Business Opportunity Rule #522418-11188

Submission Number:
Steve Voiles
Initiative Name:
Business Opportunity Rule
Federal Trade Commission Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing to express my concerns with the FTC's proposed Business Opportunity Rule R511993. I became an Herbalife Distributor in order to provide for myself and my family for the rest of our lives. Due to corporate downsizing and job outsourcing it had become apparent that the traditional career that I've had for most of the past 41 years (I am a tool designer on the computer) would not be able to provide the security and employment that would carry us thru our "golden" years. I saw the Herbalife opportunity as a means to make a positive difference in people's lives while providing a good stable income for retirement. What better service could I provide for people than to help them become more fit and healthy both physically and financially? I have been involved with Herbalife for 4 years. I've seen a dramatic difference in my personal, physical and financial life, as well as that of my family. We have all lost significant amounts of weight and kept it off due to the wonderful products that we have available thru Herbalife. Our overall health has greatly improved as well. Our finances are finally stable. After years of living paycheck to paycheck we are actually seeing a light at the end of the tunnel. Our bills are all current, we have almost no outstanding credit card debt and we are starting to re-grow our retirement nest egg. All of this is because we saw an opportunity, looked carefully at all the information provided to us and made the decision and tried Herbalife. They have provided all the training and mentoring that I've needed to start and maintain my business. They have also taught me how to teach these same skills to my customers and dowlnine. I've found nothing more rewarding than having someone tell you "You've changed my life." either from the health and fitness benefits they've gotten from the products or from the financial benefits provided by the extra income. From what I understand of the proposed rules they would have little impact on the dishonest or unscrupulous direct selling companies but they would pose a very large burden upon us honest hard working direct sellers. There is already a three day rule stating that a person has three days to change his mind which allows for a full refund if the buyer were to change his mind. Herbalife provides thirty days to request a refund for any reason. Having to wait seven days to complete the purchase of a new distributor kit and product for resale could prove disastrous because in the weight loss field the customer usually wants to start when the motivation strikes which means now. If I can't satisfy that need when the prospective distributor wants it they will go elsewhere. The written disclosure would be extremely time consuming to acquire because a new and unique disclosure must be provided for each new distributor due to the proximity rule. It would almost certainly drive up my costs due to the amount of man hours that the company would be required to expend supplying these disclosures for each new distributor. Also the large amount of time and money that would be required to request, deliver and store these disclosures would be very burdensome to my business. Whereas a dishonest or fraudulent direct seller would not hesitate to use a "generic" disclosure for everyone thereby they would insure no extra expense or burden. While I do support your efforts to prevent consumer fraud by dishonest or unscrupulous direct sellers; they make my work much more difficult; I feel that you should as an agency revisit how you propose to implement this. The rules as I read then will only bury those direct selling companies that do follow the rules and are legitimate in an extremely punitive amount of paperwork that will have very little effect on those who don't follow the rules. Sincerely, Steve Voiles