| Comment Number: | 522418-01961 |
| Received: | 6/13/2006 7:43:36 AM |
| Organization: | Partylite Gifts |
| Commenter: | Cindi Wilmot |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I would like to applaud the FTC for taking action on unscrupulous direct sales businesses with the FTC Business Opportunity Rule #R511993. It is my hope that you will take the opportunity to hear suggestions from those in the Direct Sales industry regarding this ruling, so that it can positively impact our industry and those planning to join it. I have been a consultant with Partylite Gifts, one of the top direct sales companies in the world, for 12 years. It has been my privilege to be in leadership for 10 of those years. This business has enabled my husband and I to raise our 6 children without daycare and to provide for them opportunities they would not otherwise have. It has made us better parents, due to the flexibility of the work and the opportunity to learn people skills all along the journey. In addition, I have had the honor of helping consultants in South Central PA start their own businesses; help their families; grow as individuals and positively impact their finances. There are 75 consultants currently on my team and over the past decade, hundreds have been positively impacted by this exceptional company. In all that time, I DO NOT KNOW OF ONE PERSON WHO HAS LOST MONEY IN THIS BUSINESS. This is because Partylite is a company that is designed for consultants to earn income. It is NOT a company who wants consultants to be their best customer. That said, I implore you to listen to the words of suggestion from those on our team and the teams of other reputable Direct Sales Companies that have been around for decades. It has been brought to my attention that the FTC is currently suggesting some rulings that may negatively impact new consultants and their sponsors: The suggestions to have a disclosure document with a seven day waiting period and the names and contact information of the 10 nearest consultants are the points I wish to discuss with you at this time. I think that disclosure is a great thing. There are 100 new start up companies per year and I know that many of them are not at all reputable. I do not have any problem with Partylite and other companies having such a disclosure and I do encourage it. However, to wait seven days would negatively impact the new consultants I deal with and their consumers. To start with, many people, especially in today's financial market, need to start making money as soon as possible. Currently, a new consultant can be earning income within a week. Obviously, this FTC ruling would affect that. In addition, customers who have purchased items from that show expect their products in a timely fashion. Many of us submit orders the very night of a show and this could negatively affect our customer service in an era when ordering efficiency is fantastic. The thing that concerns me most is the disclosure of contact information for the nearest 10 consultants. While I personally have nothing to hide and am willing to talk to anyone about our business, this seems very extreme to me. I envision spending 90% of my sponsoring time talking to other peoples' potential sponsors! This does not even make sense and surely there must be an easier way. In addition, the privacy issues are immense. Would you want your personal contact information distributed to everyone who asks? And how does one keep the unscrupulous consultant from swaying a consultant to join her team instead? I do not propose to be any kind of expert on these things, but I'm sure there must be a more efficient way to help others avoid scams, without negatively impacting how things are run by established businesses. Perhaps the focus needs to be on start-up companies, not on those who are established and reputable. If there were a neutral site to check on companies, or if the Direct Selling Association could be utilized, these might be places to start to protect consumers. Thank you for your time. Again, I urge you to consider the views of those from long-time DS companies. Cindi