Case #209-2025: Administrative Closure - PHP Agency, LLC

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #209-2025: Administrative Closure - PHP Agency, LLC

 

Company Description

PHP Agency, LLC (“PHP” or the “Company”) is a direct selling company founded in 2009 and headquartered in Addison, Texas. The Company specializes in training and resources for insurance agents. Additionally, through the PHP platform, insurance agents can be appointed to the Company’s insurance carrier partners to sell life insurance and annuity products.

 

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 of advertising in the direct selling marketplace and pertains to earnings claims disseminated by PHP and its salesforce members. The representative claims that were disseminated on Facebook, YouTube, and the Company’s website formed the basis of this inquiry and are set forth below:

 

Earnings Claims

  1. “Tired of feeling stuck in your current situation? Want to build a career that offers financial freedom, flexibility, and the chance to make a difference in people’s lives? 
  2. At PHP Agency, we’re more than just a business—we’re a movement. 
    Here’s what we offer: 
    Unlimited Growth Potential – Your success is in YOUR hands. 
    World-Class Training – No experience? No problem. We provide all the tools you need to succeed. 
    Flexible Schedule – Take charge of your time and design the life you want. 
    Impact Lives – Help families secure their financial futures while building your own legacy. 
    Whether you’re looking for a career change, side income, or a chance to build something meaningful, this is your opportunity to step up and make it happen! #FinancialFreedom” 
    (January 2025)
  3. “I JUST STARTED MY NEW BUSINESS FOR FINANCIAL FREEDOM!  I'm seeking friends who are committed to securing their financial freedom and eager to escape the rat race. If you're serious about transforming your life and building a brighter future for your family, I'd love to hear from you. #makingithappen2025” (January 2025) 
  4. [06:48] “. . . we came in our very first check we I literally made more than what I was bringing home in my 40-hour work week from helping one family. . . .”(October 2024)
    “Are you looking for a career that offers financial freedom, personal growth, and the chance to help others? PHP Agency is that place for you!
    Why Join PHP?
    - Extra Income: Boost your earnings with our competitive commission structure.
    - Financial Freedom: Build a secure and unlimited income.” (September 2024) 
  5. “Do you thrive on helping others achieve financial freedom and security?  
    Join us at PHP Agency, where we're dedicated to empowering individuals and families through our proven financial solutions. 
    Why PHP Agency? 
    Impact: Make a meaningful difference by educating and empowering others to take control of their financial futures. 
    Support: Access to world-class training and mentorship from industry leaders. 
    Flexibility: Work at your own pace, whether part-time or full-time, and enjoy unlimited earning potential. 
    Together, let's build a future where financial security is within reach for everyone. #financialfreedom” 
  6. “To realize this vision, PHP has partnered with some of the world’s leading insurance carriers to offer clients personally suitable life insurance and annuity products and; provide a part-time or full-time career opportunity to those wishing to pursue a career as life insurance agents.” 
  7. Video of PHP agents disclosing yearly and monthly earnings: 
    “450 Grand” made in the last 12 months 
    Typical monthly earnings during an agent’s second year “ A hundred and 4 thousand in a month” 
    Nurse who is working as a PHP agent: “earning 60,000 a year on a part time basis” 
    Video caption: “#php #phpagecy #financialfreedom #getlicensed #annuities #investinfamily #lifeinsurance #anualidades #moneymoneymoney #moneygetmade #gettingmymoney”
  8. “Let me Know How I Can Continue To Serve You. 
    #financialfreedom #wealth #wealthbuilding #retirement” (December 2024) 
  9. Video stating: “A space where they can really achieve not just financial freedom but generational wealth”  
    Caption: “#moneyworkforyou #generationalwealth #financialfreedom”
  10. “#FinancialFreedom” (November 2024) 
  11. “Unlimited Growth: Your success has no ceiling here. The harder you work, the further you go.
    Impact: Make a difference by helping families secure their futures while securing yours. 
    Financial Freedom: Turn ambition into action and action into wealth. 
    #FinancialFreedom”  (December 2024) 
  12. “Every day can be your weekend when you’re an entrepreneur. I was so blessed to spend time with the PHP fresno team at this spectacular mansion. We are teaching people how to make six figures in less than a year. #retirehappy #PartTimeIncome” (December 2024) 
  13. “Do you have the drive to achieve financial freedom” and  “#FinancialFreedom” (November 2024) 
  14. How To Create Wealth 2022 Video: 
    [7:50] “I can show in this episode how to create an asset, create a business on a part-time basis that will start to meet and exceed your full-time income if you choose the work of this industry with inside this platform. The value I want to share with you is how to create wealth for the rest of your life in four different steps 
    [18:57] “Right now since there is a huge demand and not enough supply, well guess what? This is opening up for you to build a business over the next year, five, ten, maybe in 20 years, for you to build something that’s an asset that down the road you can create generational wealth and pass on to the next generation.”  
    [41:40] “I have a lot of people in our business that have even made a six-figure income. One of our fastest guys right, fastest of six figures on a part-time basis, did it in 11 months” 
     

 

Company’s Position

PHP did not attempt to substantiate the claims identified in this inquiry but instead took action to have the claims removed. PHP reviewed and requested the removal of all the social media posts identified in this inquiry and modified the claims posted on the Company’s website. As a result of its actions, the Company reported to DSSRC that all of the subject claims in the inquiry have been removed or modified.

The Company noted that it added language to its New Associate Agreement that all new PHP members sign, clarifying the compliance requirements for posts on social media. Moreover, the PHP is in the process of issuing a Social Media Compliance Certification that will be mandatory for all PHP agents. This will further enforce compliance requirements for social media posts. Additionally, the Company has conducted various field leadership training that further provide guidance to its salesforce members on compliance requirements and measures. Lastly, PHP works with a third-party monitoring company to review and correct, if necessary, any social media posts.

 

Administratively Closed Resolution

DSSRC appreciated the good faith efforts made by PHP to address all 14 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 PHP salesforce member can generally expect to earn significant income (i.e., “full-time income” “unlimited income” “financial freedom”) through participation in 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 further 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 earning claim they must have a reasonable basis for making any income claims. 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

 

Conclusion

Based upon PHP’s good faith efforts to modify and remove all 14 social media posts identified by DSSRC in this inquiry, DSSRC administratively closed its inquiry.

 

Company Statement

“PHP Agency, LLC appreciates the opportunity to work with BBB DSSRC in responding to this inquiry.  We are fully committed to truthfulness and transparency when promoting our business opportunity. Our reputation for integrity with consumers and industry peers alike is something we endeavor to protect. PHP is committed to identifying and acting on opportunities to provide compliance training, monitoring, and tools, such as social media templates, to our sales force.”

 

(Case #209, Closed on 4/14/25)
© 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