| Comment Number: | 522418-06013 |
| Received: | 7/4/2006 10:07:04 PM |
| Organization: | USANA Health Sciences |
| Commenter: | Laurie Monson |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
We are writing this letter because we are concerned that the FTC’s proposed Business Opportunity Rule (R511993) could cause great harm to our USANA Health Sciences business. We have worked very hard over the past 5 years to build our business. It has taken a lot of time and much energy to build it to the point it is now. We feel that that this rule goes very far in trying to protect the public by proposing requirements that will make it very difficult for us and others to sell USANA products. USANA has a 100% money back guarantee for 30 days opened and unopened product so this 7 day rule is not necessary. We also have a 90% guarantee for 330 days for unopened product. This rule would require extra paperwork and time not only for us but also for USANA Corporate. People these days are sue happy so they will sue for any reason. This rule will not take in account the fact that the company was found innocent in the case of a law suit. If USANA was found guilty then this would already be public record. If USANA is not guilty then it makes no sense to disclose these lawsuits. This puts a bad light on USANA whether they did anything wrong or not. Finally, the proposed rule requires the company to disclose to each prospective independent USANA Associate the names and contact information of a minimum of 10 previously enrolled Associates who live nearest to the prospective Associate. With identity theft happening all over, we are very uncomfortable with giving personal information to individuals without their permission. People will not want to sign an application to have their contact information disclosed to future buyers. What also disturbs us is that we do a lot of effective cold marketing over the phone. These prospects once they have a list of 10 Associates in their area can call them and go with anyone of them and not come into our business. Not only that, but these prospects can try to recruit USANA people into their own entrepreneurial businesses. This ruling will make recruiting prospects a very long and tedious process. USANA will have to hire more people because of each person coming into anyone’s business will need a list of Associates in the prospect’s area. We have been USANA Associates for over 5 years. Originally we became Associates because we really liked the products. We then decided to get involved with the opportunity because we needed an extra stream of income for our family of 6. We really depend on this extra income to make ends meet. Through USANA we have had huge personal growth and have changed from very shy to very confident. This wouldn’t have happened without our USANA business and the wonderful people that we have been able to meet. FTC has done some good work to protect consumers, but we believe that this proposed new rule is going to harm our USANA business. Please reconsider this ruling… Thank you for your time and reading our comments. Sincerely, Steve and Laurie Monson