| Comment Number: | 522418-10075 |
| Received: | 7/15/2006 5:16:25 PM |
| Organization: | Cookie Lee Jewelry |
| Commenter: | Sharda Kratcha |
| State: | CO |
| 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. I believe in its present form, it could prevent me from continuing as a Cookie Lee consultant. I understand that the FTC's responsibility is to protect the public from "unfair & deceptive acts or practices," but some of the sections of the proposed rule will make it very difficult if not impossible for me to sell Cookie Lee jewelry products. One of the most confusing& burdensome sections of the proposed rule is the seven day waiting period to enroll new consultants. Our initial start-up costs are between $300 & $600 & that is a very reasonable amount to start ones own business. People purchase TV's, cars & more that cost far more than that & they don't have to wait 7 days. The proposed waiting period gives the impression that there might be something wrong with the plan. This would impact my record keeping process as well & would also cause people to wait unneccessarily to get started in their new business. The proposed rule also calls for the release of any information regarding lawsuits involving misrepresentations or unfair or deceptive practices. 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 Cookie Lee was found guilty of something. Otherwise Cookie Lee & I are put at an unfair advantage even though neither of us has done anything wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest the prospective purchaser. If I am in a department store, I do not request the personal information on their last 10 customers that were in line or the last 10 people that are closet to the store who purchased. This could be detrimental to anyone involved in supplying this information considering the rampart identity theft that is taking place in our country today. No only that, but it would be interfering with my relationship to my customer & their privacy. It would be very uncomfortable for all concerned. I have been selling Cookie Lee Jewelry for almost 10 years. I love the product, quality & the business plan. It gave me the opportunity to improve my own self-esteem & grow. I am now retired & depending on the income for our retirement years, so it could cause financial hardships. I appreciate the work of the FTC to protect consumers, but feel that this proposal has unintended consequences. Thank you for your time in considering the above comments. Sharda Kratcha Director II, Cookie Lee Jewelry