2023 Activity Report for the Direct Selling Self-Regulatory Council

Activity

Report

2023

2023 Activity Report

for the Direct Selling

Self-Regulatory Council

This Activity Report outlines the notable initiatives

undertaken by the Direct Selling Self-Regulatory Council

(DSSRC) in 2023, including its monitoring of direct selling

advertising and marketing, its case work, and DSSRC’s

continuing educational initiatives for the direct selling

channel.

In 2023, DSSRC provided active oversight of product and business

opportunity claims disseminated by direct selling companies and their

salesforce members. DSSRC initiated its 485th case inquiry, hosted the

third annual Direct Selling Summit, released its comprehensive Guidance on

Income Disclosure Statements for the Direct Selling Industry, and provided

guidance and instruction on earnings and product claims emphasizing

compliance supervision to numerous direct selling companies. In addition to

providing educational presentations on its self-regulatory program, DSSRC

engaged with various state and federal government agencies in discussions

about its collaboration with the direct selling industry.

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Introduction

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DSSRC has continued its eorts to monitor direct selling marketing and identify

unsupported and inaccurate claims related to the anticipated income of salesforce

members participating in the direct selling business opportunity. DSSRC also reviewed

claims that explicitly or implicitly communicate inaccurate descriptions of the performance

of products in speciﬁc contexts. This scrutiny aligns with ongoing regulatory actions,

such as warning letters issued by the Federal Trade Commission (FTC) to direct selling

companies for such claims and the FTC’s ongoing consideration of rulemaking to address

deceptive and unfair marketing using earnings claims.

In 2023, DSSRC initiated 94 case inquiries, including ﬁve compliance inquiries, with 30

pending inquiries that will carry into 2024. DSSRC published 40 formal case decisions

and 44 administratively resolved inquiry summaries on BBB National Programs’ website

in 2023. Notably, some of these cases were carried over from inquiries initiated in 2022.

DSSRC adopts an administrative closing approach if the direct selling company commits,

within the initial 15 business days of receiving DSSRC’s Notice of Inquiry, to discontinue or

signiﬁcantly modify the disputed claims. Failure to receive such a commitment leads to the

transition of the matter into a formal case review.

Of the 94 inquiries initiated in 2023, all but two were a result of program monitoring, with

those two matters brought to DSSRC’s attention by non-governmental organizations

(NGO). 39 of the inquiries involved member companies of the Direct Selling Association

(DSA), while the remaining 55 inquiries involved non-member companies.

In 2023, DSSRC referred ﬁve cases that included patterns of business opportunity

and/or product performance claims to the FTC and State Attorneys General oces

for enforcement. During this period, DSSRC also identiﬁed and communicated 947

representative claims to direct selling companies, consisting of 298 product claims and 649

business opportunity/earnings claims, such as those with lavish lifestyle representations.

While DSSRC speciﬁcally identiﬁes representative claims in its Notice of Inquiry to direct

selling companies, DSSRC requests and encourages the company to address any similar

claims in their marketing materials beyond those speciﬁcally identiﬁed by DSSRC.

Most of the earnings claims inquiries centered on unqualiﬁed representations (e.g.

“unlimited income”) or insucient disclosures for atypical earnings claims. DSSRC

emphasized the need to provide such disclosures clearly, conspicuously, and in close

DSSRC Casework

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proximity to the triggering atypical claim. Companies participating in such inquiries with

DSSRC either discontinued or modiﬁed the claims to include references to the generally

expected income in the depicted scenario.

Similarly, direct selling companies have addressed the issue of unqualiﬁed company bonus

and incentive claims by including disclosures indicating the percentage or number of

program participants obtaining such rewards. This involved direct communication with

active salesforce members to remove relevant social media posts or add appropriate

disclosure language. In accordance with DSSRC’s recommendations, companies have also

increasingly requested social media platforms to disable posts directly. Approximately 90%

of identiﬁed claims in 2023 originated from direct selling company and salesforce member

social media accounts, with the majority on Facebook. The rest were on company websites

and video platforms, such as YouTube.

Apart from the ﬁve case referrals, all of the companies that were the subject of DSSRC

inquiries were responsive and participated in the self-regulatory forum. Following receipt

of the DSSRC Notice of Inquiry, companies contacted DSSRC and engaged in telephone/

649

business

opportunity/

earnings claims

Claims Brought to the Attention

of Direct Selling Companies

298 product claims

649 business opportunity/earnings claims

298

product

claims

90%

social media

accounts

Claims Found on Social Media

90% social media accounts

10% on company websites/video platforms

10%

on company websites/

video platforms

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video calls to discuss the process, often expressing support for voluntary industry self-

regulation.

While DSSRC continues to identify isolated claims related to the treatment of viruses

in general, representations speciﬁcally tied to COVID-19 disseminated by direct selling

companies and/or their salesforce members continued to diminish signiﬁcantly. In 2023,

DSSRC commenced only seven inquiries that included claims related to COVID-19. This

marked a marginal decrease from the nine COVID-19-related cases in 2022. The 2023

inquiries included the review of eight product performance claims mentioning COVID-19

and two claims associating COVID-19 with the direct selling business opportunity.

Among the seven inquiries, two were part of administratively resolved inquiry summaries,

four were part of formal DSSRC decisions, and one inquiry is still pending.

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DSSRC independently monitors the dissemination

of earnings and product claims by direct selling

salesforce members across various social media

platforms and the websites of all direct selling

companies in the United States. In 2023, to expand

the scope of its monitoring, DSSRC collaborated with

two third-party monitoring companies with expertise

in understanding the nuances of the direct selling

space. DSSRC reviews the analytical data provided

by the monitoring companies to identify potential

violations of applicable FTC rules and regulations.

References to salesforce members achieving

“ﬁnancial freedom” from the direct selling business

opportunity (i.e., communicated in express claims

or hashtags) was the most identiﬁed earnings claim

according to DSSRC’s monitoring data, followed by

claims pertaining to career-level income, full-time

income, passive income, replacement income, and

unlimited income.

With respect to product claims, representations

promising substantial weight loss (communicated

in express representations or through “before and

after” depictions) was the most identiﬁed category

of claim identiﬁed in DSSRC’s monitoring, followed

by references that direct selling products can treat

or address conditions of anxiety, depression, eczema,

and/or pain and inﬂammation. DSSRC also identiﬁed

a number of claims that related to the treatment of

serious disease conditions such as cancer, diabetes,

and autism.

While Facebook continues to record the highest

number of infractions, there has been a decrease of

approximately 20% in the number of potential claims

DSSRC Monitoring

From January 1 through

November 30, 2023,

DSSRC monitoring

identiﬁed:

 Approximately

422,108 Unique URLs

 6,573 Unique URLs

Reviewed as potential

incidents

 2,593 Facebook

Posts

 384 Instagram Posts

 523 YouTube

Videos

 101 TikTok Videos

 46 Twitter Posts

 83 LinkedIn Posts

 1,550 Health-

Related Product

Posts

 2,045 Business

Opportunity Income

Posts

 56 COVID-19 Posts

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appearing on that platform. Conversely, the number of claims identiﬁed on Instagram rose

by 58%. DSSRC has also observed salesforce members utilizing several alternative social

media platforms to communicate claims, including platforms such as LinkedIn, Loom, and

Pinterest.

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The Summit featured keynote speaker Nevada Chief Deputy Attorney General Mark J.

Krueger and remarks from leading brand expert Patrick Hanlon. Florida Attorney General

Ashley Moody also provided brief comments regarding issues of priority at the Florida

Attorney General’s oce.

Direct Selling Summit:

Responsible Brand Growth

On July 27, DSSRC hosted its third annual Direct

Selling Summit, bringing together business leaders,

legal professionals, and compliance experts from

across the direct selling industry. The virtual, half

day event was an educational opportunity, providing

attendees with tips and best practices for responsibly

growing their direct selling brand, increasing

consumer trust, and staying compliant.

PANEL 1

Participants on the ﬁrst panel, An Expert Discussion: The FTC’s

Rule-Making Process Regarding Earnings Claims, moderated by

BBB National Programs’ Executive Vice President of Policy, Mary

Engle, discussed the FTC’s recently published Health Products

Compliance Guidance, updating and replacing its longstanding

Dietary Supplements: An Advertising Guide for Industry, highlighting

important changes to the guidance that apply to any company

making health-related claims in advertising and the type of

substantiation that should be considered by companies when

disseminating health-related claims.

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PANEL 2

The second panel, Claims LIVE: The Challenge of Providing Claim

Oversight at Live Events, explored best practices for ensuring that

claims made at live events are truthful, accurate, and compliant

with industry regulations and guidelines. This panel, moderated

by Jonathan Gelfand, Chief Legal Ocer and SVP Business

Development at Beachbody, LLC explored strategies for training

and educating direct selling companies and independent salesforce

members on how to communicate claims and representations in a

compliant manner while also discussing approaches on how to avoid

problematic express and implied product and earnings claims.

KEYNOTE SESSION

During the keynote session, Nevada Chief Deputy Attorney General Mark Krueger

discussed the mission of Nevada’s Bureau of Consumer Protection. The focus was on

protecting the interests of Nevada, its residents, consumers, and businesses, while

also ensuring a fair, honest, and competitive marketplace. Mr. Krueger highlighted the

distinctions between legitimate direct selling companies and illegal pyramid schemes and

provided insight on the civil and criminal penalties imposed by Nevada law. Additionally, Mr.

Krueger spoke about the educational resources provided by his oce, the dierent sources

of investigations that come before the Nevada Bureau of Consumer Protection, and how to

ﬁle a complaint with the Nevada Attorney General’s oce.

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PANEL 3

The ﬁnal panel, The FTC and Direct Selling: Reading the Agency

Post-Noland, Pre-Neora was moderated by John Villafranco from

Kelley Drye & Warren, and delved into the ramiﬁcations of this

year’s U.S. District Court decision involving the FTC vs. James D.

Noland. This case encompassed allegations of pyramid scheme and

unsupported earnings and product performance claims. The panel

discussed how this case could be distinguished from another FTC

case involving similar allegations against the direct selling company

Neora. Emphasis was placed on the broader impact of these cases on

the direct selling industry, what the implications might be for Neora,

and the overall outlook for the future of the direct selling channel.

DSSRC appreciated the direct selling industry’s support of the Direct Selling Summit.

More than 125 industry professionals registered for the event, including registrants from 21

dierent DSA member companies.

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DSSRC had numerous opportunities to share the commitment of the direct selling industry

to independent self-regulation with state and federal government agencies and industry

stakeholders in 2023. Through each of these opportunities, the DSSRC team was able to

discuss its work in providing guidance and instruction to direct selling companies regarding

claims of product performance and income opportunity.

In January, DSSRC Vice President, Peter Marinello, and Deputy Director, Howard Smith,

spoke with industry thought leaders at DSA’s Compliance Ocers’ Retreat in Irvine,

California to present a draft of DSSRC’s Guidance on Income Disclosure Statements for the

Direct Selling Industry. The compliance ocers were very receptive to the DSSRC guidance

initiative and provided valuable feedback for DSSRC to consider in the ﬁnal publication of

the document.

In February, Marinello attended the Republican Attorneys General Association Winter

National Meeting in New Orleans and had an opportunity to discuss the direct selling

industry’s commitment to independent self-regulation with several Attorney Generals and

their sta members.

Later that month, Marinello presented at the 2023 Direct Selling Leadership and

Compliance Summit in Salt Lake City on a panel entitled “Dealing with Nastygrams:

Responding to Regulators and Industry Opponents.” During the session, he discussed how

cases are administered at DSSRC, eective techniques for companies responding to a

DSSRC inquiry, as well as how DSSRC addresses non-responsive salesforce members and

problematic social media posts disseminated by salesforce members located outside of the

Socializing the Industry’s

Commitment to Advertising Self-

Regulation

DSSRC had numerous opportunities to share

the commitment of the direct selling industry to

independent self-regulation with state and federal

government agencies and industry stakeholders in 2023.

Through each of these opportunities, the DSSRC team

was able to discuss its work in providing guidance and

instruction to direct selling companies regarding claims

of product performance and income opportunity.

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United States.

In March, Marinello and Smith participated on a call with DSA’s Board of Directors,

providing an update on DSSRC’s monitoring and casework and discussed recent case

referrals that were sent to the FTC and State Attorneys General oces.

In May, Smith presented at the BBB Bootcamp in Dallas, which provided training for those

who conduct advertising reviews and investigations for BBBs across North America. The

presentation, “Introduction to BBB National Programs | NAD & DSSRC Case Overviews,”

provided a summary of BBB National Programs’ work in advertising self-regulation, a

primer on the fundamental tenants of advertising law, and a focused discussion of the

FTC’s recent Health Products Compliance Guidance.

In June, at the DSA Annual Meeting in Scottsdale, Marinello spoke with a group of general

counsel regarding updates to DSSRC’s Guidance on Income Disclosure Statements as well

as with a break-out session about the implications of the FTC’s Penalty Oense Notices

and the recently published FTC Health Products Compliance Guidance.

Following July’s Direct Selling Summit, Marinello spoke at a conference in August that

was hosted by the Direct Selling Educational Foundation at Emory University’s Goizueta

Business School. The “Building Trust in the Marketplace” conference focused on how self-

regulation contributes to business and consumer conﬁdence and how the direct selling

industry has demonstrated its commitment to third-party administered self-regulation.

In September, Marinello visited the oces of the National Consumer League and spoke

with John Bryault, VP Public Policy Telecommunications and Fraud. Peter explained the

beneﬁts of independent third-party self regulation in the direct selling industry and how

DSSRC provides claim oversight and educational resources for industry stakeholders.

Later that month, Marinello and Smith were guest lecturers at St. John University’s School

of Law’s Consumer Protection class where they discussed the fundamental principles of

industry self-regulation, drawing distinctions between self-regulation and government

regulation. They presented various case examples and conducted a detailed analysis to

illustrate how DSSRC evaluates advertising and marketing claims within the direct selling

industry. The presentation also covered the initiation and resolution processes for inquiries,

providing students with a comprehensive understanding of the mechanisms employed by

DSSRC.

Later that month, Marinello and Smith provided a program update to DSA members at

the Association’s Legal and Regulatory Seminar in Washington, DC, where they discussed

several of DSSRC’s accomplishments since its inception in 2019, as well as some of the

challenges and obstacles encountered and the various indicators and metrics used to

assess the program’s eectiveness.

In October, Marinello moderated a panel at the Soft Law Summit, an event hosted by

BBB National Programs’ 501(c)3 foundation, the Center for Industry Self-Regulation. The

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panel, which included Brian Bennett from DSA, the Associate Director at FTC’s Division of

Marketing Practices Lois Griesman, and two professionals from other industries, explored

the ways in which industry trade associations contribute to the development of self-

regulation programs and examined the underlying motivations, potential beneﬁts, and the

broader impact these initiatives can have on industries, businesses, and consumers.

In December, Marinello and Smith participated in DSA’s Ethics webinar to discuss the recent

publication of DSSRC’s Guidance on Income Disclosure Statements for the Direct Selling

Industry and provided detail on the purpose of the document and how it could assist

companies in utilizing an income disclosure statement while considering issues pertaining

to segmentation, presentation, and transparency regarding income that can be generally

expected by the typical direct selling business opportunity participant.

DSSRC also had several occasions in 2023 to speak with sta members at the FTC’s

Division of Marketing Practices regarding recent DSSRC initiatives and casework.

Additionally, DSSRC discussed the direct selling industry’s self-regulatory program with

Consumer Protection Divisions in various states, including Tennessee, Utah, Florida, and

Nevada.

DSSRC’s work, impact, and speciﬁc cases were mentioned more than 20 times in 2023 and

were the subject of several articles that ran in Social Selling News, HBW Insight, Natural

Products Insider, and NutraIngredients, among other publications.

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In October, DSSRC published its Guidance on Income Disclosure Statements for the Direct

Selling Industry to help direct selling companies provide truthful and non-misleading

information regarding the levels of income that can be generally expected by salesforce

members who engage in the direct selling business opportunity.

The Guidance emphasizes the importance of accurate and transparent income disclosure

for direct selling companies and their salesforce members and was derived from numerous

conversations with industry stakeholders. The Guidance draws from sources such as the

FTC’s dot.com Disclosure Guide, the 2018 FTC Business Guidance Concerning Multi-Level

Marketing, DSSRC’s Guidance on Earnings Claims for the Direct Selling Industry, and DSA’s

Code of Ethics in an eort to provide education and support to the direct selling channel in

upholding the fundamental principles of accurate claim dissemination.

The Guidance touches on several key principles and issues for consideration when a direct

selling company prepares an income disclosure statement (IDS), including, but not limited

to, deﬁning an IDS, transparency and clarity of the income opportunity, presenting data in

an easily understandable format, and setting realistic expectations regarding the income

that can generally be expected by the typical direct selling salesforce member.

DSSRC Guidance on Income

Disclosure Statements for the Direct

Selling Industry

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In 2023, DSSRC continued in the role of Code Administrator for the enforcement of DSA

Code of Ethics complaints. The Code of Ethics is designed to ensure ethical business

practices for DSA members and to create a framework for ethical conduct, fostering trust

within the industry and protecting the business interests of consumers and independent

salesforce members.

DSSRC worked in collaboration with DSA to establish and implement transparent complaint

handling procedures to ensure prompt resolution of all complaints. The complaint handling

procedures include the review and determination of whether a violation of the Code of

Ethics has occurred and for the Code Administrator to answer as promptly as possible all

queries relating to the Code of Ethics and its application.

DSSRC continues to work closely with DSA to ensure that Code matters are resolved

expeditiously and that all parties to a Code inquiry have a full and fair opportunity to be

heard.

DSA Code Administrator Work

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In 2024, DSSRC will make a concerted eort to increase the transparency of its reporting

of administratively closed cases and to work with direct selling companies to disclose

information about the inquiry to industry stakeholders. Transparency builds trust among

stakeholders, including consumers, member companies, and regulatory bodies.

When the resolution process is transparent, it further enhances the credibility of DSSRC,

demonstrates its accountability, and ampliﬁes the commitment of direct selling companies

to promoting ethical standards, adhering to the principles of compliant claim dissemination

and substantiation, and being held responsible for their decisions and actions.

Clear and transparent reporting also educates stakeholders about the resolution process,

helping them understand the criteria, considerations, and outcomes of administratively

closed cases, which will contribute to a better public understanding of the industry’s

commitment to self-regulation.

Importantly, when the resolution process is transparent, it serves as a deterrent to non-

compliance. Companies are more likely to adhere to ethical standards if they know

that the resolution of cases is scrutinized and reported transparently and facilitates the

identiﬁcation and advocacy of industry best practices. By openly discussing the resolution

of cases, DSSRC can accentuate the positive action taken by direct selling companies and

provide information regarding practices that other companies may choose to adopt.

Added clarity to the reporting process will also allow DSSRC to better address concerns

and misconceptions that may arise during the resolution process and provide an

opportunity to elaborate on the rationale behind decisions. Regulatory agencies and

industry stakeholders have an expectation of transparency in self-regulation endeavors

and, by aligning with these expectations, DSSRC can enhance its eectiveness and

legitimacy of the program in the eyes of regulators and the public.

A list of direct selling companies that were the subject of DSSRC administratively resolved

inquiry summaries in 2023 is included in this report’s Appendix.

DSSRC looks forward to working with stakeholders in 2024 to eectively demonstrate the

good faith eorts and commitment of direct selling companies to industry self-regulation.

Case Reporting Transparency

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2023 DSSRC Administratively Resolved Inquiry Summaries

In accordance with Section V(D) of the DSSRC Policies and Procedures, DSSRC will

administratively close an inquiry that involves social media posts that originate outside

of the United States and/or involve a small number of social media posts when it is

determined that the Company has demonstrated a bona-ﬁde, good faith eort to have the

claims at issue removed from circulation and commits to use its best eorts to ensure that

Company and/or its salesforce members will refrain from communicating similar claims in

the future. Details of such closures are reported in the Administratively Resolved Inquiry

Summaries section on the DSSRC page of the BBB National Programs website.

Below is a compilation of the direct selling companies that were the subject of 2023

DSSRC Administratively Resolved Inquiry Summaries, along with a short statement from

several companies that chose to furnish DSSRC with further details regarding their ongoing

compliance endeavors.

 Cabi

 CBD Pure

 Changing the Future Outcome

 Chalk Couture

 Cutco

 Forever Living

 Hempworx

 Isagenix

“Maintaining compliance is a key focus for Isagenix, and we actively monitor our ﬁeld to

ensure adherence to our standards. Upon receiving the inquiry, we promptly addressed the

problematic claims, resulting in the removal of all oending posts and videos within 48 hours.

Additionally, we have used this feedback to proactively identify and rectify similar claims in

the future. We extend our gratitude to the DSSRC for bringing these income claims to our

attention.”

 J. Hilburn

“J.Hilburn values and upholds the principles set forth by the Direct Selling Self-Regulatory

Council (DSSRC). We understand the importance of maintaining accurate and transparent

information within the direct selling industry. In response to the DSSRC’s investigation, we have

taken immediate action by reaching out to all individuals associated with the ﬂagged social

Appendix

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media posts, urging them to remove any misleading claims. We remain committed to diligently

pursuing the removal of any false claims made by current or former stylists representing

J.Hilburn. Our ongoing eorts include continuous monitoring of social media platforms to

identify and address any potential violations promptly. J.Hilburn is dedicated to fostering an

environment of compliance and ethical business practices among our stylist community. We

emphasize the importance of accurate income claims and pledge to work collaboratively with

the DSSRC to rectify any concerns raised. Our commitment to industry self-regulation remains

unwavering, and we will continue to take proactive measures to ensure the accuracy and

integrity of information shared by our stylists.”

 L’Bri

 LifeWave

“LifeWave is committed to being an exemplary corporate citizen by striving to promote only

the best business practices at the corporate and brand partner levels. In recognizing the

vital importance of maintaining compliance with regulatory standards, LifeWave continually

focuses its eorts on bolstering its compliance personnel and internal resources, updating

and maintaining its Policies & Procedures to reﬂect current regulatory needs, utilizing top

compliance monitoring systems and platforms, and developing compliance training programs

and tools to provide its Brand Partners with clear guidance for a deeper understanding of best

practices.”

 Limelife by Alcone

 Mannatech

“On October 13, 2023, Mannatech was informed of a DSSRC inquiry regarding 7 problematic

social media posts disseminated on Facebook, TikTok, YouTube, and LinkedIn by company

salesforce members (“Associates”). Upon receiving this notiﬁcation, the Mannatech compliance

team took immediate action to remove all the problematic posts. Mannatech was successful

in removing 6 of the 7 social media posts. The only post remaining is from a former Associate

in our South African market. Mannatech attempted to contact the individual via phone call,

email, and Facebook messenger but to date, has not received a response and has been unable

to have the post removed. Since the individual refuses to comply with the company’s requests,

Mannatech’s compliance team reached out to Facebook notifying them that the remaining post

contains unauthorized income claims and requested its removal. To date, we have not received

a response from Facebook.”

 NewAge/Ariix

 Nikken

 Norwex

 Organo Gold

Organo appreciates the eorts and additional security of the DSSRC and we recognize and

embrace the oversight. Organo and its Compliance Department are committed to working

together, continuing to protect the reputation of the industry for independent business owners

as well as customers. We have increased our global outreach and compliance training as we

navigate international regulations and are steadfast in our messaging to adhere to our policies

and procedures.”

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 Paparazzi

 PM International

 Princess House

 QuiAri

 Red Aspen

“Red Aspen is pleased to know that its compliance eort is working, eective and the

compliance manager is doing a fantastic job! Of the ﬁve incidents recently reported by DSSRC,

Red Aspen addressed and resolved four BEFORE they were reported to the company by

DSSRC! The ﬁfth incident was never identiﬁed by Red Aspen’s compliance software, but when

asked, the perpetrator willingly removed her post.”

 Regalware

“Regal Ware is deeply committed to cultivating an ethical salesforce dedicated to building

and nurturing trust in all our interactions. We prioritize this commitment through continuous

improvement eorts and strict accountability measures. Our approach includes comprehensive

training programs, continuous monitoring, frequent audits, and open, honest dialogues with

our salesforce. Upholding ethical conduct and unwavering adherence to company policies and

regulations are core values our company steadfastly embraces.”

 Rexair

 Sabika

 Saba

 Scentsy

“Scentsy appreciates the guidance and help in identifying problematic behaviors in our

independent sales force provided by the DSSRC. Despite a robust training program, active

ﬁeld monitoring, corrective actions taken by our internal compliance team, occasionally

DSSRC locates online posts that have not yet been identiﬁed by Scentsy’s compliance team.

In 2023, DSSRC helped Scentsy by identifying seven problematic posts making income claims

by Independent Scentsy Consultants. Each of these posts included an income claim without

making adequate disclosures or including disclaimers. Three posts appeared on Facebook

or Facebook stories. Two of the three Facebook posts were duplicates A fourth post was a

screen shot of one of the Facebook posts appearing on another website (loom). Two dierent

Scentsy consultants, Brooke Balduck and Martha Murray made these posts. After contact by

the Scentsy compliance team, Martha removed her posts. Brooke attempted to update her

posts with income disclosure and other disclaimers, but also eventually removed the posts after

additional guidance. Two of the remaining posts appeared in YouTube videos, made by Chloe

Cox and Autumn Hanson. Autumn and Chloe altered these posts when contacted by Scentsy

compliance to add income disclosure statements and disclaimers. The ﬁnal post identiﬁed

by DSSRC appeared on Pinterest and was made by a former consultant, Cassandra Remier.

Although she no longer sell Scentsy products, Scentsy’s compliance team contacted Cassandra

and requested that she remove the post and reminded her that some obligations (such as not

making misleading income statements) survive the termination of her sales contract. Scentsy

maintains a list of independent consultants contacted by its compliance team, its outside

monitoring resources, or DSSRC to ensure that there are not repeat oenders.”

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 Signature HomeStyles

“Signature Homestyles appreciates the Direct Selling Self-Regulatory Councils organization’s

role, governance, and insight. It is imperative to Signature Homestyles that we and our

contractors do not publish or otherwise communicate anything regarding our business model

that could be interpreted as misleading. We strive to be as transparent as possible to create a

fair and equitable opportunity for our selling organization. Thus, we coach and enforce these

guidelines within our organization and its contractor salesforce on an ongoing basis.”

 Sipology

 Surge 365

“Surge365 endorses the DSSRC’s eorts to ensure ethical practices in our marketplace.

Surge365 has a comprehensive compliance program designed to prevent and mitigate

compliance infractions. The DSSRC’s eorts ensure a level playing ﬁeld in this arena.”

 Tastefully Simple

“Tastefully Simple welcomes the oversight on the DSSRC. If issues of concern arise, Tastefully

Simple reaches out to the consultant to address the speciﬁc situation and, where appropriate,

provides ongoing training and information sharing on key issues of importance. Further,

Tastefully Simple provides pre-approved templates and marketing materials for consultants

which meet or exceed the DSSRC standards.”

 Talk Fusion

 The Happy Company

 Thirty-One Gifts

“Thirty-One Gifts understands the importance of DSSRC’s role and we are grateful that it

provides a valuable mechanism for self-monitoring in the Direct Selling industry. We join with

the DSSRC in supporting, promoting, and maintaining the highest levels of truthful messaging

in our industry. We also understand the importance of ensuring that income and lifestyle

representations are truthful, accurate, and, when necessary, contain appropriate disclosures.

To that end, when DSSRC brought to our attention eleven (11) social media posts by our

distributors.”that were incongruent with these philosophies, we immediately took action, and all

posts were deleted in less than a month.

 Total Life Changes

“Total Life Changes (“TLC”) appreciates that DSSRC ﬂagged certain social media posts made

by former and current salesforce members that violated TLC’s policies and procedures. TLC

employs robust training, monitoring, and enforcement procedures and had already identiﬁed

most of the claims for removal prior to DSSRC’s inquiry. TLC is committed to compliance and

enhancing the industry’s commitment to self-regulation to ensure truthful, accurate, and non-

misleading advertising.”

bbbprograms.org

BBB National Programs

Direct Selling Self-Regulatory Council

2023 Activity Report

 Touchstone Essentials

“Touchstone Essentials takes its responsibilities to consumers and regulators seriously. The

prevalence of social media and the ability for any consumer to create a post about a product

presents unique challenges for direct sales companies. To meet this challenge, we partnered

with Field Watch, a direct sales compliance monitoring platform. We continue to proactively

examine online activity for potential claims and our Compliance team makes every eort to

resolve any issues in a timely manner.”

 TruAura Beauty

 Vollara

 Wine Shop At Home

 Zyia

“Zyia Active LLC (hereinafter “Zyia”) takes its compliance matters seriously and in relation

to the administrative action submits that as part of its compliance eorts at that time, Zyia

contracted with a third-party compliance company, Field Watch, to assist in monitoring its ﬁeld

representatives. Unfortunately, Field Watch failed to notify Zyia in a timely manner of a few

income claims that were online. Zyia’s own compliance department, once notiﬁed immediately,

contacted the representatives and the sites were removed as part of Zyia’s ongoing compliance

eorts. Zyia continues to utilize its own personnel to monitor representative activities.”

About the Direct Selling Self-Regulatory Council

The Direct Selling Self-Regulatory Council (DSSRC), a division of BBB National Programs,

provides independent, impartial monitoring, dispute resolution, and enforcement of product

claims and income representations made by direct selling companies and their salesforce

members across digital platforms. The DSSRC seeks to establish high standards of integrity

and business ethics for all direct selling companies in the marketplace.

About BBB National Programs

BBB National Programs is where businesses turn to enhance consumer trust and consumers

are heard. The non-proﬁt organization creates a fairer playing ﬁeld for businesses and a

better experience for consumers through the development and delivery of eective third-

party accountability and dispute resolution programs. Embracing its role as an independent

organization since the restructuring of the Council of Better Business Bureaus in June 2019,

BBB National Programs today oversees more than a dozen leading national industry self-

regulation programs, and continues to evolve its work and grow its impact by providing

business guidance and fostering best practices in arenas such as advertising, child-directed

marketing, and privacy. To learn more, visit bbbprograms.org.

bbbprograms.org