DSSRC Administrative Closure #315

The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") regarding four social media posts that communicated earnings claims and five posts that communicated health-related product claims. DSSRC expressed concern that the earnings claims conveyed that a typical salesforce member could achieve “financial freedom” and that typical Company salesforce members could earn significant (e.g. $20,000 a month) income from the Company’s business opportunity. The health-related claims included representations that the Company’s products could address significant health-related conditions including anxiety, migraines and depression. The claims were disseminated on social media channels including Facebook, YouTube, Twitter and TikTok.

The Company took prompt action to address the social media posts identified by DSSRC. Specifically, within 10 days of receipt of DSSRC’s Notice of Inquiry, the Company provided DSSRC with a substantive written response outlining its compliance policies, its internal policies and procedures, and ongoing monitoring of its salesforce members.  

In addition, the Company informed DSSRC that it was able to effectuate the removal of all but one of the social media posts identified in this inquiry. With respect to the one remaining post, the Company demonstrated to DSSRC that it used its best efforts to effectuate removal of the post including the termination of the account of the individual responsible for disseminating the claim due to his lack of cooperation in removing the post. In addition, the Company reported the claim to the social media platform and requested that it be removed.

Based on the foregoing, DSSRC found that the Company made a bona fide, good-faith effort to address DSSRC’s concerns and administratively closed this inquiry.

(Administrative Closure #315, closed on 04/09/24)
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