|Received:||7/10/2006 12:46:15 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear FTC Members: Currenty you are proposing new regulations impacting the Direct Sales Industry. Having worked in this industry since 1998, I am writing to ask you to reconsider 2 of them. The first of these is the requirement to give to an interested party the names of the 10 people closest to them geographically as references. There are a myriad of reasons I think this idea is ill advised. I believe this requirement puts all direct sales consultants at a clear risk for burgulary, robbery, identity theft or worse. If this requirement goes into effect, I can see the seedier side of our society pretending interest to gain access to the 10 required references. By pretending to be interested, they find out where and when our training are. They now have information on 10 homes in their area, where people may not be home, because as law abiding citizens, we provided them with that information. Heaven forbid, that a reference in a effort to be helpful and genuine, reveals that she is a single mom and that she doesn't know what she would do without her PartyLite income. What sort of harm could come to her should an unscrupolus person know this? Did we just set her up for rape or worse? Secondly, our company has structure in place so that we have the opportunity to invite people from all over America to join our teams. I personally have team members in 8 states and on 1 military base. Another 50% of my team lives 100 miles or more from me. Were this requirement in place, we would not have this ability, adversely impacing our incomes. It could also keep us from being able sponsor friends and family members who do not live near us. Thirdly, if this requirement exists, no one new to the company can advance. Having to supply 10 references gives you no chance to get the first one. As you can see, a 10 person reference requirement could keep people from advancing beyond themselves, could keep others from branching out geographically and could bring property or physical harm. This requirement would bring the business of many of us to a screaching halt, which I know is not your intent. The second item I would like you to reconsider is the 7 day look over requirement. In our industry, a good 25% our our new consultants come from people who decide the day of their show to join our company. This is not to say, however, that they have not had conversation with someone before hand. We give written information to many people and have conversations with them before the actual decision is made. One of the things about our company is that once a decision is made, the new person can start making money right away. We can have them trained, business kit in hand in 24 to 48 hours. On more than one occassion people have started for the immediate money ~ to keep a house out of foreclosure ~ to buy food for their kids ~ to leave abusive relationship. These are important reasons to allow the flexibility of a start date, I am sure you would agree. Another, and perhaps, more general reason, is that studies show that when people wait more than 24 to 48 hours they talk themselves out of joining. They never get to see how successful they could have been, because they never allow the chance. This impacts the potential income of not only the new consultant but the sponsoring one as well. Again, probably not your intent. Our company lets a person start with no out of pocket expense and offers a buy back option as well. Perhaps more stringent controls, such as we place on ourself, are more in order than stiffling the excitement and promise a new consultant has when s/he sees the opportunity. While I appreciate the FTC's efforts to protect consumers, in this case I feel you would be harming them instead. I also know, that should these 2 requirement become law, my income and therefore my future will be hugely and adversly impacted. Please, I beg of you, do not go forward with these two proposed regulations.