Comment Number: 522418-12370
Received: 7/17/2006 9:01:17 PM
Organization: Arbonne International
Commenter: Jennifer DeKok
State: MN
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am an Independent Consultant with Arbonne International, one of the fastest growing NWM companies in the industry. Part of the reason I joined Arbonne was because their ethics and integrity are so much greater than any company I've every worked for in the corporate world. The majority of people signing up with my company do so to purchase their products at a discount and not necessarily to create their own business. The required disclosure and earnings statements and the required list of all distributors who have cancelled their distributorship in the previous last two years may cause the sponsoring process to become cumbersome and difficult for people just looking to purchase products at wholesale. These requirements may create unnecessary alarm and concern about the legitimacy of the profession and my business opportunity to prospective distributors. The proposed seven day waiting period between receiving the disclosures and enrollment would likely cause a potential distributor to lose their enthusiasm for joining my company. The costs of complying with the requirements would increase expenses to the company which may be passed on through the selling price of goods or services we offer. In fact, the very nature of this ruling is evidence that the FTC does not truly understand that the vast majority of distributors conduct business ethically and honestly every day and that such a ruling threatens the livelihood of these individuals. Working for a NWM company is truly the American Dream. Where else can a person from any background, from a person with an 8th grade education to a person with a degree in brain sugery, start in the same place and work their way to the top of a company with only their own hard work and sweat equity? Our industry is the fastest growing industry in the nation and is the only industry that actually gets better when the economy is bad. Please do not penalize the people who have chosen to have a home based business, the essential entrepreneurs of America, by forcing all of these unnecessary requirements on them. Thank you for your consideration.