| Comment Number: | 522418-11382 |
| Received: | 7/17/2006 11:09:11 AM |
| Organization: | ACN |
| Commenter: | Debbie Davis |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I believe if this NPR is adopted in its current form, it could have a devastating impact on our company and industry. Complying with this would be an unfair burden to my business as well as to our company’s overall business. This could affect thousands of ACN employees and tens of thousands of ACN independent reps. I got involved with ACN in 1993. I was a stay-at-home mom with no business background. The 1st yr I made several thousand dollars which was tremendous because it proved to me that it worked. The next year, I made about $50,000 and then about $200,000. I then made about $700,000 and for the last 9-10 yrs I averaged approx $500,000 of income/yr. My husband was an executive at Chrysler making 6 figures, after a Masters Degree and a 16 yr career. We walked him away after 3 yrs involvement with ACN and have been depending on ACN as our sole source of income ever since. With that kind of income, I can assure you that much of it has gone right back into the economy, so ACN has been a blessing to not only me and my family but also it has been a legitimate source of growth to our economy. I’ve grown tremendously through ACN. I’m able to train large groups of reps on stage at public arena-type settings as well as more intimate home presentations. When I started, I couldn’t talk to two people at once. I had very low self-esteem. This business has allowed me to break through all my fears and I can’t tell you how liberating that has been. My husband has also been blessed with these same treasures, as well as our 3 children. What a terrific environment to be around – 14 years of positive exposure to handling the good, the bad & the ugly for our kids! My specific concerns: • Regarding the proposed 7 day waiting period – it automatically & unfairly casts a negative light on our industry/company. Why should every direct sales company be punished for the actions of a few bad apples. • The record keeping would be an administrative nightmare. Not only might we lose some very good people because of the “out-of-site”, “out-of-mind” scenario it would create – good people who could go on to achieve tremendous financial gains as so many have over the years, but it would be a tremendous waist of time having additional tracking measures just to maintain which prospect is at what day in the waiting period to come aboard. Imagine if the same rule applied to selling cars or houses after one has secured financing – what is the sense of it? It would be a very unnecessary delay in the operations of my business – a business, I might add, that has about $300 million of revenue streaming through it each year! • Regarding providing references – it would be impractical to find the 10 nearest geographically located distributors. And even if we did, a bright, energetic, motivated individual who is longing for this opportunity might get knocked out of the box by someone who got involved with ACN and did nothing to build their business, and then went on to blame ACN instead of their own lack of actions. It really shouldn’t matter to anyone what someone’s opinion about the company is – good or bad, because they can’t assure that the new person will work at the same rate that the referenced rep did, or know the same people that the rep did. It’s no different than in the job market – some are performers, some are not. Does that mean the company is good or bad? I don’t think so! And I can’t think of one person who would be comfortable with the thought that our federal government is mandating that ACN give out the names and phone numbers or addresses to prospective reps with the state of privacy, safety & identity concerns which surrounds us today. I appreciate what the FTC is trying to do here, but the proposed ruling would unfairly target legitimate direct selling businesses. Fraudulent actors will never comply with this or any law. The FTC must come up with a law that legitimate businesses can live with.