| Comment Number: | 522418-01825 |
| Received: | 6/12/2006 11:06:30 AM |
| Organization: | Shaklee |
| Commenter: | Karen Bowman |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, R511993 Dear Sir or Madam I am writing to express Very Strong opposition to the proposed Business Opportunity Rule R511993. I understand that the Federal Trade Commission must protect the public form "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me and future business builders to operate our business as a Shaklee Independent Distributor. The most confusing and troublesome setion of the proposed rule is the seven-day waiting period to sign up new distributors. Most of the people who sign a Shaklee application are consumers of the products who may later after seeing how great the products work choose to become a business builder, and all they do is call Shaklee corp. with their SS number, with not other hidden costs..They are now a Business Builder...This is a small amount compared to consumers big and extravagent purchases......The waiting period is also unnecessary in that Shaklee Corp. already has a 90% buyback policy for products. The disclosed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. In the day of idenity theft, I am uncomfortable giveing out that personal information of other Shaklee distributors, without their knowledge or consent. I understand that those who sigh up after the rule takes effect would be told in writing "If you buy a business opportunity form the seller, your contact information an be disclosed in the future to other buyers. "This would dissuade new people from signing up as distributors as they are concerned not only abut idenity theft, but also about theeir distributors. The 10 refference requirement is and administrative burden. To obtain the list of 10 prior purchers, I will ned to provide Shaklee Co with the prospective distributors address and wait to receive the list of the 10 nearest distributors who bacame dist. within the past 3 years. Each new recruit will need a custonized disclosure statement. This will cause great delay. The prioised rule calls for the release of any information regarding lawsuits that allege misrepresentation, or unfair or deceptive practices over a 10-year period. It does not matter if the company was found innocent or not liable.. It does not make sense to me that I would have to disclose these lawsuits unless Shaklee Corp, or its oppicers, directors or sales dept. employees, had been found quilty or liable. 50 Year old Companys like Shaklee based on the Golden Rule living would be at a disadvantage compared to start -up compnays which may not have experienced litigation. Dr Shaklee 50 years ago began this business on the Golden rule to make an opportinity for anyone regardless of age, sex or ethnic background. To have a future others only dream of.. I have been in Shaklee for over 15 years and enjoy a life of Health and earn an P/T income that at 60 I am hoping to have this be my future retirement and not have to use any Social Security. My family and I depend on this income for our livelyhood to suppliment our budget...Without it would be at a loss. Thank you for considering my comments Karen Bowman