| Comment Number: | 522418-11163 |
| Received: | 7/17/2006 4:56:01 AM |
| Organization: | |
| Commenter: | Marilyn Joy Axtell |
| State: | HI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I started using products from Young Living Essential Oils 3/05 and recently began to build my business with this exceptional company when I experienced many health benefits, including improved immune system and increased energy. Business Opportunity Rule R511993 would severely affect my efforts to spread the word on these superior products and to supplement my income. Comments on specific sections: Seven-day waiting period: most people buy a Young Living starter kit for the very reasonable (and refundable) price of $49.95, including a briefcase, educational materials, and samples, and entitling them to buy products at wholesale prices. Where is necessity of a waiting period? Litigation information: It is not right to demand that distributors be required to disclose lawsuits unless Young Living was found guilty of deceptive or unfair practices. References: In this day and age of exploding ID theft, this requirement would have an extreme chilling effect. Besides, Young Living does not sell business opportunites--it gives people the chance to buy health-improving products at wholesale prices for the cost of a returnable kit. Cancellation: It's unrealistic to demand that a company maintain lists of distributors who have allowed their membership to expire and to provide the lists to prospective distributors. Exemption: In 1979 the FTC said "When the required investment to purchase a business opportunity is comparatively small, prospective purchasers face a relatively small financial risk". The proposed rule eliminates the exemption which was set at $500 in 1979. As mentioned earlier, Young Living distributors are not franchise purchasers--they buy a returnable kit for a modest price. Please reinstate the $500 exemption! I appreciate the FTC's work to protect consumers. However, I believe this proposed rule would have many unintended consequences, would increase the costs of doing business for both Young Living and distributors, and decrease the chances of many people to supplement their income. Mahalo for your consideration. Very truly yours, Marilyn Joy Axtell