| Comment Number: | 522418-06883 |
| Received: | 7/7/2006 8:30:50 PM |
| Organization: | Herb Store & Education Center |
| Commenter: | Loring Hammer |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam, I want you to know that if the proposed Business Opportunity Rule R51193 is adopted in it's present form, it will greatly undermine my livelihood as a Nature's Sunshine distributor. In my Herb Store & Education Center, where I educate people in healthy eating and the use of herbal remedies, most of my clients and customers sign up as Members or distributors of Nature's Sunsine products so they can get the products at less cost as well as stay on their health building programs long enough to get results. If they have to wait seven days to finish their application process, that is too long for most people to wait. This will cause them to not be able to start their program for approximately 2 weeks. NONE of my clients and distributors purchases more than $100 worth of products in their signing up process. Most of them just sign up with only $40 worth of products. If Rule 511993 takes effect it will cast a direct selling plan as a negative thing. It will also lead to problems with the record keeping and administrative problems as well as cause unnecessary delays. This Rule does not distinguish between winning and losing lawsuits. It is impractical for me to find 10 nearest distributors and it raises privacy issues due to ID theft and safety regarding references. I DO understand that there may be fraudulent groups of people out there, but the company Nature's Sunshine has NEVER been one of those problems. I have been selling (and signing up distributors) in NSP for over 30 years and it is my ONLY means of support. Please do not force us to fit in a Rule that does not really apply here. In fact, direct selling is a legitimate business, and many people in this country are supporting themselves in these kinds of businesses and in so doing are paying their fair share of federal and state taxes. So, that will be affected, too. Please look at this issue and understand what it will do to a HUGE number of independent distributors in this country! Thank you for your consideration and PLEASE make the necessary changes to this Rule R511993 so it protects legitimate direct selling business in this country. Sincerely, Loring L. Hammer Herb Specialist for 30 years and counting!