| Comment Number: | 522418-05987 |
| Received: | 7/4/2006 6:40:22 PM |
| Organization: | Young Living Essential Oils |
| Commenter: | Elisabeth Gottl |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Opportunity Rule R511993 Dear Sir or Madam, I am writing because I am concerned about the proposed Business Opportunities Rule R511993. I believe this proposed rule could prevent me from conducting business as a distributor for Young Living Essential Oils. Some of the sections in the proposed rule will make it difficult for me to sell Young Living’s products. As a distributor of Young Living, I, as well as the majority of distributors, promote the purchase of products rather than any business opportunity. I have been associated with Young Living for several years. Using the products, I have come to realize the exceptional quality of these products and the health benefits my family has received using these products daily. I finally feel I am ready to share my discovery with others which concerns me because the proposed rule may make it more difficult for me to do so. Young Living’s Starter Kits cost only $50. Each kit contains products, samples, training materials, etc., which are worth far more than the sale price. When a starter kit is purchased, the purchaser becomes a distributor and is granted special discounted pricing on all orders. No commissions are paid on these kits. If the customer decides to return the kit, Young Living will fully refund the cost. Having a seven-day waiting period gives the impression that there might be something wrong with the company or the compensation plan. Requiring a seven-day waiting period before a new distributor is allowed to place an order would be destructive to the business of thousands of distributors who a building a business around Young Living products. This waiting requirement would be very burdensome because I would have to keep detailed records from the first time I speak with each and every person about Young Living, and it would create lots of unnecessary paperwork to send these reports to my company headquarters. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation or unfair or deceptive practices, regardless of whether the company was found innocent or not. Nowadays, any individual or company can be sued for any reason. It does not make sense that I would have to disclose these lawsuits unless Young Living were found guilty. Otherwise, my company and I are put at an unfair disadvantage even though the company has done nothing wrong. To release this information would be misleading to prospective distributors. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. With identity theft cases arising daily, I could not in good conscience provide personal information to strangers. In order to get the list of prior purchasers, I would need to send the address of the prospective purchaser to Young Living headquarters and then wait to receive the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a distributor: “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. Furthermore, Young Living does not sell “business opportunities” in the fashion. I appreciate the work the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences, and there are less burdensome alternatives available to achieving your goals. Thank you for your time in considering my comments. Respectfully, Elisabeth Gottl