| Comment Number: | 522418-08618 |
| Received: | 7/13/2006 2:21:34 AM |
| Organization: | Lia Sophia |
| Commenter: | Deloris Paschal |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing this letter because I am concerned about the proposed Business Opp Rule R51193. I believe that in its present form it could prevent me from continuing as a Lia Sophia advisor. I understand that part of the FTC's duties are to protect the public from unfair and deceptive acts or practices, yet some of the sections in the proposed rule will make it difficult if not impossible for me to sell Lia Sophia Jewelry. I am a part-time Lia Sophia advisor. I work a full time job and plan to retire in 7 years. The extra income I make with Lia Sophia jewerly will better prepare me for my retirement. On of the most confusing and burdensome section of the proposed rule is the 7 day waiting period to enroll new recruits. The Lia Sophia sales kit only cost $149.00. TV's, cars and other items cost much more and there is no waiting period. This waiting period gives the impression that there might be something wrong with the company or compensation plan. Plus it is unnecessary because Lia Sophia already has a 90% buyback policy for all products/sales kits purchased by a salesperson within the last 12 months. Under this waiting period I will need to keep very detailed records when I first speak to someone about Lia Sophia and will then need to send in many reports to my company HQ's. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation or unfair or deceptive practices. It does not matter if the company was found innocent. It does not make sense to me to disclose that a suit was filed against Lia Sophia unless found guilty. Also, the proposed rule requires the disclosure of a minimum of 10 prior purchases nearest to the prospective purchaser. In order to get the list I will need to send the address of the prospective purchaser to Lia Sophia HQ's and then wait for the list. I think this will prevent many people from wanting to sign up as a salesperson because their contact information can be disclosed in the future to other buyers. People are very concerned about privacy and identity theft. I appreciate the work that the FTC does to proctect the consumers, but I believe this proposed new rule has many unintended consequences and there are less burdensome alternatives to achieving your goals. Thank you for your time in considering my comments. Respectfully, Deloris Paschal