| Comment Number: | 522418-08869 |
| Received: | 7/13/2006 4:05:42 PM |
| Organization: | Arbonne International |
| Commenter: | Alonna Smith |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its current form, it could prevent me from continuing as an Arbonne Independent Consultant. I understand that part of the FTC’s responsibility is to protect the public from “unfair and deceptive acts or practices,” but some areas of the proposed rule will make it very difficult, if not impossible, for me to sell Arbonne products and sponsor people into the business. The most onerous section of this proposed rule is the 7-day waiting period to sign up new Consultants. Arbonne Starter Kits cost a small amount of money, and the proposed waiting period gives the impression that there might be something wrong the Arbonne opportunity. With this waiting period requirement, it would be extremely time consuming to keep very detailed records about when I first speak to someone about Arbonne and keep track of when to follow up. One of the key elements to my success in this business has been capturing the enthusiasm and immediate results prospects experience with Arbonne products; the waiting period would potentially limit my ability to grow my business. I am also concerned about this rule because it calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices, regardless of whether the company was found innocent. It seems unfair to disclose lawsuit information untless Arbonne has been found guilty of something. It feels like we are being penalized by the impression a lawsuit would leave, even if I have done nothing wrong. Lastly, this proposed rules require that I disclose a minimum of 10 Independent Consultants nearest to the prospective Consultant. I think providing references is actually a great idea except for the fear of identity theft, which is a huge problem today. I am very uncomfortable about giving out personal information to strangers about individuals without their knowledge. In addition, sharing this information could damage the business relationship of references with those involved in other companies or businesses, or provide an unfair advantage to competitors. In order to get the proposed list of 10 prior Independent Consultants, I would need to send the address of a prospect to the Arbonne corporate office in California and then wait for the list. The proposed rule also includes the language, “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers” and prospects will be understandably concerned about their privacy. I would find it an invasion of privacy to disclose personal data, for my business purposes. I have been an Arbonne Independent Consultant for more than 3 years. I became a Consultant because I love the products and I needed to find something that could eventually provide me with a full-time income. Since starting my Arbonne business, I have developed a team of 65 Independent Consultants across the country and as a team, we are helping our families enjoy better lives. I think it is great that the FTC is concerned about protecting consumers, but I believe this proposed new rule would have many detrimental (and unintentional) consequences and I hope there are other ways to resolve these, without putting my income at risk, as well as the income of millions of other successful network marketers. Thank you for your time and understanding. Sincerely, Alonna Smith