Consumer News

MLMs Continue to Recruit with Deceptive Earnings Claims investigation finds 98% of MLMs using misleading income claims.


Consumer News

MLMs Continue to Recruit with Deceptive Earnings Claims

I am in over 50,000 in debt from thinking all the money I spent on my business … was a good investment. It was the worst decision by listening to my upline/leaders. I put my blood sweat and tears into this MLM…. I was promised 6 figure income. I was promised yearly trips. I really believed everything they fed us.

This consumer comment to the FTC in 2022 exemplifies what a yearslong investigation into 100 multilevel marketing (Multilevel Marketing – a way of distributing products or services in which the distributors earn income from their own retail sales and from retail sales made by their direct and indirect recruits.) companies found – that 98 percent of the companies misrepresented the amount of money typical participants were likely to earn – misrepresentations that are tremendously harmful to consumers.

In 2022, Samuel Levine, the director of the FTC’s Bureau of Consumer Protection, stated, “By now and for some time, MLMs should know what the law requires and how to comply with it,” noting that “false and unsubstantiated earnings claims cause immense harm to consumers and to honest businesses competing for talent.” Levine went on to explain that, “under the FTC Act, any MLMs and MLM participants that make earnings claims must accurately represent their business opportunity and what a prospective participant is likely to earn. The representations must be truthful, non-misleading, and substantiated.” Levine made the remarks in a speech to the national trade association for the direct selling industry known as the Direct Selling Association (DSA or Association).

In 2017, set out to determine how many DSA member companies were following FTC law when it came to using earnings claims to recruit distributors. That investigation revealed that 97 percent of DSA members were making inappropriate income claims. And while a lot has happened in the intervening years,’s latest investigation shows that one thing has remained the same – the practice of recruiting in the MLM industry using deceptive and unsubstantiated income claims remains nearly universal. This is a particularly worrisome trend given that the majority of MLM distributors lose money or make no money.’s Latest Investigation

This time round, when sought to determine how prevalent the use of deceptive earnings claims are in the MLM industry, it not only included every member of the DSA but also added seven large non-DSA member companies to its investigation to increase the sample size. added these companies because DSA membership has dropped almost 34 percent between 2017 and 2023 – declining from 140 companies to 93.

Specifically, using the June 1, 2023 DSA membership list, and adding eXp Realty, Tupperware, LegalShield, Pruvit, doTerra International, Monat Global and Vida Divina, investigated the 100 companies and found that 98 percent were making misleading income representations in 2023. has collected more than 2,000 examples dating from 2018 to the present of companies and/or their distributors making inappropriate earnings claims on their websites and social media platforms. This, despite the fact that DSA President Joseph Mariano was quoted in 2019 as stating, “Anyone who’s saying that you’re going to make a lot of money [with an MLM] is not telling the truth.”

The claims that has compiled range from assurances of being able to quit your job, to earning a full-time income, to achieving financial freedom. There are also more modest but still deceptive claims of making an extra income or supplemental income (more on this point in the next section). And similar to our 2017 investigation, these earnings representations were not hard to find. For the majority of companies, the claims were front and center on their websites and social media pages. In fact, has a sampling of more than 1,300 inappropriate earnings claims made directly by MLM companies. Other assertions of atypical wealth were found simply by googling the name of an MLM company and “free car,” “travel incentive,” “extra income” or “financial freedom,” resulting in a plethora of posts making deceptive earnings claims. Indeed, we even found a deceptive earnings claim on the DSA website where YOR Health’s company description states, “With the YOR Health Distributorship opportunity, you will make some new friends and experience the fun spirit of everybody involved; all while building towards your financial freedom and living a healthy lifestyle.” notified all companies making inappropriate earnings claims of its investigative findings, as well as the DSA and the DSSRC, the industry’s self-regulatory program funded by the DSA.

Show Me The Money

Jordan Essentials
Damsel in Defense
eXp Realty
Vida Divina
YOR Health
Rodan + Fields
New Earth

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To make rational decisions about MLM participation, potential and low-level distributors need accurate information about what they can reasonably expect to earn after common expenses but MLMs are not providing this type of information to recruits in their marketing material. Instead, the vast majority are hiding the economic realities of joining their organizations in favor of presenting atypical and unsubstantiated earnings claims. Among the MLMs found using misleading earnings claims to recruit distributors were:

[To view a sample of inappropriate income claims made by the 98 MLM companies (and divisions of companies), click here.]

In addition, over the years, has also investigated a number of MLM companies individually, exposing thousands of deceptive and unsubstantiated income claims. Some of the companies examined include IM Mastery Academy (fka iMarketsLive or IML for short), Beautycounter and Pure Romance, companies which were not part of this investigation. To learn about other MLM income claims investigations by, click here.

Most Distributors Make No Money or Lose Money

The earnings reality is extremely different from the marketing hype MLM companies engage in. The FTC warns that: “Most people who join legitimate MLMs make little or no money. Some of them lose money.” Indeed, even the DSA president has acknowledged: “Most distributors will not realize a replacement income, let alone a lavish lifestyle.”

When undertook its income claims investigation in 2017, it found income disclosure statements for 32 out of 140 MLM companies. According to those financial statements, 80 percent of the companies’ distributors grossed less than $100 a month before expenses. For about half the companies, a majority of distributors earned no money at all. This time round, we were able to find income statements for 60 companies (including Canadian disclosures when a U.S. one was not available). Unfortunately, the picture has not gotten any rosier. For those companies that provided enough information to calculate overall earnings, more than 80 percent of the companies’ distributors made $1,000 or less for the year (less than $20 a week) before deducting business expenses. For half the companies, on average more than 60 percent of distributors made no money at all. And these statistics are likely inflating the overall success of the typical distributor as will be examined below.

Moreover, a investigation into non-DSA MLM company LuLaRoe, which settled a pyramid scheme case with the state of Washington in 2021, revealed that between 2016 and 2019, at least 115 LuLaRoe distributors (or former distributors) had filed for personal bankruptcy. In fact, LuLaRoe distributors were more likely to end up bankrupt than to reach the highest tier in the company’s distributor ranks. (LuLaRoe was not part of’s current investigation.)

These findings are further supported by consumer survey studies. AARP published a consumer survey in 2018 that found nearly three-quarters, or 74 percent, of MLM distributors “lose money or make no money.” And a 2018 survey of more than 1,000 MLM participants conducted by MagnifyMoney found similarly dismal results: the typical participant earned $18.18 a month before deducting business expenses.

Given these data, even MLM marketing claims that distributors are making “supplemental,” “extra” or “modest” income – or just “income” – are misleading. For starters, using the word “income” implies that money is being received on a regular basis and that one is earning more than they are spending on their business. But that is not the typical case for most MLM distributors as many of the income disclosure statements that examined revealed. By way of example:

  • Nu Skin states, “many Brand Affiliates never qualify for payment of sales compensation…. On a monthly basis, an average of 23.58% of U.S. active Brand Affiliates earned a sales compensation payment.” This means that more than 76 percent of Nu Skin distributors earned no compensation payments on a monthly basis in 2022.
  • Forever Living writes in its disclosure statement that, “in an average month, 89.8% of purchasers globally did not receive any meaningful compensation or earnings from Forever.”
  • Immunotec’s 2021 income disclosure statement indicates that more than 75 percent of distributors earned nothing ($0) for the year.
  • Mannatech indicates that only 3,128 out of 18,446 distributors earned commissions or bonuses in 2022 – put another way, 83 percent of distributors earned no commissions or bonuses.
  • According to Modere, “many Social Marketers never qualify to earn commissions…. On a monthly basis, an average of 31.5% [of] all active Social Marketers earned commissions,” which translates to more than 68 percent of “active” distributors earning no commissions on a monthly basis in 2022.
  • Neora indicates that in 2022, “64.6% [of Active US Brand Partners] did not earn any cash commissions.”
  • New Earth states that “[i]n 2020, 24% of Associates earned commissions,” which also means that 76 percent of Associates earned no commissions.
  • Plexus writes that “[i]n 2020, an average of 14.4% of all Brand Ambassadors … earned income (excluding retail profits).” Conversely, more than 85 percent of Ambassadors did not earn income (excluding retail profits).
  • Sunrider indicated that in 2022, “[t]wenty-seven percent of all IBOs, active and inactive, on an average, received a payment” – and that means the other 73 percent of IBOs did not earn any payments that year.
  • Vollara’s income disclosure states “approximately 80% of our business associates … didn’t earn a commission in 2017.”
  • YOR Health writes, “As of 10/2023 the number of current YOR Health independent distributors who have not received any commissions, bonuses or overrides is … 76.02% of such independent distributors.”

These admissions clearly support the growing body of evidence that typical MLM distributors make no money or lose money – especially when business expenses are taken into consideration. As 4Life cautions in its disclosure, “Any representation or guarantee of earnings would be misleading.”

Moreover, it is likely that the earnings statistics reported by MLM companies for the minority of distributors that actually do earn money are inflated. Most of the disclosure statements reviewed in this investigation selectively manipulated the data. For one thing, the majority of statements only provided earnings statistics for distributors that remained “active” for the entire year. This can make a huge difference in earnings representations. Tastefully Simple illustrates this point, reporting that, “[t]he average 2022 income for an active consultant was $1,333.” But when all consultants were accounted for, earnings dropped by 42 percent to $776 for the year or less than $15 per week before expenses.

And this tactic of narrowing the sampling size to only include select distributors is commonly combined with other manipulative maneuvers such as providing “averages” for “active” distributors. Earnings averages of active distributors will never inform consumers as to what typical distributors earn because so many of the compensation plans are designed to give most of their money to a few select people at the top. As one MLM CEO stated earlier this year, “There’s a lot of companies out there where there’s not a lot of money at the base. There’s a lot more money going to the top.”

A select few of the income disclosure statements reviewed illustrate this divide as they provide information for both typical distributors and average distributors – tellingly, average earnings were always higher than typical earnings (or in math parlance – the mean was always higher than the median).

  • Scentsy, which separates its distributors into two groups – those who were with the company for the entire year and those who were not – reports that the average annual commission for year-long distributors in 2022 was $2,775.90, while the median for the year was $963.06, which is less than $20 a week. As for the 75 percent of distributors that were not with the company for an entire year, the average annual commission was $228.29, while the median annual commissions was $133.33 (or less than $3 per month before expenses).
  • Reliv International states that “the median payment to all Distributors was $0 in 2022 (the average (mean) total payment made to all Distributers [sic] was $1,418)”
  • According to Mary Kay’s 2022 Canadian disclosure statement, “[a] typical participant in the Mary Kay Independent Sales Force does not earn any commissions or bonuses.” While “Independent Beauty Consultants who were eligible for commissions or bonuses earned … an average of $208 in 2022.”

Moreover, and as previously noted, these figures do not take into account expenses that MLM distributors incur. And when these expenses are factored in, costs can easily exceed any earnings made. Monat, in its 2022 income disclosure statement explained that Monat business expenses “may include, but are not limited to, the purchase of a starter kit, payment of renewal fees, purchases of product samples or inventory, shipping costs, transportation costs, training and educational expenses, and travel expenses. In some cases, these costs and expenses may exceed the amounts earned by Market Partners for MONAT.” The company goes on to say, “you may lose money.”

An ex-Rodan + Fields distributor told the FTC in 2022 of her experience with expenses:

I never received any information on the amount of money I would have to spend to keep my account active each month or how much I would have to purchase in “samples” to get new customers. I was told I just had to buy the product pack and I would be set. This was not true. After spending $1,000.00 on the initial product pack, I was encouraged to buy more product each month to keep rank and stock pile every time there was a sale. I had to pay to go to convention as well. I ended up losing thousands of dollars and making nothing.

At Immunotec,’s investigation found, low-level distributors are told that conventions are “not optional” and that “the investment you make in events is nothing compared to what you are going to see in your business.”

USANA was the only company out of the 60 that published income disclosure statements that attempted to take some expenses into consideration when calculating “active” distributor earnings. In its 2022 income disclosure, the company indicated that 78 percent of active distributors made a “net profit” of $500 or less (less than $10 a week) after taking into consideration the costs for “non-commissionable purchases … and shipping and taxes paid by Associates.” USANA went on to state that, “[n]et profit does not include expenses incurred by an Associate at their discretion in the promotion of their business, nor does it include Associate spending that is deemed personal consumption.”

Common costs that MLM companies in our investigation did not take into consideration when calculating distributor earnings included:

  • Start-up fees, including product bundles
  • Annual registration and renewal fees
  • Monthly business support fees
  • Annual or monthly website costs
  • Office supplies
  • Conference fees
  • One-day company or distributor events
  • Travel
  • Insurance premiums
  • Legal and/or accounting fees
  • Mandatory monthly product or service purchases
  • Online paid search engine advertising

While the information provided in the MLM income disclosure statements reviewed was often extremely misleading even when they were not entirely false, in the aggregate, no amount of manipulation could hide the fact that the typical MLM distributor makes no money or loses money, especially when expenses are taken into account.

Ineffective Disclaimers

Since earnings expectations are “highly relevant” and “often the single most decisive factor” in deciding whether or not to join an MLM, it stands to reason that recruits would benefit from accurate information about earnings potential. But as a general matter, when MLMs market their business opportunity, they fail to disclose what the typical distributor earns. Instead, the vast majority of companies opt for generic fine print disclaimers that do not provide any substantive information but do provide active distributors and the company with the option to blame the recruit if (or when) they fail.

Touchstone Crystal in a recruitment video asks consumers if they’d like to say “yes” to their “dream vacation” and “put a lot more money in [their] pocket[s].” But there is no information with regard to what the typical TC Consultant earns in this video. Instead, the company has a disclaimer at the end stating in fine print, “TC Consultant results depend on factors such as individual efforts and skills, customer base and time devoted to the business and may differ significantly from person to person.”

Thirty-One Gifts’ “Dare to dream bigger” video includes the atypical achievements of some very successful distributors like the representative who paid off her mortgage 24 years early and became “completely debt free.” At the end of the video, the company states, “Representations made about income should not be considered typical or guarantees of your potential earnings or profits as a Thirty-One consultant. For more information, see our income disclosure statement (IDS) …” (For those willing to take the time and effort to find it and do some math, that statement indicates 47 percent of consultants earned less than $100 (or about $8 a month) for 2022.)

Ambit Energy puts it this way in its income disclosure statement:

Building a business requires a long-term commitment to personal and team goals. The amount of effort ICs [aka distributors] put into their business directly correlates to their level of success. Nothing that lasts is built in days or weeks. By working hard, staying focused over time and actively pursuing Ambit-sponsored training opportunities, ICs can improve their abilities, develop new skills and increase their ability to succeed.

Similarly, Amare Global states in its disclosure:

Generating meaningful compensation requires considerable time investment, work, effort, commitment, personal skill, and market conditions. Amare does not guarantee any compensation or financial success, and results will vary widely as no two businesses are alike. This is not a “get rich quick” or guaranteed endeavor. Just like building any business, there are many factors that contribute to building a successful Amare business. is aware of only one MLM company that appeared willing to admit that recruits can fail through no fault of their own in its income disclosure statement – Isagenix, which states in its disclosure, “Even those who dedicate a significant amount of time, effort, and personal funds may not achieve a meaningful level of success.”

And because most MLMs do not clearly and conspicuously disclose what a typical recruit earns, the majority of MLM participants come to regret their choices. The 2018 AARP study referenced above found that nearly two-thirds of MLM participants, or 65 percent, would not rejoin the same MLM knowing what they know now, and 62 percent would not now be interested in joining any MLM. Further evidence of distributor regret stemming from an ill-informed decision is the fact that most participants do not stay on for long: 25 percent of MLM participants surveyed by AARP reported participating for less than six months, 44 percent for less than a year and 68 percent for less than two years.

According to the AARP survey, it appears that in many cases, participants’ change of heart is linked in substantial part to gaining a more accurate picture of actual earnings:

  • Over half, or 52 percent, believed that the company’s representations of their chances of financial success were “not too accurate” or “not at all accurate.”
  • Forty percent felt that the company had misled them.
  • More than a third, or 36 percent, of those who left MLMs cited earning less than expected as one of their reasons for leaving.
  • Twenty-nine percent agreed with the statement, “The commission structure mostly benefitted those at the top, not me.”

In sum, many recruits would make different decisions about MLM participation and spending if they were better informed about the earnings potential.

Industry Responds received responses from a number of companies regarding its findings. For example, Monat said it is committed to presenting the business opportunity “accurately and fairly” and in a way that complies with the law. The MLM said it will remove any inappropriate posts identified by Neora said while its compliance department reviews the examples of deceptive income claims provided by, it will work with the DSSRC to “ensure our adherence to the law on acceptable income claims.” And AdvoCare said it will conduct an investigation and share the results with

In response to receiving copies of the notification letters sent to each of the companies, the DSSRC noted that it “is committed to reviewing the posts that [] brought to our attention and to take the appropriate actions to best address those claims/posts that we determine to be improperly communicated.” And the DSA noted that it was “confident that DSA member companies will review [’s] results with seriousness and respond as appropriate and necessary.”

Regulatory Changes Are Afoot

For far too long the MLM industry has been able to avoid regulatory oversight at the expense of vulnerable and susceptible consumers who are struggling to make ends meet. According to a UC Berkeley Professor of Business, MLM recruiting is aimed at “people who are at vulnerable places in their lives – perhaps someone who’s in a lot of debt, just had a baby, or lost a job.” A business reporter found: “Often, the poor and less formally educated are targeted by multilevel marketing.” A former distributor concurred: “These companies have really targeted these low-income … women … siphoning what little money we have here away from the families who need it because they’ve been sucked into these scams.” The AARP survey correspondingly found that factors positively correlated with joining an MLM included single parenthood, low household income and a recent bankruptcy filing, layoff or other negative life event.

It appears now, however, that the tides may be turning on the regulatory front, especially as it pertains to deceptive earnings claims. In the intervening years since’s 2017 income claims investigation, multiple regulatory proposals have been made to address the MLM industry’s near-universal use of inappropriate income claims. Below are four such initiatives that have been started in the last five years:

  • DSSRC: Cognizant of the mounting criticism of the MLM industry, in January 2019, the DSA created a new third-party, self-regulatory entity known as the Direct Selling Self-Regulatory Council. The DSSRC was created to monitor health and income claims disseminated by all U.S. direct selling companies, not just DSA members. Limited in scope and resources, however, there is no evidence to date that the DSSRC’s actions have in any way persuaded the industry as a whole to change its behavior to conform to legal norms. In fact, more than 20 companies in’s sampling have been the subject of prior DSSRC case decisions (sometimes more than once) for making problematic income claims, including Aloette, Daxen, doTerra (twice), Enagic, Essential Bodywear, Enzacta, Global Domains (twice), Herbalife, Immunotec, jBloom, Juice Plus, Mary Kay (twice), Primerica, Pure Haven, Reliv International (twice), Sanki Global, Shaklee, Southwestern Advantage, Sunrider, SwissJust, Tastefully Simple and Traveling Vineyards.
  • Penalty Offense Notices: Four months after sent a letter to the FTC urging it to implement a penalty offense program directed at the MLM industry, the FTC, in October 2021, sent notices of penalty offenses to more than 630 MLMs, including 99 out of 100 companies that included in its 2023 earnings claims investigation (it does not appear that AdvoCare received a notice). The notices informed these companies that their use of deceptive income claims could lead to significant financial penalties. Specifically, the FTC can now fine these MLMs up to $51,744 when they knowingly engage in a practice (like using deceptive earnings claims) that has been ruled unlawful in a final cease and desist order following a fully adjudicated administrative proceeding. In May 2022, filed a complaint with the FTC urging the commission to use its penalty offense authority against DSA member company Forever Living.
  • Earnings Claims Rulemaking: Recognizing that it cannot reimburse victims of deception using its penalty offense authority, in March 2022, the FTC published an Advanced Notice of Proposed Rulemaking asking if it should implement a rulemaking concerning deceptive and unfair earnings claims, which would permit the agency to not only penalize bad actors but also compensate victims. In response, the FTC received more than 1,600 comments, with a substantial number of those comments focused on deceptive earnings claims made within the MLM industry, including one from urging the FTC to initiate a rulemaking prohibiting deceptive or unfair earnings claims, and the following comment from a former distributor:

I am a former Market Partner with Monat Global. I was part of the company for nearly 4 years. I was regularly encouraged to share how Monat had helped me to pay off credit card debts, car notes, or bills – to encourage people to join my team. The problem was, I was told to share this even if it was not true. I was frequently bullied and ostracized or insulted if I did not agree to push the narrative that the company was financially taking care of me – when it was in fact, not.

  • Business Opportunity Rulemaking: As part of its 10-year review of the Business Opportunity Rule, the FTC sought comment in late 2022 asking, among other things, if the rule should be expanded to include more business opportunities, like direct selling. Specifically, the FTC stated that, “[d]espite the aggressive enforcement program at the Commission, deceptive earnings claims continue to proliferate in the marketplace, and many of them are not covered by the Rule.” In January 2023, filed a comment urging the FTC to include MLMs in its Business Opportunity Rule.’s investigations into the direct selling industry over the past 10 years make clear that MLMs will never voluntarily abstain from making deceptive earnings claims as that would run counter to their pursuit of profits. MLM companies will only comply with the law when the costs of doing so are less than the benefits of noncompliance. The implementation of any or all of the proposed regulations above may be one way to influence the industry’s expected costs by making their deceptive earnings representations prohibitively expensive.

The Fallacy that Deceptive Earnings Claims Are Not Prevalent

In recent years, the DSA has taken to arguing that illegal earnings claims used to market MLM companies are few and far between. It supports this proposition using DSSRC data – arguing that while the DSSRC reviews hundreds of thousands of URLs each year, it only finds a few hundred deceptive MLM income claims every year. However, the dearth of deceptive earnings claims found by the DSSRC does not logically support the DSA’s conclusion that it is because such claims do not actually exist. Rather, the more logical conclusion that follows from the fact that the DSSRC has a hard time finding inappropriate income claims is that its resources and/or tactics for finding such claims are lacking.

By way of example, in 2020, the DSSRC’s first full year of operation, it publicly identified approximately 225 inappropriate income claims made by more than a dozen companies. That year, compiled a sampling of more than 750 inappropriate income claims published by one MLM company – Market America, with more than 450 of those claims being posted by the company in the first nine months of 2020. identified nearly 100 Power Profiles of successful distributors making atypical earnings claims on the company’s website, a playlist of almost 300 Power Profiles on the company’s YouTube channel and more than 200 social media posts from the company using a #financialfreedom hashtag.

Similarly, in 2022, the DSSRC publicly identified a total of approximately 600 deceptive income claims across dozens of companies. That same year, catalogued more than 5,500 deceptive income claims being made directly by a single company – Forever Living. One needed to look no further than the company’s website to start finding the deceptive claims. On the website, there were claims of unlimited earnings, boasts of being able to travel the world and assertions that distributors achieved time freedom. There was also a six-minute video on the site that said, among other things, “we even have a very generous chairman’s bonus program that gives you access to tens of millions of dollars in annual rewards” as the video showed images of distributors receiving giant bonus checks. In addition, the website linked to an “Incentives” brochure, which contained captions such as “Show Me The Money” along with images of large checks, amazing travel destinations and luxury items such as cars and yachts.

Indeed, as our current industry investigation (and the one conducted five years ago) makes clear, the use of inappropriate earnings claims to recruit consumers and convince low-level distributors to remain at MLM companies is a continuing and prevalent industry practice.

Over the years, has identified more than 13,000 instances of MLM companies and their distributors using atypical income representations in their marketing materials, reached out to hundreds of direct selling companies asking them to stop violating the law, and urged compliance with the law at several MLM industry conferences. Rest assured,’s efforts will continue for as long as it takes to ensure that reliable and accurate earnings information is available to all consumers in order for them to make informed decisions about whether or not to join (or stay) with any MLM company.

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