| Comment Number: | 522418-07702 |
| Received: | 7/11/2006 2:47:06 PM |
| Organization: | Czebiniak & Ketchum Associates |
| Commenter: | Phyllis Ketchum |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 11, 2006 I am writing to express strong opposition to the proposed Business Opportunity Rule R511993. I understand that the Federal Trade Commision must protect the public from "unfair and deceptive acts or practices," but the rule as proposed would mke it ver difficult for me to operate my business as a Shaklee Independent Distributor. A confusing and burdensome section of the proposed rule is the seven-day waiting period to enroll new distributors. Most of the people who sign a Shaklee application are consumers of the products. If they later wish to build a business, all they must do in supply Shaklee Corporation with their Social Security Number or Tax Identification 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. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. In this day of identity theft, I am uncomfortable giving out the personal information of other Shaklee distributors, without their knowledge or consent. This requirement would dissuade new people from signing up as distributors as they are concerned not only about identity theft, but also about their privacy. Also providing a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for such other opportunity. We have been Shaklee Distributors for more than 38 years. Originally, I became a Shaklee Distributor because I love the Company's nutritional/personal care/household products and wanted to earn some additional income working from home. Now our families depend upon this extra income for our livelihood. Thanks for considering my comments. Phyllis Ketchum