Business Opportunity Rule #522418-12554

Submission Number:
Initiative Name:
Business Opportunity Rule
Dear Sir or Madam, I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a Southern Living at Home Consultant. I understand the part of the FTC's responsibilities is to protect the public from "unfair and deceptive acts or practices", yet some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell Southern Living at Home products. I have been a Southern Living at Home Consultant for 4 years. Inititally, I became a consultant because I felt the products were exceptional and I wanted to earn some additional income. Now my family is supported through my direct selling business. The future of my family is dependent on the stability of the direct selling industry. One of the most confusing and cumbersome sections -of the proposed rule is the seven-day waiting period to enroll new consultants. Southern Living at Home's sales kit only costs $199. People buy TV's, cars, and other items that cost much more and they do not have to wait seven days. The waiting period gives the impression that there might be something wrong with the company or the compensation plan. I also think this seven day waiting period is unnecessary, because Southern Living at Home already has a 100% buyback policy for all products including sales kits purchased by a salesperson. Under this waiting period reequirement, I will need to keep very detailed records when I first speak to someone about Southern Living at Home and then will need to send in many reports to my company headquarters. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation or unfail or deceptive practices. It doesn't matter if the company was found innocent. Today anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless Southern Living at Home is found guilty. Otherwise Southern Living at Home and I are put at an unfair advantage even though Southern Living at Home has done nothing wrong. Finally, the propsed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, we should not comprimise the privacy of anyone. I appreciate the work that the FTC does to protect consumers, yet I believe this rule has many unintended consequences and there are less burdensome alternatives available to acheiving your goals. Thank you for your time and consideration Respectfully, Molly Mabry