| Comment Number: | 522418-02443 |
| Received: | 6/15/2006 8:58:37 PM |
| Organization: | Sunrider International |
| Commenter: | Sabrina Frederick |
| State: | Not in the US |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Sabrina Frederick June 12, 2006 Dear Sir or Madam: I am writing this letter in response to the proposed Business Opportunity Rule R511993. I am concerned about this proposal because I believe that in its present form, it could prevent me from continuing as an Independent Sunrider Distributor. I understand that the responsibilities of the FTC is to protect the public from unfair and deceptive acts, but some of the proposed rules will make it very extremely difficult if not virtually impossible for me to continue my Sunrider business. One part of the proposal that really concerns me is that seven- day waiting period to enroll a New Distributor. This gives the impression to people that there might be something wrong with the plan. Another concern with the seven-day waiting period is that the administrative will have to keep very detailed records of the people I talk to about Sunrider, and then having to send numerous reports back to Sunrider’s headquarters. This is really time consuming. In this day and age I am trying to save time so that I can spend it with my family. I also think this seven-day waiting period is unnecessary because Sunrider has an excellent 60 day return policy for all existing Distributors. This applies to all products. Sunrider also has a 90% buyback policy for former Distributors applicable to all products purchased within the last twelve months. Rule R511993 also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. In this day and age anyone or any company can be sued for almost anything. It does not matter if the company was found innocent. It does not make sense to me that I would have to disclose these lawsuits unless Sunrider is found guilty. Otherwise, Sunrider and I are put at an unfair advantage even though Sunrider has done nothing wrong. Finally, the following sentence in the proposed rule really concerns me and may prevent people to sign up as a distributor “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” They may be reluctant to share their personal information with individuals they have never met before. Especially in this day and age people are very concerned about their privacy and identify theft. The proposal also requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. This also concerns me, because as I stated above people are very concerned with their privacy and identity theft. I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to Sunrider headquarters and then wait for the list. This is also very time consuming. I have been an Independent Sunrider Distributor for more than 3 years. Originally, I became a Sunrider Distributor because I love the products and wanted to consume them. Then I realized that when I share this opportunity with my friends and family I am able to earn some additional income and also assist them in earning additional income. Also through Sunrider I have learned important leadership skills as well as communication skills and have helped other to build these qualities as well. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving its goals. Thank you for your time in considering my comments. Sincerely, Sabrina Frederick