| Comment Number: | 522418-09613 |
| Received: | 7/14/2006 8:24:20 PM |
| Organization: | |
| Commenter: | Charles Cox |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
We want you to know that we are strongly opposed to the so-called Business Opportunity Rule--R511993. Perhaps it should be called the Discouraging of Business Opportunities Rule inasmuch as that will be the effect it would have on our Shaklee Products business. When we became distributors of these products some 37 years ago, there was no fee to join. Now it is a nominal $19.95, with more than that amount likely to be saved in a new member's first order of products. We have never made it our practice to sel" the business opportunity because our focus has been on the very effective products. Nonetheless, we are glad to make available to our retail customers the opportunity to become members and save 15%. Some of them go beyond that and sponsor other members, becoming distributors themselves and saving even more on their own purchases. They also then receive bonuses--paid by Shaklee Corporation--on their group volume. Much of my income-earning life has been spent in Christian education, which does not pay well. Our Shaklee income has enabled me to do the sacrificial Christian service. In both areas--Christian education and Shaklee--we are helping others and thankful to be able to do so. Rule R511993 would likely curtail this significantly. It calls for a seven-day waiting period before a person who is ready to save would be permitted to do so. It also requires that such a person be given ten or more people who are already Shaklee Products distributors so they may be contacted for their input to the potential member's decision. This is a serious imposition on those ten and is superfluous in that, by virtue of the fact that they are distributors, their input would be heartily positive. We are aware that there are fly-by-night companies whose so-called business opportunities are spurious. No doubt the intent of Rule R511993 is to curtail such and protect the people upon whom they would prey. Shaklee has been in business for half a century and is well recognized for its integrity in product formulation, product distribution, and the opportunity for unprecedented financial benefits. It may not be feasible for you to institute a rule that would exempt reputable companies, so it would seem best not to have any such regulation as Rule R511993. Yours in sincerity, Charles D. Cox and Gladys Cox