Case #217-2025: Administrative Closure - Total Life Changes, LLC

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #217-2025: Administrative Closure - Total Life Changes, LLC


 

Company Description

Total Life Changes, LLC (“TLC” or the “Company”) is a multi-level marketing company that was launched in 1999 and headquartered in Fair Haven, Michigan. The Company markets health, wellness, and beauty products, including weight management, nutrition, energy, and skin care 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 industry and pertained to income claims disseminated by TLC salesforce members. DSSRC was concerned that the representative claims below communicated the message that the typical TLC salesforce member can generally expect to earn significant income from the Company’s business opportunity.

The representative claims that formed the basis of DSSRC’s inquiry are set forth below.



Earnings Claims

  1. “With their support, I was able to shed 20 lbs and become the best version of myself. Now, I am eager to help others achieve their goals and attain financial independence.”1 (July 2023)
  2. “💰 Financial Freedom – Earn money through product sales, bonuses, and team-building.”
  3. “Are you ready to transform your health, boost your energy, and create financial freedom? With Total Life Changes, you get the products, the support, and the opportunity to build a thriving business while helping others!💡 Earn extra income”2 (February 2025)
  4. “Build your own business and create financial freedom.”
  5. “Building generational wealth #generationalwealth #financialfreedom” (May 2020)
  6. “Join me in my quest financial freedom and a healthy lifestyle while blessing others” (August 2020)


 

Company’s Position

Following TLC’s receipt of the DSSRC Notice of Inquiry, it informed DSSRC that the posts identified by DSSRC violate TLC’s Policies and Procedures and TLC had proactively taken action in connection with a number of the claims before receipt of DSSRC’s letter.

More specifically, TLC took immediate steps to address each of the non-compliant claims referenced in the Notice of Inquiry, including the suspension of accounts of the individuals responsible for the claims. The Company has successfully facilitated the removal of eight of the nine identified claims.

With respect to the one post, which remains publicly available, the Company explained that the Instagram post was disseminated in 2020 by an inactive salesforce member based in the United Kingdom. In addition to its efforts to contact the individual responsible for the post, TLC contacted Instagram to request removal of the non-compliant post and submitted a trademark complaint to the social media platform. The Company provided DSSRC with copies of its correspondence to the inactive salesforce members and Instagram.

According to TLC, its Policies and Procedures and Advertising Policy provide detailed guidance for salesforce members regarding how to market and sell Company products in compliance with laws. In order for a salesforce member to gain access to their account on TLC’s virtual back office, they must acknowledge that they have read and agree to comply with both the Policies and Procedures and the Advertising Policy.

More specifically, TLC’s Policies and Procedures strictly prohibit salesforce members from making express or implied claims that anyone will achieve any specific level of income or success aside from any such claims TLC has pre-approved. Salesforce members are only allowed to truthfully, accurately, and fairly explain the TLC Compensation Plan and show the possible ways a salesforce member can earn commissions or bonuses under the plan.

Company salesforce members are further prohibited from using examples that are unreasonable or exaggerated and required to comply with the TLC’s more detailed Advertising Policy, which provides simple, clear principles for salesforce members to follow in marketing the Company’s products and the business opportunity, including practical examples of compliant and non-compliant practices and statements. Furthermore, according to TLC’s Policies and Procedures, salesforce leaders or sponsors are also responsible for supporting, educating, and training new salesforce members and are instructed to take an active role in monitoring salesforce members in their downlines to ensure they do not make improper product or income claims.

In addition to prescribing standards for truthful advertising in its Policies and Procedures and prohibiting claims related to “financial freedom” identified by DSSRC, TLC consistently reminds and trains salesforce members on these policies. Specifically, the Company informed DSSRC that it has developed claims-focused training materials that are made available to salesforce members in the Company’s virtual back office. The Company also conducts in-person and virtual compliance trainings available to all salesforce members as well as more targeted one-on-one training sessions with salesforce leaders to promote compliance with the Company’s policies and applicable laws and regulations. The Company’s compliance team also regularly participates in weekly leadership and business calls with salesforce members where they announce compliance updates based on identified issues, remind them of dos and don’ts for product and earnings claims, and share available resources.

TLC proactively monitors salesforce members for compliance with Company policies and has procedures in place to respond to any salesforce member action that violates applicable laws and regulations. The Company has been working with a third-party monitoring vendor to help monitor salesforce member claims on social media and identify content that violates Company policies. The TLC compliance team also separately conducts manual searches for potentially non-compliant claims and screens social media accounts for those who have posted problematic claims to identify if there are other problematic posts. As noted earlier in the Company’s Position, TLC had already identified some, but not all, of the claims identified by DSSRC and attempted to remediate them.3



Administratively Closed Resolution

DSSRC acknowledged and appreciated TLC’s prompt response in addressing its concerns and confirmed that the Company voluntarily facilitated the removal of eight out of the nine claims, while exercising its best efforts to resolve the one remaining social media post brought to its attention. DSSRC determined that the good faith efforts of the Company were necessary and appropriate.

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.”4 The FTC Guidance further notes that claims of significant earnings are atypical to what the average participant would earn.5  Accordingly, disseminating an atypical earnings claim such as one suggesting that a Company representative will receive financial security from the business opportunity may create an inaccurate impression with a prospective salesforce member. 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 the claim. 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.”6

Regarding the single post from 2020 that remains publicly accessible, the Company took several steps to address DSSRC’s concerns. As evidence of its efforts, the Company furnished DSSRC with a copy of the communication it sent to the former salesforce member—whose account is now inactive—requesting that the post in question be taken down. When this outreach proved unsuccessful, the Company subsequently contacted the social media platform hosting the content to report the unauthorized claim and formally requested its removal. A copy of this correspondence was also shared with DSSRC. Although the post is still available online, DSSRC concluded that the Company made a good faith effort and exercised reasonable diligence in seeking its removal.

Based upon the actions taken by TLC to address DSSRC’s concerns, the inquiry was administratively closed.



Conclusion

DSSRC confirmed that eight of the nine earnings claims brought to the Company’s attention have been removed and that TLC made a good faith effort to address the post that remains publicly accessible by making a request to the inactive salesforce member and the social media platform to remove the post.

As a result of these actions, DSSRC administratively closed the inquiry.



(Case #217, closed on 5/29/25)
© 2025 BBB National Programs





[1] DSSRC identified this claim in two different Facebook posts that were disseminated in July 2023.

[2] DSSRC identified this claim in three different Facebook posts that were disseminated in February 2025.

[3] When the TLC compliance team identifies a claim of concern, the compliance team will issue a warning to the salesforce member and direct the salesforce member to remove or edit the post and work with the salesforce member to educate and train them on why their claims are problematic (with links to the TLC Advertising Policy and the Policies & Procedures). The salesforce members is also required to complete training and pass relevant quizzes on product and/or income claims. If salesforce member fails to cooperate or comply with the request, TLC would typically proceed to suspend the salesforce member account and place their commissions on hold.

[4] 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.

[5] Id at Section 13.

[6] Id.