| Comment Number: | 522418-04313 |
| Received: | 6/26/2006 2:03:39 PM |
| Organization: | Build My Own Web |
| Commenter: | Lorin Sourbeck |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
June 26, 2006 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: My name is Lorin Sourbeck, I am an independent business owner with Market America. Having worked for about 15 years for big corporations, I found a better way to do business, that has more integrity, more care and more support than anything I have ever seen. This business is built on teamwork and mutual success. 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 Market America Independent Distributor. I understand that part of the FTC’s responsibilities is 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 Market America products and services. I am able to work at home and take care of my kids -- something we couldn't afford to do otherwise. Having had medical conditions too, my job was uncaring and not in the least helpful. I have been an Independent Distributor for Market America, Inc. for more than 2 years. Originally, I became a customer of the company’s products. Because I like them and wanted to earn some additional money – I became a small business owner. Now my family absolutely depends on this extra income to supplement our budget… I am very much AGAINST this 7 day waiting period. One of the most confusing and burdensome sections of the proposed rule is the seven day waiting period to enroll new distributors. Market America’s subscription (sales) kit costs under one hundred dollars, it includes essential manuals, educational materials and resources we need. People buy TVs, cars, and other items that cost much more than that and they do not have to wait seven-days. This waiting period gives the impression that there might be something wrong with the plan. I also think this seven-day waiting period is unnecessary. Under this waiting period requirement, I will need to keep very detailed records about when I first speak to someone about Market America and will then have to send in many reports to Market America headquarters. The paperwork will be overbearing and burdensome. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. This requirement may be in violation of my state’s laws regulating referrals, testimonials and advertising. Furthermore, people are very uncomfortable giving out the personal information of individuals to strangers - especially without their approval and the possibility of identity theft. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. The proposed rule also calls for the release of any information regarding lawsuits. 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. Market America and I are put at an unfair disadvantage - even though Market America has done nothing wrong. What you are trying to do is really upsetting and it is putting over 100,000 families at risk. In all my years, this is the most honest and caring business I have ever seen. It is NOT one of those Multi Level companies that SHOULD be monitored, in fact, other businesses should be measured by how Market America conducts business. The honesty, the caring, the family, it is an amazing opportunity to help people. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences for small business owners like me. And, that there are less burdensome alternatives available in achieving its goals. Thank you for your time in considering my comments. Sincerely, Lorin Sourbeck