Comment Number: 522418-04967
Received: 6/28/2006 11:30:05 PM
Organization:
Commenter: Cheri Nutting
State: NH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear Sir or Madam: I have been an Independent Consultant with Arbonne International for almost 3 years now. Arbonne has been the best thing to ever happen to me. The personal and professional growth that I have achieved thanks to Arbonne's training and resources is outstanding. I'm so happy to work with a company who's integrity is as high as Arbonne's. With Arbonne, I am able to support my family financially while working from home. I now have time to volunteer in our local schools and community and I am always available to my children and family. 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 an Arbonne Independent Consultant. I understand that part of the FTC's responsibility is to protect the public from "unfair and deceptive practices" but some areas of the proposed rule will make it difficult, if not impossible, for me to sell Arbonne products and sponsor people in the business. One of the most confusing and restrictive sections of the proposed rule is the 7-day waiting period to sign up new consultants. Arbonne's start up kit is a nominal amount of money and the proposed waiting period gives people the impression that something might be wrong with the Arbonne opportunity. The waiting period would limit my ability to grow my business and cost me more time and delay helping new consultants get started. In my opinion this isn't like buying a gun or getting married, both things that sometimes have a waiting period because of the serious consequences involved in making a hasty decision. It is $29 for informative materials and business aids and an identification number to purchse products at a discount and potentially earn an income with Arbonne. This is less money than you might spend on a pair of jeans that don't fit quite right or a meal that you didn't like. I believe a waiting period to be unreasonable. The proposed rule calls for the release of ANY information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. A lawsuit may incorrectly imply wrongdoing and it seems unfair to disclose lawsuit information unless Arbonne has been found guilty of something. I fear being penalized by the impression a lawsuit would leave, even if I have done nothing wrong. The proposed rule requires the disclosure of a miminmum of 10 prior Independent Consultants nearest to the prospective Consultant. I am glad to provide references, but I am uncomfortable giving out personal information about individuals, without their permission or knowledge to strangers. I don't understand why we would be asked to share this information. When applying for a job in a traditional workplace, no employer would be asked to give the names of past employees who held the position being applied for. I am well aware of the fact that I am not employee of Arbonne, nor do I employ anyone, we are all independent consultants. I am trying to draw a comparison here to what that would be like in a traditional work setting. Prospects would be concerned about their privacy if we will later be giving their information out. I truly appreciate the work of the FTC in protecting consumers, but I believe that this proposed new rule would have many detrimental (and unintentional) consequences. I hope there are alternative means to resolving the outstanding issues at hand, without harming the livelinhood of millions of successful network marketers, like me. Thank you for your time and understanding. Sincerely, Cheri Cheri Nutting