Case #123-2023: Administrative Closure – Seint Beauty
BBB NATIONAL PROGRAMS
Direct Selling Self-Regulatory Council
Case #123-2023: Administrative Closure – Seint Beauty
Company Description
Seint Beauty (“Seint” or the “Company”), formerly Maskcara Beauty, is a multi-level marketing company founded in 2013 and based in St. George, Utah. The Company markets consumer and personal care products with a focus on cosmetics and cosmetic accessories.
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 respective salesforce members.
This inquiry concerned 14 earnings claims disseminated by Company salesforce members. The subject claims were located on Facebook, Instagram, Twitter, and YouTube and are set forth below:
Earnings Claims
- “I love my part time job with Seint and I was able to replace my nursing income with my Seint income.”
- “Looking for a job???? Need the extra income???
Want to supplement (or even replace) your current income?”
“With Seint you can do as little or as much as you want. If you just want to dabble a little bit and make a lie fun money...you can. You want to hit the ground running and replace an income...you can!”
- “If SEINT is something you've considered, weither it's for a side income or a full time income, we are here to help you where ever your goal is…Unlimited Residual income…Trips! (you can earn 2! But there’s many more!)”
- “Do you need a little extra income?
Do you like to have a new little side hustle?
Are you looking for something part time?
Maybe your full time job needs a change?
My goal is to replace my full time job with Seint”
- “a side gig that brings some extra cash flow to your family… or a full time job that can replace an income and allow you to stay home!”
- “I have been able to replace my corporate income
Infinite bonuses”
- “The Seint compensation plan is extremely generous, with commissions ranging from 20%-40% with NO required minimum to sell. That’s right, you earn commission on anything and everything you sell, no matter what. With endless opportunity for growth, you can even replace your income with hard work and a creativity!”
- “The financial and time freedom are such a blessing to me and my family!”
- “financial freedom…generating extra income”
- “financial freedom”1
- “Covid been hard? YES! Not just financially, but also mentally and physically!
Seint has given me the motivation to get up and get ready every morning, provided me with a supportive community that I can always count on and financial freedom!
Stop living paycheck to paycheck!!”
- “it can give you financial freedom if you make it a business.”
- “giving single mom‘s financial freedom again”
DSSRC expressed concern that the earnings claims set forth above may be representative of the types of claims being disseminated in the market regarding the Company’s business opportunity and convey the message that Company salesforce members can generate full-time, replacement, or unlimited residual income and achieve financial freedom by participating in Seint’s business opportunity.
Company’s Position
Seint promptly acknowledged receipt of DSSRC’s Notice of Inquiry and informed DSSRC that it immediately began working to remedy the claims at issue. The Company did not attempt to substantiate the claims DSSRC brought to its attention.
Instead, Seint informed DSSRC that it contacted each of the salesforce members responsible for the claims at issue and provided additional salesforce education regarding earnings claims. All posts were successfully removed or modified to address DSSRC’s concerns.
Analysis and Recommendation
As noted in section 1 of the DSSRC Guidance on Earnings Claims for the Direct Selling Industry, it is misleading for a direct selling company and/or its salesforce members to make any earnings claims unless the direct selling company and/or its salesforce members: (A) have a reasonable basis for the claim at the time the claim is made; and (B) have documentation that substantiates the claim at the time the claim is made.2
For purposes of a DSSRC inquiry, DSSRC will evaluate any claim based upon the context in which the claim appears and the potential net impression of such claim to the audience. Some words and phrases, however, are prohibited when made to a general audience of prospective or current salesforce members. Such words and phrases include “unlimited income,” “full-time income,” “replacement income,” “career-level income,” or any substantially similar statements or representations. Other terms, such as “passive income” and “residual income,” are prohibited when they convey that income can be continuously earned by salesforce members with little or no ongoing effort.2
Here, DSSRC determined that the prompt actions taken by the Company to facilitate removal of the earnings claims at issue in this inquiry were necessary and appropriate.
Conclusion
DSSRC recognized and appreciated the good faith actions taken by Seint to address its concerns. Based upon Seint’s bona fide efforts in this regard, DSSRC administratively closed the inquiry.
Notwithstanding these efforts, DSSRC will continue to monitor the earnings claims being made regarding the Company’s business opportunity and may commence a compliance inquiry should DSSRC continue to see improper earnings claims being disseminated by the Company and/or its salesforce members.
(Case No. 123-2023, closed on 7/19/23)
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[1] Claims of “financial freedom” appeared across multiple posts.
[2] See DSSRC Guidance on Earnings Claims for the Direct Selling Industry at https://bbbprograms.org/programs/all-programs/dssrc.
[3] Id at section 2.