| Comment Number: | 522418-13223 |
| Received: | 9/6/2006 3:29:49 PM |
| Organization: | Arbonne International |
| Commenter: | Becki Shah |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Regarding proposed Business Opportunity Rule R511993: Dear Sir or Madam, I am writing a rebuttal to comment 522418-04905. In that comment, the commentor stated that the 45 day return policy and 3 day termination policy gives people adequate time to change their mind if they decide not to sign up for this business. I disagree wholeheartedly. I signed up for Arbonne 4 months ago under a good friend, and I believed what I was told about the company by my good friend and our upline. I looked over the policies and procedures, but because I believed everything I was being told, and because I knew nothing about MLM to begin with, I had no doubt that this would work quickly and that the $4,000 I invested in products over the next couple of months was well worth it. I was told that the quickest way to succeed was to invest in 6-12 kits upfront and "give" them to potential business builders during an initial meeting, then if they liked them they could just pay me later. I did not know that this is called "frontloading" and is illegal. I also stocked up on brochures, catalogs, samples, etc., so that I could run my business right. I was also told that "stacking" my downline was the quickest way to succeed, but I later found out that this is also illegal, just like product frontloading. In addition, I found out some very serious information about the dangers of the technology the company uses in the majority of their skin care products, which are labeled as "Pure, Safe and Beneficial". Needless to say I am having to go back and refund all of my friends and family who I signed up or sold these products to because of what I've found out about the business practices AND the products, but I cannot get a refund myself because the majority of what I bought when I started my company is over 45 days old! I believe that it takes much longer to find out the REAL truth about a company than just 3, or even 45 days. People need to receive a disclosure UP FRONT stating ALL of the facts about a company, and about MLM and what is legal and what is not, BEFORE they sign up, otherwise they are being "sold" by a person who is usually a good friend or even family, and they believe what they are being told about the good ethics of the company, etc. Unless someone chooses to do alot of research on the company policies and products themselves during the first 3 days, most likely they will believe what they are told and pass this information on to others they sign up as truth, that is why the REAL truth must be presented to everyone up front so that they will have a chance to make an informed decision based on the facts, not the fantasy that is presented to them by the company consultant (usually a good friend whom they trust). Thank you. Sincerely, Becki Shah