| Comment Number: | 522418-00164 |
| Received: | 6/1/2006 7:28:02 AM |
| Organization: | Shaklee Independent Distributor |
| Commenter: | Betty woodhouse |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opportunity Rule, R511993 I am writing this letter to express my strong opposition to the above rule. The rule as proposed would make it very difficult to operate as a Shaklee Independent Distributor. One of the most confusing and burdensome sections is the 7 day waiting period. Most people who sign an application do so to buy products at a discount. If they wish to build a business all they need to do is supply Shaklee with a SS# or TaxID#. There is no additional kit or fee required. The Shaklee Member Kit costs only $19.95. This is far less then many household purchase such a TVs etc., none of which have a 7 day waiting period. In addition the 7 day waiting period in unnecessary as Shaklee already has a 90% buyback policy for products including the Member Kit, purchased by a distributor in the last 2 years. The proposed rule requires the disclosure of 10 prior puchasers nearest to the prospective buyer. In this day of ID theft, I am uncomfortable giving out someones personal info to strangers. I believe that this would dissuade new people from signing up as they would be concerned about ID theft and their privacy. The 10 reference requirement is an administrative burden, and would result in a delay longer then 7 days before a recruit can sign an application. The proposed rule calls for the release of any info regarding lawsuits. It does not matter if the company was found innocent or liable. It does not make sense to me to disclose this info unless the company was found guilty or liable. Fifty year old companies like Shaklee would be placed at a disadvantage compared to start up companies, which may not have yet experienced litigation but are far more likely to have legal issues surrounding their opportunities. I love Shaklee products and have been using them for 30 years. I became a distributor 5 years ago to earn extra income. I appreciate the work of the FTC, but I feel this rule has many unintended consequences for direct sellers and that there are less burdensome alternatives available to the agency to achieve it's goals. Thank you for your time. Sincerely Betty Woodhouse