| Comment Number: | 522418-08808 |
| Received: | 7/13/2006 2:05:59 PM |
| Organization: | Herbalife |
| Commenter: | Tim Hendricks |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 12, 2006 Dear Sir or Madam: I am writing to express my concerns with the FTC's proposed Business Opportunity Rule R511993. I became an Independent Herbalife Distributor to build an income for my family so that my wife and I could leave our 9-5 jobs and create some real security for our children and our future. I have been personally using and distributing the Herbalife products for over 10 years. During that time, my wife and I have helped hundreds of people directly and thousands indirectly with the Herbalife products and business opportunity accomplish positive change in their lives. In turn, Herbalife has compensated us very well for our consistent efforts, enabling both of us to leave our jobs, come home to start our family and raise 2 incredible kids that get to have their Mom and Dad at home with them every day sowing into their lives. The particular provisions in the FTC proposed rule, R511993 are very disturbing to me, and threaten the very existence of the income stream that is used to care for my family. In particular, this proposed rule would cause me and my entire team of Distributors a substantial burden in sponsoring Herbalife Distributors into our team. Every Herbalife Distributor would have to: Obtain the written disclosure statement from Herbalife (Which causes a huge delay) I would have to then have my prospective Distributor that is ready to begin their training sign the disclosure statement and then forward a copy of that signed statement to Herbalife headquarters (another big time delay). Then wait another 7 days before I can allow the prospective Distributor to sign the Herbalife Distributor Application and actually begin their training and building their business. As it stands now, if I talk with Mary and she is ready to get started, we can start her training THE SAME DAY and have her using the products and helping other using the products (thereby putting money in her pocket) with 72 HOURS. If this proposed rule is passed, it could take TWO WEEKS OR MORE to help Mary get started. To me, this seems absurd for a company that has the track record and business growth of Herbalife. 26 years and counting, publicly held and traded on the prestigious NYSE (symbol HLF) and growth from 1.2 Billion in retail sales in 1996 to 2.6 Billion in retails sales last year with a target of surpassing 3 Billion worldwide this year. I am a former US Marine that served my country honorably, willing to die defending the freedoms we have fought hard for over the last 200 years. I am now an entrepreneur building and living the American Dream. I support FTC’s goal of preventing consumer fraud and always operate my business with the utmost honesty and integrity. I think the FTC absolutely needs to revisit its proposal, taking into account the significant burden it would impose on legitimate direct sellers like me. Sincerely, Tim Hendricks