| Comment Number: | 522418-09141 |
| Received: | 7/13/2006 11:48:47 PM |
| Organization: | AdvoCare |
| Commenter: | Lynn Willing |
| State: | KY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing this letter concerning the proposed Business Opportunity Rule R511993. I believe that in its current form, it could make it extremely difficult for me to continue operating as an AdvoCare Independent Member. I understand that part of the FTC’s responsibilities is to protect the public from unfair and deceptive business practices, but some of the sections in the proposed rule will make it very difficult, if not impossible, for me to successfully share products and the business opportunity. AdvoCare International, a direct sales company based in Carrollton, Texas, offers high-quality nutritional products. I became a Member of AdvoCare because I like the products and wanted to earn some additional income. There are more than 100,000 AdvoCare Members across the United States that this new rule, if implemented, would burden. I would like to share several key concerns. First, I am against the seven-day waiting period to enroll new Members because an unrealistic delay would cause uncertainty and is totally unnecessary considering AdvoCare already has a buyback policy for all products and the sales kit purchased by the Member within the last 12 months. This sales kit costs only $50. This waiting period implies there is something inherently wrong with the business plan and that there is some kind of pressure being placed on the buyer - completely not so! It is simple and fast to receive a refund if someone changes their mind. Under the proposed waiting period, I will also need to keep very detailed records when I first speak to someone about AdvoCare and will then have to send in many reports to the AdvoCare Home Office. Those requirements would create an impractical and undue burden on my time as an independent Member. The proposed requirement that I provide personal information of previous purchasers in a new members' geographical area is shocking. It would create an unneccesary burden on me as an independent distributor building a business, would bring up confidentiality issues and cause undue delays in enrolling prospective product purchasers or Members -For example, in order to get a list of 10 prior purchasers, I would need to send the address of the prospective buyer to the AdvoCare Home Office and then wait for the list. The momentum to make the purchase may be lost. I also think the proposed rule will prevent many people from wanting to sign up as a Member. My family depends on this income, and the proposed rule may greatly hamper my ability to contribute to my family’s well-being. I appreciate the work of the FTC to protect consumers, but I believe there are less burdensome alternatives available in reaching its goals. Thank you for your time in considering my comments. Sincerely, Lynn Willing