| Comment Number: | 522418-00835 |
| Received: | 6/5/2006 12:19:35 PM |
| Organization: | Shaklee Distributor |
| Commenter: | Kixmoeller |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To whom it may concern, I am writing this letter to express my strong opposition to the proposed Business Opportunity Rule R511993. I understand that it is the responsiblity of the Federal Trade Commision to protect the public from "unfair and deceptive acts and practices," but the rule as propsed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. Most of the people who sign an application do so to purchase shaklee products at a wholesale price. In other words, they are solely consumers of the products. If they later wish to build a business, all they must do is supply Shaklee Corporation with their Social Security Number or Tax Identification Number. There is no additional kit, fee or application required. The Shaklee Member Kit costs only $19.95. This is far less than many, if not most, consumer purchases, from TVs to all manner of household appliances, none of which require a seven-day waiting period. In addition, the seven-day waiting period is unnecessary in that Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. In this day of identity theft, I am uncomfortable giving out the personal information of other Shaklee distributors, without their knowledge or concent, 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 information can be disclosed in the future to other buyers." I believe that this would dissuade new people from signing up as distributors as they are concerned not only about identity theft, but also about their privacy. People today are understandably reluctant to share their personal information with individuals they may never have met, as am I. It is clear that these requirements, if enacted, would place a serious and undue burden upon Shaklee Distributors all across the country. We believe this Rule, if enacted, would have a negative impact on our business as well as all direct selling businesses. Shaklee Corporation is a fifty-year old company and I have been part of this company for 38 years. I trust this company and love their products. My parents sponsored in 38 years ago to earn extra money. My mother built the business so well that my father quit his job to work with her full time. Now that my father is gone, the business has provided my mother with no financial burden for the rest of her life, and she can be active on a part-time bases and still enjoy her golden years with her kids, grandkids and great-greandchildren. While I appreciate the work of the FTC to protect consumers, I believe this proposed new rule has many unintended consequences for direct sellers and that there are less burdensome alternatives available to the agency to achieve its goals. Thank you for your time in considering my comments. Sincerely,