| Comment Number: | 522418-11470 |
| Received: | 7/17/2006 12:10:02 PM |
| Organization: | |
| Commenter: | Benjamin Brown |
| 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 concerning the proposed Business Opportunity Rule >R511993. I believe that in its current form, it could make it extremely >difficult for me to continue operating as an AdvoCare Independent Member. I >understand that part of the FTC's responsibilities is to protect the public >from unfair and deceptive business practices, but some of the sections in >the proposed rule will make it very difficult, if not impossible, for me to >successfully share products and the business opportunity. > >AdvoCare International, a direct sales company based in Carrollton, Texas, >offers high-quality nutritional products. I became a Member of AdvoCare >because I like the products and wanted to earn some additional income. >There are more than 100,000 AdvoCare Members across the United States that >this new rule, if implemented, would burden. > >I would like to share several key concerns. First, I am against the >seven-day waiting period to enroll new Members. An unrealistic delay would >cause uncertainty and become extremely burdensome. AdvoCare's sales kit >costs only $50. Consumers may purchase products that cost more than a kit >and they do not have to wait the seven days. This waiting period also may >imply that there is something inherently wrong with the business plan. I >also think that it is unnecessary because AdvoCare already has a buyback >policy for all products and the sales kit purchased by the Member within >the last 12 months. Under the proposed waiting period, I will also need to >keep very detailed records when I first speak to someone about AdvoCare and >will then 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. > >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 the personal information of individuals to >strangers. People are very concerned about identity theft and will be >reluctant to share their personal information with people they may have >never met. > >Finally, 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. > >My family depends on this income, and the proposed rule may greatly hamper >my ability to contribute to my family's well-being. I appreciate the work >of the FTC to protect consumers, but I believe there are less burdensome >alternatives available in reaching its goals. > > > >Thank you for your time in considering my comments. > >Sincerely, > > > >Benjamin A Brown II > >