| Comment Number: | 522418-01928 |
| Received: | 6/12/2006 9:26:58 PM |
| Organization: | |
| Commenter: | Susan Inouye |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 12, 2006 Susan Inouye Federal Trade commission /Office of the Secretary, Room H -135 (Annex W) Re: Business Oppportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter because of my concern about the proposed Business Oppportunity Rule R511993. I believe that in its present form, it could prevent me from continuing to be a Mannatech direct selling distributor. The FTC must protect the public from “unfair and deceptive acts or practices,” but some sections of the proposed rule will make it very hard, perhaps impossible for me to sell Mannatech products. The seven day waiting period to enroll new distributors is extremely confusing and burdensome. Mannatech’s sales kits cost as little as $39.00 plus tax and shipping. People buy all kinds of products ranging from computers to cars and other costly items, and they do not have to wait seven days. This waiting period casts a questionable light on the plan, as if there might be something wrong with it. Also, the seven day waiting period is unnecessary since Mannatech already has in place a 90 % buyback policy for all products including sales kits purchased by a salesperson within the last twelve month period. This waiting period requirement will force me to keep very detailed records when I first speak to a person about Mannatech, and I will then have to send in numerous other reports to Mannatech headquarters. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices, even if the company was found innocent. In today’s society people will sue over practically nothing. It is unjust for me to have to disclose lawsuits unless Mannatech is found guilty. Otherwise, Mannatech and I are put at an unfair advantage although Mannatech has done nothing wrong. Lastly, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. There is too much identity theft going on for me to be giving out personal information of individuals to strangers. This practice could also deter people from purchasing from me, not to mention damage the business relationships of the references who might be involved with other companies, including competitors. I would also have to get the list of the 10 prior purchasers by sending the address of the prospective purchaser to Mannatech headquarters and then wait for the list. The following sentence required by the proposed rule will very definitely discourage most people from wanting to become a distributor: “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” Having already had someone steal one of my credit card numbers and charge huge amounts, I would personally NEVER EVER sign up for a business that divulged my personal contact information, nor would anyone else that I know of! I have been a Mannatech distributor for five and a half years. I like the products and wanted the chance to earn some extra money. As a single parent, I now depend upon this extra money to help pay for my daughter’s medicines and medical bills since we do not have health insurance. I am grateful for what the FTC does to protect consumers, but this proposed new rule has many unintended consequences. There are certainly less burdensome ways to achieve its goals. Thank you for your attention to my comments. Sincerely, Susan Inouye