| Comment Number: | 522418-00354 |
| Received: | 6/1/2006 5:29:09 PM |
| Organization: | Coogan Associates |
| Commenter: | Joanette Coogan |
| State: | WI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing to express my strong opposition to the proposed Business Opportunity Rule R511993. This rule would make it very difficult for me to operate my business as a Shaklee Independent Distributor. My reasons are: 1. The seven-day waiting period to enroll new distributors is very confusing and quite burdensome. Most people sign an application to purchase products at a wholesale price as a consumer of the products. If later they desire to build a business, they just supply Shaklee with their SSN with no additional kit, fee, or purchases needed. Also this waiting period is unnecessary as Shaklee Corporation already has a 90% buyback policy for products including the Member Kit. 2. In regard to the disclosure of a minimum of 10 prior purchasers, I am uncomfortable giving out personal information of other Shaklee members without their knowledge or consent to strangers. People today are reluctant to share personal information with all the identity theft issues. 3. Providing the ten references could damage people's businesses. This could be an invitation to solicit existing distributors for other opportunities. 4. This could also be a paperwork nightmare having to obtain the list of 10 prior purchasers. The waiting period and potential additional waiting time could disuade many people from joining who wish to start earning income immediately. 5. The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentation, ou unfair or deceptive practices over a ten year period. It does not matter if the comaphy was found innocent or not liable. That makes no sense at all unless there is liability involved. A strong stable ethical company like Shaklee--in business for 50 years--would be placed at an extreme disadvantage compared to start-up direct selling companies. My husband and I have been Shaklee distributors for more than 30 years. Originally, we became distributors to purchase the products the products wholesale because of the health benefits we experienced. We also wanted to earn some additional income working from home to pay off our debts. We were both teaching school at the time and had a huge financial indebtiness. Well, we paid off our loans and bills and today we depend upon this income for our livelihood. We are in our 60's and Shaklee provides us with an income to maintain a quality lifestyle and not depend on the government for our subsistance. I appreciate the work of the FTC to protect consumers. But, I believe this proposed new rule has many unintended consequences for direct sellers and that thre are less burdensome alternatives availalbe to the agency to achieve its goals. Thank you for your time in considering my comments. Sincerely, Joanette E Coogan