|Received:||6/1/2006 12:46:07 PM|
|Commenter:||Mary L. and Elmer Seelbinder|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Business Opportunity Rule R511993 Dear Sir or Madam: I am writing this letter to express my strong opposition to the proposed Business Opportunity Rule R511993. I understand that it is the responsibility of the Federal Trade Commission 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 a Shaklee Independent Distributor. one of the most confusing and burdersome sections of the proposed rule is the 7 day waiting period to enroll new distributors.. Most of the people who sign an application do so to purchase Shaklee products at a wholesale price.The membership kit is only 19.95 far lewss than most. most consumer purchases from Tvs to all manner of household appliances, none of which require a 7 day waiting period. which is unnecessary in that Shaklee Corporations already has a 90% buy back policy for products, including the Member Kit, purchased by a distributor within the last two years. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I believe this would dissuade new people from signing up as distributors as they are concerned not only about identity theft, but also about their privacy. People today are understandalby reluctant to share their personal information with individuals they may never have met. providing the ten references also could damage the businesses of numerous Shaklee distributors. The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentation or unfair or deceptive practices over a ten year period. Fifty year old companies such as Shaklee Corporations and their distributors would be placed at a disadvantage compared to start-up direct selling companies, which may not yet have experienced litigation but which are far more likely to have legal issues surrounding their opportunities. I have been a Shaklee Distributor for more than 25 years, I became a Shaklee Distributor because I love the company"s nutritional products, which changed the health of my husband and my health around, to an optimal state. We both had minor ailments that if not given the alternative choice of pure Shaklee nutrition, could have developed into major illnesses, if treated by prescription drugs that just mask the symptoms until the body becomes completely depleted of healthy cells.We also use all of the personal care/household products and air and water purifiers, and now we use the income we receive every month to supplement our retirement income in addition to helping others achieve better health, and additional income. While I appreciate the work of the FTC to protect consumers, I believe this proposed new rule has many unintended consequences for direct sellers and that there are less burdensome alternatives available to the agency to achieve its goals. Thank you for your time in considering my comments, Sincerely, Mary Lou Seelbinder Independent Distributor.