| Comment Number: | 522418-12206 |
| Received: | 7/17/2006 7:10:51 PM |
| Organization: | The Pampered Chef |
| Commenter: | Lisa Bedford |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, Matter No. R511993 I am writing to voice my concern about the proposed Business Opportunity Rule. I am an Independent Executive Sales Director with The Pampered Chef and have been with the company for nearly fourteen years. My Pampered Chef business allows me to stay home with my young children, contribute to our family’s income, and save money for our future. In my previous career I trained school teachers for one of Phoenix’s largest districts. I found the Direct Sales industry to be more rewarding and flexible than a fulltime job outside the home. It is very possible that the passage of the Business Opportunity Rule would cause enough difficulty for myself and for The Pampered Chef and that my business would come to an end. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new Consultants. The Pampered Chef’s starter kit only costs $90. 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 The Pampered Chef already has a 90% buyback policy for all products including sales kits purchased by a salesperson within the last twelve months. In fact, new Consultants who order our Starter Kit, pay the $90 and then never submit the four shows they have agreed to do, are never penalized and get to keep the kit regardless. The proposed rule requires the disclosure of a minimum of ten 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 consent) 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 The Pampered Chef 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.” I know that I would not agree to have my personal information given to strangers. I am sure there is a very small percentage of people in this industry who do not conduct their businesses with honesty and integrity. But those people are found in every type of career and in every walk of life. The Business Opportunity Rule will punish businesswomen like myself for the actions of a dishonest few. The vast majority of us realize that the success of our business depends on the trust our customers have in us. I do appreciate the efforts of the FTC in protecting consumers. However, this Rule will have unintended consequences and will do more harm to the honest people in this industry than those it intends to target. Thank you for your time and attention to my concerns. Sincerely, Lisa L. Bedford Independent Executive Director with The Pampered Chef