Business Opportunity Rule #522418-11925

Submission Number:
Lori Smiley
Initiative Name:
Business Opportunity Rule
Dear Sir or Madam, I am writing this letter out of concern about the proposed Business Opportunity Rule R511993. I believe that in it's present form it will prevent me form continuing as an Arbonne Independent Consultant. I understand and support the FTC's responsibility to protect the public from unfair and deceptive business practices. Some of the rules would make it impossible, or very difficult to sell Arbonne products and sponsor people into my business. One of the most confusing and restricitve sections is the proposed 7 day waiting period to sign up new consultants. The cost of becoming an Arbonne consultant is $29, a nominal amount of money. The proposed waiting period gives the prospect the impression that there may be something shady going on, when there is not. Many people that I sponsor into this business just want to pay sign up fee and then get their own products. I do not believe that should be a problem. Another problem with the waiting period would be the amount of paper work involved with keeping very detailed records about when I talk to people. One of the reasons I joined this business and decided to build a business was the fact that there was very little paper work involved. One of the most important elements to my business success is that I can capture the enthusiasm and help prospects experience immediate results with Arbonne's products. The waiting period would potentially limit my ability to grow my business. The proposed rule also calls for the release of ANY information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It doesn't matter if the party involved was found innocent. We all know how "lawsuit happy" some individuals are. A lawsuit may incorrectly imply wrongdoing on the company's part or even my part and that seems unfair to me as the Independent Consultant who is running my business honestly. Finally the proposed rule requires disclosure of a minimum of 10 prior Independent Consultants nearest to the prospect. I am glad and willing to provide references, but I am uncomfortable giving out people's personal information to strangers. Also, sharing this information could damage an individual's business relationship with their current job, as many of my team members' ultimate goal is to quit their full time job. Privacy is an important concern for many people and this proposed Rule has several issues that would be of concern to me and my prospective consultants. I have been an Arbonne Consultant for over 2 and a half years. I became a consultant because I loved the products and nothing had ever given me such immediate and excellent results. I chose to work this as a business to give my family choices and to take the pressure off of our single income family and because of the integrity and culture of the company. This business have given my family so many blessings, not all of them monitary. I have been able to help so many others achieve success - helped mothers find a way to stay home with their children, supported missionaries, given to the Juvenile Diabetes Foundation, etc. I have a team of over 2,000 Independent Consultants across the country and together we are changing lives and making the country a better place to live. I truly appreciate the work of the FTC in protecting consumers, but I believe this Rule would have many detrimental effects on my business. I hope there is an alternative solution to the issue at hand; one that would not harm the livelihood of millions of successful network marketers, like me. Thank you for your time. Sincerely, Lori Smiley Independent Consultant National Vice President Arbonne International