Young Living. Additionally, it would create lots of unnecessary paperwork to ahve to send these reports to our company headquarters. When people buy other items (like TVs, cars, even firearms) that cost much more than $50, they do not have to wait seven days. Litigation Information. The proposed rule also calls for the release of any information regarding lawsuits involving m isrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent or not. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless Young Living was found guilty. Otherwise, Young Living and I are put at an unfair advantage even though neither of us has done anything wrong. To release this information would be misleading to prospective distributors. Sincerely, Gary L. Lyle