| Comment Number: | 522418-10296 |
| Received: | 7/16/2006 2:22:07 AM |
| Organization: | Weekenders U.S.A and Liasophia Jewelry |
| Commenter: | Janice Paulsen |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 15, 2006 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its present form, it could prevent me from continuing as a Weekenders fashion consultant and a Liasophia Jewelry advisor. I understand that part of the FTC's responsibilities is to protect the public from unfair and deceptive acts and practices. Weekenders and liasophia have always been very fair and honest in dealing with their advisors and the consumers; and yet, some of the sections in the proposed rule will make it very difficult for me to continue to sell my products. I have been a fashion coordinator with Weekenders USA for over 3 years, and just recently also started selling jewelry as a Liasophia advisor. Both companies have exceptional products and I am proud to be a representative for both. I am an elementary school teacher so my main income does not come from direct sales; however, I'm sure you're aware that teachers are not paid what they should be for the job they have and their years of education. Therefore, my direct selling career helps make ends meet and it is something I would like to continue doing when I retire. You might say that my family's financial future is dependent on the stabiity of the direct selling industry. One of the most confusing and burdensome sections of the proposed rule is the 7 day waiting period to enroll new consultants. Liasophia'a starter sales kits only cost $99, and Weekender's slightly more, and they are getting jewelry and clothes that are worth a great deal more than that for their investment. Even if they decided a month after joining that they didn't really want to be in sales after all, they would have made a good investment (they would have $500 worth of jewelry and a $1,000 worth of clothes for a fraction of the cost). Every day people spend thousands of dollars buying cars, TVs, etc. (that they probably can't afford, and won't make any money off of) and they don't have to wait 7 days! This waiting period gives the impression that their might be something wrong with the company or the compensation plan--there's not! Also, most direct selling companies already have a 90% buyback policy for all products, including sales kits, purchased by a salesperson within the last 12 months. Finally, the proposed rule requires the disclosure of a minimum of 10 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 private information to strangers. In order to get the list of the 10 prior purchasers, I will need to send the address of the prospective purchaser to Weekenders or Liasophia headquarters and the wait for the list. Then prospective salespersons may say to themselves, "If I buy into this business opportunity, my contact information will be disclosed in the future to other prospective buyers." People are very concerned about their privacy and identity theft. They may be reluctant to share their personal information with individuals they have never met, and therefore turn down an opportunity to get into a great business that could greatly improve their way of living. In conclusion, I appreciate the work that the FTC does to protect consumers; however, I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available to achieving your goals. Please be fair to the hundreds of thousands of people who are involved in direct sales, and are also consumers. Thank you for taking the time to read this letter and consider my comments. Respectfully, Janice Paulsen