| Comment Number: | 522418-01771 |
| Received: | 6/11/2006 2:05:27 PM |
| Organization: | Avon Products |
| Commenter: | Melanie Teague |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it Concerns: I'm writing this letter because I'm concerned about the proposed Business Opportunity Rule R511993. I believe in its present form, it could prevent me from continuing as an Avon Indep Sales Rep. I understand that part of the FTC's responsibilities is to protect the public from "unfair and deceptive acts or practices," yet some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell and recruit Avon products and representatives. I've been an Avon representative for over 8 years. I started my business after my mother died from her battle with lung cancer. My daughter was 4 years old and I decided I didn't want to work outside the home anymore. Time is so precious and our children grow up so fast, I didn't want to lose any time with her. It's been wonderful to be home and watch her grow and blossom and take an active part because of Avon and its earning opportunities. Avon was the perfect opportunity for me to earn income that our family needed and for me to spend time watching her grow up. I did research on the company and felt Avon fit right in with what I was looking for. The future of my family is dependent on the stability of the direct selling industry. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new representatives. Avon's sales kit only costs $10. This small investment is perfect for the single parent, low income person who needs to find a way to make money. I have representatives in my downline whose lives have changed dramatically because of Avon and its earning opportunities. People buy TVs, cars, computers and other items that cost so much more and they don't have to wait seven days. This waiting period gives the impression that there may be something wrong with the company or its compensation plan. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about Avon and will then need to send in many reports to my company headquarters. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair/deceptive practices. It does not matter if the company is found innocent. Today, anyone or any company can be sued for anything. It doesn't make sense to me that I would have to disclose these lawsuits unless Avon is found guilty. Otherwise, Avon and I are put at an unfair advantage even though Avon has done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest the prospective purchaser. I am glad to provide references, but not giving out the personal information of individuals without their consent to strangers. Also giving out this information could damage the business relationships of the references with other businesses or companies including those of competitors. In this day of identity theft, this makes me very uncomfortable. I also think the sentence "If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers." I will lose current and future representatives. I myself am not sure I would continue with Avon knowing some stranger can access my personal information without my knowledge and consent. I appreciate the hard work the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences and there are less burdensome alternatives available to achieve your goals. Thank you for taking time to consider my comments. Respectfully, Melanie Teague Avon Indep Sales Rep/Recruiter/Certified Beauty Advisor