DSSRC Administrative Closure #247

The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The claims at issue were all disseminated on Facebook. DSSRC contacted the Company and expressed concern that these social media posts could be reasonably interpreted by consumers as meaning that the Company’s business opportunity provides salesforce members with unlimited income, passive income, residual income or the opportunity to replace an income.

The Company promptly responded to DSSRC’s inquiry and stated that its internal teams have diligently worked to address all concerns raised by DSSRC. The Company further stated that it takes compliance with FTC and industry guidelines seriously and, accordingly, it took further remedial actions including updating and publishing guidelines for its salesforce members. The Company further indicated that it will re-publish salesforce guidelines on a bi-monthly basis going forward and such information will be accessible online for all Company salesforce members. The Company indicated that it took further action to contact the salesforce members responsible for dissemination of the claims at issue, coached them about best practices and had them remove the claims. Initially, the Company was able to resolve all but three claims. But, after following up with the salesforce members that disseminated the remaining two social media posts, all but one have been removed. Such efforts by the Company included notifying a salesforce member located in Canada that their account was placed on hold until the social media post in question was deleted. The Company also demonstrated to DSSRC that it was attempting to work with Facebook to remove the one remaining social media post at issue.

Based upon the Company’s good faith actions to address DSSRC’s concerns, the inquiry was administratively closed.

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