| Comment Number: | 522418-03419 |
| Received: | 6/19/2006 8:04:07 PM |
| Organization: | World Citizens, an Independent Shaklee Distributor |
| Commenter: | Susan Bodlak |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 19, 2006 Re. Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter to express my strong opposition to the above-mentioned Proposed Rule. This would serve to make my Shaklee business, as an Independent Distributor, more difficult for me to conduct. I am already a working mom, and look for every way I can find to simplify my business. This rule would do the opposite. The seven-day waiting period to enroll new distributors is worse than the three-day cooling off period now imposed on contracts that are signed. I understand that this is to give the new propect time to change their minds. But if a new recruit of mine were to change their minds, Shaklee Corporation has a buyback policy for the Membership Kit if purchased within the last two years. And this fee is only $19.95, which is very reasonable. I agree with the statements of my fellow Shaklee distributors which you have undoubtably already read, that requiring the names and contact information of ten prior purchasers of the business opportunity would virtually shut down any future recruitment I may do. Very few people are likely to be comfortable with providing this information, given that there is no way to know how it will be used, shared or sold by the new prospect. The proposed rule calls for the disclosure of any and all lawsuits over the last ten years, regardless of the outcome of the suit. In this litigious society, most every company has been sued, rightfully or wrongly, at some time. Not all prospects will be capable of evaluating the lawsuit for merit. They will simply see that someone in the Company had been named as a Defendant, and they will walk away. As has been pointed out, this will be a major advantage for new, start-up companies as compared to an established company such as Shaklee. This would very much encourage companies who have been found legally liable to fold up their operations and re-open with a new name...a deceptive practice which is also difficult for the uninitiated prospect to detect. I began my relationship with Shaklee, like so many others, to be able to purchase the products at a discount. My entire family has benefitted healthwise, and over the years, I have learned the tremendous business advantages available to those who conduct a Shaklee business. I am able to make extra income while helping other families improve their health as well. My husband works in the volatile telecommunications industry, and we look at our Shaklee business as a safety net, something to fall back on if he were to lose his job. I appreciate that the FTC is looking out for the best interests of consumers, and this is, of course, necessary, given the level of fraud practiced by some unscrupulous parties. However, this rule, as written, would have difficult consequences which are more than likely unintended, but still potentially disasterous for us small business owners who wear many hats and are already stretched very thin. Thank you for your time and attention. Sincerely, Susan Bodlak Independent Shaklee Distributor