| Comment Number: | 522418-08532 |
| Received: | 7/12/2006 11:11:48 PM |
| Organization: | Cookie Lee Jewelry |
| Commenter: | Christine Kirchenberg |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing regarding the proposed Business Opportunity Rule R511993. While the FTC has a responsibility to protect the public from 'unfair and deceptive acts or practices', I believe the proposed rule as written will have a very negative impact on many individuals like myself who are involved in the direct sales business to the point that I may no longer be able to sell my product, which is Cookie Lee Jewelry. One of the sections that is of greatest concern is the proposed rule that a person must wait 7 days to enroll as a new consultant. I see no logic in the necessity for this proposal and it would imply to a prospective rep that there may be a problem in the company. Also, people purchasing large $ items from any retail business are not required to wait for their purchases which often involve much more money layout than joining Cookie Lee. I do not know of anyone who ever signed up and then got a bad deal because they did so. The contract rule of 3 days would still apply for anyone who may change their mind. Adding 4 extra days is unnecessary. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices, regardless of whether the company was found innocent of such practices. Today, anyone or any company can be sued for anything whether found on any solid basis or not. This proposal would certainly put the company in a bad light, since its reputation would be put at great risk before guilt or innocence could be established. The proposed rule that there should be a disclosure of at least 10 prior purchasers makes no sense at all and would force us to publish names of people without their consent, a practice that would not be allowed or tolerated in a regular store business transaction. While the work of the FTC is intended to protect consumers, the above proposals would do nothing to benefit or protect the consumer, but would end up doing much to destroy the business base of any direct sales person such as myself. I would request the FTC to reconsider the entire issue by coming up with alternatives that would protect BOTH the consumer as well as the direct selling consultants. Thank you for your consideration of my concerns and comments. Chris Kirchenberg, Sr. Consultant with Cookie Lee Jewelry