Most Deceptive Ads of 2024
Here were some of the worst ads TINA.org investigated this year.
What we learned upon taking a closer look at this new MLM.
“If you want or need to make money, we have what we think is the most viable, sustainable business model that’s going to allow you to make money quickly and in the near term but also sustainably in legacy fashion. That’s right, those are bold words but that’s my heart, that’s Nick, that’s Larry’s, and we know there’s a lot of people hurting and looking for a real legitimate home-based business that they can align their gifts, their talents, their treasures with.”
These are the words of Eric Allen, who along with Nick Sorenson and Larry Lane are the cofounders of Nélo Life, a new MLM that is recruiting consumers during a “pre-launch” phase. Right now, the only part of its “LIFEstyle memberships” available to the public is a travel membership but the company promises many perks for members to come.
Consumers can pay $79 (an initial $20 fee plus an ongoing $59 a month LIFEstyle membership fee) to sign up to become a Nélo Life affiliate and participate in the company’s business opportunity.
Our interest piqued, and after receiving a consumer tip, TINA.org took a closer look at this new MLM on the block. Here’s what we learned and what you should know about Nélo (pronounced knee-low) Life.
Allen, Sorenson and Lane were top distributors in an MLM called FinMore, formerly known as TranzactCard, which marketed a banking card.
According to Scott Kufus, another former FinMore/TranzactCard distributor who has also made the switch to Nélo Life (as an affiliate, not a cofounder), his previous MLM had its “ups and downs.”
“We had a business model that was flawed in a way that it wasn’t legal for a while so they had to sort of rein it back in and then bring it to a point where it would sustain itself in the marketplace,” Kufus said in a March webinar.
Kufus tells FinMore distributors to sign up with Nélo Life as a “Plan B” – and to bring their teams or downlines with them.
There is no mention of the cofounders’ previous involvement with FinMore/TranzactCard on the Nélo Life website. A recent blog post titled “Radical Transparency in Nélo Life” merely states that Allen, Sorenson and Lane “were active together in a previous network marketing company, but were not on the ownership side.”
In response to a request for comment by TINA.org, Allen reiterated that Nélo Life’s cofounders “never held any corporate position at Finmore/TranzactCard.”
“Furthermore, none of the ownership group from Finmore/TranzactCard has any involvement – passive, financial, or otherwise – with Nélo Life,” he said.
With regard to Kufus’ attempts to recruit FinMore distributors to Nélo Life, Allen said:
No one who chose to join us from TranzactCard/Finmore was given a free position here or any guarantees. … Also, please note that the majority of people joining our company had nothing to do with TranzactCard/FinMore.
“We are not attempting to build a successful business on the ashes of another,” Allen told TINA.org.
Though Nélo Life is only three weeks into a “pre-launch,” TINA.org found the company already making problematic income claims about its business opportunity. (This comes just a little over two months after TINA.org published its industry investigation findings that 98 percent of MLMs misrepresented the amount of money typical participants were likely to earn.)
In addition to Allen’s quote above about making money fast and “sustainably,” which implies that affiliates will receive money on a regular basis like they would with an income, the cofounders’ webinar also discusses the hypothetical earnings affiliates can achieve.
And Kufus claimed that affiliates “can earn thousands of dollars in April and even a greater income in May and June.”
But how can Allen and Kufus substantiate such earnings claims if the MLM hasn’t even fully launched yet? In fact, Allen told TINA.org that Nélo Life doesn’t plan to publish an income disclosure statement with the earnings of its affiliates until “after our first year in business.”
The FTC, in a new business guidance for MLMs, answers the question “Is it okay for an MLM to tell potential participants about how they could hypothetically earn money?” this way:
A hypothetical earnings scenario — such as, “if you recruit 30 people who each sell $1,000 of product each month, you will earn $1,500 a month” — may imply that the assumptions made (e.g., the number of people recruited, the amount sold by each recruit) are consistent with the actual experiences of typical participants. If the assumptions are not so because most participants do not achieve them, the earnings scenario likely would be false or misleading to consumers, violating the FTC Act.
It goes on to state:
If an MLM does not have evidence of the typical earnings of its participants (including any costs that its typical participants incur), it should refrain from making any earnings claims and ensure its participants do the same.
In communications with TINA.org, Allen said the Kufus video had been “removed at our mandate to Scott Kufus, who was also given a warning.” TINA.org confirmed that the Kufus video has been taken down. The cofounders’ webinar, however, remains in publication.
But misleading earnings representations aren’t the only things to watch out for…
There is no compensation plan for consumers to review on Nélo Life’s website. But according to the cofounders’ webinar, it appears a primary way to make money as a Nélo Life affiliate is by recruiting others into the organization.
In the webinar, Lane is tasked with outlining the “ways to get paid” with Nélo Life’s “unified global pay plan.” Though the webinar indicates there are multiple ways to get paid, Lane describes the “unified bonus” as “the brilliance of our compensation plan.”
Here’s how the unified bonus works: You pay $79 to sign up to become an affiliate and get someone else to pay $79 to become an affiliate and then that person gets two more people to pay $79 to become affiliates within 30 days and you get a $75 unified bonus.
Allen wraps up the presentation telling viewers:
You should be thinking strategically. Who did I want on my two line, that’s your first tier, who do I want on my four line, that’s your second tier in the matrix, who might be coming in on my eight line or third tier in the matrix…
For those of you who like visuals, here’s a diagram shown on the screen during the video presentation:
Yes, we see the pyramid shape too. The FTC, in determining whether an MLM is operating an illegal pyramid scheme, says it “will look at, among other things, the behavior the MLM is incentivizing in participants, what income expectations it creates through its marketing, and how its participants are trained and compensated.”
In our request for comment, TINA.org asked Nélo Life how its distributors (i.e., affiliates) are primarily compensated. In response, Allen said Nélo Life affiliates “are compensated only through the purchase of our $59 USD/month LIFEstyle Memberships, as well as various products and services that will soon be available on our LIFEshop e-commerce platform.”
The Nélo Life cofounder also told TINA.org that the company has received “numerous testimonials from LIFEstyle Members who have saved significantly on travel bookings through our services,” and that the comp plan “is readily accessible in our Affiliate’s Digital Office.”
“Unlike many others, we do not publicize the Compensation Plan on our front-end website because we aim to be a customer-focused company,” he said.
Nélo Life claims on its website to offer “a comprehensive suite of services designed to enhance your lifestyle, travel experiences and financial well-being.” But as of early May, the only product available to LIFEstyle members is LIFEtravel, the travel membership that promises “insider pricing” on hotels, resorts, cruises, vacation rentals and more.
Allen told TINA.org that LIFEshop, which will carry nutritional supplements, will open its virtual doors in the “next two weeks or sooner,” and LIFEstreaming, which will feature online classes taught by the “world’s top experts and thought leaders,” will launch “in the latter part of May.”
Then there’s LIFEtrade, an investment trading platform that is only available outside of the U.S. and Canada.
“While we are confident that LIFEtrade is fully legal to operate in both countries, our legal counsel has advised us to avoid launching initially in these regions due to the ever-changing regulatory environment,” Allen said.
Find more of our coverage on MLMs here.
Here were some of the worst ads TINA.org investigated this year.
Supplement MLM takes down dozens of deceptive claims following TINA.org investigation.
A disproportionate number of students that have defaulted on their students loans attended for-profit colleges.