| Comment Number: | 522418-09720 |
| Received: | 7/15/2006 12:35:21 AM |
| Organization: | Balanced Life Enterprise (Independent Shaklee Distributors) |
| Commenter: | John DeLong |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, R511993 I am writting to express STRONG OPPOSITION to the proposed Business Opportunity Rule R511993. I Understand that the Federal Trade Commission must protect the public from "unfair and deceptive acts or practices,"but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. The 7 day waiting period to enroll new distributors is confusing and BURDENSOME. Most of the people who sign a Shaklee application are consumers of the products. IF THEY LATER WISH TO BUILD A BUSINESS, ALL THEY MUST DO IS SUPPLY SHAKLEE CORPORATION WITH THEIR SOCIAL SECURITY # OR TIN#. NO ADDITIONAL KIT, FEE OR APPLICATION IS NECESSARY. The Shaklee Member Kit costs only $19.95. This is far less than most spend on purchases of household appliances, internet access etc. ALL of which require NO WAITING period! Shaklee Corp has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last 2 years. The proposed rule requires the disclosure of 10 prior purchasers nearest to th prosapective buyer .With the abundance of Idenity Theft, I would feel very uneasy about giving out personal information of other Shaklee Distributors, without their knowledge or consent. As I undertand it, after the new rule took effect the new application would have to include on it the statement "If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers". Seems like this would keep many people who need the health building benefits of Shaklee products ( and sign up mostly to be able to get their products at a discount) to do so for fear of idenity theft or FEAR OF STRANGERS CALLING THEM. The 10 reference requirement is an administrative burden. To obtain the list of 10 purchasers, I will need to provide Shaklee Corp with the prospective dictributor's address, and wait to receive the list of the 10 nearset distributors who became distributors within the past 3 yrs. Each prospective recuit will need a customized disclosure statement. This will result in a delay far longer than 7 calendar days before anyone can sign an application. Many people enter direct selling to earn extra income for a specific goal, such as a special purchase for birthday gifts and holidays, or a family vacation. The wait which the new rule proposes may make that goal unattainable. I have been a Shaklee Distributor for more than 22 years. For most of those years I just got the products for our family, lots of relatives and friends. THEN WHEN I HAD AN ACCIDENT AND WAS UNABLE TO WORK AT MY REGULAR JOB I DECIDED TO FOCUS ON THE EARNING OPPORTUNITY. THAT HAS ALLOWED MY FAMILY TO CONTINUE PAYING OUR BILLS. I AM SO THANKFUL!! My injuries where such that I'll most likely never be able to return to my work as a truck driver . I will need to depend on my Shaklee earnings. Will you please consider my situation and how R511993 may hamper my ability to earn a livelihood. Sincerely, John DeLong