|Received:||6/12/2006 10:57:27 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as an AdvoCare Distributor and destroy my small business. I have been an independent Distributor with AdvoCare for almost 3 years. Originally, I started my Network Marketing because of the products I loved them and wanted to earn some additional money. Now my family depends on this extra income to supplement our budget. Please don’t destroy my small business we need it! If your intention is to protect the consumer, then REQUIRE a money-back guarantee. Quite honestly, I find the 7 day waiting period foolish. Networking marketing is a terrific way for someone who needs money and is willing to work and earn it the hard way, by going out and selling great products. When I needed to buy a new refrigerator, I went out and found people who wanted to purchase my products. They were happy with their purchases and I was happy to have a place to keep my food fresh. I’m a mother of 2 who needs to have flexible hours and a good, flexible business that brings in real income. Multi-level marketing is a great way to build up people and teams. MLMs are volunteer armies, and if they aren’t treated with respect, leadership and training, they leave. Top leaders know this and work hard to build up people. Because of this, it is more critical in an MLM to build up a team of people than it is in corporate environments. Every corporation and government agency has a hierarchy created to maintain a level of management that looks very similar to an MLM. The difference between corporate hierarchies and multi-level marketing is that an individual can make a higher income than their sponsor in an MLM; whereas, I have never seen a boss make less income than someone “under” them. Quite honestly, top money earners only make top money if they are helping lots of people make money. This is just one of the many reasons I am a huge believer in network marketing. Obviously, there are people who feel they have been “taken” and you felt a need to respond. It’s unfortunate these people didn’t A) do their due diligence or B) do the work. Without both, there is no income. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my products. This waiting period will give the public the idea that there’s something wrong with me or our plan and also reflects badly on me. I also think this seven-day waiting period is unnecessary, because AdvoCare already has a 100% buyback policy for all products including sales kits purchased by a Member/Distributor. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Member with AdvoCare. AdvoCare's New Member kit only costs $50. People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone a prospect and will then have to send in reports to my company. I am a small home business and this will burden, hurt or destroy my business. This proposed rule is bad!! 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. Women in my organization may be subject to sexual or racial harassment, so this part can’t go in at all, unless the FTC passes an addition to this rule Prohibiting sexual or racial attacks related to this disclosure. In the end the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. Thanks for your help.