| Comment Number: | 522418-00891 |
| Received: | 6/5/2006 4:59:30 PM |
| Organization: | Nature's Sunshine Products |
| Commenter: | Jeri Spencer |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been a member of Nature's Sunshine for over 10 years, giving people the opportunity to purchase products at wholesale prices. I am concerned that Business Opp Rule R511993 will severly undermine my business. It is impractical to find the closest 10 distributors to each person that I sign up in NSP as they are scattered throughout the US, let alone keep records of people who have canceled or dropped their memberships. It would also be invasive to those people's privacy to give their names to a total stranger. Many people who sign up in a direct selling business do so to purchase the products at a lower cost and aren't interested when they begin in building a business. They end up build businesses as a result of wanting to share the products they are using. This rule would put a negative light on direct selling plans, create overwhelming paperwork, and cause totally unnecessary delays. Overregulation of a industry that is not causing harm does not serve the public. Nature's Sunshine complies with all applicable buy back requirements and always makes it easy for individuals to exit the company if the opportunity is not the right one for them. The proposed waiting period gives the impression that something is wrong with the plan, when even large purchases of TV's, appliances and cars do not have this waiting period. The seven day waiting period is unnecessary and will interfere with my ability to enter into lawful transactions and enroll new distributors. While I appreciate the work of the FTC in protecting consumers, I believe this proposed new rule has many unintended consequences that could be avoided by a different approach. Thank you for your time in considering my comments