| Comment Number: | 522418-09578 |
| Received: | 7/14/2006 7:03:32 PM |
| Organization: | lia sophia advisor |
| Commenter: | Christine Mehan |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
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. 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. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to lia sophia headquarters and then wait for the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson - “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. Further, 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 lia sophia products. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new advisors. lia sophia's sales kit only costs $149. People buy TVs, cars, and other items that cost much more and they do not have to wait seven days. This waiting period gives the impression that there might be something wrong with the company or the compensation plan. I also think this seven-day waiting period is unnecessary, because lia sophia already has a 100% lifetime guarantee or buyback policy . Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about lia sophia and will then need to send in many reports to my company headquarters. In addition, I will also need to inform the new recruit of THEIR reporting and record requirements, which may ADVERSELY afffect their decision in choosing to become a recruit or advisor. 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 lia sophia is found guilty. Otherwise, lia sophia and I are put at an unfair advantage even though lia sophia has done nothing wrong. Finally, I have been a lia sophia advisor for only four months, but I have more than recouped my initial investment of $149. It is important to note that I originally became an advisor in my company because I felt the products were exceptional and I needed to earn additional income to support myself and the lifestyle I want to live, all of which are absolutely dependent upon the stability of the direct selling industry. Let the future of the industry be decided by those actively involved in it and not by government rules and regulations. This is America - "the land of the free" - so let the independent selling agents conductly business freely WITHOUT burdensome requirements that would destroy THEIR futures. Thank you for your consideration, Christine.