| Comment Number: | 522418-02429 |
| Received: | 6/15/2006 7:38:02 PM |
| Organization: | |
| Commenter: | Daniel Sherman |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am responding to the proposed FTC Business Opportunity Rule (R511993). I have been a network marketing professional since February of 2005 as an independent distributor for Nu Skin Enterprises. The company I represent, Nu Skin, has been in business for over 20 years and has a Dun & Bradstreet 5A1 rating. Nu Skin Enterprises produces personal care products under the Nu Skin brand, health and wellness products under the Pharmanex brand, and technology products under the Big Planet brand. I am a 29 year old married man, my wife is expecting our first child in December. I have a bachelor of science from Penn State University and a master of science from the University of Illinois at Urbana-Champaign, both in civil engineering. I decided to become a network marketing professional after less than 2 years practicing engineering because I wanted a job or a business that I could work from the comfort of my home while providing my family with the quality of life we deserve. The network marketing and direct sales industry is the only place I have found the opportunity to produce a full time income working from the comfort of my home. The following are my specific comments of the proposed FTC Business Opportunity Rule (R511993). 1. I oppose the creation of a waiting period that requires someone to wait seven days after they sign up to begin their distributorship. This will create a significant administrative burden on both us as independent distributors and on the companies we represent. I believe that having and disclosing a return policy would allow those whose change their minds about an opportunity to get their money back, but would not delay or penalize those who are ready to get started with their business. 2. I support an average earning income statement. I oppose written substantiation of an average income statement due the excessive burden it creates. 3. I support disclosure of previous litigation of companies, executives and affiliated companies in cases of fraud and misrepresentation only if the party was found guilty. 4. I support disclosure of business references done upon the request of the buyer. only if the they are not limited to closest geographic proximity due to the use of internet technology. 5. I support the disclosure of a cancellation or refund policy. 6. I support disclosure of refund and cancellation payments only if the disclosures are averaged out over a year. I thank you for the opportunity to provide my comments and input on this most important topic.