| Comment Number: | 522418-09944 |
| Received: | 7/15/2006 2:05:38 PM |
| Organization: | LifeWave Distributor |
| Commenter: | Lynn Weitzel |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
7/15/2006 Re: Business Opportunity Rule R511993 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. While I understand the responsibilities of the FTC to protect the public from “unfair and deceptive acts or practices,” I believe that this proposed rule could prevent me from continuing as a distributor for LifeWave. There are specific sections in the proposed rule that will make it very difficult, if not impossible, for me to sell LifeWave's products. Like myself, the vast majority of LifeWave distributors promote the purchase of product rather than any business opportunity. I only recently became a distributor with LifeWave. I became involved with this company because I felt the products were exceptional and, as a retiree, so that I could earn additional income. My family and I enjoy the health benefits of using these products daily and are excited to be part of LifeWave. The future of my retirement is dependent on the stability of the direct selling industry. Seven-Day Waiting Period - One of the most confusing sections of the proposed rule is the seven-day waiting period to enroll new distributors. Having this waiting period gives the impression that there might be something wrong with the company or the compensation plan. Requiring a seven-day waiting period before a distributor is allowed to even place an order would be destructive to the businesses of thousands of distributors who are building a business around LifeWave's products. It would also be quite burdensome for me to keep detailed records of when I spoke with every single person about LifeWave, and it would create lots of unnecessary paperwork to have to send these reports to my company headquarters. Litigation Information - 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 or not. 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 LifeWave were found guilty. Do the pharmaceutical companies have to disclose every lawsuit brought against them before a prescription can be filled by the public? References - The proposed rule requires the disclosure of a minimum of ten prior purchasers nearest to the prospective purchaser. I am glad to provide references, but, in this day of identity theft, I am very uncomfortable giving out the personal information of individuals, particularly without their approval, to strangers. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses, including those of competitors. The proposed rule would be damaging to my business, my livelihood, and my family and friends ability to use LifeWave's excellent and helpful products. Sincerely, Lynn Weitzel