| Comment Number: | 522418-02234 |
| Received: | 6/15/2006 12:03:18 AM |
| Organization: | |
| Commenter: | Joan Lubar-Alvarez |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing to express strong opposition to the proposed Business Opportunity Rule R511993. I understand that the Federal Trade Commission must protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. I have been a Shaklee Distributor for more than 20 years. Originally, I joined Shaklee because I love the Company's products and wanted to earn some additional income working from home. Now my husband and I depend upon this income for our livelihood. My husband has Parkinson's and cannot work and I am the sole supporter of our family. I cannot imagine how I would be able to follow all of these restrictions and requirements (if I could even find the information) and still run my business. The seven-day waiting period to enroll new distributors is extremely cumbersome, especially with the required information you are asking us to provide. Most of the people who sign a Shaklee application are consumers of the products and the Shaklee Member Kit costs only $19.95. [For many, the choice to become a distributor of the products comes later.] This is far less than most consumer purchases, from TVs to all manner of household appliances, none of which require a waiting period. Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years and a 100% money back guarantee for most products for consumers. Many of us do business around the country, especially with a website accessed by any consumer or potential distributor. I would not necessarily have any other customers or distributors in that area and can't even imagine how difficult it would be to find them. In addition, I don't feel comfortable giving out the names of other Shaklee distributors that I might know. It seems to be an invasion of their privacy. In addition, providing a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for such other opportunity. Please reconsider what you are proposing. It definitely does not make sense in our business, especially when we already have our own guarantee to protect our customers and distributors. Thank you for considering our response, Sincerely, Joan Lubar-Alvarez Shaklee Distributor