Comment Number: 522418-03172
Received: 6/17/2006 8:36:09 PM
Organization:
Commenter: Pamala van der Veldt
State: OK
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a Mannatech Associate. I understand that part of the FTC's reponsibilities to protect the public from "unfair and deceptive acts or practices, " but some of the sections in the proposed rule will make it very difficult, if not impossible for me to sell Mannatech products. I am opposed to the seven day waiting period. People don't have to wait 7 days when they buy other items that cost much more than our Mannatech products. This will make people thing some thing is wrong with our products. No one wants to wait for nutritional products an extra 7 days. Our company already has a 90% buy back policy for all it's products.I would need to keep very detailed records under this waiting period requirment. McDonald's doesn't have to keep records of the name and address of every person that buys a hamburger from them and report back to company headquarters. As a Mannatech Associtate, I should not have to do this either. The proposed rule also calls for the release of any information reguarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless Mannatech is found guilty. Otherwise Mannatech and I are put at an unfair advantage even though Mannatech has done nothing wrong. Finally the proposed rule requires the disclosure of a minimum of 10 prior purchases nearest to the prospective purchaser. I am glad to provide references but in this day of identity theft, of which I personally have been a victim of, I am very uncomfortable giving out personal information of customers to strangers without their approval.This could also damage the business relationship of the references who may be involved in other companies of businesses including those of competitors. In order for me to get a list of 10 prior purchsaers, I will need to send the address ofhteh prospective purchaser to Mannatech headquarters and then wait for several days for the list. I also think the following sentence required by the proposed rule will prevent many people form wanting to sign up as an associate. If you buy a business opportunity from the seller, your contact information can be disclosed to other buyers in the future. That is just not good business. People are vvery concern about their privacy and identity theft. They will be reluctant to share their personal information with individuals thay have never met. Do you give out you Social Security number to someone on the phone???? I know I don't. I have been in Direct sales since 1997. Almost ten years now , my family has depended on this second income to supplement our budget. Having been in terrible car accident I was unable to go to work outside the home and this has allowed me the opportunity to work from home, in between physical therapy and doctor appointments. It has been such a blessing in our lives. I appreciate that you are trying to protect consumers, but I believe this new proposed rule will add many uneeded burdons to businesses, endless, redundant paperwork and lost business for those of us in Direct Sales. There must be a better way, fair and excepetable to all. Thank you for considering my comments. Sincerely, Pamala van der Veldt