Comment Number: 522418-09647
Received: 7/14/2006 9:44:08 PM
Organization: lia sophia jewelry
Commenter: Renee Swiggum
State: IL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. IThis proposal may very negatively impact me and other small business consultants from conntinuing 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 lia sophia jewelry. I began selling this jewelry about 2.5 yrs ago and have enjoyed the income it provides me. I am able to purchase a new vehicle and pay off some expenses because of the fun venture. One of the most confusing sections of the proposed rule is the seven-day waiting period to enroll new Advisors. lia sophia’s sales kit only costs $99.00. 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. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about lia sophia and will then need to send in many reports 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, the company and I are put at an unfair advantage even though the company has 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 I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Doesn’t this go against the Privacy Act? 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’s 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. Thank you for your time and considering my position. Please reconsider this Rule. When I became an Advisor, all of the above would have just been inconvenient and wouldn't have made a difference for me. Respectfully, Renee Swiggum lia sophia Advisor