DSSRC Administrative Closure #220

The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a company (“Company”) regarding five social media posts disseminated on Facebook that were identified pursuant to its monitoring of the direct selling industry. The posts included references to, among other things, the Company’s “unlimited income” potential, claims that salesforce members will earn “residual income” and a statement regarding how the business opportunity can “change financial futures for generations.” One post disseminated by a salesforce member also stated that since using the Company’s product, they are now “taking less or no medications.”

DSSRC was concerned that these posts may be reasonably interpreted as communicating that Company salesforce members would earn a substantial income through its participation in the Company’s business opportunity and that Company products may be used as a substitute for prescription drug products.

Following its receipt of DSSRC’s Notice of Inquiry, the Company immediately addressed DSSRC’s concerns and was able to remove four of the posts within 72 hours. With respect to the remaining post (i.e., “unlimited income”), the Company sent out removal notification the same day that the inquiry was received from DSSRC. Unfortunately, the Company’s attempts at contacting the salesforce member were unsuccessful.  The Company then followed up with phone calls and emails on three different days. Consequently, the salesforce member’s account was officially terminated because she did not respond to the Company’s take-down requests. In further efforts to have the post removed, the Company then reported the post to Facebook.

Accordingly, DSSRC administratively closed this inquiry based upon the good faith efforts and due diligence demonstrated by the Company to address DSSRC’s self-regulatory concerns. 

(Administrative Closure #220, closed on February 24, 2022) 
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