|Received:||6/2/2006 9:14:36 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am very concerned that the proposed rules would make it very difficult for me to stay in business, and prevent my customers from receiving personal discounts that are now available to them. A Nature's Sunshine membership entitles my customers to purchase their product directly from the company at wholesale prices for their own use, or from my shop at a discount. This makes the product much more affordable for them, allowing them to enjoy the benefit of more product, or more change in their pockets. I offer this benefit to everyone who wants to purchase a significant amount of product as a service. Many if not most of these people sign up simply for the discount, and signing up costs them NOTHING except that they make a purchase AT WHOLESALE PRICE RATHER THAN AT RETAIL. Commission I receive from my downline make it possible for me to offer this and still keep my shop doors open. While most of my customers have no intention of ever selling anything, as members they have the opportunity should they desire, but there is never any pressure to do so. In the natural health business, most people who become distributors are those who have had a personal experience of healing by having used the product, and out of that may develop a desire to share their knowledge and experience with others to help them. Your proposed rules would make it too difficult for me to offer this discount to my customers unless they express a desire to become distributors, and even then I'm afraid that I would find it impossible to comply with all the rules. It would be extremely difficult for me to know who the nearest 10 distributors are, or to keep up to date information about how many stop being distributors and what their profits are. Certainly, it would be nearly impossible for the company itself to calculate average profits because they have no access to such information as expenses for advertizing, training and travel that may be incurred by distributors. As I am new to retail, it is difficult for me to even calculate my own profits at this point, but I know I Love the opportunity to help others that this business offers me, and want to continue. And I believe it has the potential to be very profitable in my future. Statistics about how many do not remain as distributors would shed an unfair light on the business, as well, because most never intend to distribute in the first place. They simply enjoy the benefit of the product for personal use at prices lower than retail. Often they buy product for a specific set of symptoms, get relief, and move on. Their membership simply expires after 1 year and that's all there is to it. Your rules would make it necessary for the Nature's Sunshine company to continually maintain up to date records and keep all their distributors informed. This would add a significant amount of expense, which would then have to be passed on to the customer as well. Because Nature's Sunshine never pressures their customers to join, never asks for up front money that is not reimbursed by giving free product of equal value, has a very low membership price (only $40), and gives members discount benefits that exceed their membership price whether they ever choose to sell of not, it seems ridiculous to think that these rules would benefit my customers, or those who might like to become distributors. In fact, I can't imagine any of my customers having any desire to read all the information your proposed rules would require me to provide them. The effect of these rules would not protect them, but rather cause me to be vulnerable to accidentally violating them, Nature's Sunshine to go to much added expense to keep up to date data for their distributors, and customers to pay more for their product. Is the goal of this proposal to create new government jobs? Bigger government, more unnecessary oversight and more taxpayer expense is not what this country wants or needs. Car dealers would be better targets for more regulation.