Comment Number: 522418-00627
Received: 6/3/2006 11:48:15 AM
Organization:
Commenter: Nancy Douglas
State: OH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing this letter to express my oppostition to the proposed Business Opportunity Rule R511993. I understand it is the responsibility of the Fed.Trade Commission to protect the public from unfair and deceptive acts or practices, but the rule would make it very difficult for me to operate my Shaklee Business. One of the most confusing and burdensome sections of the proposed rule is the seven day waiting period to enroll new distributors. Most people who sign an application are doing so to purchase Shaklee products at a wholesale price not to sell product. If they wish to build a business later they simply add their Social Security #. There is no additional kit, fee or application. The Shaklee Member Kit cost only $19.95 and for that they receive some information, catalogues, a DVD, etc. and the right to buy or sell product. This is far less than most consumer purchases, from TVs to all manner of houselhold appliances, none of which require a seven day waiting period. Shaklee already has a buy back policy for products that distributors buy including the Member Kit within a 2 year period from purchase. How much more fair can you get. The proposed rule requires the disclosure of a minimum of 10 prior purchaseers nearest to the prospective purchaser. This is unbelievable...the problems that would exist with this rule. First identity theft, I am uncomfortable giving out the personal info of other Shaklee distributors to strangers. I understand that those who sign up after the rule takes effect would be told in writing "If you buy a business opportunity from the seller, your contact info can be disclosed in the future to other buyers. This would stop people from signing up as distributors to protect their privacy. Also providing 10 references could damage the businesses of numerous Shaklee distributors. Lower ranking distributors often are involved in more than one direct selling company. Providing a list may be an invitation to solicite existing distributors for other opportunities and draw them away from Shaklee. The 10 reference requirement would also require much work and be a burden. It will cause delays in sponsoring and since most people are interested in getting started right away once they see the opportunity or once they decide to buy products they could easily change their mind if they had to wait. Some people become distributors to just get a handful of people to buy from them so they can make an extra $100 to buy their own products. Shaklee has a 50 year history of being an upstanding company and this rule would take away our ease in doing business. If a company is underhanded in some practice put them out of business but do not make everyone conform to such a burdensome practice. I have been a Shaklee member\distributor for 30 years. I became a Shaklee distributor to simply purchase product at a reduced cost. As I loved the products I couldn't help but share the products. As a result it became my career. I am now 60 years old and if you make my life miserable by having to follow such a ruling, it would hinder my ability to sponsor people and hurt my business. I know many people would be in this same situation as many of my friends are now senior citizens and we are hindered enough by rising costs, age discrimination, etc. I am sure your can find a better way to protect consumers then this new rule which has too many unintended consequences to the direct seller. Please protect the direct sellers as well as the consumers. I too am a consumer so I want protection but not at such a price. Nancy Douglas