Comment Number: 522418-00436
Received: 6/1/2006 10:48:25 PM
Organization:
Commenter: SHIRLEY DAVIS
State: CO
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. 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. I have been a Shaklee Distributor for almost 12 years and most of the people I sponsor desire to only purchase Shaklee products for their own use and not to build a business. They pay only $19.95 for that privilege. I do not receive a penny of that cost. In return they receive a kit of materials valued at more than $19.95. In fact, Shaklee has a buy back policy for products purchased if people are not satisfied with the products. Shaklee has always honored this Satisfaction Guarantee. On the other hand, if one wants to build a business then they must provide their Social Security number to do so and purchase a business kit at $39.95 containing some products, CD's, literature and training materials. Again, I do not receive a penny of this investment. Providing 10 references would damage the businesses of numberous new people desiring to build a Shaklee business. And new members probably don't even have 10 prior purchasers nearest to the prospective purchaser! People today are understandably nervous about sharing their personal information with individuals they may never have met, therefore, for them to be notified that their contact information would or could be disclosed in the future to other buyers would be of deep concern and prevent many from wanting to build a Shaklee business. All this would also create an adminstrative burden for the Shaklee Corporation in attempting to protect the privacy of their distributors. One of the most confusing and burdensome 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 right away for their own use. In other words, most people are solely consumers of the products, they need them NOW and would find it confusing as to why they must wait to purchase, let's say, $75.00 worth of products at wholesale. What if SAM'S CLUB required people to wait a week after joining before they could shop there? The disclosure of lawsuits over the past 10 yrs even if the accused was found totally innocent or not liable would be a deterent to those desiring to be associated with a company, even when the company has extremely high integrity and respect. Older companies, such as Shaklee which is 50 years old would be at a grave disadvantage compared to brand new companies without any history of litigation. Too many people today bring lawsuits against a company just because they are disgrumbled about how they were treated even if the company or their employees were not at fault. I joined Shaklee because the nutritional products brought me health that I had not had for 20 years previously. As a result I have not had to take any prescription drugs. I am a Holistic Nutritionist and Shaklee has the highest level of safety, quality, integrity of any other company I have researched. I get consistent results with these products. My clients love the products as I do. My husband and I depend upon the additional income to supplement our retirement income, making it possible for him at 80 years old not to have to work to meet our bills. I also appreciate the ability to work from home and not having to fight traffic and buy gas to create this 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, Shirley E. Davis