| Comment Number: | 522418-07040 |
| Received: | 7/8/2006 7:03:45 PM |
| Organization: | Nutrazon International |
| Commenter: | Scott Beaudry |
| State: | WI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am writing this letter because I have serious concerns regarding the proposed Business Opportunity Rule R511993. I strongly believe that this rule in its present form, will prevent me from continuing as an Independent Nutrazon Distributor. I realize the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will make it very difficult if not impossible for me to sell Nutrazon® products.One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new Distributors. Nutrazon’s Starter Pack costs only $120, and is not a mandatory purchase in order to become an Independent Nutrazon Distributor. People buy TVs, cars, and other items that cost much more than that and they do not have to wait seven days. This waiting period gives the impression that there might be something wrong with the plan. I also think this seven-day waiting period is unnecessary because Nutrazon already has a generous 60-day return policy for existing Distributors that is applicable to all products, including the Nutrazon Starter Pack. Nutrazon also has a 100% buyback policy for former Distributors applicable to all products purchased within the last twelve months. Another problem with the seven-day waiting period is the administrative burden of keeping very detailed records when I first speak to someone about Nutrazon, and then having to send numerous reports to Nutrazon headquarters. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless Nutrazon is found guilty. Otherwise, Nutrazon and I are put at an unfair advantage even though Nutrazon has done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, (and I have had my identity stolen) I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. In addition, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to Nutrazon headquarters and then wait for the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson: “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. I have been an Independent Nutrazon Distributor for more than 3 years. Originally, I became a Distributor of Nutrazon’s products because I love the product and wanted to earn some additional money. Now my family depends on this extra income to supplement our budget. I’m planning on making Nutrazon my full time income, but if this rule goes into affect I truly believe I won’t be able to do that! I have been in the home base business industry for over 15 years, and this industry has truly change my life for the better, I’m a better father, Husband, Son, employee, productive citizen, this industry has taught me more than all my schooling combine and this ruling will prohibit thousands of people from experiencing the advantage of entrepreneurship, working from home and having the control over there own lives. Sincerely Scott Beaudry