Business Opportunity Rule #522418-11721

Submission Number:
Marceline Kolf-Coco
Initiative Name:
Business Opportunity Rule
Dear Sir or Madam:I'm writing this letter to express my strong opposition to the proposed BusinessOpportunity(opp.)Rule R511993.I understand that it's the responsib.of the FTC to protect the public from "unfair and deceptive acts or practices",but the rule as proposed would make it very difficult for me to operate my business as an independent distributor(distrib) for Wellness International Network,Ltd.(WIN).One of the most confusing and burdensome sections of the proposed rule is the 7-day waiting period to enroll new distrib's.Although WIN requires a completed distrib. application for distrib's to sell products,the personal purchase of product is strictly optional.WIN's System for Success costs only $99 and provides valuable marketing and communication tools-weekly newsletter,quarterly magazine,a personal website and shopping cart to name a few of the benefits.The cost of WIN's application fee is far less than many, if not most, consumer purchases, from TVs to all manner of household appliances, none of which require a 7-day waiting period and do not provide an opp.for a person to become a business owner.The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser.There are many problems with this proposed requirement.In this day of identity theft,I am uncomfortable giving out the personal information of other WINdistrib.'s,without their knowledge or consent,to strangers.I understand that those who sign up after the rule takes effect would be told in writing "If you buy a business opp. from the seller,your contact information can be disclosed in the future to other buyers".I believe that this would dissuade new people from signing up as distrib.'s as they are concerned not only about identity theft,but also about their privacy.People today are understandably reluctant to share their personal information with individuals they may never have met.Providing the 10references also could damage the business of numerous WINdistrib.'s.Lower ranking distrib.'s often are sometimes involved in more than 1direct-selling company.Providing a list to a potential recruit-who may already be a distrib. for a competing,direct-selling company-may be an invitation to solicit existing distrib.'s for such other opp.'s.The 10reference requirement also is an adm. burden.In order to obtain the list of 10prior purchasers,I'll need to provide WIN with the prospective distrib.'s address,and then wait to receive the list of the 10nearest distrib.'s who became distrib.'s within the past 3years.Each prospective recruit will need a customized disclosure statement.This will result in a delay for longer than 7calendar days before any potential recruit can sign an application.In view of the fact that many people enter direct selling part-time to earn extra income for a specific goal,such as holiday purchases or a family vacation;the long wait which the proposed rule will entail may take the goal unattainable.The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentat. or unfair or deceptive practices over a 10year period.It doesn't matter if the company was found innocent or not liable.Today,almost all business lawsuits contain claims of misrepresentat. or unfair competition.It doesn't make sense to me that I would have to disclose these lawsuits unless WIN,or it's officers,directors or sales department employes,have been found guilty or liable.Otherwise,14-year old companies such as WIN and their distrib.'s would be placed at a disadvantage compared to start-up,directselling companies,which may not yet have experienced litigation but which are far more likely to have legal issues surrounding their opp.'s.I've been a WINdistrib. for more than 3 years.Originally I became a WINdistrib.because I love the company's nutritional and personalcare products and wanted to earn some additional income with my own business.Now I depend upon this extra income for our livelihood