| Comment Number: | 522418-00672 |
| Received: | 6/3/2006 4:18:54 PM |
| Organization: | Tri Wellness |
| Commenter: | Roberta Crowell |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam, I strongly oppose Business Opportunity Rule R511993. I understand it is the responsibilty of the FTC 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. More than 95% of the people who sign Shaklee Distributor applications ($19.95) to be in my group do so soley for the purpose of buying the product at a discount and would find the proposed 7 day waiting period confusing and burdensome. If they decide later that they want to build a business all they have to do is provide Shaklee with their SS#. There is no additional fee/kit required. The proposed rule requires disclosure of at least 10 prior purchasers nearest to the prospective purchaser. I would not be comfortable giving this information out and have always tried to protect the privacy of my Member/Distributors. I believe this rquirement would keep many from signing applications and then they could not get the benefit of the discount price. Providing 10 references also could damage the business of numerous Shaklee distributors. Lower ranking distributors often are involved in more than one direct selling company. Providing a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for other companies. The 10 references list would also create a record keeping nightmare and a longer delay in the prosect's ability to become active in either buying at the discount or starting their own business. The proposed rule requires release of any information regarding lawsuits alleging misrepresentation or unfair practices over a 10 year period whether found innocent or not liable. That would put a 50 year old company like Shaklee at a disadvantage with young companies where there has not been time for the need for lawsuits to develop. I have been a proud Shaklee business owner for 29 years. I fell in love with the products after using them helped me get rid of almost daily headaches. I started selling the products because our family needed additional income at the time and I loved selling something I believed in. For the past 15 or more years my Shaklee income has been my major source of monthly income and I believe that adaption of the proposed R511993 would threaten my ability to continue earning that income. I believe the FTC could find less burdensome alternatives to this proposed rule that would fulfill the necessary need to protect consumers. Respectfully Yours, Roberta S. Crowell Independent Shaklee Distributor