| Comment Number: | 522418-03851 |
| Received: | 6/22/2006 3:48:23 PM |
| Organization: | Vemma |
| Commenter: | Jeff Bedbury |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it may concern, I am writing you today as a response to to the proposed FTC Business Opportunity Rule. While I understand that the FTC has good intentions behind this rule and welcomes public comments, it's intended purpose to protect all citizens from falling victim to hurtful and fraudulant schemes will, in this form, have a devastating impact on the direct sales industry. My wife and I have been in the industry for 11 years having started with New Vision International. New Vision's reputation speaks for itself and now Vemma has also become a big part of our daily life in dramatically affecting the health of our family and friends throughout the country. Our experiences have taught us both volumes in interacting with people, public speaking and so much more. Our lifestyle has been enhanced by our efforts with the company as the compensation plan is very fair and the company goes out of it's way to service it's members and make sure that it is in compliance at every level.Vemma, for instance, doesn not charge it's members a fee to join and has a 100% empty bottle money back guarantee on it's product. A member can cancel his or her membership at any time without penalty. Everyone we work with at the corporate office is top notch and our yearly events are truly inspiring as we've seen so many people's lives impacted positively over the years. While I understand there are fraudulant groups out there, this particular rule unfairly targets legitimate direct selling businesses like Vemma and New Vision. For example: 1) The 7 day waiting period will cast the direct selling plan in a negative light from the get go. 2) It will also create major record keeping and administrative problems. 3) It will create unnecesary delays in our day to day business and is basically very impractical. The Elimination of the $500 business threshold: 1) This will force the majority of direct selling companies to comply with other provisions of the proposed rule that are more appropriate for businesses requiring a greater investment than a direct selling business. LItigation Reporting: 1) This requirement is unfair in that it does not distinguish between winning and losing lawsuits. And it substatiates it's irrelevance at the reporting of almost all litigation regardless of the outcome. Earnings Claims: 1) This requirement is very cumbersome as it is difficult for us to collect all of the required data. 2) Those that have always provided inaccurate data will continue to do so while legitimate companies will comply as they always have. References: 1) It is impractical for us to always find the "10 nearest existing sales people". 2) There would be major Privacy and safety concerns. 3) Possible corporate liability for ID theft. In sum, this proposed Business Opportuiity Rule, in this form, would be devastating to our industry. This proposed rule, by casting such a wide net, will literally devastate a legitimate industry that provides over 13.6 million individuals the opportunity to start their own business.Companies like New Vision International and Vemma and the countless others out there that have positively affected people's lives over the years by playing by the rules and setting a high standard of excellence, should not be punished by such a wide sweeping proposed rule.I hope that this letter will make you take pause and realize that companies like New Vision and Vemma, and the thousands of members who get up every day and go to work to make a better life for themselves and their families, want to work with the FTC to stop fraudulant business opportunities and make sure they understand that not all MLM's are created equal. Sincerely, Jeff Bedbury