| Comment Number: | 522418-06593 |
| Received: | 7/6/2006 8:16:16 PM |
| Organization: | Independent Consultant, Arbonne International |
| Commenter: | Noemi Obenhaus |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Dear Sir or Madam: It is my belief that Business Opportunity Rule R511993 in its current form could prevent me from continuing as an Arbonne Independent Consultant. While I realize that FTC’s responsibility is to protect the public from unfair and deceptive practices, it is my opinion that some areas of this proposed ruling will make it very difficult, if not impossible for me to sell Arbonne products and sponsor people into the business. The seven-day waiting period that is proposed would cast direct selling in a negative light. Direct selling has come into its own in the last several years. And, in my opinion has proven to be a viable alternative to those who need to earn additional income and/or want to own their own business. The record keeping that would be involved would be a tremendous burden to Independent Consultants like myself, who start their Arbonne business while maintaining a full time job and in most cases raising a family. One of the key elements to the success I have had in my Arbonne business has been capturing the enthusiasm and immediate results prospects experience when they use the Arbonne products; the waiting period would potentially limit my ability to grow my business. The litigation reporting requirement would only be just if it distinguishes between winning and losing lawsuits. A law suite may incorrectly imply wrongdoing and it would seem unfair to disclose lawsuit information unless Arbonne had been found guilty of something. In my opinion the requirement for references would be impractical and an additional burden to every Arbonne consultant. There is also the matter of privacy issues due to ID theft and safety. Most people are very sensitive to this issue and understand the ramification of identity theft. I have been an Arbonne Independent Consultant for the last twelve months. Arbonne has been a blessing in our whole family’s life. When I started my Arbonne business, I had a full time job as a bookkeeper and an additional part-time job. Arbonne became my third job. There has been a great deal of work, but my business and out team has grown considerably since I began my business. Over the last 12 months Arbonne has proven to be a company of great integrity. Arbonne has demonstrated that they truly are dedicated to making sure that all its consultants have the best training possible on its products and o the company. This is probably the major reason that our team has done so well. Selling Arbonne products has contributed to our family’s financial stability. I am now able to conduct my Arbonne business on a full time bases. The personal journey has proven to be far more important than the increase in my monthly earnings. Arbonne is probably the hardest work I have ever done and absolutely the most rewarding. Selling on a one-to-one basis has been something I never dreamed I could do. I am extremely proud to represent a company of such excellence. While I understand and appreciate the necessity of the Federal Trade Commission and I also understand their work on behalf of all citizens, I believe the Federal Trade Commission’s proposed ruling would unfairly target legitimate direct selling businesses. Thank you for your time and understanding. Sincerely, Noemi Obenhaus Independent Consultant Arbonne International