|Received:||7/14/2006 10:02:04 AM|
|Organization:||Independent Stampin' Up! Demonstrator|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am concerned about the proposed Business Opportunity Rule R511993. If the proposed rule goes into effect, I will not be able to continue my business as a Stampin’ Up! (“SU”) Independent Demonstrator. I understand that the FTC is trying to protect us against frauds and schemes that exist, but this rule will make it impossible for me to continue doing what I love most, sharing my love of rubber stamping with others. I became a SU demonstrator to try to earn some extra money. I have been told since I started stamping in 1999 that I missed my calling, that I should do this for a living. I am a very shy person, and in becoming a demonstrator, it has taken me out of my comfort zone and is teaching me daily how to speak in front of others. I have learned so many valuable things and would be devastated if I would have to give this all up. I have also made many wonderful friends that I never would have met if it weren’t for SU. I don’t understand why it would be necessary for us to disclose information about lawsuits brought against Stampin’ Up! When I go to a Michaels or an A.C. Moore to purchase stamps or scrapbooking materials, I don’t first research to see how many lawsuits have been brought against these stores or stamp companies. I’m also concerned about the seven-day wait in order to sign up a new demonstrator. SU already has a buy back policy of up to one year should someone change their minds after signing up. It sounds like this seven day waiting period is insinuating that there is something wrong with Stampin’ Up! or their products and would definitely send a message to any new recruit that there is a problem with the company and they might not understand that this is just the “law.” Speaking as someone who has had my identity stolen, the proposed rule regarding giving out personal information for the nearest 10 demonstrators scares me to death. The thought of having to hand out personal information to total strangers, without their permission, is very discouraging. This could also lead to competitors stealing information for their own benefit. They could take this list and try to solicit for their own businesses. Would the law then protect the demonstrators from unwanted solicitations? I know that I would never join a company if I knew ahead of time that my personal information would be given out to total strangers at any given time. I would love the opportunity to turn this into my sole business and be able to work out of my home. But more importantly, this business is giving me the opportunity to build my confidence and realize that I am not worthless and that I may have something to say that others may find valuable. When I first considered joining SU, the low cost of the starter kit is what made it possible for me to join. I think that the law should still govern potential business with a start up cost of over $500, as it currently stands. I am thankful that the FTC is looking out for the consumers, but I think changing the law as it is currently proposed, would be absolutely detrimental to the U.S. economy. There are thousands upon thousands of home-based individuals in this country that would no longer be able to afford to stay in business. Stampin’ Up! alone has over 40,000 demonstrators and I’m sure companies like Avon, Tupperware, Mary Kay, QuixStar (the original Amway), Fuller Brush, etc. would also lose thousands of business owners. Many of us depend on the income from our businesses for food, rent or mortgages, college tuition, and most importantly these days – gas, etc. How many families would have to have moms go back to work to make ends meet? I truly hope that you will reconsider this proposed rule. I know there are bad seeds in every business, but to penalize the rest of us for the few would be detrimental.