| Comment Number: | 522418-00796 |
| Received: | 6/5/2006 12:35:52 AM |
| Organization: | Signature Homestyles |
| Commenter: | Mary Wallace |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-00796.pdf Download Adobe Reader |
Comments:
Mary Wallace, Independent Consultant/Senior Representative SIGNATURE HOMESTYLES June 5, 2006 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I’d like to ask your agency to consider less onerous measures. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new Representatives. Our company’s Starter Case only costs $100-$175. Signature HomeStyles already has a 90% buy-back policy for all products including Starter Cases purchased by a salesperson within the last 12 months. The reporting requirements are too cumbersome and will cause in increase in our product prices for the extra administrative work involved. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose litigation information on ANY lawsuits regardless of the outcome. I would gladly disclose information on pending lawsuits and on lawsuits that determined my company was at fault (along with what corrective measures had been taken to correct the problem). Finally, the proposed rule requires the disclosure of the 10 Representatives nearest to the prospective Representative. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. In fact, it seems like this rule could be a conflict with privacy issues and guidelines in many cases. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. I have been a Signature HomeStyles Representative for more than 4 years. My family depends on this extra income to supplement our budget. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving its goals. Thank you for your time in considering my comments. Sincerely, Mary Wallace