Case #204-2025: Administrative Closure - MAKE Wellness
BBB NATIONAL PROGRAMS
Direct Selling Self-Regulatory Council
Case #204-2025: Administrative Closure - MAKE Wellness
Company Description
MAKE Wellness (or the “Company”) is a direct selling company headquartered in St. George, Utah and founded in 2024. The Company primarily markets health and wellness products with a strong focus on dietary supplements and plant-based bioactive peptides.
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 of advertising in the direct selling marketplace and pertains to income claims disseminated by the Company and its salesforce members.
The representative claims disseminated on the Company website and on Facebook formed the basis of this inquiry and are set forth below:
Earnings Claims
- We’ve built a pathway for creating life-changing income and a legacy business through a custom-designed commission plan, tailored specifically for the modern affiliate. ..
Uncapped Earnings - The more you sell, the higher your commission—up to 40%!”
(Company website) - “Join MAKE Wellness today and embark on a journey of health, wealth, and unparalleled personal freedom.”
(Company website)
- “financial freedom #FinancialFreedom”
(Facebook November 2024)
- “become a founder of this wonderful company and earn bonus income for the rest of your life with this company.”
(Facebook November 2024)
- “Our new e-commerce team helped 386 people earn at least $500 last month!🎉
That’s:
✔️386 car payments covered
✔️Countless Target runs funded (you know we all need that)
✔️Real financial freedom for 386 individuals and their families
Let’s break it down—that’s a minimum $6,000 raise a year. 🤯Imagine what that could mean for your household: paying down debt, building savings, or saying “yes” to opportunities you’ve been dreaming about. #FinancialFreedom”
(Facebook November 2024) - “Your why may look drastically different from mine. It may be as simple as paying for childcare...or it could be much bigger, like being able to retire from your 9-5 and traveling while working.”
(Facebook November 2024)
- “I’m no longer setting ‘hopefully I can make enough for groceries’ goals. We are looking at car goals, house goals, travel goals and retirement goals!”
(Facebook)
Company’s Position
MAKE Wellness did not attempt to substantiate the claims identified in this inquiry but instead took action to have the claims modified or removed. As a result of its actions, the Company reported to DSSRC that all of the subject claims in the inquiry have been removed.
The Company informed DSSRC that it was launched in November of 2025, and although still in a “start-up” mode, it is quickly building out its capabilities and processes. MAKE Wellness stated that it has built in policies and new processes that will ensure it complies with the best practices of the industry for a healthy and sustainable business.
To address the concerns raised, the Company reviewed the identified claims and took prompt and corrective actions. This included updating content and reaching out directly to Affiliates. Affiliates received training, education, and additional guidance to reinforce MAKE Wellness’ Policies and Procedures and adherence to its marketing guidelines.
Additionally, the Company continues to audit its corporate websites, education and training materials, marketing materials, and product information to ensure they all align with both DSSRC guidance and Federal Trade Commission (FTC) guidelines.
MAKE Wellness stated that it is in the process of building out a team, including cross-functional organizational support to monitor compliance. Company executives supervise a team that utilizes a combination of manual and automated monitoring through an independent, third-party monitoring service to review social media posts, websites, and promotional materials, and partners with the sales and marketing teams to educate, train, and advise salesforce members on key policies and issues. Affiliates are also encouraged to self-report any income claim concerns or misleading claims they come across and have access to MAKE Wellness teams through social media and the Company website as well as its customer and affiliate support teams.
MAKE Wellness explained that first-time violations receive a written warning and a request for updating content and/or removal with follow up until the issue is resolved. Repeat offenders or those who fail to comply are subject to account suspension, penalties, fines, and additional disciplinary action, up to and including termination, as outlined in the Company’s Policies and Procedures.
MAKE Wellness noted that it is in the process of developing compliance assets and an onboarding training program for new Affiliates to be completed within their first 90 days. This training will focus on proper income and lifestyle claims supported by a combination of social media outreach and dedicated Affiliate training calls. MAKE Wellness compliance is working closely with its sales team to ensure a unified approach, equipping all new Affiliates with the knowledge and tools necessary to adhere to marketing guidelines, including both product and earnings claims.
The Company indicated to DSSRC that it is developing pre-approved marketing guidelines, such as “Do’s and Don’ts,” along with weekly “MAKE it Right” tips shared on MAKE Wellness’ social media channels. The Company stated that these resources are in full compliance with legal and direct selling standards and are designed to help both new and experienced Affiliates confidently and compliantly share information about MAKE Wellness products and income opportunities.
MAKE Wellness emphasized that it is deeply committed to maintaining the highest ethical standards in its business and marketing practices.
Administratively Closed Resolution
DSSRC appreciated the good faith efforts taken by MAKE Wellness to address and remove all of the claims identified by DSSRC in this inquiry. DSSRC determined that the Company’s actions were necessary and appropriate.
DSSRC determined that the claims in this inquiry communicated the message that a typical MAKE Wellness Affiliate earns significant income (i.e., “life changing income,” “$500 a month,” “financial freedom”) through the Company’s business opportunity.
The FTC Business Guidance for Multi-Level Marketing (“the FTC Guidance”), states that “any earnings claim should reflect what the typical person to whom the representation is directed is likely to achieve in income, profit, or appreciation.”1 The FTC Guidance notes that claims of significant earnings are atypical to what the average participant would earn.2 Thus, disseminating atypical earnings claims may create a deceptive impression about the business opportunity. In this regard, if a participant in an MLM or direct selling opportunity makes an income or earnings claim, they must have a reasonable basis for making it. This includes “reliable, empirical evidence demonstrating that the typical person in the group . . . is likely to realize . . . an amount equal to or greater than that conveyed by the earnings or lifestyle claim.”3
The DSSRC Guidance on Earnings Claims for the Direct Selling Industry (“the DSSRC Earnings Claim Guidance”) similarly cautions direct selling companies and their independent salesforce members against the use of language or images that communicate “earnings beyond what can be generally expected by the typical salesforce member in the depicted circumstances.”4 The DSSRC Earnings Claim Guidance further notes that “[s]ome words or phrases carry a particularly high risk of being misleading to consumers when communicated in a general context. Such words and phrases include but are not limited to “financial freedom…”.5
In the present inquiry, MAKE Wellness revised the two claims at issue on its website, took action to contact the salesforce members responsible for the earnings claims identified by DSSRC, and was successful in removing all five claims from social media.
Conclusion
Based upon MAKE Wellness’ good faith efforts to modify and remove the seven total claims identified by DSSRC in this inquiry, DSSRC administratively closed its inquiry.
Company Statement
“Make Wellness is a company built upon our reputation for utmost transparency and building a simple, consumer focused brand delivering high-quality products to our customers. To support our mission, we are fully committed to truth and transparency for all of our affiliates when sharing, promoting or describing our business opportunity. We continually seek for ways to assure that our reputation for honesty and transparency is protected in building a sustainable and healthy business model for all who choose to engage. We continue to invest in assuring all of our affiliates have access to the education and training needed to assure vigilance, and many enhancements, leveraging digital and online availability and enhanced marketing templates and tools are rolling out currently and will continue over the next few months.”
(Case No 204-2025, Closed on 3/20/25)
© 2025 BBB National Programs
[1] See Fed. Trade Comm’n, Business Guidance Concerning Multi-Level Marketing, Section 13 (April 2024) https://www.ftc.gov/business-guidance/resources/business-guidance-concerning-multi-level-marketing#deceptive.
[2] Id. at Section 13.
[3] Id.
[4] Direct Selling Self-Regulatory Council, Guidance on Earnings Claims for the Direct Selling Industry, General Principles (2022). dssrc_guidanceonearningsclaimsforthedirectsellingindustry.pdfGeneral principles
[5] Direct Selling Self-Regulatory Council, Guidance on Earnings Claims for the Direct Selling Industry, Section 6(A) (2022). dssrc_guidanceonearningsclaimsforthedirectsellingindustry.pdf