| Comment Number: | 522418-09858 |
| Received: | 7/15/2006 11:52:10 AM |
| Organization: | Advocare |
| Commenter: | Kathleen Hunt |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I would like to share several key concerns regarding this ruling. First, I am against the 7-day waiting period to enroll new Members. An unrealist delay would cause uncertainty and become extremely burdensome. Adovare's sales kit costs only $50. Consumers may purchase products from a large retail chain that cost much more than a kit, and they do not have to wait seven days. This waiting period may also imply there is something inherently wrong with the business plan and possibly the products. Adovcare has a buy back policy for all products and the sales kits purchased by the Member within the last 12 months. In addition, under the proposed waiting period, I will also need to keep very detailed records when I first speak to someone about Advocare and will 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. If this is passed, I might as well stop introducing this superior product to others. I have a full time job, and I will not have the time needed under this plan to keep such detailed records ... again, does a retail chain have this type of burden? Second, the proposed rule requires the disclosure of individual salespeople or product purchasers geographically closest to the prospect. I am willing to provide references, but in this day and age of identity theft, I am very uncomfortable giving out person information of individuals to strangers. The disclosure practice would also 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. A retail facility such as Walmart or GNC does not have to provide this type of record keeping when selling nutritional products. My family depends on this income and the proposed rule may greatly hamper my ability to contribute to my family's well being. Although I appreciate the work of the FTC to protect consumers, I believe there are less budensome alternatives available in reaching its goals. Thank you for your time in considering my comments. Sincerely, Kathleen B. Hunt