| Comment Number: | 522418-07038 |
| Received: | 7/8/2006 6:47:34 PM |
| Organization: | PartyLite Gifts |
| Commenter: | Karla Powell |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am an independant agent with PartyLite Gifts, a member of the Direct Selling Association. I am against the FTC passing the regulations listed in this email for the following reasons. PartyLite has always adhered to the ethical guidelines of the Direct Sales Association, but two of the regulations being considered by the FTC could directly affect my PartyLite business, particularly with regard to my success as an independant agent to further build my business. 1. A seven-day waiting period This would mean that a potential new Consultant could not join until seven days after being provided with detailed papers about PartyLite. An interested Hostess might have to wait to turn her Show into a Starter Show. This 7 day waiting period conflicts with PartyLite's guidelines of submitting orders within 5 days of a show for prompt processing/customer service causing unnecessary delays for new consultants and for guests who are expecting their products promptly. She'd also lose the momentum of her enthusiasm and that of her friends and family. PartyLite Gifts has been in business for 33 years and is a member of the the Direct Selling Association. They have proven themselves as a leader in the Candle Industry as well as Direct Sales and neither should a company such as PartyLite or the independant agents who represent PartyLite be forced to prove themselves each time. As an independant consultant, it would directly impact each consultant's ability to build their businesses by missing company deadlines which in turn could directly impact income and unit structure as well. 2. Ten required references To sponsor someone, it would be necessary for an individual Consultant to provide each potential new Consultant with names and phone numbers of ten geographically closest Consultants so they could get references about PartyLite. PartyLite Gifts has been in business for 33 years and is a member of the the Direct Selling Association. As an independant consultant, it would directly impact one's ability to start their own business if they did not know anyone in their area. Not only would this be time-consuming from a clerical point of view, I would consider it an invasion of privacy. I understand the need to police unscupulous companies, however I do not see how a 'blanket' approach to this would fix anything. A company that has been in business as long as PartyLite or any other member of the DSA should not have to RE-PROVE themselves to the FTC. Although I am an indepentant agent of PartyLite, I am still bound by their regulations or face loss of my privileges with them. Passing this regulation would only hurt the small business persons who are already complying with company and/or DSA rules/regulations. Unscrupulous businesses will already have this worked into their scheme. Please do not pass this regulation and put another strain on the small businesses of this country. Thank you.