Comment Number: 522418-09818
Received: 7/15/2006 10:22:59 AM
Organization: GlycoIvy
Commenter: Jessica Bronson
State: FL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear Sir or Madam: I am writing this letter because I am extremely concerned about the proposed Business Opportunity Rule R511993. I strongly believe that this proposal will prevent me from continuing as a Mannatech Associate. I understand that the goal of this proposal is to protect the uneducated consumer from unfair practices but some of the sections in this proposal will make it practically impossible for me to continue helping people that are searching for a solution to their troubles. One of my biggest concerns is the proposed seven day waiting period to enroll new associates. Enrolling with Mannatech can start with as little as $100. People are able to buy cars, boats, and other much higher price items immediately. Even more troubling is that there is only a three day waiting period to buy a handgun. This proposed waiting period gives the impression that there is something sinister about these direct-selling programs. Also, there are many people who take Mannatech products to help with life-threatening illnesses. I do not see how ANYONE or any committee has the right to delay the availiblity of help to someone in such dire need. Mannatech also has a 100% moneyback guarantee, so if someone were unsatisfied they can get reimbursed. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices, regardless of whether the company was found innocent. Imagine if this rule applied to many other areas. What if doctors, lawyers, and large corporations were forced to disclose this type of information to their prospective clients? In today's society anyone and any company can (and are) sued for just about anything. Frivolous lawsuits run rampant in this country alone. This rule would cast my company in a negative light even though they have done nothing wrong. Finally, this proposal requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective buyer. I have no problem providing references from buyers who agree to share their experience, but I am wholeheartedly opposed to giving out personal information to total strangers. How would you feel if you wanted to join an opportunity and found out that your personal information would be disclosed to other buyers? In this day of identity theft, this part of the proposal is preposterous. How could we protect our buyers? It would be impossible. I have been a Mannatech Associate for over two years. In addition to the health benefits I have experienced and the extra income the business provides, I have been fortunate enough to make a real difference in the lives of people searching for solutions. I am one of over a million people who benefit from the great work this company does. I appreciate and understand the work of the FTC to protect consumers, however I strongly believe that this proposal will have the opposite effect and will do much more harm than good. There are other alternatives to achieve this goal without attaching such a negative connotation to all direct-selling companies. Yes, there are some unethical companies in our business. But that is true for any business. It is unfair to penalize the majority that are providing a great service because of the few who are doing harm. Thank you for your time and consideration of my comments. Sincerely, Jessica I. Bronson