| Comment Number: | 522418-01263 |
| Received: | 6/7/2006 1:10:42 PM |
| Organization: | Nicholls and Associates |
| Commenter: | Thomas Nicholls |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing this leter to express my strong opposition to the proposed Business Opportunity Rule R511993. I understand that it is the responsibility of the Federal Trade Commission to protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. One of the most confusing and burdensome sections of the proposed rule is the seven day waiting period to enroll new distributors. 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 the Social Security Nuumber of Tax Identification Number. There is no additional kit, fee, or application required. The Shaklee Member Kit costa only $19.95. This is far less than many, if not most, consumer purchases, from TVs to all moanner of household appliances, anoe of which require a seven-day waiting period. In addition, the seven day waiting period is unnecessary because SHaklee Corporation already has a 90 % buyback policy for products, including the member kit,purchased by a distributer 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 consent to strangers to comply with the disclosure of a minimum of 1- prior purchasers nearest to the prospective purchaser. Shaklee does not limit my ability to contact or sell to a specific area, so I might not know of other customers within the specified ares, as contacts sometimes come via e-mail, without a location given. I have been a SHaklee customer for about 20 years, and have been a distributor for most of these years. Original I became a customer for the health benefits of the products, and after finding out how well they worked for me, I have introduced them to other people. Now in retirement I utilize the extra income provided to supplement my retirement benefits. While I appreciate the work of the FTC to proect customers, I believe this proposed 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, Thomas J. Nicholls