| Comment Number: | 522418-08932 |
| Received: | 7/13/2006 5:33:27 PM |
| Organization: | lia sophia |
| Commenter: | Erin Degregorio |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Erin DeGregorio lia sophia Advisor 7/12/06 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 present form, it could prevent me from continuing as a lia sophia advisor. 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 my products and build my business. Let me tell you why I started this business. I have been a lia sophia advisor for 6 months now. Originally, I started my business because I felt the products were exceptional and I wanted to earn some additional income. However, shortly afterthart I left my full time job because in researching this business, I realized I could stay home with my 2 children and help other women do the same, while still making a great income. It is not about the money, (although that can be great too), I found purpose in both my parental opportunities as well as helping other women find their own purpose, whether it be additional in come, time with friends, or building a strong business for a low start up cost to replace their job income. I am working hard at building this so that I can support my family and help other women do the same. My goal is to help as many women achieve their dreams as possible! I am extremely concerned because the future of my business is dependent on the stability of the direct selling industry, which may be threatened by your rulings. The most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new advisors. Our sales kit only costs $99. People buy TVs, cars, and other items that cost much more and they do not have to wait seven days. In the case of automobiles, quick purchases have caused BURDENSOME debt for people who did not take the time to think. With only a $99 start up cost, telling people they have to wait 7 days would give the impression that there might be something wrong with the company, product or the compensation plan. I myself would not have joined had I had to wait 7 days as I would have been quite skeptical. I tripled my investment with the first show I did and if I HAD decided not to do it, I still would have been $200 richer. I am so thankful I didn’t have to wait seven days. I may have lost my enthusiasm by then or worse, just decided against this awesome opportunity because of a negative impression. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. What concerns me is 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. And in that case it would be only fair to disclose the information. Otherwise, lia sophia and I are both put at an unfair advantage even though we have done nothing wrong. 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. I do not even give out my own address to customers, just my phone, website and email address along with my advisor number until I know them better. I carry a large quantity of jewelry so giving out MY address could be extremely dangerous. 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. I recently was notified by a retail store that because I used a credit card there, my information may have been stolen. My husband’s identity and personal information may also have been jeopardized due to a government employee losing an unsecured laptop with military members private records. In this day and age most people will be reluctant to share their personal information with individuals they may have never met. I appreciate the work that the FTC does to protect consumers, yet I believe this proposed new rule has many unintended consequences. It appears some poor practices by some companies are being used to punish an entire industry. And these same concerns can be legitimate in many other industries not subject to the proposed direct sales ruling. Thank you for your time in considering my comments Respectfully, Erin DeGregorio