| Comment Number: | 522418-08687 |
| Received: | 7/13/2006 10:31:04 AM |
| Organization: | Herbalife Independant Distributor |
| Commenter: | Terry Cleveland |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Dear Sir or Madam: We are writing to express our concerns with the FTC's proposed Business Opportunity Rule R511993. We became Herbalife Independent Distributors to improve our health and generate supplemental income. We both lost 30 pounds and 50 pounds respectively and kept it off for 13 years using the Herbalife products. We have also been selling the products 12 years. The income has allowed my husband to quit his corporate job 7 years ago and come home to help me raise our 3 grand children we have living with us. With Herbalife we have our health and family. The proposed Business Opportunity Rule R511993 would make doing our business nearly impossible and put us out of business. Bringing others into the business would be difficult time wise if we had to obtain the written disclosure statement from Herbalife for each business prospect. Most people who need additional income do not have the luxury of time to wait for this type of written disclosure statement from Herbalife. The information required in such a disclosure statement such as the names and contact information for 10 prior purchasers who live closest to the prospective purchaser would create an administrative quagmire. If the prospect is then required to sign such a disclosure statement and mail to Herbalife the average person would feel this is far too much required to purchase the products and/or participate in the business opportunity and simply not follow through such a long arduous process. Having the prospect wait seven days before they could sign the Distributor Application or make any payment related to the opportunity is not necessary, as they would never make it through such a gauntlet of requirements. As a self employed entrepreneur we do support FTC’s goal of preventing consumer fraud, but we believe the agency needs to revisit its proposal to take into account the significant burdens it would impose on legitimate, hard-working direct sellers such as ourselves. Sincerely, Marlene & Terry Cleveland