|Received:||6/29/2006 11:27:13 PM|
|Organization:||Advocare International Independent Distributor|
|Commenter:||David and Glenda Hendrickson|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:RE: Proposed Business Opportunity Rule R511993. As is, this proposal will make it almost impossible to continue making a living as an Advocare Independent Member and I am sure that is not your intent. Like many direct sales companies we appreciate your desire to protect the public from unfair and deceptive business practices. However, Advocare International, Carrollton, TX offers high-quality nutritional products through more than 100,000 members across the United States and we have a variety of concerns about the proposal--the undue burden it would place on our business. As you know, record keeping can be an extreme burden for one or two people employed in a home based business. Record keeping detracts from the time necessary to make a living without adding costs that make the business undesirable. Federal laws and state laws already exist, and respectable direct sales companies follow these laws to protect the interest of the public (including generous buy back policies). For example, Advocare already has a buyback policy for all products and the sales kit purchased by members in the last 12 months. This is normal industry practice so why do we need this other rule on top of rules we already have (seven-day waiting period)? Because identity theft is rampant today people are very uncomfortable giving out personal information to strangers as proposed by your disclosure rules. The disclosure practice and waiting period necessay to get a list of 10 prior purchases would be impractical to continue an ongoing and viable business killing the desire for prospects to be a part of a company offering great products but an impossible business opportunity. As you know, the direct sales industry is a major player in the U.S. commerce activity. Many people have become extremely skeptical of legitimate direct sales (which already keeps people from participating in these opportunities) and this will most certainly add to that perception problem. Please don't kill our ability to make an income. We are so concerned about this and don't need this burden--please reconsider this proposal! Thanks for your consideration.