| Comment Number: | 522418-06604 |
| Received: | 7/6/2006 8:56:47 PM |
| Organization: | Young Living Oils |
| Commenter: | Diane Ogata |
| State: | HI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Diane M Ogata Young Living Oils Distributor Date July 7, 2006 Re: Business Opportunity Rule R511993 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that this proposed rule seriously affect my small business opportunities. I have been a distributor with Young Living for 3 years. I became involved with this company because I felt the products were exceptional and I wanted earn additional income. Through Young Living, I have made many friends, and like- minded women. I introduce everyone I know so they can live healthier life. These products are a part of my daily routine, and thankful to be part of Young Living team. We have come to rely on this supplemental income from my direct selling business. Seven-Day Waiting Period is one of the most confusing sections of the proposed rule is the seven-day waiting period to enroll new distributors. When a Starter Kit is purchased, the purchaser becomes a distributor and is granted special discounted pricing immediately. If they want to cancel on their own of course they can, and even be refunded if they change their mind. So this 7-day rule is unnecessary. Litigation Information: Perhaps this could be re-written 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. It makes me think of the Better Business Bureau, you can call any time about the legitimacy of a company and unresolved complaints. There are plenty of complainer’s, and folks who try to sue as money- making adventure. So that’s not fair to group good and bad law suits together. References:The proposed rule requires the disclosure of a minimum of ten prior purchasers nearest to the prospective purchaser. I am glad to provide references but 10!!! How about 3? I would have to away to get such a list to the headquarters and wait for a responses, the company would be inundated with calls in order to comply, not to mention privacy acts and identity theft! Cancellation notification: Why would you want to maintain such lists? People change their mind, move, and financial changes. Exemption FTC currently states: “When the required investment to purchase a business opportunity is comparatively small, prospective purchasers face a relatively small financial risk.” This exemption is necessary because without such an exemption, the proposed rule places an unreasonable burden on tens of thousands of YL distributor’s, like myself, and on millions of direct selling and network marketing distributors throughout the US. Please reinstate at least a $500 exemption. I appreciate the work that the FTC does to protect consumers, I hope I did not offend you.Please re- think this bill and its consequences. Thank you for your time in considering my comments. Check us out at www.younglivingoil.com, we are very organized and helpful. Respectfully, Diane Ogata, MAJ, OTR/L Young Living Oils Distributor# 743678