| Comment Number: | 522418-02110 |
| Received: | 6/14/2006 11:28:54 AM |
| Organization: | A Firm Foundation LLC |
| Commenter: | Denise Vance |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing this letter because I am concerned about the proposed ruling R511993 on Business Opportunity. I believe that in its present form it could prevent me from continuing as a Mannatech Distributor. I understand you are wanting to protect the public from "unfair and deceptive acts or practices," but some of the language in the proposed rule will make it very difficult if not impossible for me to sell Mannatech products. One of the most confusing and burdensome sections of the proposed rule is the 7 day waiting period to enroll new Distributors. Mannatech sales kit only costs $99.00 People buy TV's, cars and other items that cost much more that that and they do not have to wait 7 days. This waiting period puts doubts in the mind of those interested in our products. I also think this 7 day waiting period is unnecessary, because Mannatech already has a 90 percent buyback policy for all products including sales kits purchased by a saleperson within the last 12 months. This will cause a lot of unnecessary paper work and tracking of when I talk to people and sending paper work into the Mannatech headquarters. The proposed rule also calls for me to release any information of lawsuits involving misrepresentation, or unfair practices. It does not matter if the company is found innocent. It does not make sense for me to disclose these lawsuits unless Mannatech is found guilty. Otherwise, Mannatech and I look bad and are treated unfair even though Mannatech has done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. This is ludicirous, what about identity proctection. There are too many people looking for opportunities not only to steal possible prospects from you but to take advantage of a situation to steal personal information. Nobody will want to be put on a list to be contacted by a stranger. We have a good systen now. Please don't throw a monkey wrench into a good protective system where we build trust with our prospects. We need to protect people from identity theft, not open it up. I have been a Mannatech Distributor for more than 12 years. We became involved with Mannatech products looking for better health but also for the income. We live solely on Mannatech income that comes in every month. I totally believe in the Mannatech and what it does. This is our future, please don't handcuff us in building our future or the future of others wanting an opportunity to better themselves. I appreciate the work of the FTC to protect the public, but I believe this proposed rule has many unintended consequences and that there are less burdensome alternatives in achieving its goals. We all want protection, but there are better methods, than those previoulsy proposed. Thank you for your time in reviewing my comments on this matter.