Comment Number: 522418-00801
Received: 6/5/2006 3:04:13 AM
Organization:
Commenter: McCoy
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

 I am concerned about the proposed Business Opportunity Rule R511993. In its present form it could prevent me from continuing to be an Independent Sunrider Distributor. In trying to protect the public from unfair and deceptive practices you are making it difficult for me to sell the wonderful Sunrider products. Concerning the 7-day waiting period...the cost of a $140 Starter Pack is optional. Sunrider has a 60-day return policy applicable to all products including the starter pack and a generous 90% buyback policy for former distributors for products purchased within the last 12 months. This 7-day waiting period will be an administrative nightmare, plus it gives the impression that something must be wrong with Sunrider, the products and/or the opportunity. Sometimes when I share information about Sunrider I give them a brochure with my phone number and website. If they go to my website and order a Starter Pack without contacting me, how will this rule apply? Will their order be held up for 7 days before shipping? How will I be expected to report this?! Concerning releasing information about lawsuits involving misrepresentation, the Rule does not seem to allow for reporting any positive results such as the company being found innocent. Why disclose lawsuits if Sunrider was not found guilty? This will be unfair and will cause me to lose customers before they have a chance to try the wonderful products. As for disclosing 10 prior purchasers nearest to the prospective purchaser...this would expose them to all kinds of people and situations. Identify theft is a real problem today. Sexual predictors are also a very real problem. Would you want the information of your children or spouse to be passed around to various people without your knowledge?! Disclosing the past purchasers information could cause me to be subject to a lawsuit by them, or at the least cause me to lose customers. This rule will drastically reduce the number of people from joining Sunrider or even ordering products. This portion of the Rule is unfair and extremely unsafe for all concerned. Competitors could have a heyday with this list. A person could purchase a Sunrider product just to get a list of customers for a competitive product. This would be extremely unfair. I share information about movies, restaurants and other goods and services and there is no 7-day hold or mandatory discloser of personal information when sharing this helpful information. Sunrider has been in business for almost 25 years with hundreds of thousands of distributors in over 38 countries. They must be doing something right. I have been a Sunrider distributor for 8 years. I became a distributor for the health of my family then got excited after we got great results. I started sharing Sunrider information and products because I care about people. I didn't know about the financial benefits Sunrider offers for about 4 months. My family consumes a lot of Sunrider products now so I am grateful the company offers a plan that covers the cost of my products and provides a way for me to help my church as well as others who need help. I know the FTC is trying to protect consumers, but I believe this proposed new Rule has too many consequences and will be devastating to Sunrider and all its distributors. The cost to the government to enforce this Rule will be astronomical. There must be a better way to achieve your goals. I hope you will consider my comments and find them helpful. Sincerely, Mrs. McCoy