|Received:||7/17/2006 10:03:56 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Sue Smalheiser EDC/Usborne Books July 17, 2006 Dear Sir or Madam: > I am writing this letter 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 EDC/Usborne Books Education Resource Provider. 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 Usborne Books! > I have been an Usborne Books consultant for more than 9 years. Originally, I became a consultant in my company because I felt the products were exceptional and I wanted to earn some additional income. Now, I am earning enough additional income to provide my family with the little extras that mean so much to kids, such as camp and sports activities. My family loves what I am able to do for them as a result of my direct selling business. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new consultants. EDC/Usborne Books sales kit costs between $29-$99.00! 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 EDC/Usborne Books already has a 90% buyback policy for all products including sales kits purchased by a salesperson within the last twelve months. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about EDC/Usborne Books and will then need to send in many reports to my company headquarters. > 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. 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 EDC/Usborne Books 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. 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, Sue Smalheiser > > > > Sue Smalheiser > > > Usborne Books - The Books Children Love to Read! > Complete catalog online at: > > > Register for the monthly drawing of $50.00 in FREE books!