| Comment Number: | 522418-01198 |
| Received: | 6/6/2006 9:35:39 PM |
| Organization: | Signature HOME Styles |
| Commenter: | Fern McCloud |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 5, 2006 After reviewing the proposed Business Opportunity Rule R511993, I believe that it would be detrimental to my business. Protecting people from "unfair and deceptive acts or practices" is part of the FTC's responsibility, which I understand. There are some sections in this proposed rule that would make it very difficult for me to sell Signature HomeStyles and recruit others to do so. The seven-day waiting period to enroll new representatives is one of the most confusing and burdensome sections. The starter case for Signature Home Styles only costs $100-$175. This is not nearly as much as people pay for TVs, cars and other items and they don't have to wait seven days! This waiting period could send a message that there is something wrong with the plan. We already have a 90% buy-back policy for all products including Starter Cases purchased by a salesperson within the last 12 months, which makes the seven-day waiting period totally unnecessary. I also would be expected to keep detailed records when I first contact someone about Signature Home Styles and will then have to send many reports to the Home Office. ANY information about lawsuits which involve misrepresentation, or unfair or deceptive practices are to be released, whether or not the company was found guilty. This does not make sense to me at all and puts Signature HomeStyles and me at an unfair advantage, even though Signature HomeStyles has done NOTHING wrong. As far as the disclosure of a minimum of 10 Representatives nearest to the prospective Representative. I don't have a problem providing references; however, in this day of identity theft, I don't think it's a good idea to give out personal information of individuals (without their approval) to strangers. People are not going to be willing to sign up as a salesperson if the following sentence is required, "If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers." Privacy and identity theft are important issues for most people these days and they will be reluctant to share this information with people they may have never met. I have been a Representative for 8 years, and love the opportunity to be able to work the business around family activities while making some decent money to contribute to the family budget. I fully appreciate the work of the FTC to protect consumers, but I believe the proposed new rule has many unintended consequenses. There have to be less burdensome alternatives available in achieving the goals. Thank you for your time in considering my comments. Sincerely,