| Comment Number: | 522418-00124 |
| Received: | 5/31/2006 10:33:19 PM |
| Organization: | Mannatech |
| Commenter: | Vlasak |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
May 31, 2006 Federal Trade Commission/Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Ave. NW Washington DC 20580 Dear Sir or Madam: I am writing this letter to express my concern about the proposed Business Opportunity Rule R511993. I have been in the direct selling industry for about 15 years and I am concerned that the proposed rule mentioned above would make it difficult for me to continue with my business. I have participated in several direct selling companies, but the one in which I have found the most success is a company called Mannatech in Coppell Texas They are an a very ethical company and of high integrity. I understand that the FTC plays a key role in protecting the public from scammers, but I feel that adding a lot a complicated rules for the average person to understand and follow would be burdensome, confusing, and unnecessary in starting a network marketing business. I started in network marketing business originally in order to be able to work from home to allow me to be there at all times for my children. Now, as I am approaching retirement age, I see my Mannatech Business as my retirement...allowing me not to have to depend on Social Security, and allowing me an independent lifestyle as I age. I am very concerned that burdensome rules for network marketing will interfere with my plans for retirement. The parts of the proposed rule that concern me are: The Seven-Day Waiting Period. This would project a feeling of danger. A legitimate network marketing company offers no danger, only opportunity. People can enter my business by purchasing a product pack for as little as $100 - which includes a product worth more than $100 (and it is refundable if they change their mind). Why should it be harder to purchase a product pack such as this than it is to purchase items from a store? Disclosure of 10 Prior purchasers. This would be a very burdensome and confusing requirement. Now, more than ever, people are protecting their financial activities. Many do not want their identities and activities passed around on lists - I know I certainly don’t. Litigation Information With the current litigious environment where a company can be sued for no cause whatsoever, I find it very unproductive to have to divulge litigation until a final judgment is reached. Based on this input, I am hoping that you will find less burdensome alternatives in the case of the direct selling industry. Thank you for your time in considering my comments. Sincerely, Joanne Vlasak