| Comment Number: | 522418-02438 |
| Received: | 6/15/2006 8:39:50 PM |
| Organization: | J Weber Communications |
| Commenter: | Jean Weber |
| State: | OK |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-02438.pdf Download Adobe Reader |
Comments:
Re: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing to express opposition to the proposed Business Opportunity Rule R511993. This ruling would create serious problems for me as an Independent Associate with Mannatech, Incorporated. It may even make it impossible to operate my business. The seven-day waiting period before enrolling a new associate is problematic. Most people who sign up in Mannatech become Associates in order to purchase the products at a wholesale price. There are a few members or retail customers, but most choose to become Associates. There is no additional fee to become an Associate when products are purchased. Also, Mannatech has a buy-back policy for products, further negating the need for a waiting period. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. This brings up the right of privacy of those prior purchasers who may not want their personal information shared with others. This information would have to be coordinated by the company since most of the people I refer to use the products are scattered around the country. Therefore I could not personally keep track of that data. I know there are many people in the Tulsa area where I live who use these products, but the person who enrolled me lives in Maryland. At the time I enrolled he was very willing to let me speak to others who are using the products, and I didn’t care where they lived. Asking people to sign a release to disclose their personal information to strangers by a stranger would greatly impair the way we do business. There are some Mannatech Associates who enjoy a nice income as business owners and many others who are only interested in purchasing the products at the lowest possible price. The current system in our company serves both interests well. The requirement for the release of any information regarding lawsuits also causes problems for excellent, ethical companies such as Mannatech. There may be fully ungrounded lawsuits which were thrown out of court or settled to save the company time and money. Mannatech carefully provides rules and guidelines for doing business as an Associate in a legal and ethical way. There may be Associates who break those rules, but the Company deals with those individuals directly. The actions of an individual who acts outside the company guidelines and rules and results in a lawsuit should not reflect on me or the Company I represent! I have been a Mannatech Associate for over two years. I originally purchased many products because I had multiple serious health challenges and I was desperate for help. I had no intention of building a Mannatech business. In fact, I was in another network marketing company at the time. I had such astonishing positive results after taking Mannatech products that people kept asking me what I had done to get healthy. So, I ended up with a real Mannatech business…kind of by default! Now, after feeling healthy for so many months, I am quite passionate about the products and I am compelled to share the story with others. I now depend on the income generated from my Mannatech business. I strongly believe this proposed ruling will have many unintended negative consequences for independent home business owners like me. I realize the value in challenging scam operations but this new ruling would hurt legitimate, ethical solid companies such as Mannatech, Shaklee, Melaleuca, and others…AND the hundreds of thousands of independent business owners who represent these great companies. Thank you for accepting and considering my comments. Warmest regards, Jean Weber