Comment Number: 522418-07771
Received: 7/11/2006 5:20:39 PM
Organization: Herbalife Int'l
Commenter: rene porcile
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
Attachment: 522418-07771.pdf Download Adobe Reader

Comments:

Rene & Ana Porcile  July 12, 06 To the Federal Trade Commission: I am writing to you to express my concerns with the FTC’s proposed business opportunity rule R5 11993. My wife Ana and I have been product users and distributors since 1993. We believe in Herbalife’s vision of providing the best quality and most effective nutritional products in the marketplace and in Herbalife’s business opportunity that educates people to greater financial freedom, if they want to do the work. For 13 years we have shared our results on the products and have help thousands of people improve health and finances. As a result of Herbalife’s training system and our own efforts we have learned a lot and grown a lot. We think that part of the FTC’s proposed rule will have us doing too much unnecessary paperwork or running around. For example: We would have to obtain a written disclosure statement from Herbalife. The statement would contain, among other things, the names and contact information for 10 prior purchasers who live closest to the prospective purchaser. We would have to send the disclosure statement (as signed by the prospect) to Herbalife, and we would have to keep a copy or record of having done so for at least three years. We would then have to wait seven days before our prospect would be allowed to sign the Distributor Application or make any payment related to the opportunity. In conclusion, as good servants to the community and as good entrepreneurs, we support FTC’s goal of preventing consumer fraud, but we think the agency needs to revisit parts of its proposal to take into account the significant burdens it would impose on legitimate, hard-working direct sellers, people like ourselves. Sincerely, Rene & Ana Porcile