Comment Number: 522418-02176
Received: 6/14/2006 6:17:43 PM
Organization: AdvoCare Independent Distributor
Commenter: Cynthia Vindiola
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Thank you so much for drafting rules to protect me as a citizen with a small business. I truly believe you have my best interests in mind. However, 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 independent AdvoCare Distributor and destroy my small business because of the waiting period, the disclosure rule, and the paperwork it would require. I have been an independent AdvoCare Distributor for almost 2 months. I started in April on products and saw the huge difference that they made in how I felt and my overall health. Because of them, I have been able to reduce my medical expenses and have a better outlook on life so that I have become a better contributor to society. I found the opportunity with AdvoCare for network marketing to be a favorable solution to the growing debt in my family. Since I started just a short time ago, my husband and I have already paid off our credit card debt! This opportunity has kept us from having to file bankruptcy and “drain the system.” My husband and I are depending on the extra income that I am working hard to earn in order to pay down our debt to the I.R.S. rather than settling it for pennies on the dollar. Please don’t destroy my small business; my husband and I need it! I know it is your intention to protect me as an individual from corrupt individuals who have solely my pocketbook in mind. However, I believe that this proposed law does just the opposite. Because the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser it gives criminals a greater opportunity for identity theft and consequently may create racial or sexual crime at the same time. 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. 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. This will cost the government even more money! I also believe that the law will hurt my business because of the waiting period. This section would make it hard or almost impossible for me to sell my AdvoCare products and multi-level marketing opportunity because it will give the public the idea that there’s something wrong with me or my plan. I also think this seven-day waiting period is unnecessary, because AdvoCare already has a 100% buyback policy for all products including the $50 membership kits purchased by a distributor. Under this waiting period requirement, I will need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. I am a small home business and this burden will hurt or destroy my business because I will be required to find a place to store these records. I do not want to accrue more debt because of this law! I also do not want to promote global warming with all of the paper required for my records. What would the EPA have to say about that? I am a good American citizen and this proposed rule will hurt me and my family. Please vote against this proposed law and save my small business! Thank you so much for reading my letter and considering the needs of my family.