| Comment Number: | 522418-11235 |
| Received: | 7/17/2006 8:49:46 AM |
| Organization: | |
| Commenter: | Sally Gervin |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I believe that the Business Opportunity Rule, R511993 will make it impossible for me and others to purchase and promote the many high quality products available through the direct selling industry. I have been a distributor for Young Living for several years. I became involved with this company because of their superior products and their integrity in the direct selling industry. The Seven-Day Waiting Period is confusing and discouraging to new distributors. It implies that there might be something wrong with this company (or any company) that already offers a complete money-back satisfaction. To have to wait seven days before a new distributor can purchase products would be very discouraging for such a person. The record-keeping for these small business people would be excessive and burdensome. In today’s world of “let’s sue for whatever rubs me the wrong way” the release of litigation information that didn’t result in any guilty verdict for the company isn’t appropriate. The section on References would require me to give out personal information of individuals to strangers. Giving references is a natural and expected part of doing business, but it should be at our discretion. The sentence required by the proposed rule –“If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers”—would concern anyone who is aware of identity theft. Young Living simply does not sell “business opportunities” in this fashion. Supplying Cancellation lists to every potential distributor and wholesale customer would be an unrealistic burden. In companies such as Young Living there are tens of thousands of distributors and customers who come and go every year; it’s just a natural part of most any selling-type business. Please reinstate at least a $500 exemption. In 1979, the FTC wisely said: “When the required investment to purchase a business opportunity is comparatively small, prospective purchasers face a relatively small financial risk.” I believe this proposed new rule has many unintended consequences. Surely there are less burdensome alternatives to achieve your goals of protecting consumers. Thank you for taking my views into consideration.