| Comment Number: | 522418-01216 |
| Received: | 6/7/2006 1:21:44 AM |
| Organization: | Life Resources |
| Commenter: | jana shiloh |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
This may appear to be a form letter but it is not. Please read: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a consultant who both sells directly and is alos a distributor in a couple of network marketing companies. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will make it very difficult if not impossible for me to sell products.I am an honest upstanding citizen. The 7 day waiting period is one of discrimination against network marketed products- it is the most confusing and burdensome . Enrolling new members (will this also apply to Sam's Club?) and requiring this waiting period for a membership that only costs $25 or less feels like malicious discrimination. People buy much more costly items and they do not have to wait seven-days. This waiting period certainly dampens the enthusiasm and conveys the fact that the government thinks there is something wrong with the company. I also think this seven-day waiting period is unnecessary, because every company I have seen already has a 90- 100% buyback policy for all products including sales kits purchased by a salesperson within the last twelve months. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about my company- I use and sell products from New Vision , Royal bodycare and Stem Enhance- all reputable companies.and will then have to send in many reports to headquarters. On Lawsuits: The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unlessthe company in question is found guilty. this again points to discrimination since no other company is forced to do this. As per references:Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. 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.What about all this privacy stuff the government has forced on us? How can you get around that one? Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to headquarters and then wait for the list. 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. I knopw I would not want to sharemy personal information with individuals I may have never met- would you? This is totally unrealistic and agian aimed at taking down these types of companies I havae been a distributor for 10 years in a variety of companies making unique products available that were unavailable elsewhere; the Doctor I work with has also participated for that reason. As a benefit, I started eaqrning money that I now depend on to supplement my budget. I appreciate the work of the FTC to protect consumers, but I this ruling has gone overboard in discrimination. It is hard enought o make a living without cutting into many people's hard earned and honest work and income, while invading others privacy as well. Jana Shiloh