Comment Number: 522418-10248
Received: 7/16/2006 12:13:25 AM
Organization: lia sophia
Commenter: Mary Frances Downs
State: OH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing because I am very concerned about the proposed Rule R511993. I understand that you have responsibilities to protect the public from "unfair and deceptive acts or practices," yet some of the sections in said rule will make it next to impossible for me to sell Lia Sophia products and continue to grow my business. Who will protect me? People get very enthused over Lia Sophia products and it is no wonder that they are excited to become an Advisor. Setting a 7 day wait period is going to put a huge damper on that enthusiam and in the long run will not have saved anyone anything. Lia Sophia offers a very reasonable start up kit cost (only $99) which provides over $400 dollars in sample jewelry plus catalogs and order forms and training materials. $99! People can buy TVs, cars, and other items that cost so much more and they are not expected to wait. People can buy guns faster than that. Who's to say when day one begins, anyway? I was interested in becoming an advisor with Lia Sophia and had been approached to join long before I actually "signed on the line." Who will keep up with all these records? Everyone will be equally confused. The next issue I have is the requirement to disclose a minimum of 10 prior purchasers. I don't have that many recruits, yet! Beyond that simple problem is the very real and basic -- people do not want to have their information handed out to just anybody. How about giving the prior purchasers some protection? I hate to be so negative about something that was worked on by so many people, but the reality is no one who worked on writing this proposal could have given the people already happily and successfully involved in the independent sales industry a moments thought. If they had, they would realize that this proposed rule will do nothing more than ruin personal businesses. All this extra fuss and work to save a few people from making "rash decisions." Whatever happened to "let the buyer beware?" Why can't we expect the people who are being taken in by all the crooks to be more reasonable? I am sorry that they are not able to recognize a scam when they see one, but why do I and my colleagues have to suffer because they make unwise choices? And once they've made their choice why not expect them to own up to being foolish instead of suing the company involved which then leads to persecuting EVERY direct sales business -- shifty or not? In conclusion, I would like to say that I do appreciate the enormous task that the FTC has in protecting consumers, yet I believe this proposed new rule has many unintended consequences and there has to be less burdensome alternatives to achieve your goal. Thank you for consideration. Respectfully, Mary Frances Downs