| Comment Number: | 522418-08770 |
| Received: | 7/13/2006 12:55:28 PM |
| Organization: | lia sophia |
| Commenter: | Mary Van Abel |
| State: | WI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Mary Van Abel July 13, 2006 Division Manager, lia sophia To Whom It May Concern: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a lia sophia advisor/manager. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” yet some of the sections in the proposed rule will make it very difficult, if not impossible, for me to sell lia sophia products. I have been a lia sophia advisor/manager for almost 2 years. Originally, I became an advisor in my company because I felt the products were exceptional and I wanted to earn some additional income. I was a stay at home mom for 6 years who gave up a second income to raise my children! Financially, it was a struggle and bills began to pile up. I needed to do something without giving up the flexibility to be there for my children. The lia sophia opportunity gave me both. The business opportunity was presented to me very clearly and precisely. There were no catches or gimmicks and all of what they told me has worked. I remember my very first pay check; $83.78! That was very exciting to me and it has only gotten better since. Now I actually feel as though I contribute to my family both financially, as well as being home with my children and being able to cover all of their needs. I then began to present the opportunity in the same way I had been presented the opportunity because it made such a huge difference in my life. Today, my organization has around 120 women who are experiencing the same freedom, flexibility and income. We have a business plan that works. Women love to share things. Showing someone how to become a successful business owner is not a crime, it is a life changing opportunity! And that what lia sophia does for women-it changes them in more ways than just financially. It has changed so much of me personally and the opportunity to share this and make other women feel more confident, worthy, and successful is something I want to do for the rest of my life!!! One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new lia sophia advisors. Lia sophia’s kit only costs $149.00. People buy TVs, cars, and other items that cost much more and they do not have to wait seven days. This waiting period gives the impression that there might be something wrong with the company or the compensation plan. The initial investment to start your own company with lia sophia is minimal compared to franchising or opening a small business! Where can you start up your own company for $149 and expect to make a 6 figure income in THREE years! Also, when I first speak to someone about lia sophia, I will then need to send in many reports and unnecessary paper work to my company headquarters. 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. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless lia sophia is found guilty. Otherwise, lia sophia and I are put at an unfair advantage even though lia sophia has done nothing wrong. Do other professionals have to do this…I have never seen anything like this from my doctor and I know he was sued and his job could actually hurt or kill someone. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to lia sophia headquarters and then wait for the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson - “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met, as would you and I. I appreciate the work that the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences and there are less burdensome alternatives available to achieving your goals. Thank you for your time in considering my comments. Respectfully, Mary Van Abel, Division Manager