Business Opportunity Rule #522418-11110

Submission Number:
Carol Storey
Initiative Name:
Business Opportunity Rule
Reference: Business Opportunity Rule, R511993 Dear Sirs and Madames, Since I was about 3 years old, I have been involved with Direct Marketing Companies. My parents were both self employed and had their own business. Through those years I learned to respect the independent salespeople and what they represent. My Mom taught me that if you sell a product you will always have money available to you on a consistent basis. My Mom sold Stanley Home Products and my Dad had a cookie route for the stores. My parents family were farmers by trade and my parents wanted to give us the opportunity to have more than they did growning up on a farm. Direct selling gave us that opportunity. It taught us how to be friendly to others, how to speak in front of groups, it gave us pride to know that the people we meet have a need for the products we sell. I appreciate the FTC's mission in protecting the public against predators, but on the flip side of the page, I am concerned about the impact this rule,Business Opportunity rule, R511993, will have on legitimate companies. I am an independent representative for two companies, Mary Kay, and XanGo. The sevenday waiting period would hinder customers, from receiving their products promptly. It would cause a negative reflection on the companies because people would not understand why they have to wait. The record keeping would be more and would cause administrative problems. More paperwork would have to be done and would be impractical. The $500 business threshold would be unfair to companies who want to have a lesser start up cost for their distributors. The litigation reporting would be irrelevant and bias in not reporting all information including outcomes as well as the litigation itself. Reporting of earning claims would be difficult to collect, and the "bad actors" would not provide accurate data, while legitimate companies will. Privacy and safety issues will arise requiring references of "10 nearest existing sales people". Reference requrements could possibly result in corporate liablity for ID theft. The service the FTC does for the consumer is a difficult undertaking. Legitimate companies, some long standing, some new ones, could suffer from this new ruling of April 2006. The Business Opportunity Rule, R511993, needs to be reviewed with changes including the seven day rule, the "10 nearest existing sales people" and privacy issues, Earnings claims, Litigation reporting, and elimination of the $500 business threshold. Thank you for allowing me to respon to this information and I sincerely trust that you will take this info into consideration before implementing this rule. carol storey