|Received:||9/18/2006 3:06:07 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear Sir or Madam, I am writing in reference to comment 522418-09331, reguarding the proposed Business Opportunity Rule R511993. I disagree with comment that the wait period would be detrimental to their business. I was an Independent Consultant with Arbonne for two years. How the business works or the Policies and Procedures of the company were never fully explained to me prior to signing up as a consultant. It was a spur of the moment decision and I was in before knew how things worked. Had the wait period been in effect, I would have researched MLM's, Arbonne, discussed my plans with family, and had a chance to READ the Policies and Procedures Manual. I would have been more informed, and more able to make an educated decision. Now all I am is disappointed that I spent time and money listening to the people training me to do unacceptable business practices. I truly believe that the atmosphere in which most of recruiting is performed (meetings or home parties) does not lend itself to promoting professionalism with these companies. The sponsors are in a rush to recruit while the person signing up believes that they are starting a business. Most new business owners take time to research what laws will govern them as business owners. However, I think recruiting people quickly is the goal so that the upline can succeed. This only creates haste and confusion for trusting and unsuspecting people. Full disclosure, meaning facts about a company's record and the MLM industry and how it ALL works, needs to be provided to potential prospects. I believe a wait period would not give the impression that companies are hiding something (unfortunately, they are) but give the impression that they are professional company with sound business practices helping people make informed decisions before investing their money and time. I believe MLM's, specifically Arbonne, thrive on the trust factor, because so many teams are promoting practices that completely go against the Policies and Procedures. Implementing the wait period would go along way in taking the stigma of deception off these MLM companies and help people run their businesses according to the rules and laws outlined in the Policies and Procedures. I just began researching MLM's (two years after starting my business) and found all kinds of discrepancies between what is outlined in our policies and procedures and the way my upline was training us. That is why I am no longer with this company. Thank you.