| Comment Number: | 522418-07502 |
| Received: | 7/10/2006 11:59:28 PM |
| Organization: | |
| Commenter: | Susan Gail |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 10, 2006 Federal Trade Commission Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 Dear Sir or Madam: I am writing to express my concerns with the FTC's proposed Business Opportunity Rule R511993. I have been a dedicated Herbalife Distributor for almost 25 years. I have personally benefited from the good health these products have provided and so has my family. I originally began as a distributor to solve a debt issue. I was a secretary at the time, with no sales or management background. But with the support of my sponsor and the training tools that Herbalife provides, I was able to get out of debt the first year and go on to make more money part-time than I did on my job. I have now been able to provide for my family things they would never have been able to have, security for my parents in retirement, and educational opportunities for my nieces and nephews. I’ve also become a capable trainer and leader. I have helped over 3,000 people to utilize the Herbalife opportunity to create a significant income for themselves. I support efforts to prevent consumer fraud. As an Herbalife distributor, I go to great lengths to make sure that my prospects understand what they are getting into, because it in the best interests of both of us to do so. No one wants to waste time building something that was not clearly understood in the beginning. However, the proposed rules create from the outset an adversarial “guilty -until –proven- innocent” context which destroys the trust relationship that I try to build with my new business associates. It is an unnecessary and ineffectual burden to require that I: request a disclosure statement from the parent company every time I speak with a prospect—which is something I do every day. find 10 purchasers local to the prospect. send all this to the prospect to sign wait 10 days even after he as read and signed everything. This is harsh as well as redundant. Furthermore, business would grind to a halt and no one would achieve the benefits that owning a business provides. Again, I applaud the agency’s efforts to protect the public, but I request that you re-evaluate the proposed steps in order to achieve the real goal, which is keeping the entrepreneurial spirit of America alive. Our opportunity and the opportunity of other legitimate direct-sales companies is the average person’s best chance to change their lives. I am proof of that. Sincerely, Susan Gail