| Comment Number: | 522418-11734 |
| Received: | 7/17/2006 2:57:11 PM |
| Organization: | Total Wellness |
| Commenter: | Theresa Sakas |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Theresa Sakas Total Wellness July 17, 2006 Re: Business Opportunity Rule, R511993 Dear Sir or Madam, I am writing to express my stong opposition to the proposed Business Opportunity Rule R511993. I understand that the Federal Trade Commission must protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for me to operate my business as a Shaklee Independent Distributor. I have been a Shaklee Distributor for more than 12 years. Originally, I became a Shaklee Distributor because I loved the Company's nutritional/personal care/household products and wanted to earn some additional income working from home. Now, as a single mom, this income has become my livelihood. It has allowed me to be at home, while raising my daughter! And I depend on it. A confusing and burdensome section of the proposed rule is the seven-day wating period to enroll new distributors. Most of the people who sign a Shaklee application are consumers of the products. If they later wish to build a business, all they must do is supply Shaklee Corporation with the Social Security number or Tax Identification Number. No additional kit, fee or application is required. The Shaklee Member kit costs only $19.95. This is far less than most consumer purchases, from Tv's to household appliances, none of which require a waiting period. The wait period is also unnecessary in that Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. In this day of identity theft, I am uncomfortable givng out the personal information of other Shaklee distributors, without their knowledge or consent. Providing the 10 references also could damage the businesses of Shaklee distributors. Lower ranking distributors often are involved in more than one direct selling company. Providing a list to a potential recruit, who may already be a distributor for a competing direct selling company, may be an invitation to solicit existing distributors for another opportunity. The 10 reference requirement is an administrative burden. To obtain the list of 10 prior purchasers, I will need to provide Shaklee Corporation with the prospective distributor's address, and wait to receive the list of the 10 nearest distributors who became distributors within the past three years. Each prospective recruit will need a customized disclosure statement. This will result in a delay far longer than seven calendar days. I work with many people who enter direct selling to earn extra income for a specific goal, holiday purchases or family vacations. This wait may make the goal unattainable for many people! Thank you for considering my comments. Sincerely, Theresa Sakas