| Comment Number: | 522418-07672 |
| Received: | 7/11/2006 1:59:00 PM |
| Organization: | Simmons Distributors |
| Commenter: | Margaret Simmons |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opportunity Rule R511993 Dear Sir or Madam I wish to express strong opposition to the proposed Business Opportunity Rule R511993. I understand that the FTC must protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. Fifty year old companies such as Shaklee would be a disadvantage compared to start-up companies, which may not yet have experienced litigation but are far more likely to have legal issues surrounding their opportunities. I have been a Shaklee Consumer for over 25 years and a Shaklee Distributor for at least 10 years. I began as a consumer of the nutritional products and, after checking out the business side of Shaklee, became convinced that this is a reputable company ... a conviction which has many times over shown me that I made the right decision when I became a Distributor. Please don't burden me with what I think are unnecessary requirements. I have at least two examples: First … the seven-day waiting period to enroll new distributors. Most of the people who sign a Shaklee application are consumers of the products. Like me, if they later wish to build a business, all they must do is supply Shaklee Corporation with their Social Security Number or Tax ID Number. No additional kit, fee or application is required. The Shaklee Member Kit costs only $19.95. This is far less than most consumer purchases, from TVs to all manner of household appliances, none of which require a waiting period. The waiting period is also unnecessary in that Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. Second ... the 10 reference requirement. To obtain the list of 10 prior purchasers, I will need to provide Shaklee Corporation with the prospective distributor's address and then wait to receive the list of the 10 nearest distributors who became distributors within the past three years. Each prospective recruit will need a customized disclosure statement. This will result in the delay far longer than seven calendar days before anyone can sign an application. Many people enter direct selling to earn extra income for a specific goal, such as holiday purchases or a family vacation. The wait which the proposed rule creates may make the goal unattainable. Thank you for your consideration, Margaret Simmons