Case #220-2025: Monitoring Inquiry – Thrive Life, LLC

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #220-2025: Monitoring Inquiry – Thrive Life, LLC
 

 

Company Description 

Thrive Life, LLC (“Thrive Life” or the “Company”) is a direct selling company founded in 2004 and based in American Fork, Utah. The Company manufactures and markets freeze-dried and rehydrated foods, offering a range of products including fruits, vegetables, meats, grains, dairy, snacks, and complete meal kits.

 

Basis of Inquiry

The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.

This inquiry concerned earnings claims disseminated by Company salesforce members on Facebook, Instagram, and on the Company website. DSSRC was concerned that the earning claims that were the subject of this inquiry communicated the message that the typical Thrive Life salesforce member can earn significant income through the Company’s business opportunity. The representative claims that formed the basis for DSSRC’s inquiry are set forth below.

 

Earnings Claims 

  1. “financial freedom” (October 2023)
  2. "Are you tired of the 9-5 grind and being too exhausted for anything at the end of the day❓ Are you looking for financial independence & future residual income that you can pass to your children❓” (March 2023)
  3. “You can simply get the best perks and be your own customer, share to help cover extra household expenses, or grow a serious income”
  4. “I’m in Cancun right now, this is actually the sixth trip that I’ve earned”  (August 2023)

 

Company’s Position

After receiving the DSSRC Notice of Inquiry, the Company took immediate action to address DSSRC's concerns, emphasizing its commitment to ensuring that its salesforce operates in a compliant environment while communicating truthful and accurate product and earnings claims. As a first step, the Company clarified to DSSRC that four of the claims in question were distributed by a different direct selling company with a similar name.1

The Company did not attempt to substantiate the earnings claims in the social media posts that were identified in the inquiry. Rather, the Company indicated to DSSRC that it would take the necessary action to remove the non-compliant posts.

Thrive Life notified DSSRC that it had taken steps to remove the Facebook post referencing 'financial freedom' and had instructed the salesforce member responsible for the “financial independence” claim to either remove or revise the post.

Additionally, the Company advised DSSRC that the claim on its website regarding the potential for salesforce members to earn “serious income” is being removed, and that the YouTube video featuring a salesforce member in Cancun, claiming “this is the sixth trip I’ve earned,'” will be appropriately modified.

 

Analysis

Thrive Life did not attempt to support the four claims with substantive data but, instead, elected to use its best efforts to remove the posts in their entirety or modify the messages that were communicated to the public. DSSRC determined that the Company’s actions were necessary and appropriate.

Thrive Life was successful in removing the first post which referenced “financial freedom.”

DSSRC determined that the second post at issue (“Are you tired of the 9-5 grind and being too exhausted for anything at the end of the day❓Are you looking for financial independence…”) could be reasonably interpreted as meaning that the typical Thrive Life salesforce member could generally expect to receive financial stability from the Company’s business opportunity. During the pendency of the self-regulatory inquiry, Thrive Life indicated that it had reached out to the independent consultant responsible for disseminating the earnings claim and asked her to change the post or remove it entirely. However, the post remains publicly accessible in its original context and there was no confirmation provided by Thrive Life to DSSRC indicating that the salesforce member would adhere to the Company’s request to reconcile the post.

It is a fundamental principle of advertising law that an advertiser has the burden to support any reasonable interpretations of its claims.2 Accordingly, DSSRC remained concerned that the term “financial independence” could be reasonably understood synonymously with the term “financial freedom” and noted that a claim promising financial independence from participating in a direct selling business opportunity carries a particularly high risk of being misunderstood by consumers when communicated in a general context.

In addition, DSSRC determined that the language in the post stating “Are you tired of the 9-5 grind and being too exhausted for anything at the end of the day,” could be interpreted by a prospective salesforce member as meaning that the typical Thrive Life salesforce member earns enough money from the Company’s business opportunity to replace income earned at a 9-5 job.

Although Thrive Life did confirm to DSSRC that it attempted to contact the salesforce member responsible for disseminating the post and request that it be removed, in light of the fact that the salesforce member has not been responsive to the Company’s request to disable the post, DSSRC recommended that Thrive Life attempt to contact Facebook to inform them of the unauthorized income-related post and request that it be removed and provide DSSRC with a copy of the correspondence to the social media platform. In addition, if the salesforce member is currently active with the Company and continues to be unresponsive to Thrive Life’s requests to remove the post, DSSRC recommends that Thrive Live initiate enforcement proceedings pursuant to its Policies & Procedures and suspend or terminate the account of the individual.

The claim that Thrive Life salesforce members can generally expect to receive “serious income” from the Company’s business opportunity was presented in the form of a testimonial on the Thrive Life website. Although the Company committed to having the claim taken down, the claim currently remains accessible on the Thrive Life website. Viewed in its full context—“…help cover extra household expenses, or grow a serious income”—DSSRC concluded that readers could reasonably interpret the statement to mean that a typical Thrive Life salesforce member can earn substantial money through the Company’s business opportunity. Because the Company did not provide data demonstrating that the typical Thrive Life participant receives “serious income” from the business opportunity, DSSRC determined that the claim was inappropriate. Moreover, DSSRC emphasized that the claim’s presentation as a testimonial does not affect how it is interpreted or its regulatory implications.

According to section 255.2 of the FTC’s Guide Concerning the Use of Endorsements and Testimonials in Advertising (the “FTC Testimonial Guides”)“An advertisement containing an endorsement relating the experience of one or more consumers on a central or key attribute of the product or service also will likely be interpreted as representing that the endorser’s experience is representative of what consumers will generally achieve with the advertised product or service in actual, albeit variable, conditions of use. Therefore, an advertiser should possess and rely upon adequate substantiation for this representation.  If the advertiser does not have substantiation that the endorser’s experience is representative of what consumers will generally achieve, the advertisement should clearly and conspicuously disclose the generally expected performance in the depicted circumstances, and the advertiser must possess and rely on adequate substantiation for that representation.”

DSSRC also identified a section of the webpage claiming that “Earning Made Easy - From nutrition and convenience to financial and time freedom, Thrive Life is the answer!”). As DSSRC noted previously in the Analysis section of this report, any unqualified reference to “financial freedom,” particularly if it is associated with “easy” earnings, will be closely scrutinized by regulators as it may be reasonably interpreted as conveying the unsupported message that life-changing financial results are typically received by participants in the Company’s business opportunity.

Accordingly, DSSRC recommended that Thrive Life take immediate action to remove claims from the Company website referring to salesforce members receiving “serious income” and “financial freedom.”

Lastly, regarding the YouTube video that highlights Company rewards and incentives (i.e., “I’m in Cancun right now, this is actually the sixth trip that I’ve earned”), DSSRC has previously recommended that when a social media post promotes incentives received by a company salesforce member, the post should include a clear and prominent disclosure, placed near the claim, indicating what percentage of the Company’s salesforce has actually received such rewards.3

Thrive Life indicated that it was in the process of addressing the appropriateness of the incentive claim in the video, however, the only current disclosure in the video states “This is my own personal experience with Thrive Life. My results are not typical. While this type of success is possible, there is no promise, of income or guarantee that you will achieve the same results.” DSSRC determined that this disclosure does not adequately convey how frequently such incentives are earned by an average member of Thrive Life’s salesforce and as such, recommended that the 14-minute video, which makes ongoing reference to Company incentives, be either completely removed or modified to include repeated, clear and conspicuous disclosures highlighting the number or percentage of Company salesforce members that have earned incentive trips.

 

Conclusion

DSSRC confirmed that Thrive Life removed one of the four social media posts that were at issue in the inquiry. DSSRC recommended that Thrive Life remove claims from the Company website referring to salesforce members receiving “serious income” and “financial freedom.” DSSRC also concluded that references to salesforce members receiving “financial independence” from the Thrive Life business opportunity be similarly removed, as should comparisons of income received from a 9-5 job. Lastly, DSSRC recommended removing the YouTube video in its entirety or adding clear, repeated disclosures showing how many salesforce members earned incentive trips.

 

Company Statement

“Thrive Life is fully committed to truthfulness and transparency when promoting our business opportunity. We have a great reputation with consumers and industry peers and it's something we endeavor to protect. We agree to comply with the recommendations made by DSSRC and will continue to identify and act on opportunities to provide further compliance training and tools to our sales force to assist them in communicating truthful and accurate information to the public.”

 

(Case #220, closed on 6/11/25) 
© 2025 BBB National Programs

 

 

[1] Claims that were not associated with Thrive Life have been excluded from the Basis of Inquiry. DSSRC will pursue those claims made in separate inquiry directed at the company whose salesforce members are responsible for disseminating those posts.

[2] See 1984 FTC Policy Statement Regarding Advertising Substantiation - https://www.ftc.gov/legal-library/browse/ftc-policy-statement-regarding-advertising-substantiation Appended to Thompson Medical Co., 104 F.T.C. 648, 839 (1984), aff’d, 791 F.2d 189 (D.C. Cir. 1986), cert. denied, 479 U.S. 1086 (1987). 

[3] See SeneGence International, DSSRC Case #207-2025 and MONAT Global Corp, DSSRC Case #171-2024.