| Comment Number: | 522418-09297 |
| Received: | 7/14/2006 10:30:17 AM |
| Organization: | Mannatech |
| Commenter: | Sorista Tary |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Sorista M. Tary July 14, 2006 Dear Sir or Madam: I am contacting you because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a Mannatech associate. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” yet some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell Mannatech products. I have been Mannatech associate for more than a year and it is one of the best choices I ever made. Not only do the products I sell meet their claims, they surpass them. People on the products are finding so many improvements happening. Originally, I became a Mannatech associate in my company because I felt the products were exceptional and I wanted to earn some additional income. Now my husband and I are beginning to dream big as we see how great the impact of this business could make in our financial lives. The future of my family is dependent on the stability of the direct selling industry. The seven-day waiting period to enroll new associates makes no sense at all. The average order may be somewhere around $125 and People have the freedom to buy vitamins, food as well as TVs, cars, and other items that cost much more and they do not have to wait seven days. This is just flat out discriminatory. If people should have to wait 7 days before any transaction in the USA, I think many people would start checking out the rest of the world for a new place to live. Example: I take my baby to the emergency room and have to wait 7 days—NOT. I found a product that could affect the health and well being of my dying parent who is lying on their possible deathbed in the hospital and I have to wait 7 days—NOT, I don’t think so. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. 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 Mannatech is found guilty. Otherwise, Mannatech and I are put at an unfair advantage even though Mannatech has done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. I appreciate the work that the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences and there are less burdensome alternatives available to achieving your goals. Thank you for your time in considering my comments. Respectfully, Sorista M. Tary