|Received:||7/17/2006 7:50:49 PM|
|Organization:||Barefoot Possibilities Marketing Group|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-12276.pdf Download Adobe Reader|
Comments:I am writing to express strong opposition to the proposed Business Opportunity Rule R511993. We accept FTC need to protect the public from "unfair and deceptive acts or practices," but the rule as proposed puts the burden of proof in entirely the wrong place. As an ethical business person for 35 years, these proposed regulations would freeze business and create an unimaginable and unnecessary bureaucratic nightmare. It would certainly make it very difficult for me to operate my business as a Shaklee Independent Distributor. Here are just some of the issues that we see as burdensome & totally unnecessary: *seven-day waiting period to enroll new distributors. Most of the people who sign a Shaklee application are consumers of the products. Who wants to wait a week to purchase consumable products? *If they later wish to build a business, No additional fee is required. The Shaklee Member Kit costs only $19.95. This is far less than most consumer purchases, from TVs to all manner of household appliances, none of which require a waiting period. * The waiting period is also unnecessary in that Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. *Disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. What a nightmare! Go online or look in any phone book and you can find thousands of them for yourself. *In this day of identity theft, why would anyone want to give out the personal information of other Shaklee distributors? Who would agree to become a distributor if their identity becomes public to anyone who asks? *Providing the 10 references also could damage the businesses of Shaklee distributors. Why give out information to solicit competitors. *The 10 reference requirement is an administrative burden. *The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentation, or unfair or deceptive practices over a 10-year period. It does not matter if the company was found innocent or not liable. In this litigious society, what a way to strangle even a legitimate business. Fifty-year old companies such as Shaklee would be at a disadvantage compared to start-up companies, which may not yet have experienced litigation but are far more likely to have legal issues surrounding their opportunities. I have been a Shaklee Distributor for more than 35 years. The income from our business supports our family. These proposed changes would provide an administrative nightmare, a financial liability, and we see no benefit to protecting the consumer besides a bureaucratic nightmare.