|Received:||7/17/2006 11:36:47 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:There are a number of aspects of the Rule as proposed that could have a negative impact on recruiting by placing an undue burden on the Company, myself and my downlines. A significant burden in the proposed Rule is the potential requirement that each prospective distributor be given a disclosure document in the form prescribed by the FTC, containing, among other information: The name, city, state, and telephone number of at least the 10 purchasers within the past three years who are located nearest to the prospective purchaser's location; The total number of purchasers of the opportunity during the past two years; All legal actions during the past 10 years alleging fraud, misrepresentation, securities law violations, or unfair or deceptive practices against the Company, any of its officers, directors or any employees involved in sales of the opportunity, regardless of whether the Co. or the officers, directors or employees were found not guilty or not liable. The biggest obstacle is probably that, under the proposed Rule, the disclosure document must be presented to the potential recruit at least seven calendar days before the recruit may sign an application or make a payment. A separate disclosure document is required if ANY earnings claim is made. Each application, disclosure statement, disclosure receipt and oral or written request for cancellation would have to be maintained by you for three years. It is clear that these requirements, if enacted, would place a serious and undue burden upon Shaklee Distributors, and would unnecessarily complicate the process of sponsoring. I believe this Rule, if enacted, could have a negative impact on my business as well as all direct selling businesses.