An Employment Scam in the Financial Services Industry
A Warning for Recent College Grads and Others New to the Financial Services Industry

[Financial Scam Home]

CONTENTS:

Introduction

How The Scam Works

Fighting Back

Contact Author




A List of Some MLMs, Past and Present

Some have been investigated by the FTC; some are no longer in business. Believe me, there are many, many more. There's one starting up and one going out of business every minute, so it isn't worth keeping the above list up-to-date. This list doesn't even include the many, many companies utilizing MLM structures and practices who do not fit neatly under the current MLM legal classification. Before you get too excited about any "business opportunity", remember how many before you thought the same of their own biz opp!

You may search this page by using CTRL+F in your browser window.

1-800-PartyShop
1 800 Wine Shop
121.tv
1CellNet
1network.com
1st Family
1Voice Worldwide
2by2.net
2000now.co.uk
21st Century Nutriceuticals
21stNetwork.com
2-Day Slimdown Momentum Worldwide
2Xtreme Performance International
4E-Corp
4 the Good Life
4Life Research, LC
5LINX Enterprises Inc
7startrading Pvt. Ltd.
8Point Communications
A1 Internet Service Provider
aatcm
A Better Chance PTY
Abundant Health Ltd.
Abunza
Acai Plus
Acara
Accelerated Internet Income Strategies
Accentz
Acceris Communications
Accountanet Ltd
Achievers Unlimited
Communications
Achieve Success Team (AST)
Achievers Unlimited, Inc.
Acme Trade Link
AcoMark Concepts Pvt. Ltd.
Active 8
Act II Jewelry, Inc.
ACTIS Global Ventures
Active Business Solutions
Active Life
Adapt-a-Life Inc
AdCalls Inc
Addcell
Adora LLC
Ad Powerone
Adsavers
AdSurfDaily
Adora LLC
Advanced Health Care Systems / Dean Distributors, Inc. / Cambridge Direct Sales / Medibase
Advantage Conferences
Advantage International
Advantage Marketing Systems, Inc
AdvantageMax
Advantage Nutraceuticals
AdverWorld
Advita Energy
AdvoCare International
Aerus LLC / Electrolux USA
Affinity Just-2
Affinity Lifestyles
Affordable Energy
Affordable Luxuries
AFM Technologies
Agel Enterprises LLC
Agent Nation
AGLOCO
AGS Wholesale Distributor
Agua Dulce
Aihu Inc
Albert Konder Collection
alcome perfumes & cosmetics
AllXClub
AIM International
Aim Renaissance Ltd.
Airlume, Inc.
Airnex Communications Inc
Airseed
Akuna Health Products
Albert Konder Collection
Allegrovision Marketimg pvt.ltd.
Alive International
AliveMax
Alive Worldwide
AlkalineLife.com
All That's Natural
AllAdvantage.com
All Dazzle
Alliance Nutritionals
Alliance Technology Intl (ATI)
All Jeweled Up
AllXClub
Aloette Cosmetics
Alpha 2000 Ltd
AlphaCom, Inc.
AlphaTonics
Alpine Industries, Inc.
AlpineV
Amazon Herb Company
AMC Corporation
Ambit Energy
AmCall Long Distance Services
amega global
American Bill Money
American Bio Labs Inc.
American Communications Network (ACN)
American Dream Nutrition
American Freeway 100
American Health and Financial
American Image Marketing
American Income Life Insurance
American Longevity
American Petroleum Promotions
American Shoppers Network (ASN)
America's Future
America's MLM Consultants
America's Team
American Telecom Network (ATN)
Americore Mortgage
Americraft Cookware
AmeriKare
AmeriLat
AmeriPlan Dental Care
AmeriPlan USA
Ameriquest Travel
AmeriReach
AmeriSciences
AmeriTalks.com, Inc.
AmethystShells
Amigo Health Inc.
Amkey Inc.
AMS Health Sciences (Advantage Marketing Systems)
Amsoil
Amsonline
Amway / Quixtar / Alticor / Team of Destiny
Ancestry.com
Ancient Legacy
Anew International
Angel Company
Angela Moore Inc
Anise Cosmetics
Annása
Apeus
Aqua America
aquachi.us
Aqua Genus
AquaSource
ARAS Tiernahrung
Arbonne International, Inc.
Ardyss International
Armchair Tycoon
Aromatic Delights
Array International
Art & Soul Inc.
Art and Soul in the Home
Art Finds International
Artistic Impressions, Inc.
Art of Better Living
A Sandy Clough Tea
Asantae (Inflammation Solutions)
Ascend Technologies International
Ascential Bioscience
Ashley's Garden
Aspire Worldwide
Aspiritus
Assantae (Inflammation Solutions)
Assured Nutrition Plus, Inc.
ATG Technologies
AtHome America, Inc.
ATN
A Touch of Tahiti
ATX Inc.
Auction
Diner
Aularale Cosmetics Inc
AuraStella
Auto Dream Team Building System
Avalar Network, Inc.
Avalar Real Estate Alliance / Avalar Real Estate & Mortgage Network
Avalla
AVAR Direct
Avedis Group
Avon Products, Inc.
Awareness Corporation
AwarenessLife Corporation
AxsWorld
AyurVida
Azante Jewelry
Aztech Financial
B&F System Inc.
BabyCrazy
Baby Splendor
Bacchus Weinhaus
Balance Company
Balanced Living Company
BAMBRIA.com
Bangalore True Value Marketing PVT LTD
Barefoot Books
Barclays System
Basic Energy & Affiliated Resources, Inc.
Bausparkasse Mainz
Baywood International
Bazi
Bead Retreat Ltd.
Beads of Hope LLC
Beat The System
BeautiControl
Beauty Counselors of /du Canada Inc.
Become International Inc
Bel'Air
Benchmark USA
Benefactory
Berry Tree
Bessemer Sales
Bestline
Best Travel Spot Online
Better Universe
Bhartiya Online Service System Pvt. Ltd. (B.O.S.S.)
bHIP Global
Big Bang Infonetwork Pvt. Ltd.
BigBanyanTree.com
Big Book Direct
BigBooster7Million
Big Co-op.com
BigDot1
Big Ear Inc.
Big Enough
BigSmart
Big Yellow Box
Billion Dollar Travel Network
Bimini Essentials
Bing Han Enterprises Ltd
Binney & Smith At Home, LLC
BioBlueprint
BioComfort Produkte zur Gesundheitspfledge GmbH
BioCrave Health Products
Bio EnerChi Company
BioGenica
Biogenx Global
Biogime
BioGreen Systems Inc
Bio Lumen Essence
Biometics International, Inc.
BioNovix
BioPerformance
BIOPRO Technology
BIO-WATER
Bio-Wealth
Birthday Shack
Bittersweet Candle Co.
BizAdigm
BizAdSplash
Biz Calling Cards
BizzBuzz
BizNas.com
Black Magic 95
Blessed Hope Communications
Blessings Unlimited
Blue Strawberry Bath
Boagie Report
Bobri
Bodega Chocolates
Bodies Best International
Body Alive International Inc. / Oxygen Labs
Body Electric
Body Extreme
Body Shop at Home
Body Shop Direct
Body Soul Elements
Body Wise International, Inc.
Bodyguard Technologies
Bookbiz
Books and Beyond, Inc.
Bookwise Books
Boresha Coffee
Boston Finney
Boudoir Bliss
BOV Intimates
BPI Worldwide
Brain Garden
Breakfast Club
BR Global Inc
BRIDAL ACCENTS, LTD.
Bright Minds - Critical Thinking
Brite Music Inc
Briteage Health Corporation
Broad Point Communications
Brown Bag Gourmet Goodies
Brown Bag Party
B's Purses & Accessories
BuildReferrals.com
Bulletin Board
BurnLounge
Business Cybernetics Ltd.
Butterfly Worldwide LLC
Cabionline
Cabouchon International
Cajun Country Candies
Call The Planet (CTP)
Calls for Kids
Cambridge Diet / Cambridge Health Plan Ltd
Canadian Diamond Traders
Candle Creations by Sandie
CandleWealth International
Can-Talk
Cantos Marketing Pvt. Ltd.
Cantralliance
Canyon World Quest
Capella Group Inc
CardConcepts
Care One, Inc
Care Entree
Carico International, Inc.
Carlisle
Carlson Craft
Carolina Fine Cookies
Caruba International
Cashcard Worldwide
Cash Cards International
Cash Club
CASHCulture.com
Cash Evolution
Cash Leveraging System
Casino Cash
CCO Telecom
CDDiscounter.com
CDI Telecom
Celebrating Home
Celebration Fashions Inc
Celebrations by Lillian Vernon
Celestial Harvest
Cell Tech
Cellphone Toolbox
Cello In A Box
CellWireless Corporation
CenterSource Life Systems
Cera Bella
Chamelle
Champion Communications
Charmed Moments
Charmelle
Changes International Inc.
Chantal B - Paris
Character Building Company
Charitable Partners
Charity Bond
CharityFirst
Charmed Moments
Charmelle
Che-Ching
Chef Selections
Chef Specialties Company
Cherish Designs
Chesapeake Bay Company
Chews 4 Health
Chez Ami
ChicBoutique at Home
Chicken Soup for the Soul Supplements
Chic Pursenality Inc.
Child-Shield-USA.com
Chi Machine
Chu's Pearls LLC
Circles of Life USA
Citizenre Corporation
Claire Murray Home Gallery
Clark Enterprises
Claudia Jean Collection
ClayTime Inc.
Clearock, Inc
Cleary Hudson Constructoin (CHConstruction)
Clear Your Credit, Inc.
Cleure
Clever Container
ClickBank
ClickIncomes.com
Close to My Heart
Club Atlanta Travel
ClubBucks Rewards Progrm
Clubco
Club Depot
Club Joe Coffee
Club Midas
ClubShop Online
Clustered Water
Coastal Vacations
Cobra Group
Coffee Club International
CoffeeFair
CoffeeFirst LLC
Cognigen Networks Inc
Colesce Couture (Cameo)
Colonial Structures Inc
Color Connections
Color Me Beautiful
Comforts of Home Inc
Comfort Zone / PRISM ENTERPRISES
Competitive Games Inc
Concorde Group
Conklin Company, Inc.
Connect 24/7
Consumer 1st
CONSUMER DIRECT
Consumers Direct Buyers Network (CDBN)
Conybio India
Cookie Lee Inc
Cookie Life
Cooksey Keepsakes
Coral Connection
CORE Club
CoreVital International
Corlink Communications
Cossets Marketing Pvt. Ltd.
Cosway Phils, Inc.
Country Bunny Bath & Body
Country Charm Candle & Soap Co.
Country Club
Country Peddlers & Company of America, Inc.
CouponsMan
CPL Media
Crafts ala Cart
Crafty Kids Pty Ltd.
Create-A-Book Inc
Creations
Creative Memories
Creative Network International
Creative Photo Concepts
Credit Development International
CRK Interactive Inc
Cristian Lay
Cruise to Cash Vacations
Culture Farms
Custom Corner
CUTCO / Vector Marketing Corp / Alcas Corporation
Cutting Edge International
Cutting Edge Vitamins
Cybergold Inc
CyberWize.com
Daisy Blue Naturals LLC
Dale Networks Pvt. Ltd.
Dane Nig Ltd
Dare2BU Records Inc
Darius Marketing, Inc.
Darswinkle's Delights
DASH Minerals
Dashyn Delights
Data Life Associates
Data Process Marketing (DP Marketing)
Dautol
DAXEN INC.
DaySpring
Daystar
DEAXIS LLC
Debt Free America
Debt Free Publishing Inc /
DebttoFreedom.com
Debt Zapper
Deesse International Gmbh
Delfin International
Demarle At Home, Inc.
Denali Health Sciences
Designed By You
Desire Parties
Destinations By Mava D.
Destinations Fashions
Destiny-2000 ltd.
Destiny Telecomm International
DeTech, Inc.
Devas Online Business Marketing
Dewsoft Overseas
DHS Club
Dialer Freedom
Diamond Cash Club
Diamond Club of America
DiamondCreek Candles
Diamond Depot
DietBlends
Digital Crown Holdings Ltd. (DCHL)
Digital Dynamix (Trillion Dollar Trend)
Diolink
Diotek India Limited
Direct 2U Fashions Pty Ltd
Direct Educational Technologies India, Ltd.
Direct Matches.com
Direct Nutrition Inc
Discount Home Shopping Club (DHS)
Discovery Toys
Discovery Toys Inc.
DK Family Learning Educational Products
DNAINDIA
DoItAll Travel
Dominator Clothing
Doncaster
Doodles Direct
Do Re Me & You!
Dorling Kindersley
DoTerra Earth Essence
Dove Chocolate Discoveries
Downline Building Group
Dragon Slayer
Dr. Glass Window Washing
Dream Impressions
Dream India Concepts
DrinkACT
Dr. Nona International, Ltd
DropshipDesign.com
Dr. Organics, Inc
DS-MAX U.S.A. Inc. / Innovage
DSX
Dubai MLM
DubLi Network / DubLi.com GmbH
Dudley Beauty Corp LLC
Dudley Products
Dutch International
DWG International
Dynamic Essentials
Dynamic Freedom, Inc.
Dynamic Wealth
Dynamite Marketing
Dynasty of Diamonds
E3Flix Inc
Earth Angels
Earth Essence
Earth Pride International
Earth Safe & Wellness
Technologies Inc.
Earth's Elements
Earth Tribe Aromatics
Easy Daily Cash
Easy Marketing Inc.
Easy Multitrade International
Easy Pha-Max
Easy Postcard Marketing
Easy Way International
Ebiz.com Pvt Ltd
ebiznas
eBiz Rotator
eBook Wholesaler
Ecash Trust
ecb4U
Eclipse Jewelry in Motion
ECN
EcoEnergizer
EcoQuest International
eCosway.com
Eden River
eDirect America
Edmark International
EDT International
Education Explorations
E. Excel International
efusion
E-GroceryCoupons.com
eHostingBiz.net
Eiro
EIS Emergency Information Services
Eismann International Ltd
eKaire
Elearnexpress.com
Electric Life
Electrum International
Elektro & Metallwaren Vertriebs GmbH
Elements Home Spa
Elite Choice Nutritionals
Elite Profit Network
ELIXIR-HEALTH
Elnapress Inc.
Elysee Scientific Cosmetics
Emancipation Network
emarket pros
Emerald Coast News
Emerald Passport (Profit Masters)
Emilys Attic
Éminence Organics
Empexis Corporation
Empire Business Brokers
Empower Life International
Empower Net
Enagic USA
Enchanted Potions
Enchanted Scents & Potions by Design
Enchanting Scents Designs
Energetix Magnet Therapy
EnergyCel Marketing Group
Energy Release
Enerstem (Entrenet Nutritionals)
eNewLife
English Collectables
Enhanced Living International
Eniva Corporation
Enjo Ltd
Enliven International Inc.
Enlyten
Enrich International
Entech Corporation
Entertain With Ease!
Entertaining at Home
Entrenet
Entrust America
Envigra
Envion
Environmental Construction Tech
Environmental Nutrition Network
Enviro-Tech International
EnvisionCC
Enzacta
E'OLA Products International
EonDeck.Com, Inc.
eorbiter
Epic Network International
Epicure Selections
EplanetParadise
ePyramids
Equinox International / Trek Alliance / Advanced
Marketing Systems / BG Management
Equitynet
Equity Now America
Esa-Star Touch International
Escape International LLC
Espial USA
Esquire Marketing
Essante Corporation
ESSE Designer Sterlling
Essen USA
Essential Bodywear
Essentially Yours Industries Inc.
Essentials Blue Line Cosmetics Ltd.
eStarNetwork
Esther
Esteem Jewelry
Esteem Now Inc
Esthetics International Group Bhd
Eterna Health
Eternal HGH
Etherea Aromatics
Ethnic Expressions
Ethos Environmental Inc
Euphony Communications
Eurobotanicals Inc.
Eventus International
EverydayWealth
Evolution International
eWorldMedia.com
eWorldnet
Excel Telecommunications / Vartec Telecom
Executive Connections Network
eXfuze
Explose EU
EXOVAP Ltd.
Express Online
Extreme Powerline
Extreme Proteam
Extreme Research Corp
ezeADZ
EZEEBIZ.COM PVT. LTD.
E-ZineLibrary.com
EZ Wealth by Design
Ezze net
F.A.I.T.H. Company
Family and Friends Financial
Family Books at Home
Family Health Network
Family Integrity Buyline, Inc (FIBI)
Family Manager
Family of Eagles
Family Solution
Fantastic Life Systems
Fantasy Inc
Fantasy Lady
Fashion Suitings Pvt. Ltd. (RCM)
Fax Box Network
Federal Chamber of Commerce
Federal Financial
FemOne
FIACom Inc
Fifth Avenue Collection
Filway
Financial Circuit
Financial Destination Inc
Financial Freedom Society
Financial Health Research Institute (FHRI)
Finanzas Forex (Evolution Market Group, Inc. )
Fine-me-a-trip.com
Fine Choice Food Club
Finest Accessories Inc
Firelead Affiliate Network
Firestone Farms Down Home
First Financial Security
First Fitness International
First Marketing Group
First Place Realty
First Quadrant International
First Step
Five Dollar Gimmick / Buzzard Holdings Ltd
FixMyCrib.com
Five Star Auto Club
Flavon Group kft
Flashnet
Flight of Fancy
Flint River Ranch
FNUSA
Focus International Credit Card Plan
FoodTech International
Footprints International
For Earth Incorporated
Forever Green
Forever Int'l
Forever Living Products International
For Every Home
Forever Young Pty Ltd
For Every Body
For Every Home
ForMor International
For More International
Forte Builder (New Vision)
Fortuna Alliance
Fortuna Inter Nusantara
Fortune21
Fortune High Tech Marketing
Fortune in Motion
Fortune Quest
Forum Technologies
For You, Inc.
For Your Pleasure Inc
Found You Online, Inc
Fountain of Life .
Fourfront Limited
Four Seasons Candle Co.
FOURSTP MARKETING PVT. LTD.
Fragrant Lemon Peel (the) TFLP
France Bed Sales Co Ltd
France Luxe
Freebie Force
Free Card Matrix
FreeCoralCalcium
Freedom America
Freedomgel
Freedom One Services
FreedomQwest
Freedom Rocks
Freedomstar Communications
Free Gifts Galore
Free India Concepts
FreeLife International
FreeNetSolution
Free Network
Freeway 100
Free Yourself
Freitas Bueno Consultoria Juridica
French Rags
Frequency Foods
Friuli Thermolana SRL
Frozen Lease
Frutaiga
Fruta Vida
Fruitaiga
Fuel Freedom International
Fuel Legacy International / eefuel
Fuel Zone
Fuh Jen International Co Ltd
Fukufuku Co Ltd
Full-Circle Success
Fuller Brush Company
Fund America Inc
Fun For Life Club
Fun Quest of America
FUN Unlimited (Power Pops)
Funky Diva Shop
Furnished Garden
FutureMart
FutureNet, Inc.
Future World Corporation
Fuzzy Zoeller Productions, Inc.
Gabby Goodies
Gakken Credit Co Ltd
Gakken Home Study Co Ltd
Gakushin Co Ltd
Galaxy Products & Services Inc
Galaxy Products & Services Inc
Game of Opportunity, LLC
Gano Excel USA Inc
GASAG Direkt
GmbH
Gas Net
GasUpUSA
Gathering of Goddesses
GBG
GCMI Long Distance
G'Core Group Inc
GemCap Equity Management, Inc
Geminet
GEM Lifestyle
Generations of Health AB
Genesis Pure
Genesis Secret
Genesis Today, Inc.
GeneWize Life Sciences
Genossenschaft Arbeitsheim Wangen
Geon Limited
Getaway Club
GetGasFree Marketing Group
Get Moving Today (GMT)
Get the Word Out!
ghpSport
gibLine
Giffarine Skyline Unity Co Ltd
Giftware Plus
Gioielli International Inc
Giving You Credit, Inc.
GLA International, Inc.
GladNet Corporation
Glass Bracelet
Global$nowball
Global Assistance Network for Charities
Global Cause
GLOBAL COLLABORATORS
Global Communications Solutions Inc.
Global Community
Global Domains International (GDI)
Global Elite Marketing
Global Equity Marketing and Global Equity Lending (World Leadership Group)
Global Gold Marketing
Global Health Trax
Global Interactive Investment Club
Global Learning Ltd
Global Network Development
Global Network Marketing, Inc.
Global Nutrition Network
Global Options NZ Ltd
Global Prelaunch
Global Procurement Corp
Global Prosperity Group / Global Prosperity Marketing Group
Global Resorts Network
Global Travel International
Global Village Market
Global Vision
Global Wealth Trade Corp
Global Wellness Club
Globalwon
GlobalFX Network
GlobalTelework
Global Travel Trends (PRT Travel)
Globestar
Globion
GNLD International
Gnnuri Inc
Go4Millions
Go Auto Club
Go-Go for Life International LLC
GoHFT
Going Platinum, Inc.
Goji Juice
Gold Canyon Candle
Goldbiz Inc
Golden Chemical Pty Ltd
Golden Neo-Life Diamite International (GNLD)
Golden Nutrition
Golden Pride International
GoldenRAM Direct Inc
Goldiger Marketing
Gold Mine International
GoldQuest
Goldshield Elite / Changes Intl.
Goldshield Group Ltd.
Gold Unlimited
Gonis GmbH & Co.
Good Books & Company, LLC
Good Life International
Good Nature Company
Good to Grow Garden Outfitters, LLC
Got Zip Inc
Gourmet Coffee Club
GoYin
Grand Ware Co Ltd
Great American - The Wholefood Farmacy
Great HealthWorks
Great Life International
Great Life Products.com
GreaatShades
Great Thornton
Green & Health Bio Marketing (P) Ltd,
Green Mountain Energy
Green Planet Bio Products
Green Valley
Greenwood Health Systems
Greenzap
Greeting Cake Company
Greta's Bake at Home Cookies
GRI Telecommunications
GroceryBiz
Grove Marketing
GT Trends
Gulf Coast Nutritional Inc (Noah's Ark)
H2Oil Corporation
Habitude International
HAKA Kunz GmbH
Hakaju Institute for Health Science Ltd
Half Water Half Gas
Halpage Overseas PVT LTD
Hanbul Co Ltd
Hankook Glandoman Publishing Co.
Happy Family Corporation
Happy Gardener
Ha-Ra Nederland
Harmonde
Harmonika Dinamika
Harvest America
Harvest Grove
Harvest Home Candles
Harvesting America
Hatsuda Co Ltd
Hawaii HerbalTech Corporation
HB Products
Healing America
Health 4 Wealth
Health & Nutrition Network
Health Driven
Health Dyamics Research Company
Healthe-Choice
Health First Technlogies GOHFT
Health for Life
Health-Mor
Health Thru Nutrition (HTN)
Health Voyage
Healthient
Healthy Homes Marketing Pte Ltd
Healthy Living Pvt Ldt
Healthy Outlook
Healthy Pet Net / Trilogy International
Healthy Steps
Heart Warming Creations Inc
Heart Warming Goodness
Healthy Coffee LLC
HealthyPetNet
Heim & Haus, Produktion
Heim International Co Ltd
Helicolor France
HelpWithTeenagers LLC
Henn Workshops
Henri Maire
Henry Beautiful
Herbalife / Newest Way to Wealth
Herbitrol
Herbazone
Herbo International Pvt.Ltd
Herios AB
Heritage Health Products
Company
Heritage Makers
Herway Inc
H.I.D. International
Hi Energy Weight Control Inc
High-Desert (M) SDN BHD
Highlights-Jigsaw Toy Factory, Ltd.
High Opportunity
High Velocity Video
Petroleum Enterprise (HOPE)
High-Tech Safety
Higher Ideals
Highlights-Jigsaw Toy Factory, Ltd.
Hillary's Blinds Ltd
Hindustan Lever Network
Hits USA
Hobson Audley
Holbrook Cottage, Inc.
Holiday Magic
Holy Tea Club
Home & Garden Party Ltd
Home-Business-Funding
Home Business Group
Home Business Incubator
Home Business Monthly
Home Choice
Home Direct Lts
Home Interiors & Gifts, Inc.
Homeline Electronics AG
Homelend / Homenet
Homemade Gourmet, Inc.
Homemailers Programme
Homemaker's Idea Club/Company
Home Owners Network Club
Homes For Living
HomeTec
Home Travel Agent
HomeWare Creations
Honeysuckle Cove
Horizons Marketing Group
Hot Conference
Hottpixx.com
House of Commons
House of Health
House of Lloyd (Christmas Around the World)
House of Sara Lee
Household System Co Ltd
HRP Marketing PVT LTD
Hsin Ten Enterprises USA, Inc. (HTE USA)
Hunt'n Biz & Fish'n Biz
Hy Cite Corporation
IamVoip
Iberinox S.A.
iBuzzPro
ICI
ICON Communicator
ICR Services, Inc
IDA Marketing Services
Idea Concepts
I Deal In Travel
Ideal Health International
Ideal Solutions Int'l
I.D. It! Plates
Idn-Nu Skin INternational
Iexalt Family
iFreedom
Ignite Inc
Ignite/Stream of Energy
Igonet
iKobo, Inc.
Ikuei Co Ltd
Ikueisha Co
ILC - Laurent Cristonel
iLearningGlobal.tv (ILG)
I-LINK Worldwide LLC
I Luv My Pet Inc
Images
Imagine2020
Iman
Imandi Rewards
Immunocal
Immunotech Inc
Immunotec Research
Imn Dot Com Pvt. Ltd.
Imogen Concepts Inc
iMoms (Internet Moms)
Impact America
Imperiale World Services SPA
Importupp Ltda
Immunotec
IMX
IncomeWorks
INCOMNET COM (SIMPLE2 NET)
Incorporated Company Flare
Incredible Products
iNetStar International
Infinity800
Infinity Downline
Infinity Int'l Health & Beauty
Infinity Success
Infinity2 Inc
Initial Outfitters
Initials Inc
InkVogue Ltd T-A Vogue Care
In-Home Art
Initial Outfitters
inmediaONE Bertedsmann Direktvertriebe GmbH
Innerfeel
InnerLight International Inc
Innovage
Innovative Technologies Corp of America
INS Enterprise SCN BHD
Inside-n-out
Inspired Aroma Inc
InstantEbookBusiness.com
Integrated Synergy
Integris Global, LP
Intelligent Nutrients
Intelligent Nutrition Systems Inc.
Interactive Ventures Corporation
Interfield Systems Inc
International Direct Mail Network
International Galleries (IGI)
International Global Opportunity Network LLC / IGONET
Inetekk.com
Interiors by Totally Tropical
International Business Network, Inc.
International Heritage
International Metals & Trade
International Philanthropists Society
International Team Works Inc. (ITI)
International Wealth
Internet 4 Families (I4F)
Intimo Lingerie Pty Ltd
In Touch Communications and Networking Inc.
Intway World Corporation
iNutrition
Invisus Direct
Inwayy
IONIQUE
IONYX International
IPC International Publishing Co AB
IPowerBiz
I Remember When
Iron Curtain Labs
Isagenix International
ISI Value Network
ISPVIP.Biz / ISPVIP.net, LLC
isXPERIA
ITI
It's Life
ITV Ventures
It Works! Marketing Inc
Ixora Corporation SDN BHD
Jafra Cosmetics International, Inc.
Janglefish
Janome Sewing Machine Co Ltd
Japan Life America Corp
Japan Life of India
JBP Associates Ltd
Jean Guthrie Beauty Care
Jenny Lane SA
Jerky Direct
Jet Set Life Technologies Inc
Jeunique International, Inc.
Jewelry at Home
Jewels by Park Lane
JewelWay
JGO
Jiff-e-Books
Jigsaw Toy Factory Pty Ltd
J Lynn Designs, Inc
J.M. Fino Lda
JM Global
Jockey Person to Person
Joielle LLC
Joker 88
Jolica
Jordan Essentials
joseph wealth systems
Jowalet Co Ltd
Joy Enterprises
Joystar
JRJ Co Ltd
JS Homestyle, LLC
J-S-R International
Jubilee International
Juice Plus
Juki Co Ltd
Julian Hill Parfum AB
Juliana Collezione
Jurak Corporation Worldwide
Jus International
Just Add Guests
Just Deutschland GmbH
Just Ducky Originals
Just For Fun
Just S.A.
Justine Pty Ltd
Justine Avon
Juvio
Kabel Deutschland Managment GmbH & Co.
Kadima Inc
Kanebo Ltd
Kanosis
Kara Vita LLC
Kaire International / Kaire Nutraceuticals
kallis kreations
Kara Vita, LLC
KareMore International
Kasey's Coupons
Kat's Coffees
Kazil Express USA
Kedia Infotech Limited
Keibunkan Co Ltd
Kele n Co
Keller Williams Realty
Kelly's Kids
Key West Aloe
Kharmisma Gizindo Perkasa (New Image)
khushibiz
Kidz Boulevard
KickBrix
Kiiera
Killer Buzz
Kimberly's Closet
Kinetic Resource International
Kingdom Treasures
Kings Choice
KingsMaker
KingsWay Inc
Kirby Company (Vacuum)
Kiotis
Kirks Folly Design
Kitchen Fair / Regal Ware
Kleeneze
K-LINK International
KM.net
Knutek
Kompass Infosolutions Pvt. Ltd.
Koscot Interplanetary
Krystal Planet
K Sanko Co Ltd
Ky-Ani Sun / Kyani
Kyoiku Tosho Center Co Ltd
Kyowa-Life Co Ltd
Kyowon Group
Ladybug Garden Parties
Latasia & Company
L'Bel Paris
L'Bri Pure N' Natural
Laboratorio Somar Sa De CV
Laboratorios Schule S.C.A.
Ladder Publishing Co Ltd
Lady Emily
Lady Remington Jewelry, Inc.
Ladybug Garden Parties, Inc.
Lafayette Miracle Solutions
Laga Designs
Lajann AB
Lake Industries Company
Lametco Int.
Lanfar International Co
La Principessa By Principe SAS
L Arome International
Le Reve Pty Ltd
Lars OG Lene KL & R AS
Latasia & Company / Latasia Jewelry
Leaders Club
LeadGusher
Leading Concepts
Lead Lightning, Inc
Leads2YourSuccess
L.E.A.P. (Life, Education & Prosperity Inc)
Leaving Prints
Le Club Privé
Learner's World
Learning AIDS (S) PTE Ltd
Learning Dynamics SDN BHD
Learning is an Art
Leaving Prints
LEETTRAFE INC. (Phils.)
Legacy for Life, Inc.
Legacy International Health Solutions
Legacy Network
Legacy USA (DCV)
Le Gourmet Gift Baskets Inc.
Lemongrass Spa Products
Le Naturel
Le Natural Int'l
Let's Do Tea LLC
LetsGetPaid
Leveraged Gold Club
Lexli MD, Inc.
Lexxus International
LFI Group
Lia Sophia
Liberty Financial of North America Inc.
Liberty Health Benefits Inc
Liberty Health Net
Liberty International
Liberty League International (LLI)
Liberty Management Group
Lies und Spiel Hausparty
LIFECARE
Life Dynamics International
Life Education And Prosperity
Life Force International
Life Link Ltc
LifeMax
LifeMist Home Products LLC
Life Plus International
LifePath Unlimited
Life Plus International
Life Prints
Life Quest Corporation
Life Science Technology
Life Sciences Products, Inc.
Life Sciences Technologies
LifesMiracle
LifeSpan International
Life Spring International
Lifestyles USA
LifeMist Home Products LLC
Life International
LifeTek Corporation
Lifetime Income Trusts Ltd
LifeTrends International
LifeVantage
Lifevision
LifeVita. Inc
Life Wave
Life Without Debt
Lighthouse America
Lightyear Alliance
Lightyear Wireless
LikeWear
Likisma Aromatherapy Limited
Likisma Presentations Ltd
LIMU Company LLC
Linen World
Lingerie of Hollywood
Lingua Publications SDB BDH
Linguaphone Institute Ltd
Links Worldwide Inc.
Link2BeFree
Linz Corporation Co Ltd
Lion Best SDN BHD
Liquidity International
Liqua Health Marketing Phils. Corp
Lisa Jean (Division of A Basket Case)
LISM
Little Book Company Ltd
Little Black Dress Company
Little Guy Network
Live Wire Learning Pty Ltd
Living Scriptures, Inc.
Livinity
Liwoton AG
Local Ad Link
Locality Com
Longaberger Company
Longevity Network, Ltd.
Lorimont Enterprises Pty Ltd
Lorraine Lea Linen Pty Ltd
Lotto Magic
Lotus Dragon International CO Ltd
Lotus Learning Private Ltd
Low Carb Gourmet (LifeStyle Gourmet)
LR International
LRL By You
Lucky Charms
Lunesse
Luxe Jewels
Luxelle International Inc.
Luxindo Raya
Lux International AG
Luxor Network SN BHD
Luzier
LWS Freedom
Lyc International
Lydia Home Collection
Lyon Legacy
M2CGlobal
Madame Chic Kosmetika Ab
Madame V
Maddy Moo Creations
Madison Dynamics
Magic Learning Systems
Magnapak
magnumiq (team effort, intl)
Magnus Enterprises Inc
mahadreams
MAHAMAZA.COM
Mail, The
Mail Order 2000
MakeALifeBetter.com
Make It Happen
Make Lots of $ in the Net
MakesParties.com
Maknom Int Inc
Mandura
Mannatech, Incorporated
Manna Valley
Mark I of North America
Market America, Inc.
Market Day Gourmet
Market Depot
Market India
Marketing Makeover Generator
Market Place International
Market to Success
Marlo Quinn
Marpé International
Martinique Beauty Pty Ltd
Mary Kay, Inc.
Mary Kay/Lesley
Marlo Quinn
Master Art Ab
Master's Miracle
Mastery Media Inc / Mastery TV
M.A.T.A.L.
Matchmaker Parties Ltd
Matol Botanical International
Matolindo Primantara
Matrix5
Max.com
Maximum Benefits Company
Max International
MAXeGEN
Max GXL
Maxiform SDN BHD
Maxim International
Maximus Intermediaries Limited
Max Int'l
Maxous
MAXXIS Group, Inc. / MAXXIS 2000
Mayberry America
MBF Discount Card SDN BHD / MBF Sales, LLC
MBU Inc
MCM Networking (M) SDN BHD
Medical Designs Inc
MedSources, Inc.
Mega Health
Mega Holdings Ltd
Megan's Pantry
Melaleuca Inc / The
M.O.M. Team
Melilea International
Melissa Soft Solutions Pvt Ltd
Mellenia
Menage Innovations Inc
Mentoring For Free
Mentor Network, Inc.
Mentor's Club
Mentors In Motion
Metabolife International
Metrin Life USA, Inc.
metro marketing solutions
Metropolitan Aromatherapy Home Party Company
MHC Co Ltd
Mia Bella Scent Sations
MIA Maralyn's Intimate Apparel
Mia Mariu
Michele Baratta atHome
Migalo
Miglio SA Ltd
Mihosugata Homp Co Ltd
Mike Fitzgerald
Miki Corporation
Mikimoto Pharmaceutical Co Ltd
Millennium 2000
Millenium Glotech Sdn. Bhd.
Million Wishes
MILLIONAIRES GROUP
Mill Valley
M.J. Life Enterprises Ltd.
Minebea Shinpan Co Ltd
Mini-IQ
Mintmail
Miracle2LA
miracle4life.com
MIRACLE ASSOCIATES PVT. LTD.
Miracle Mail .com
Miranda's Skin Care Sverige AB
Miraspice AB
Missing Link Education
Miya Inc
ML International
MLM Banner Exchange
MLMDynamite Inc
MLM Community .COM
MLM Search .COM
MLM World News Today
MMF India
MMOGULS
M-Net Telecon AB
Modicare Ltd
Momentum Nutrition & Health / Momentum Health Products, Inc.
Momentum Plus
Momentum Worldwide
Monarch Health Sciences
Monarch Realtors
MonaVie (Monarch Health Sciences)
Mondragon Industries Inc
Moneykey
Moneylegs Mortgage
Moneylogic
Money Manual
Money Makers United
MoneyMatters Network
MoneyTalks
Montaigne (UK) Ltd
Morgan Dane Designs
Morganics
Morinda International Inc (Tahitian Noni Int’l)
Mortgage Medic
MOR Vacations
Motivera AB
Motor Latte, Inc.
Mount Biz
Mountain Gourmet
Movie Club Plus
Moxxor
MPAD Technology Group, Inc.
M.R. Watkins Co Pty Ltd
M Studio Inc
M Tay & Co Pte Ltd
Multiforsa AG
Multiple Income Solutions
Multiple Income Streams
Multi-Pure Drinking Water Systems
Multipurpose Associates
Multiple Streams of Income
Muscle Dynamics Fitness Network, Inc.
Musical Magnets
MusicMovers, Inc.
MVP Network
MWR Systems Ltd
MXI Corp (Xocai)
My4Life
My7Diamonds
My-Friend Co Ltd
My Great Vision
My Leisure Business
Mylene Pvba
MyO3World
My Precious Kid
MySiteInc.com
My Tax Man
MyVideoTalk
My Wireless Rep
My World Marketing C C
MyWorldPLUS
My.WS
N2K International, Inc.
Namyang Aloe Co Ltd
Nanci Corporation
Nano Power Booster USA Inc
Naris Co Ltd
National Agents Alliance
National Alliance for a Debt-Free America, Inc.
National Benefits & Services
National Bodycare
National Calling Card Associates
National Companies, Inc.
National Lending Corporation
National Mortgage Associates
National Safety Associates (Juice Plus+)
Native American Nutritionals
Natur All Plus SA De CV
Natur Health
Natura Cosmeticos S.A.
Natura International
NaturaLab
Natural Air Products / Alpine
Natural Bodycare
Natural Bodylines
Natural Connections
Natural Health Trends / (NHT Global)
Natural SA
Natural World
Natural World of Aloe Vera
NaturaLab
Naturally Anew Comercio Ltd
Naturally Plus
Nature's Aromatherapy
Nature's Bodycare
Nature's Gold International
Nature's Healing Aromatherapy Inc
Natures of Scandinavia
Nature's Own
NatureRich
Nature's Sunshine Products Inc
Nature's Very Best
Nature's Wealth
Nature's Youth Direct
NaturScience
Navin Life Guards & Marketing Private Limited
Nebulis
Nebullis Network
Nefful U.S.A., Inc.
NEFX
Nelson's Secrets
NestFamily
Netcradle LTD
Net Lifestyles
NetmarkAid
Net Masters
Netrix, Inc.
Nettincome.net Limited
Networker2000.com
Networkers Club
Network Marketing Business Journal
Network TNT
Networth Cashflow Systems
Net Worth USA
NeuroGenesis, Inc
Neuro-Health (Becalm'd)
Neways
Newbie Club
New Century Life
New Image International, Inc.
New Inc
New Life Technologies
New Module Farma
New Plan Network(NPN) (AKA:WebShooter Multimedia)
New Precedence LTD
New Quest International
New Resolution Inc (NRI)
New Sun Health
New Vision International, Inc.
New Vision USA, Inc.
Neways International
Newport Ltd
Nexagen USA
NexGen3000.com, Inc.
NextFit
NEXT INDIA
Next Level Club
Nexx, LLC
NFX
NHT Global Inc
Niagara Therapy Manufacturing (Aust) Pty Ltd
Niagra Therapy (NZ) Ltd
Nichiden Co Ltd
Nihon Home Create Inc
Nihon Kenko Zoushin Kenkyukai Canada
Nikken Inc.
Nikken Global, Inc.
Nina McLemore
Nipo Co Ltd
Nippon Bunka Center Co Ltd
Nippon Josephine Co Ltd
Nippon Meard Co Ltd
Nisim International
Noahs Ark Workshop
Noah's Quest
Noevir USA, Inc.
Northern Lights at Home
Nourish The World
Nouveau Cosmeceuticals LLC
Nouveau Riche University
NouvelleHEALTH
NOVAGENIX
Nova Nutria International AG
Nove Chrome
Novia Nutria International AG
Npower Energy Sales Ltd
nPro
NQI / NQIUSA, Inc
NSA (Juice Plus)
NSE
NSGLife
Nu Creations, Inc.
Nubotanic Int.
NuChoice International
Nueworld.com Commerce, Inc.
Nu Gen World SDN BHD
Nuforever International
Nugenix
NuLegacy Rx card
Nu-Life International
Nu LifeStyles, LLC
Nu-Med, Inc.
Nuove Idee SRL
NUPRO
Nuriche
NuSkin Enterprises / Big Planet / Pharmanex / Photomax Studios
Nussentials
Nutrafina
Nutrapower
Nutrend Health Institute, Inc.
NutriCare International
NutriHealth USA
Nutri-Metics International Ltd
Nutrimetics By Avalla
Nutrimetrics North America
NutriSource
Nutri-Stahl Pty Ltd
Nutrition For Life International
NutriSystem Direct
NutriTech
Nutrition For Life
Nutriway Marketing
Nutronics International / The Coral Connection
Nutronix
NuVANTE
NuVerus
Nuvo Cosmeticos
N.Z. New Image SDN BHD
O3World
Oak Co Ltd
Oasis Lifesciences
Oasis Wellness Network
OC Rebates
OceanCity Network
OceanGrown International
October Trading
O Delizioso
OHANA Health & Wellness Company
Ohhira Nutrition (M) SDN BHD
OLA International
OmegaTrends
Omnicup
Omnilife
Omnitrition International
OM SAI ARC (P) LTD.
Once Upon a Charm
Once Upon A Family
OneBode
ONE Group
One Source Worldwide Network
Onejon Commerce Inc
Online Exchange
OnPoint Direct
Onroad Co Ltd
Onyx International
Open Door Mortgage
Open Invitation From
OpTecs
Option Energy
Option Services Ltd
Oragen International
Orange Leads
Oreck Corporation
Orenda International LLC
Orbit the Talking Computer / Orbitalk
Organic and Natural Enterprise Group
Organics Made Easy
Oriflame Cosmetics
Original Solutions Inc
Oro Club
Orovo
OTDirect.com
Our Family Favorites
OurHouse, a Division of EnvirOx, LLC
Our Own Image
Our World Network
Outback Secrets
Oxford Savings Club
Oxyfresh Worldwide, Inc.
OZMOZIZ
P.M. International
PA Associates
paid2purchase.com, LLC
Paint Box Company
Pamper My Baby
Pampered Chef Ltd
Panfele
Pangea Ltd.
Paradigm Health International
Paradigm World Marketing LLC
Paramount Technologies
Paris-Cable
Partners in Vision International, Inc.
PartyGals
Party Juice INC
PartyLite Gifts, Inc.
PassionFire International
Passion Parties by Amy
Passport To Wealth
Patchwork & Preserves
Paychecks For Life
Pay It Forward Marketing
Payline
PCI Integrated Manag. Services
PC's 4 All
Peak Energy Science
Peak Marketing Group Inc
Peak Performance Nutritional Products
People's Empowerment Group
Peoples Network
PeoplesWay.com
Performance Plus Nutritionals
Perfam Cosmeticos Ltda.
Perfect Wealth Formula
Perpetual Income Trust / Lifetime Income Trust
PetLane
Petra Fashions, Inc.
Petromagic
PetShop.biz
PetsParty
Pharmalliance
Pharmanex
PHD Products
PHENIX ( A UNIT OF GEET MARKETING PVT.LTD)
Phoenix Educational Systems Inc
Phoenix Trading
PHOENIX USA
Phone Broadcast Club
Photomax
Physicians Research Laboratories
Picture Perfect Scrapbook Company LLC
PictureRite Corp
Pierre Laforest GmbH
Pierre Lang
Pink Papaya LLC
Pinnacle Comms. Int'l. Inc.
Pinnacle Quest International
Pinnacle Plus
Pioneerbizz.com
PixMeUp
PlantMakers
Plantronics
Platinum Travel Club
PlayCheckDirect
Plaza & Janes Editores S.A.
please mum
Plexus Pink
Plexus Wireless
PM-International Nutrition and Cosmetics
Poga Moonga
Pola Inc.
Polydor Culture Club
Pony Express
Popular Club, Inc.
Postie Fashions
Powerful Warrior Group
Power of Nature
Power 2 Marketing LLC
Powerline Marketing Group
Power Mall
PowerPlusMPG (Dreamlife Products)
Power Pops
Power Wave Marketing
PRAI Beauty Events
Precis, Inc.
Preeya Home Study (P) LTD
Premier Designs, Inc.
Premier Health Link
Premiere Conferencing
PremierNet Plus
Premium Connections, Inc.
Pre-Paid Legal Services Inc.
Prepaid Online
President Natural Industrial Corp
Pres-Les
Prex Co Ltd
PriceNetUSA
Prima Rosa
PrimeBank Ltd
PrimeBuy International
Primequest International
Primerica Financial Services (PFS) / AL Williams
Primeristar
Princess House, Inc.
Princess Pearl Co Ltd
Private Quarters
Private X Collection AB
ProAutoResponder.Com
ProBuilderPlus
ProCard International
Procosmetics
Profit Central Inc
Product Driven
Pro Image International
Project 21
Project 60
Project Internet
Project Wellness
Projoba International
Pro Image International
PROLIFE GmbH
Prolifehealthcare Ltd
Pro-MA Systems
ProMedX Health Inc
Pro Monde Travel
PRo Net Communications
Pro-Sales Direct Pty Ltd
Pro Shop at Home
Prospect Planet
Prosper Club
Prosperity Automated System
Pro Star International
Pro Star Nutrition
ProStep Inc
PRONET INC
Pro Travel Network
Proven Formala
prowealthSOLUTIONS
Pro Young International
PRSI
PRT Travel
Prudent Concept Marketing Pvt. Ltd.
PS I Love You
Psix Limited
PTF Financial
Public Gold
Publifacil
PUJA Syncotex (I) LTD
Purchase Plus Buyer's Group
PurchasePro
PureInvestor
Purely Gourmet LLC
Pure Romance by Sheila
Pureworks
PURSEnality Etcetera
Purse Party Inc
Qing Mei Inc
Qi Technologies
Qivana
QuakeDog Inc
Qual-Life
Quantum Leap
Quantum International P Ltd
Quantum Wellness
Quest Group International
Quest International Ltd
Quest IV Health Products
QuestNet
Quiet Place for You
Quiet Places
Quorum Global
Rachael International
RadioFreeCash
Ragged Bears Publishing
RAG NETWORKS
Rainbow Enzymes Inc.
Rainbow Systems / Rexaire (vacuum cleaners)
Rainbow World
Rajat Consumer Services Pvt Ltd
Raj Kamal Tours & Travels
Rapido
RAISING WEALTH TREE MARKETING PVT LTD.
Rawleigh International Ltd.
RBC Life Sciences
Rbcrbc Multimarketing Pvt Ltd
RBID
RCM Business
Rday Health & Wealth
REAL ESTATE MLM . BIZ
Real Life Solutions Inc.
Realtopbuildwell (p) Limited
Redin International Pty Ltd
Red Rock Naturals
ReddRox
Reel Thing
Reeva Forman Pty Ltd
ReferralWare International
Regal Greetings & Gifts Inc
Regal Ware, Inc.
Reid Enterprises
ReishiGo,USA Inc.
Rejuvenate Worldwide
Reliv International, Inc.
RemedyBlue
Rena Ware International, Inc.
Renaissance For Life
Rennaissance – the Tax People
Repspace
Resorts 360 Vacation Club
Resource A Day
Retire Quickly Corporation
Retire On Spending
Retire Quickly Corp.
REV180
Revell SDN BHD
Reverse Funnel System
ReVita
Revolution Forever Marketing Pvt. Ltd
Revolution Road
Reward Co Ltd
Rexair, Inc. (Rainbow Vacuums)
Rexall Showcase International
RFI
R-Garden Internationale
Riccar Company Ltd
Rich Plan of Florida
Richmont Direct
Ricoh Educational Equipment CO Ltd
Ricoh Elmex Corporation
Ride-on-Music
RideOn Records
Rifiotex SRL
RightLife
RightSize
Right Solution
Rising International
RITZ MARKETING CONCEPT PVT. LTD.
RJJ Co Ltd
RMC Group Inc
RMP INFOTEC PVT LTD
Rocky Mountain International Silver and Gold, Inc.
Rodan and Fields
Rommanel
Rosemary Collections
Rotoplay
Royal BodyCare, Inc.
Royal Cosmo Co Ltd
Royal Farms
Royal Freedom
Royal Network
Royal Prestige (Hy Cite Corp)
ROYAL VISION MARKETING PVT.LTD.
SafeLeads
Safer Places
Sahara Care House
Saladmaster, Inc.
Sales In Minutes
San Michele Fashions Pty Ltd
Sani Clean Co Ltd
Sankaido Co Ltd
San-Mark Co Ltd
Sante & Beaute International Holdings Ltd
SANVI OPPORTUNITIES
Sara Lee DE
Sarah Coventry
Sargem Jewellery Pty Ltd
Save It and Make It
Savory Naturals
Scents4Relaxation
Scent-Sations Inc (Mia Bella)
Scents Unlimited
Scentsy Inc
Scentura Creations
SciMedica
ScrapBiz
Scriptures
Sea Alive
SeaAloe
Sea Biotics
Seaborne, LLC
Seasilver USA
Sea Energy
Second Nature Bath Body
Secrets of Millionaires
Secure America
Secure Independence
Secure Life
Secure Lives
Security Network Inc
Self Indulgence
Send Out Cards.com
SeneGence International
Sensaria Natural Bodycare, Inc.
SERENITY
Seriesse International
ServiceMaster
Set For Life Inc
Setting Traditions
Sevea
Sex Toys for Wholesale
sfi marketing group
Shade Clothing COllection
Shades of Color
Shaklee Corporation
Shanghai Lanfar Trade Ltd
Shanghai Nu Skin Daily Use & Health Co Ltd
Shaperite Concepts
Shape Your Future
SharedProfit.com
Share the Wealth
SharpSigns
Shine Co Ltd
Shoppers Central
Shop To Earn
ShopWurld
ShrimpUSA / Shrimp Boat USA
SHS Group Mkt (P) LTD
Shuang Hor Enterprise (Taiwan) Co., Ltd
Shure Pets Inc
Sibi
Sibu Inc.
Signature HomeStyles
Silit France
Silpada Designs
Silver Buyers Club
Silver Cache
Silver Freedom Coin Inc.
Silver Snowball
Simple Graces
Simplexity
Simplibiz.com
Simply Because
Simply Divine
SimplyFun LLC
Simply Sushi
Simply Successful Pty Ltd
Singles Club No. 50
Singles Resource Network
SISEL International
Six Figure Income / SFI Marketing Group
Skin Spa Therapies
SkyBiz
Skycom
Sky Music Private Limited
SkyQuestCom Pte Ltd
Slender Now
Slick Smiles
Slim Body Lifestyle
Slumber Parties
Smart Circle International
Smart-Mart, Inc.
Smart Responder.COM
Smartmail.biz
SmartNetworker
Smart Travel
SmartWay To Wealth
SMC Specialty Merchandise Corp
Smile Education
SMK
SND Marketing Pvt.Ltd
Snow Fresh
Soaring Eagle Ventures
S.O.B.M
SoftWebOnline
Solana International
Soma Co Ltd
SomaLife International
Sony Creative Co Ltd
Soteria Corp. / It Works Marketing
SouldEcor
SoulPurpose
Souls Essentials
Sound Technology Sales Corp
Sound Travels
Southern Heritage Inc
Southern Living at Home
South Main Designs
Southwestern Company
Spa Destinations
Spa Girl Parties Inc.
Spa Sensations Ltd
Spa Style
Sparks International
SPECTRUM LIFESTYLES
Spedia
Speedial Limited
Spick and Span
Spider Web System
SponsorDaddy
Spread The Word Ministries
Sportron International
Sportsnuts.com
Springboard
Springtex Limited
Springtree Company
Spring Wellness
Stamp Affair
Stampin' Up!
Stanley Home Products
Stanhome SPA
Star 2000 Online
Starfire International
Star International
Starlight International
StarScapes
STC Leaders Inc.
Steak Buyers Club
Steel My Heart
Stella & Dot
StemTech HealthSciences Inc
Sterling Bay
Sterling Life India
Stimulife
Story Teller
Story Time Felts
Stoxrus
Strauss Heart Drops
Strong Future International
Strategies for Success
Stream Energy
Streamline International
Studio Dee
Stuff a Friend
Success Motivation Institute
Success University
Suddenly Slender / The Body Wrap
Summit International Inc
Sun Alpha Co Ltd
Sun Charm
Sundew International
Sun Hope International Corporationa
Sundrier Mexico Inc
Sunjell
Sunless Expressions
Sunpak Corporation
Sunrider International
Sunrise Direct
Sunset Candle Company
Sunset Gourmet Food Company
Superlife
SupraLife International
Supra/Life Soaring Eagle Ventures Inc.
Suprederm International Co Ltd.
Surfing2Cash
SurfWithUs.net
Sureal International
Sunshine Products
SurveyScout.com
Surya Pagoda Mas
Susquehanna Soaps and Sundries
SVPS LTD
Sweet Berry Designs
Sweet Celebrations
Sweet Living
Sweet Prairie Soap Company
Swiss Colony Occasions
SwissJust Corporation
Symmetry Corporation
Symmetry Direct
Symmetry International
Sympatico Boydworks Pty Ltd
Synaura
Syndicate Management Services
Synecorp.com
Synergy WorldWide / Nature's
Syntec, Inc.
Syntek Global Inc
Tabolizer, LLC
Tahitian Noni International
Taiwan Naturally Plus Co Ltd
Taiway Marketing (M) SDN BHD
Taiway MLM International Co Ltd
TAKE FIVE MATRIX
Take Shape for Life Inc. / Medifast
Take Shape For Life (Medifast)
Talent Warehouse
TALISMAN
TalkAllDay-Net
Talk Fusion
Tall Poppy Creations Pty Ltd
TamaNoni, Inc.
Tanner Companies LLC
TapCity
Tara Prima Megah
TARRAH Cosmetics, Inc.
TaserNetwork
Taste D-Vine
Taste of Gourmet
Taste of Home Entertaining
Tastefully Simple, Inc.
TaxRefund1040.com
TBA Two
TBN - The Benefits Network
TBS Britanica Co Ltd
TDK Core Co Ltd
Tealightful Treasures
Team Beachbody
Team Effort International
Team Everest
Team Life Changes
Team National/ National Companies
TeamNET International
Teaporia
Tel3
Tel-a-Nation.com
Telco Global Communications (UK) Ltd
Telecard International
Telecom Global Communications LTD
Telecom-Pros
Telecom Solutions
Telehop
Telephone Information Systems (Pleasure Time)
TeleWrx / Converge Global, Inc.
Telme
Tenpaid Co Ltd
Teraforma Health
TerraCeutics LLC
Terra Mezzo
Tesko Educational Systems Co Ltd
T.F.A. In-Home Inc
That's My Baby Pet Parties, Inc.
Thevenin S.A.
Thirty-One Gifts
Thordson Pictura Verlag Ag
Three Girls Who
Thrivent Financial at Home
Thumbs Up
Thyme In The Kitchen
Tianshi Health Products, Inc.
Tickle Your Fancy
Tidal Wave
Tidings of Love
Tiens
Time To Celebrate Home
TIP's Inc.
TIRUPATI NETWORK MARKETING (P) LTD.
Tiscali
TJ Clark
Tlc Insurance India PVT. LTD.
TMII
Tokyo Gas Co Ltd
Tomboy Tools Inc
Tom Danley’s Tape of the Month
Tomorrow's Treasures / Memory Bank
Too Cute Cake
The Topline
Top Line Creations
Topp Industri AB
Tornado Ag
Total Body Wellness
Total Life Changes (TLC)
Total Link, The
Total Reach Marketing SDN BHD
Total Success Solutions Inc
Totalife International Co Ltd
Totally Tropical Interiors, Ltd.
Totalnet Plus
Total Wellness International
Touch of Tahiti
Touchstone Crystal Inc
Tow Angel, LLC
Toward Ultimate Financial Freedom
Towel Buddies
Traci Lynn Fashion Jewelry
Trade Exchange Network
Traditions Inc
Traffic Directory .COM
Traffic Oasis USA
Traffic Swarm
TrafficWave.net LLC
Traidcraft Plc
Transform America
Trans-Global Investments Universal
TransNet Connect, Inc.
TranSynd
Travel Almost Free
Travelencia
Travel Legacy International
Traveling Vineyard
Travel Makes You Happy
TravelMax International
Travelogia
TravelOne International
Travel Promotions International
Travel Reaction
Travelstar
Travelworks International
Traverus Travel
Treasure Traders International
Trek Alliance
TrendMark International, Inc.
Trilogy Essentials International Inc.
TriLokin International, Inc
Trim International
Trimurtiics
Trinkets N Dreams
Trio Co Ltd
TriStar Enterprises, LLC
TriStar Online Sales Corporation / Suble Energy Solutions
TriUnity International
Trivani International
TriVita Way International
Tru Chocolate
TruDynamics (Travel Dynamics)
TRUE MATRIX
True Wealth Creations
Trump Network
Trusted Health Products
T-Shirts With A Personal Touch
TSWBIZ
Tupperware Corporation
Turning Point
TuRobotNetwork
Two Sisters Gourmet
Ubifone
UCAN2 Opportunity, Inc.
UCC TotalHome
UCS (dba) Americans for Constitutional Action
U Design Jewelry
Ulimate Asset Protection
Ultimate Energy
UltimateMatch
Ultra Corp
UltraeStore
Ultralife, LTD
UltraLuster
Undercover Records
UndercoverWear Collection
Uni-Body International
Unicity International, Inc.
Unicity Network, Inc.
Unilife International Co Ltd
Unimax
Unique Baby Boutique inc
Unique Opportunities Inc
Unique S.A.
Unique Solutions
United First Financial
United Green Marketing
United Herbal Sciences, Inc
United Net Services
United Prosper Club
United Super Account Program
Univera Life Sciences
Universal Direct
Universal Lifestyles
Universal Wellness Network
Universal Network
Uppercase Living
U-Profit
URI International
Urilife
USAloe
USANA Health Sciences, Inc
Usborne Books At Home
US DIAL1
US Health Advisors
U.S. Safety & Engineering Corporation
USTELETRICITY NETWORK
Usteletricity Network
Utility Warehouse Discount Club
uVme
UWinFinancial
Vachaud Distribution S.A.
Valedalife
Vanda
Vanilla Gold Accumulation Plan
Vanstahl International SA
Vantel Pearls in the Oyster
Vaxa International
VBS India Ltd.
VCI MARKETING (P) LTD.
Vemma Nutrition Company
Vera Corp World Netsafe
Vergance
Versatile
Vestige Marketing Pvt. Ltd.
Viamore Corporation
ViaViente Ltd
Vibe Anti-aging
Vibrant Performance
Victorian Memories
Village Peddler & The Iron Country Store
Vintage Wines Direct Pty Ltd
VIP Domotec Italia SRL
Virgin Cosmetics Company
Virtual World Direct
Virtual World Trust
Virtually Free Internet
ViSalus Sciences
Visee International
Vision 20/20 (thinAir Wireless)
Vision For Life International
Visions Group of America
Vision International People Group
Vision Quest Worldwide Inc
Vision Travel
VitaBorn
Vitacheck
Vita Craft Corporation
Vitacube
Vita Genesis
Vitagenex
Vital-C Health Products International, Inc.
Vital Force Technology LLC
Vital Life
VitaLife 2000 / Nature's Youth
Vitality Corporation / LifeChoice Corp.
Vitality Labs
Vitallity Life Choice
Vitalus
Vitamark International
VITAMIN POWER, INC.
Vitamist
VitaNet, LLC
Viva America Marketing Taiwan
Viva Life Science, Inc.
Viva Marketing
Viva Toxic Free
Viviane Woodard Skincare
Vivannes Collection Australia Pty Ltd
Vizion One
VMCSatellite Dish Network
VM Direct (Helloworld)
Voice-Tel
VoiceWave Team
Volare AB
Vooka Technology
Vortexity
Vorwerk USA Company, LP
Votre Vu
Voyager Group Inc.
VR Tech Marketing Group
Wachter's Organic Sea Products
Waiora USA
Wallstreet Prophet
Wardson International
Warm Spirit, Inc.
Washington Softwares LTd.
Watch 24 Pty Ltd
WaterOz
Waters Phillippines
Watkins Incorporated
Waves International
WBG holding
Wealthening.com
Wealth Masters International
Wealth Pools International
WebProsperity
Webs to Multilevel
Weed Music Distribution Service
Weekenders USA, Inc.
Wellness Associates
WellnessDistributors.Com, LLC
Wellness International (WIN)
Wellness Movement Corp
WellnessOneWorld
Wellness Premium Plus
West Bend Company
West Bend Cookware
West Coast Weight Loss
West House Transport (S&E) Ltd
Western Marketing
wfhTravel
White Lily Candles
Wholefood Farmacy
Wicker Plus, Ltd.
Wildtree Herbs, Inc.
WillauTronic LLC
Wilton At Home
Winalite International
WineShop at Home
WININDIA Network Marketing Private Limited
Win Network
Wisco Co Ltd
Wodafo Biotech R&D INC
womens wealth and wellness
Wonder Lite
Wood's Potpourri
Woofgangs
Woongjin Coway Development Co
Wordpress Project
Word of Mouth
Word To The Nations
WorkSmart Ltd
World Ale Inc
World Book, Inc.
World Book Childcraft
World Book Learning Journey
World Class Network (WCN)
World Connect
World Games - WGI
World Golf Corp
World Group Securities
World Marketing Alliance (WMA) / World Financial Group (WFG) / National Lending Corp. (NLC) / Aegon Financial Group World
World Maruhati
WorldMatic
World Net Inc
World Net International
World Perfume
Worldprofit Inc.
World's Standard of Online Poker
WorldVentures Holdings, LLC
WorldxChange Corporation
WORLDWIDE
World Wide Alliance Corp (WWA USA)
World Wide Internet Marketing
World Wide Link Inc (dba) TheWWWLink
Worldwide Network Incorporated
Worldwide Wealth Creators
Worth
Wowgreen
Winlife Healthcare Inc
WQdirect.com
WT Powers
Wynlife
X2 Consulting Pty Ltd
XanGo LLC
XELR8
X-One Co Ltd
Xocai Healthy Chocolate
Xooma Worldwide
XPI Online
XtremeHealth Formulas
Xymetri
Xzotto
Yates Security Holdings Ltd
Yellowbubble.com
YOBISC
Yoffi Fine Jewelry
YOR
You5.com
YOUNGER LIVING, INC.
Youngevity, Inc.
Young Living Essential Oils
Your Family First
YourNetPlus.Com, Inc.
Your Promised Land
Youthflow Corporation
YTB Travel Inc. (YourTravelBiz, YTB International)
Yubi Co Ltd
Yves Rocher Direct Selling
Zavita
ZeBlooms, Inc.
Zenith 4 the Planet
ZenZuu
Zepter INT (UK) LTD
Zermat International LLC
Ziami GmbH
Zibycom.com
Zija International
ZINGIT.COM
Zippi.com
ZizBiz
Zoegetics
Zonenet Online
Zrii
zWallet
ZU-B International
Zurvita

Some Sources: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24
www.ftc.gov, www.sec.gov

 

 

Links and Resources

If you stumbled in the back way because you were searching for info on MLMs [multi-level marketing organizations] or SALES JOBS [particularly in the financial, real estate, personnel staffing, or auto rental industries], then you might as well read this entire site from the beginning -- much of it applies to you as well.

Inclusion or exclusion of a link implies neither endorsement nor condemnation of its subject or source. Link lists are by no means all inclusive.

Index of Links

I. Reporting Fraud / Legal
II. Research Your Company

III. MLMs - HIGHLY RECOMMENDED READING.
IIIa. My Opinion on MLMs
IIIb.
So What Exactly Separates Legal MLMs from Illegal Ones?
IV. Complaints Against MLMs Outside Financial Services Industry
V. Complaints Against Specific Financial Services Companies
VI. Books on the Financial Industry
VII. Other Links.



I. Reporting Fraud / Legal

  • Reporting Fraud.
    • Federal Trade Commission (FTC). Submit a complaint about a company. The FTC protects consumers against fraud and has an interest in stopping illegal pyramid schemes. While the FTC does not resolve individual consumer problems, your complaint helps them investigate fraud and can lead to law enforcement action.
    • Better Business Bureau. Complaints against a company can earn it an "unsatisfactory" rating in the locality in which it was reported. Keep in mind that the main purpose of the BBB is to facilitate resolving complaints against businesses, not condemn them.
    • FINRA - File A Regulatory Tip. (FINRA used to be NASD.) Perhaps you have knowledge of illegal practices by a manager, or your commission checks have been withheld for one reason or another. If you are aware of unfair practices or specific instances of abusive conduct or rules violations in the securities industry, FINRA wants to know about it.
    • SEC (Securities & Exchange Commission) - File a Complaint. Attorneys in the Division of Enforcement evaluate information and tips concerning violations of the federal securities laws.
    • IRS - Report Tax Fraud. If you believe a firm is misclassifying its employees as independent contractors, you may file a tip. If you feel you've been misclassified as an independent contractor to your detriment, submit form SS-8. The IRS can audit the firm and impose heavy fines on those caught misclassifying employees as well as save you paying taxes you aren't liable for to begin with.
    • YOUR STATE'S DEPT. OF REVENUE - Report Tax Fraud. As above. Links to all are here.
    • YOUR STATE'S DEPT. OF INSURANCE - Report Insurance Fraud. Links to all of them are here. For insurance-related issues, contact your state's Department of Insurance. Examples of insurance fraud that might be reported would be inducing policyowners to lie on their applications in order to influence rates, or even using private information from those applications to recruit the policyowner as a rep (yes, it's happened).
    • YOUR STATE'S UNEMPLOYMENT OFFICE - Obtain Unemployment Benefits. Ask for determination of employee classification (employee and not independent contractor) so you may obtain unemployment benefits. Each state sets its own standards for determination. Links to all states are here.
    • YOUR STATE'S DEPARTMENT OF LABOR - Report Labor Violations. List of them here. Report possible misclassification of employee as independent contractor, ask for a determination.
    • YOUR STATE'S ATTORNEY GENERAL - Report Legal Violations. Links to all of them are here. Report suspected fraud to your state's Attorney General, who can investigate and prosecute possible illegal pyramid schemes (those fall under CONSUMER PROTECTION).
    • EMPLOYMENT AD MEDIA. IMPORTANT! If you were recruited through a newspaper or online job search site, report the exact nature of the deception occurring within its media. Most media feel a public responsibility to remove fraudulent job postings and will do so if enough complaints are received. (See Monster.com's policy here.) Many media guidelines state that a job advertiser must offer bona fide employment, not an independent contractor or commission gig (these must be posted under "business opportunities" or "sales positions"). Remember, scammer firms cannot remain solvent if they cannot recruit, so your participation in this can aid in shutting them down when other regulatory actions fail or take too long in catching up.
    • DSA (Direct Selling Association). If your company is a member of DSA (for example, Primerica), then it must technically abide DSA's "Code of Ethics". File a "Code Complaint". Note that although the DSA requires a one-year pending membership period during which it examines the potential member "to ensure compliance with all provisions of DSA’s Code of Ethics" (*), a number of their members have been found by courts and fined by the FTC as engaging in pyramid schemes (Equinox, Omnitrition, YourTravelBiz, etc.).
  • Legal: Activism.
    • U.S. House of Representatives. Find your local legislator. Write to him or her in support of legislation that will protect consumers of jobs against businesses that misrepresent opportunities.
    • National Association of Attorney Generals. Locate your state's attorney general. Write to him or her in support of legislation that will protect consumers of jobs against businesses that misrepresent opportunities.
    • The "Anti-Pyramid Promotional Scheme Act of 2003" (HR 1220). Support modification of this now-dead bill, in whatever form it returns to haunt us, to protect consumers of jobs against businesses that misrepresent opportunities. Beware deceptive language!
      • Pyramid Scheme Alert does NOT support the "Anti-Pyramid Promotional Scheme Act of 2003" bill. See also this page. Promoted by the DSA, tricky language is:
        • "'Pyramid scheme' means any operation in which a participant gives consideration for the right to receive compensation that is derived primarily from the recruitment of other persons as participants into the operation rather than from the sale of goods, services, or intangible property to participants or by participants to others." Opponents point out that the bolded language effectively legalizes product-based pyramid schemes and renders meaningless the FTC's 1979 "Amway Safeguards" ([...] "the '70% rule' and '10 customer rule' are meaningless if commissions are paid based on a distributor's wholesale sales [sales to scheme participants], and not based on actual retail sales"). The argument here is that MLMs that better compensate recruiting over retailing to consumers outside the scheme are only encouraging participants to get rich off their downlines' backs (as with a pyramid scheme) than to actually sell products to the public at large. Fight to defeat this bill (and any future incarnation) as it reads. You may sign up for Pyramid Scheme Alert's Petition which urges the President and Congress to launch investigations of the FTC and SEC, which have for years "ignored, allowed or protected pyramid and Ponzi [scam] operators."
      • The Direct Selling Association (DSA) supports HR 1220; see their page (archived) on it. Their current page on it is here; note that it differs. In particular, the old page included language [from a 1974 FTC ruling] that found in MLM an "intolerable potential to deceive". I can understand why they reconsidered keeping that on their page. More about DSA is available in the MLMs section below.
  • Legal: Prosecution.
  • Legal: Defense.
    • California Anti-SLAPP Project. Find out how to protect yourself against "Strategic Lawsuits Against Public Participation." Includes list of states with anti-SLAPP laws.
    • MlmSurvivor.com Article on "SLAPPs". Interesting examination of Amway's attempts to protect its image. Supports argument that a company need only name or continue to name critical website operators as defendants in unrelated cases to drain their finances and force closure of their sites. All cases were dismissed, but most site operators were harrassed into closed their sites because of mounting legal defense costs.
    • The Anonymous Internet Foundation, Inc. May be able to help SLAPP targets obtain legal representation, even on a pro bono (for the public good) or reduced fee basis. Update 2009: Site does not appear to be maintained but is still active.

See the Networking page for a list of message boards you may use to complain about your firm as well.


II. Research Your Company
  • IRS Criteria for Independent Contractors vs. Employees. Make sure your firm has classified you correctly. Ask the IRS to make determination by filling out Form SS-8.
  • Local Courts. If you've got an inkling that the firm could be crooked, don't miss this step. Call the court in the firm's jurisdiction and ask the clerk to look up cases in which the firm's name is mentioned. A large number of cases could certainly indicate trouble. A case with a large number of plaintiffs could be a class-action suit. Some courts provide past court cases free online. For others, you can request print copies for a reasonable fee. It's public record. (Unfortunately, a firm can use a plaintiff's "independent contractor" status to get out of being named in the lawsuit, so you still might miss any signs of wrongdoing.)
  • SEC's Investment Advisor Public Disclosure site (FIRMS ONLY). Do the "Investment Advisor Search" on your firm. Note any marks on their "Disclosure Reporting Pages."
  • SEC (Securities & Exchange Commission). Use the "search" function to research your firm. Be sure to put the firm's name in quotes. Note any regulatory actions. If you're interested in a bit of background about the SEC, check out Reality at the SEC (archived). Author Gary Goodenow worked for the SEC as attorney and offers opinions on why it is so difficult to shut down scammers. Fascinating site from a former insider.
  • FINRA (used to be NASD; search Individuals & Firms). Look up your firm or broker and make sure they are registered in your state (use FINRA's Brokercheck). If the broker offers securities and yet is not listed at all with the NASD, BEWARE. If you will be paying for licensing, check FINRA's rates for licenses you need and don't overpay for hidden training fees.
  • Better Business Bureau. The Better Business Bureau is not necessarily a good source for learning about a company's reputation with employees, but you can learn how the business treats its clients. Complaints stay active for a very short period of time, however, and full individual complaints are not publicly searchable. At worst, the company gets an "unsatisfactory" rating, and then only in the locality in which it was reported. BBBs are discrete localized entities, not a single national watchdog entity. Keep in mind that the main purpose of the BBB is to resolve complaints against businesses, not condemn them. (A negative opinion of the BBB can be found in the red link text on this RipOffReport.com page -- it alleges that BBB membership is bought, not earned. However, the same can be said of RipOffReport, which solicits businesses to pay to join their "Corporate Advocacy Program", which then conveniently improves the business's image on the site. For instance, much-maligned Primerica, which appears to have over 600 complaints on RipOffReport, now has text on each complaint page indicating that it is "approved" by RipOffReport as a company that consumers may have confidence in!)
  • Switchboard.com. Locate people you worked with at the firm to get their stories. You may not be alone.
  • See the Networking page for a list of message boards you may use for research as well.
  • Also check Section V. (Complaints Against Specific Financial Services Companies) below to see if your company has earned its own critical website(s). You may want to add your own complaints there.
  • Search the Internet. Don't forget that you can target search results better by including the company name in "quotes". If you suspect the business is unethical, do a second search including words such as 'scam', 'fraud', or 'lawsuit' after the quoted company name. However, keep in mind that many websites are forced to close by the companies they're complaining about (SLAPP lawsuits), so the Internet can be a shaky way to find complaints! Note that you can often find archives of a website via www.archive.org.

Google


III. MLMs (multi-level marketing organizations)
Also called: network marketing, direct marketing or direct sales, matrix marketing, viral marketing, referral marketing, dual marketing, consumer direct marketing, "home-based businesses". Whether you are pro-MLM or against, you should read this entire section to learn why MLM has long been associated with fraud and how you can protect yourself.

IIIa. My Opinion on MLMs (and companies operating like MLMs)

This site was not designed to be specifically an MLM bash site, but one cannot help but note that even "reputable" MLMs have been unable to escape stinging criticism and even lawsuits from unhappy recruits and consumers. Recruits' feelings about MLMs are shockingly polar. Those who love MLMs appear to me to be: still in the earlier stages of positive emotion whipped up by their upline and organizations; earning a little and unwilling to give up hopes of riches; satisfied with a small supplemental income if they in fact aren't continuing to lose money every month; or one of the overwhelmingly small number who are making an income of any substantial size. Their most common defense of their company is that those who fail "didn't try hard enough." Those who hate MLMs are generally those who "failed" and feel absolutely betrayed when even the most modest dreams promoted by the company don't pan out after they follow the plan diligently, their back-breaking hard work often leaving behind little more than destroyed finances and shattered familial/social relationships.

MLMs often have meteoric rises and fantastic sales volumes, but I tend to believe the only reason they are able to attain those volumes is by continually mining new recruits by setting unrealistic expectations (for the vast majority). If product is moved, it appears to be because of pressure to make sales goals by obtaining mercy/trust sales to friends and family and other downline recruits with the same goal, not because the product has value on the open market. MLMs are able to avoid shouldering the cost of their sales force (salaries/wages, taxes, insurance, etc.) by classifying them as "business owners" or "independent contractors", often by promoting "fantastic" tax write-offs, independence, and dreams of wealth to them while slurring traditional brick-and-mortar businesses. (For the record, the IRS says you can't generally operate an unprofitable "business" out of your home with the "hopes" that it will pay off, and then deduct the cost and operation of a personal residence/home office; pay your family as employee write-offs; write off the family car; deduct travel, meals, and entertainment under the guise that everyone is a potential client; etc. See here.) Many distributors not only buy the products but are encouraged to pay for the company's "motivational" conventions and materials in order to "build their businesses". Additionally, MLMs are often able to dodge costly legal actions, holding the distributors responsible for infractions. The loss of a distributor doesn't hurt, since that distributor's downline is simply reabsorbed, and recruiting is constant anyway. Traditional expensive advertising costs are minimized or eliminated. I am not surprised when MLMs show up in Inc. Magazine's 500 fastest-growing privately held companies list (The Inc. 500) or Fortune Magazine's list (The Fortune 500) or Forbes Magazine's 500 (Forbes 500), if in the insurance industry, they rate well on A.M. Best's financial strength list for some years. (Search The Inc. 500 here; search A.M. Best here. Fortune's lists are available only to subscribers.) They tout this as an incredible honor, but keep in mind how they're doing it. Meteoric growth often only happens because consumers join a feeding frenzy based on deceptive income claims, and the promoters try to rake in as much as possible before getting caught!

MLMs sell (or have sold before they went bankrupt) most everything you can think of: vitamins and herbal supplements, cosmetics, perfume, clothing, lingerie, jewelry, real estate, internet service, computers, phone service and phone cards, insurance, securities, toys, legal services, auto rentals, foods, beverages, pet supplies, travel services, water filters, vacuum cleaners, greeting cards, art, candles, cutlery, cookware, security systems, books, encyclopedias, and even ostrich farms! One would think that the incredible savings on overhead would allow MLMs to sell these products for far less than same class retail products, but I personally have yet to see that be the case. MLMs must pay many layers of commissions on their products instead, and that comes out of the buyer's pocket. Many MLMers find their products difficult to retail because buyers find them too expensive, or have never heard of them, or find them to be of an inferior quality, so the main if not only source of buyers is not retail customers but either other MLMers attempting to build businesses or friends and family buying just to help those MLMers build businesses.

Even then, note that these "business owners" do not really own their own businesses and have far less control than they are led to believe. Any behaviors that the MLM deems "infractions" risk the recruit's losing his business and having his downline reabsorbed. His "business" does not exist apart from its relationship with the MLM. (Review the "Independent Contractor?" section of this site.)

Note that in 1990, only 25% of the Direct Sellers Association's (DSA) members were multi-level, as opposed to the traditional single-level (*). As of 2005, over 77% of DSA members were multi-level. By 2009, about 97% were multi-level. It makes sense to go multi-level -- there is a greater chance of profit when your sales overrides extend several or many levels down (or even indefinitely), instead of one level as with single-level direct sales organization. However, multi-level also puts more stress on recruiting downlines so higher-up participants retire early and rich instead of retailing single-level to non-MLM participants. It also encourages turning a blind eye to market saturation such that the lower levels never have the chance to "get rich", in effect threatening collapse of a pyramid built on unattainable dreams and not retail sales.

The 1979 FTC ruling on Amway required the "10 customer rule", or that a distributor must sell to 10 retail customers (not other distributors) per month to qualify for a performance bonus, in order to establish that sales were not simply fueled by dreams of riches as is characteristic of a pyramid scheme. However, a senior manager of Amway’s distributor relations section acknowledged that bonus checks get paid to distributors who have no retail sales and that it was up to the Direct Distributor to decide if this rule should be enforced (*). Amway in effect is relying on the independent contractor status of distributors to shield itself; after all, it's their business.

Once a company has been an MLM, it appears to be hard to compete selling traditional retail. Distributors don't want to compete with retailers and regard any company attempts at retailing as backstabbing. Avon dabbled briefly with it before distributor backlash changed its mind (*). According to mlmWatchdog.com, Tupperware's more aggressive 2003 experiment with selling through Target stores backfired -- sales plummeted as distributors defected. This only tends to lend further credibility to my theory that many MLM products cannot compete on their own merits in the open retail market; it must be the "business opportunity" that pushes sales. The product might be a fine high-end product or absolute rubbish, but on the open market its demand is equalized.

The simplest solution in my opinion for stamping out pyramid schemes of ALL sorts, should legislators finally demonstrate some brains, guts and integrity, would be to outlaw sales structures in which commissions penetrate more than one level deep altogether instead of creating more enforcement work for already-overextended tax-supported regulatory and law enforcement agencies, as essentially happened in the 1979 FTC ruling on Amway. This would ensure that market saturation is accounted for so that overwhelmingly unattainable dreams of riches cannot drive the business; the focus would return to retail sales, as it was with single-level direct sales. Hand in hand should be legislation requiring that new recruits be paid a base salary (not draw!) plus commission in order to eliminate the abuse of reps as misclassified independent contractors. If the business's focus is the sale of its products, it should shoulder related expenses and responsibilities instead of foisting them onto aninexperienced and unsophisticated sales force who don't understand the ramifications. That includes advertising (and not relying on the reps' friends and families for sales) as well. Yes, this would be essentially the end of MLM and a return to business as usual.

In short, I believe MLMs (and MLM type companies) are simply outdated, unnecessary, and exploitive distribution systems that cost the company next to nothing to run and falsely inflate its sales volume and bottom line, selling as many dreams and motivational baggage as products. The past 30 years have seen an explosion in MLMs and other businesses eager to assimilate MLM elements for the same benefits. While MLM may have once been a good method of reaching small out-of-the-way markets, I am extremely leery of any company that utilizes any form of it in order to move product today.

Below are some websites about MLMs, some pro, some con. Some websites are now defunct, whether the site operator simply lost interest or was forced to close the website when legal defense costs became too much. As with most any defunct website, you can use the Internet Archive "Wayback Machine" at http://www.archive.org to view historical captures.

  • Direct Selling Association (DSA). Pro-MLM. Members include multi-level sellers such as Amway and Primerica; single level direct sellers such as Mary Kay & Tupperware - which are curiously no longer listed in DSA's public directory (note historical capture as of Dec. 12, 2005) as being single-level. Note also that there is now a "Public" DSA Member Directory available to the general public, and a "Private" DSA Member Directory, available only to DSA Members; the change occurred around Dec. 15, 2005.
    • The DSA supports HR 1220 (the deceptive "Anti-Pyramid Promotional Scheme Act of 2003"); see their page (archived) on it. Pyramid Scheme Alert is AGAINST HR 1220; see why.
    • The Consumer Awareness Institute has an interesting page called "Legislators & Regulators: Beware the DSA!" See why author Dr Jon Taylor believes this.
    • At one time the DSA hijacked (archived; click on a date to see the proof) the mistyped web traffic of a critical site, www.pyramidschemealert.ORG, by registering www.pyramidschemealert.COM (& .info, .net, .biz, etc.). A screencap from July 2003 shows that pyramischemealert.com was first redirected to DSA's page on "HR 1220"; as of May 18, 2004 it redirected to DSA's page on "pyramid schemes". The Quixtar Sucks Blog posted a nice screencap of the DSA registrant, Amy Robinson (compare to 2009 record), then-VP of Communications and Media Relations at DSA. This disgraceful behavior belies the spirit of DSA's own "code of ethics", which states: "Member companies shall ensure that no statements [...] are made which are likely to mislead consumers"; and "Sellers shall truthfully identify themselves".
    • DSA membership does not come cheap, and many parts of DSA.org, particularly those regarding government affairs and legislative activism, are off-limits to non-members. I'm particularly curious what is covered in DSA's Top-Selling Product called "Coffee Break: No One is Safe from the Legislature"! (Products I WAS able to view average over $1500 for non-Members; you can imagine how many non-Members ever buy these.) As for how DSA penalizes members who violate their "Code of Ethics", the most severe penalty they can inflict is to terminate the member's DSA membership. You can guess how often DSA terminates memberships. I did find one MLM, Monavie, who may have been terminated from DSA (U.S.), but that appears to have been the result of one Amway member who was terminated by Amway and then took his downline with him to Monavie. His "crime" is technically "encouraging distributors to violate their Amway non-compete agreements". Monavie is NOT currently listed on DSA's membership, but Monavie's website, curiously enough, still includes a link not to the Canadian DSA of which they are a member, but to the U.S. DSA of which they are NOT a member!
    • Dr. Jon Taylor's "The 5 Red Flags of Product-Based Pyramid Schemes" points out that the DSA has duped multiple states into signing deceptive legislation similar to thus-far-unsuccessful proposed federal HR 1220, which would effectively legalize product-based pyramid schemes: Texas, Montana, Louisiana, Oklahoma, and New Mexico; mlmlegal.com adds Kentucky. DSA-sponsored legislation was also passed into law in Idaho in 2004 (SB 1237) South Dakota (HB 1183), and Georgia (SB 141). Other states which have been duped into adopting similar legislation include North Dakota, Maryland, and Illinois (*). According to PyramidSchemeAlert.com, Florida's SB 2648 (died in committee in 2005) is "virtually identical to a bill recently defeated in Utah" [the defeated HB 269, which was later passed in the incarnation of DSA-initiated SB 182 in 2005]. Dr Taylor blatantly says of MLM-swamped Utah's DSA-driven SB 182: "The DSA duped Utah's top law enforcement officials, legislators, and Governor Huntsman into legalizing product-based pyramid schemes." I'm sure other states have passed such laws as well while critics weren't looking.
    • In 2008 the DSA lobbied the FTC to ensure exemption of multi-level business opportunities from coverage by the FTC's Initial Proposed Business Opportunity Rule (IPBOR), which would require disclosures to the buyer encompassing things like:
      • Whether or not sellers make earnings claims
      • The name of the person making the earnings claim and the date of the earnings claim
      • The earnings claim
      • The beginning and ending dates when the represented earnings were achieved
      • The number and percentage of all purchasers during the stated time period who achieved at least the stated level of earnings
      • Any characteristics of the purchasers who achieved at least the represented level of earnings, such as their location, that may differ materially from the characteristics of the prospective purchasers being offered the business opportunity
      • A statement that written substantiation for the earnings claim will be made available to the prospective purchaser upon request
      • A list of any criminal or civil legal actions against the seller or its representatives that involve fraud, misrepresentations, or deceptive or unfair trade practices
      • The terms of any cancellation or refund policies
      • The total number of purchasers in the past two years
      • The number of those purchasers seeking a refund or to cancel in that time period
      • Names of people who can provide references
      When the FTC solicited comments on the Initial Proposed Business Opportunity Rule, 95% of the more than 17,000 comments received by the FTC came from members of the MLM industry expressing opposition to it. The DSWA (Direct Selling Women's Alliance) stated these reasons as their primary objections:
      • The required disclosure and earnings statements and the required list of all distributors who have cancelled their distributorship in the previous last two years may cause the sponsoring process to become cumbersome and difficult. (Ya think?!)
      • These requirements may create unnecessary alarm and concern about the legitimacy of the profession and your business opportunity to prospective distributors. (Unnecessary?!)
      • The proposed seven day waiting period between receiving the disclosures and enrollment would likely cause a potential distributor to lose their enthusiasm for joining your company. (God forbid a prospect actually THINKS about the decision.)
      • The costs of complying with the requirements would increase expenses to the company which may be passed on through the selling price of goods or services we offer. (You've GOT to be kidding.)

    One must wonder why the DSA and the MLM industry it represents would oppose these requirements that are designed to help the consumer avoid getting defrauded by them! After all, the entire reason the Franchise and Business Opportunity Rule exists is to define the proper scope of the term ‘‘business opportunity,’’ the types of business opportunities that are known to engage in deceptive or fraudulent conduct, and the types of disclosures that are material to business opportunity purchasers. The DSA's flimsy defense is that fraud in the MLM industry is already well covered by Section 5 of the FTC Act, but if that were the case then the new Proposed Business Opportunity Rule isn't necessary for anyone. In 2008 the DSA was apparently successful, as the FTC said: "The revised proposal [...] would not reach multi-level marketing companies or certain companies that may have been swept inadvertently into scope of the April 2006 proposal." What a convenient omission!

    • The DSA has a vested interest in helping ensure IRS laws continue to (mis?) -classify direct sellers as "independent contractors" in spite of the fact that they do not fit in that category according to the IRS's own guidelines. Why? Because it shifts the tax burden onto the contractor, and because it helps the company dodge legal liabilities by foisting them onto the contractor. The MLM can simply feign ignorance of a "rogue" distributor's "misconduct" when a consumer brings a lawsuit or a regulatory agency brings an action, even when they explicitly encouraged the often-ignorant distributor to break the law! In particular, note that you are more than likely an employee if the employer can exercise control of your work through the threat of dismissal. In 1982, Congress adopted Internal Revenue Code Section 3508 (IRC §3508) to "provide a statutory scheme for assuring the status of [...] direct sellers [...] as independent contractors." In 1994, the DSA argued with the Senate Committee on Finance that "direct sellers established themselves as independent contractors for tax purposes under the common law rules in the test case of Aparacor, Inc. v. United States, 556 F.2d 1004 (Ct. CI. 1977)." (DSA again referenced Aparacor in arguing their case in 2007 with the House Committee on Ways and Means.) However, if you study the actual Aparacor case, the trial judge's opinion states that "the word 'termination' is used in company procedures simply to signify that a relationship with a particular distributor has come to an end because of a lack of interest on the part of the distributor" and that the distributorship could be reactivated by simply ordering product. He also stated Arapacor/Queen's-Way's "primary interest is in maximum sales of its products, and it is not concerned with the ways, means and methods [control] employed to accomplish that result". The comparison of Aparacor to today's MLMs is extremely shaky, as most if not all MLMs can terminate your membership at will; one case of many concerns former Amway distributor Eric Scheibeler, who wrote a book lamenting how Amway effectively terminated the large business he'd built after he questioned his upline's fantastic income claims. Jay Van Andel, co-founder of Amway, said in 1982: "They're NOT our employees and we can't tell them or enforce things beyond a certain degree". Note the year. Of course that's rubbish. MLMs certainly DO control the "ways, means, and methods" that distributors may use to run "their own businesses" -- the distributor's "business" does not even EXIST apart from its relationship with the MLM! You can lose your entire business while the MLM can simply reabsorb your downline and replace you. Last of all, for all its support of misclassifying ICs, the DSA's own "Code of Ethics" includes an intriguing bit of double-speak entitled "Prompt Investigation and No Independent Contractor Defense" which states: "For the purposes of this Code, in the interest of fostering consumer protection, companies shall voluntarily not raise the independent contractor status of salespersons distributing their products or services under its trademark or trade name as a defense against Code violation allegations and such action shall not be construed to be a waiver of the companies' right to raise such defense under any other circumstance."
  • What's Wrong With Multi-Level Marketing? Anti-MLM. Note the section on "market saturation."
  • The 10 Big Lies of Multi-Level Marketing. Anti-MLM. Attempts to debunk pro-MLM arguments.
  • Lessons From The Pyramids: Why Nearly Everyone Loses Money in MLM, but So Many Keep Trying. Anti-MLM. Demonstrates the saturation argument against MLMs.
  • 10 Lessons for Consumers from the Equinox Case. Anti-MLM. Equinox International was shut down by the FTC in 2001 as an illegal pyramid scheme. Topics covered include why illegal MLMs (pyramid schemes) can appear so legitimate, and why they're so hard to shut down.
  • Quatloos.com: Multi-Level Marketing (MLM). Anti-MLM. Includes a brief history of MLM and why it can be argued to be obsolete.
  • Truth on MLM. Anti-MLM. Very detailed site by Dr. Jon Taylor of the Consumer Awareness Institute, featuring his 10+ years of research on MLMs. Be sure to read the "5 Red Flags" of a Recruiting MLM or Product-Based Pyramid Scheme and the Evaluation of 125 MLM Programs. Note that the latter report posits that there are only two MLMs out of hundreds that qualify as legitimate opportunities based on the "5 Red Flags". The Evaluation was updated with over 250 MLM programs.
  • LawDawg's Law Blog. In 1996, after ten years of "pointing out the fallacies and falsehoods of MLM and its hucksters", LawDawg moved on to other pursuits and his blog went offline. This link is to the archives. I found it necessary to click anywhere on text and highlight all text (CTRL+A) to read much of it, but it's all worthwhile reading. Note in particular his "Introduction to Pyramid Scheme Math". He didn't find it necessary to prove that within so many levels the MLM's participants would exceed the population of the world. Instead, he simply noted that after a very few number of levels, most pyramid schemes characteristically maintained that the bottom level would always be a certain percentage of participants (in his case a 1x6 matrix after only 3 levels yielded 83.3% ad infinitum), and if that bottom level cannot make retail sales to people OUTSIDE the scheme because of market saturation, it will ALWAYS lose money. MLM by its very structure contains no controls for market saturation.
  • The MLM File. Anti-MLM. One Ex-MLMer's 35-year experience. His motivation for creating the site: for "the hundreds of people I have personally known who have 'failed' in MLM, many of whom I directly caused to be recruited." Also includes the author's answer to the question "Is There Really 'Outstanding Growth Potential for MLM?"; you might guess his answer is "no, the rich just get richer".
  • USA Today: Don't Get Taken By Multi-Level Marketing. Anti-MLM. Author advises: "Never, and I mean never, sign up for a multilevel marketing (MLM) program"; lists why.
  • Market Saturation in MLM. Anti-MLM. Product saturation versus business opportunity saturation -- what is really being sold? Why recruit your own competition?
  • The Millenium Project's Section on MLMs. Anti-MLM. Author Peter Bowditch's entertaining opinions on and experiences with MLMs. Many comments on individual MLMs.
  • The Lies of MLM. Pro-MLM, believe it or not. Warns MLMers against perpetuating some lies that less scrupulous MLMers made up, such as "MLM is the wave of the future" and "20 percent of all millionaires in America were created through Network Marketing".
  • MLM vs Traditional Business. Pro-MLM. MLMer attempts to dissect the differences.
  • MLM Legal. Pro-MLM. MLM attorney Jeffery Babener, an active spokesman for the MLM industry who assists the DSA in compliance issues and who has counseled MLMs like Melaleuca and NuSkin, provides an excellent site detailing many issues relevant to the industry as well as a pretty detailed history of MLM regulation.
  • Anti-MLM Zealots: Do They Have A Point? Pro-MLM. 10+ year MLMer Leonard Clements offers pro-MLM rebuttals against some popular anti-MLM websites.
  • MLM.com's Directory of MLM Companies. Find out if the company that contacted you is an MLM using this searchable alphabetical directory.
  • MLMWatchdog. Pro-MLMer Rod Cook attacks pyramid schemes and abusive MLMs. Fascinating site including many legal cases.

IIIb. So What Exactly Separates
Legal MLMs from Illegal Ones?
(Under construction; opinion article last updated May 2009)

That question has been under scrutiny for at least 30 years. What follows is a history of how MLM's legality was established, and why the questions asked early on were on track - and then conveniently forgotten.

Direct sales, legitimate forerunner of MLM

In the late 19th and early 20th century, direct sales consisted of single-level direct marketing by companies such as Avon (then known as California Perfume Company). Many sold through catalogs, but catalogs did not reach every market. Early direct marketers hired salespeople to travel to small towns and rural areas not already covered by advertising to introduce residents to their catalogs and products. Commission overrides were just a way of rewarding enterprising salespeople who pressed into these out-of-the-way markets; the products virtually sold themselves for the front-line salespeople. However, these were traditional single-level sales businesses, not yet multi-level marketing organizations (MLMs). I must emphasize that direct sales only had a place in the marketing world of that time because advertising was not yet able to reach every potential consumer.

The Ponzi Scheme: Forerunner of modern pyramid schemes

The actual MLM model was preceded by a scam that could be argued to have influenced its beginnings. It existed in several forms prior, but Carlo "Charles" Ponzi's name stuck to it. In 1919, Ponzi started the scheme for which he became famous and which would later be compared to MLMs: he paid off early investors with money taken in by later investors by creating a consumer stampede with hype of phenomenal returns within a very short period of time (*). Instead of marketing his product legitimately and honestly to end consumers, he marketed to "warm market" investors, which included his extended family members, his Catholic priest, and some neighbors (*), from whom he collected a total of about $1250. Ninety days later, he returned $750 in "interest". His ecstatic original investors unwittingly did his marketing for him -- they told everyone they knew about this "bonanza," and investments snowballed.

The party did not last. Within a year, a suspicious Boston Post's front page questioned the legitimacy of the enterprise. Investors panicked and demanded their money back. The problem was that none of the "interest" was real, as Ponzi was only returning to early investors funds invested by later investors. When everyone wanted their money back, it simply wasn't around to return! Without the hype to induce new participants, Ponzi's scheme folded. Most of his 40,000 investors lost everything they had invested.

Some posit that Ponzi's scheme was not technically a pyramid scheme because he did not actually recruit others to perpetuate the scheme, but they're wrong. The mechanism is the same -- there must be early investors at the top of the pyramid whose gains are funded by later investors at the bottom, and some sort of exploitation to perpetuate sales which has nothing to do with demand for the product. Some also posit that a saturated market will inevitably cause a pyramid scheme to collapse, but that is likewise untrue. A pyramid scheme can actually reach market equilibrium, continuing as long as new participants can be motivated. There is indeed a sucker born every minute. But it is true that once a critical number of participants leave the scheme, motivation plummets and it will likely collapse.

Later enterprising scammers saw the potential in recruiting endless downline "entrepreneur-chains" who would simply duplicate the original fraud, whether knowingly or unknowingly. These later scammers were even smarter, actually -- when the law came breathing down their necks, they could simply disavow knowledge of their downlines' illegal activities. And with the money they made in their schemes, they could buy influence to stay in "business".

At least the Mafia knew you don't screw over your friends and family.

Post-Ponzi: MLM's infancy

Fast forward to 1927, when one of the earliest multi-level sales companies (if not the first), a vitamin and supplements company called Nutrilite, started (*) as California Vitamin Corporation. Nutrilite's founder discovered that selling vitamins was difficult because they were largely unheard of at the time. He literally couldn't give them away until he hit on the idea of turning consumers into distributors, paying them commissions for referrals (*). Consumers, excited by earning extra money and perhaps goaded on by claims that Nutrilite products were effective in treating cancer, heart trouble, and other ailments, bit. Gross sales soared to $500,000 a month, but in 1947 the FDA began a 4-year battle to halt these spurious claims (*). They were able to stop direct curative claims, but excited consumers' testimonials remained in marketing materials, continuing to indirectly perpetuate the myths. Thus began early rudimentary multi-level direct sales and its early battles with regulatory agencies.

In 1959, two Nutrilite salesmen became frustrated with supply problems and left (*, *), taking their Nutrilite downlines (*) of over 2000 distributors (*) with them. Rich DeVos and Jay Van Andel founded JaRi Corporation and continued to refine the MLM business model. After hitting some manufacturing snags with their own products, they launched Amway in 1959 and utilized their ready-made and expanding sales force such that sales jumped from $500,000 to $25 million between 1960 and 1964 (*) -- by a factor of 50 within 4 years. This explosive growth got attention, and critics believed that some of the largest distributors were profiting at the expense of new distributors (Ponzi, anyone?) by encouraging inventory loading (or front-loading), the purchase of more goods than distributors could sell (*). Regulatory agencies took notice but had difficulty formulating criteria that would differentiate legitimate MLMs from illegal pyramid schemes. Perhaps the difference was more subtle than they thought.

1975's Koscot case: The FTC defines pyramid schemes

In 1972, the Federal Trade Commission began investigating a cosmetics MLM called Koscot Interplanetary (I guess they had distributors on Mars), which was founded only 5 years earlier and already making $56 million a year, for being a pyramid scheme (*). The Securities and Exchange Commission joined soon thereafter, alleging securities violations. The FTC defined a pyramid as:

"characterized by the payment by participants of money to the company in return for which they receive (1) the right to sell a product and (2) the right to receive in return for recruiting other participants into the program rewards which are unrelated to sale of the product to ultimate users" (*).

This became known as the Koscot test. In the 1975, the case concluded; the FTC determined that not only did Koscot run a pyramid scheme in which Koscot motivated more distributorship sales than product sales (recruiting over retailing), but it implied that all MLMs that represent an equal opportunity for success must be inherently fraudulent due to inevitable market saturation (*):

"[...] even where rewards are based upon sales to consumers, a scheme which represents indiscriminately to all comers that they can recoup their investments by virtue of the product sales of their recruits must end up disappointing those at the bottom who can find no recruits capable of making retail sales." (FTC v. Koscot Interplanetary 86 F.T.C. 1106, 1975) (*)

Note also that the FTC in its Statement of Facts did not yet make any clear distinction between "multileveling" and pyramid selling:

"Koscot's distribution method has come to be known as multileveling or pyramid selling. Such a system has been condemned as unlawful by the Commission, as well as by numerous courts." (FTC v. Koscot Interplanetary 86 F.T.C. 1106, 1975) (*),

A major ruling (not opinion!) the FTC was referring to was issued only a year before in 1974 when it found in multilevel marketing's very structure an "intolerable potential to deceive" (*).

Curiously, the FTC would later back off from this condemnation of MLM itself. Also contributing to Koscot's condemnation was the fact that founder Glenn Turner ran a side business, "Dare To Be Great," selling "motivational materials" (books, tapes, records, seminars) to its distributors which had little value to anyone outside the company and could not be considered "retail" sales to "ultimate users". The SEC noted in its 1974 investigation that the Koscot manual instructed distributors to recruit using Opportunity Meetings, which were part of the "motivational materials" business, to drive recruitment:

"Never explain the program to a prospect before bringing him to an Opportunity Meeting. Do not mention Kosmetics or give any particulars, as many people will prejudge the program and decide it is not for them before they see the presentation. [...] When you invite a prospect to an Opportunity Meeting, arouse his curiosity. Tell him you have discovered a wonderful financial opportunity that will fit him like a glove. Or, tell him you have seen a money tree and would like for him to take a look at it." (SEC v Koscot, 1974 [*])

The FTC determined that Koscot's motivational materials side business was its main business, rewarding recruitment more than retailing of products to the financial detriment of its work force -- "money borrowed, jobs quit, homes mortgaged, and even personal bankruptcy" (*). It established that recruiting over retailing was the hallmark of a pyramid scheme.

The SEC found that Koscot's "profit-sharing arrangement" with distributors constituted an unregistered security, based on the "Howey Test" of 1946 (*):

"An investment contract for purposes of the Securities Act means a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party [...]" (SEC v. W.J. Howey Co., 328 U.S. 293, 1946)

The reason Koscot's plan constituted a security was that a distributor could "buy in" to a higher-level distributorship instead of building his own from the ground up, thus buying an enterprise that was designed to rely on the efforts of others.

Litigation ultimately forced Koscot out of business (*).

It should be noted that by the early 1970s, direct marketing and MLM were effectively obsolete, utilized by companies only for their low expenses (no advertising, salaries, pensions, health insurance, etc.) and lack of regulation (because they hired distributors as independent contractors, they were not subject to regulation under the 1938 Fair Labor Standards Act [minimum wage, overtime, unemployment], the 1970 Occupational Safety and Health Act, and the 1974 Employee Retirement Income Security Act [*], and tax withholding and reporting). Advertising was reaching almost everyone by then, so there was no longer any need for door-to-door salesmen to penetrate out-of-the-way markets. Before the Social Security Act of 1935, company benefits and pensions were few and far between and companies were still recovering from the Great Depression, so there had been greater incentive for those seeking employment to enter into a full-commission sales position that offered residual sales commissions and thus a potential retirement income. The arrangement had at one time suited both company and distributor, but now the only way to lure potential distributors away from more secure jobs with benefits was to emphasize the income angle and "independence" offered by the MLM "business opportunity". Now competing with brick-and-mortar businesses, MLMs began slurring those businesses as slave drivers who built their empires at the "expense" of their employees' efforts and, with an ironic twisting of poor logic, even compared them to pyramids in which the many at the bottom enriched the few at the top!

The 1970s saw such a proliferation of pyramid schemes that then-Senator Walter Mondale (D-MN 1964-76) sponsored a federal anti-pyramiding bill, which passed the United States Senate twice in the 1970s but never became law (*). One has to wonder what was so difficult about getting it passed when the Koscot case supposedly laid out the ground rules. The Washington Post hinted at one 1970s change that seemed to entrench MLM in spite of its tangles with regulatory authorities:

"[Amway's] founders' proximity to power -- their former congressman, Gerald R. Ford, became president [(R) 1974-1977] -- assured them political consideration as problems arose with government regulators" (*).

And so we return to the Mother Of All MLMs, Amway.

1979's Amway case: A critical one that got away?

In 1975, the FTC began its investigation of Amway, alleging that it was an illegal pyramid scheme that misrepresented its income opportunity and improperly fixed prices. Complaint counsel pointed out:

"[...] that the Amway Sales and Marketing Plan is inherently unlawful because it is 'a scheme to pyramid distributors upon ever increasing numbers of other distributors.' They argue that the Amway Plan, even without actual proof of economic failure, is 'doomed to failure' and contains an 'intolerable potential to deceive.' The complaint alleges that distributors are not long likely to recruit other distributors because 'recruitment of additional participants must of necessity ultimately collapse when the number of personal theretofore recruited has so saturated the area with distributors or dealers as to render it virtually impossible to recruit others.'"(FTC v. Amway, 1979) (*)

The FTC's 1979 Final Order on Amway found it to be engaging two counts of price-fixing and one count of misrepresentation of the business opportunity (*), but unlike Koscot, Amway was determined not to be a pyramid scheme because it had rules in place that discouraged inventory loading, the practice of encouraging a distributor to buy more products than could be sold due to the market saturation potential inherent in MLM:

  • a representative must make at least 10 sales calls a month in order to be eligible for commissions (the 10 customer rule)
  • a representative must sell 70 percent of previously ordered inventory before placing a new order (the 70 percent rule)
  • the company would buy back unsold inventory at 90 percent of cost (the 90% buyback rule)

These rules became known as the "Amway Safeguards". The Commission acknowledged the complaint counsel's argument that the 'intolerable potential to deceive' could be inherent in MLM due to its very structure but noted the argument was not yet accepted by the courts, implying it would not set precedent. It chose to work only with actual harm to consumers, not potential harm, and appeared to reason that if the market ever did saturate, distributors might waste time and effort building businesses that could never succeed but at least they couldn't lose more than 10% of their investment and be stuck with a garage full of unsalable inventory. (I guess a person's time and effort should cost them money instead of earning it.) The Commission's Opinion was critical to the MLM industry; MLM would not likely exist today if Amway had not prevailed (*).

However, complaint counsel missed some reasoning using their own statistics that could have proven Amway indeed fit the FTC's description of a pyramid scheme. Here's the FTC's definition again:

A pyramid scheme is "characterized by the payment by participants of money to the company in return for which they receive (1) the right to sell a product and (2) the right to receive in return for recruiting other participants into the program rewards which are unrelated to sale of the product to ultimate users" (*).

Now some statistics from the FTC v. Amway case:

"The number of active distributors since 1972 has remained relatively constant, fluctuating around 300,000, climbing in 1977 to about 360,000."

There was either a multi-year recruiting slump or Amway had saturated its market by 1972. Defense counsel pointed out that some distributors were able to recruit in the same markets where other distributors "failed"; thus, saturation could not have occurred yet. The Commission even deferred to a "marketing expert" called on by the defense who said that distributors who complained that they could not recruit were probably "not making the sale effort that is required"! Let's look at why recruiting would have stagnated.

The average annual turnover of Amway distributors is about 50%. The turnover rate for Amway distributors during their first year is almost 75% and thereafter about 25% a year.

If Amway's turnover was averaging 50% every year, then it was essentially replacing every recruit who dropped out. But if you extrapolate the latter figures (and complaint counsel did not), you see that 99.5% of Amway's original work force turned over in just 15 years (*) (in year one, 75 out of 100 quit [75%]; in year two, 25% of the remaining 25 quit, leaving 19 [81%]; year three, 25% of remaining 19 quit, leaving 14 [85%]; etc.). Indeed, Amway started in 1959, and only approximately 15 years later appeared to have reached saturation equilibrium. Why would such a high percentage of the original work force leave when at a bare minimum they could remain distributors and receive Amway's many everyday products at wholesale instead of retail? The products clearly weren't the motivating factor behind the vast majority of distributors' joining and remaining in Amway then. In fact, while many of an MLM's products may be legitimate and even of excellent quality, distributors typically discontinue purchasing them when they quit their MLM (*). But they were doing better than the minimum; according to Amway, a stagnant number of distributors were making more sales than ever:

"[...] the sales trend for Amway has shown almost uninterrupted growth." (*)

The average monthly BV [business volume] of Amway distributors in fiscal 1969-70 was about $20 a month. Much of this amount is consumed by the distributors themselves rather than resold. [...] Many of them consume large amounts of the products every month. [...] We note that this figure is not 'retail sales', but Business Volume -- that is, the retail value of the products purchased for resale to consumers and sponsored distributors, and for distributor home consumption which, as stated before, constitutes a large portion of all sales of Amway products. [...] Most distributors average 30% of Business Volume as income.

So according to Amway, the average distributor made about... well, $20 x .30 = $6 a month, or $72/year before expenses. Not that bad, if you note that $6 in 1969 was about $35 in 2008 (*). But wait, that's just an average (and it is gross, not net!). Remember, each time a distributor at the huge bottom of the pyramid sold something, even just to himself, his upline going up to the tiny top made money. As with the turnover example, let's see how profits in Amway were leveraged.

In attempting to recruit new distributors, respondents made generalized earnings claims like, 'You can earn $12,000 a year. . . .' [...] The Commission opinion noted that of the 12,000 distributors selling for respondents in 1969, not more than sixty, or one-half of 1 percent of the total number of distributors, made profits in excess of $10,000.

A separate source estimates Amway's 1969 sales at $85 million (*). [In 2008 dollars that translates to $498,419,618.53 (*).]

Yikes. If 12,000 distributors made only $72 a year, then Amway would have made only $2,880,000 ($72 X 12,000 = $864,000 / .30), but it made $85,000,000. The rest of that $82,120,000 ($85,000,000 - $2,880,000) went somewhere, and it wasn't to the average distributor! If distributor #60 out of 12,000 was only netting $10K/year and #600 was netting $72, you can imagine what the guy up top was netting. Since the vast bottom-tier distributors were only self-consuming,they were only losing money. And that's right, 99.5% (remember that percentage?) never earned the $12K/year that Amway represented they all had an equal opportunity of making:

Amway literature urges recruiters not to 'quote dollar incomes on specific individuals even though you may want to use their stories about the homes in which they live, the cars they drive, or the airplanes they fly.' Amway officers and other representatives have, however, orally stated specific dollar incomes which are attributed to Amway distributors. These statements are typically made in mass sales rallies which are primarily for persons who are already Amway distributors. The context of the sales talk is inspirational and it is to a knowledgeable crowd already aware of the details of the Amway Sales and Marketing Plan, and in this motivational context the statements are obviously meant and understood to be feasible goals and not guaranteed average income for the listeners.

Knowledgeable crowd? So did Amway make these people aware that 99.5% of them would fail, apparently as just "horrible salespeople"? The market of "knowledgable" people attracted to such a plan would saturate very quickly. Using just the statistics above, one could come to the conclusion that Amway was roping in a self-consuming revolving market for its own products using deception, enriching only a few at the top off the backs of the masses.

And that was apparently exactly what was happening. Remember how Koscot's founder had been operating a side business overselling "motivational tools" (books, records, tapes, seminars) to distributors in order to encourage and retain their participation, tools that had little to no value outside the scheme? Some high-level Amway distributors had apparently figured out the key to driving up their sales Koscot pyramid-style. According to Amway/Quixtar Managing Director Ken McDonald in a 2000 conversation with former high-level distributor Bo Short, Amway knew about these illegal tools businesses as early as 1965 (*). They were a problem for Amway-- the books, records, and rallies sold by these "rogue" high-level distributors competed for distributors' money that should have been going to Amway products. The rogues may have had that covered too -- today they tell their downline distributors to "buy from yourself" to "build your business" -- just find friends and family willing to do the same and everybody will get rich. They put pressure on distributors to buy motivational tapes and attend frequent seminars (not free) or risk losing their "business momentum". They encourage distributors to spend on credit in an effort to appear wealthy before they actually are, to the point of bankruptcy, foreclosure, and divorce, while at seminars they promote the business as having made them wealthy and saved their marriages. And they encourage hyperconsumption to the point that their trusting downlines fill their basements and garages with products just to make the next level of commissions and prestige -- precisely the front-loading problem that the FTC tried to address in the 1979 case. Many websites today detail this abuse, and I have little doubt this was already part of those rogues' strategy during the 60s and 70s when Amway came under FTC scrutiny for being a pyramid scheme. But they had to benefit Amway or risk having their distributorships terminated. For Amway, the payoff from the tools businesses may have been (and likely still is) huge. Recall that between 1960 and 1964 Amway sales had jumped from $500,000 to $25 million (*), reaching $200 million by 1976 (*), $1.2 billion by 1981, and more than $4 billion by 2003 (*). That's growth by a factor of over 8000 in only 43 years.

Amway definitely hit some snags along the way. A 1985 Forbes magazine article ("Cleaning Up", March 25, 1985) describes Amway's business slumping after 1981 and implies that defectors were leaving because they were either losing their shirts after being milked by the tools businesses or angry that Amway was failing to terminate the abusers (*). Only 3 years after Amway emerged victorious against the FTC, co-founder Rich DeVos chastised his organization:

"You [the Direct Distributors] present the wonderful numbers on the blackboard about all the money they [distributors] can make. Maybe you ought to tell them about all you're going to take from them [with your tool businesses] before they make any" ("Directly Speaking" tapes, 1982 [*]).

But one year later in 1983, Amway solved the illegal tools businesses problem not by terminating the distributorships of offenders but by absorbing their tools businesses into its own business, paying limited commissions on their sales (*). One website author posits rather convincingly that real estate "guru" Robert Kiyosaki's motivational book Rich Dad, Poor Dad made him a millionaire only after Amway adopted it into its tools program (*). Also in 1983, the television program 60 Minutes ("Soap and Hope"[*]) noted the connection between the riches earned by Amway's largest distributors and the illegal tools businesses. Interviewee Bruce Craig, Wisconsin's Attorney General, revealed that of 20,000 Amway distributors in Wisconsin, the average income of 99+% of Wisconsin Amway distributors was actually a net loss, and the program implied the illegal tools businesses were milking participants. (An examination of the 1979-1980 tax records in the state of Wisconsin showed that the Direct Distributors, comprising less than 1% of all distributors, reported a net loss of $918 on average [*] [*],[*].) Amway co-founder Jay Van Andel's response: "They're NOT our employees and we can't tell them or enforce things beyond a certain degree"(*). Only three years after that, one of Amway's largest distributors, Dexter Yager, admitted to Forbes magazine ("Cleaning Up", March 25, 1985) that the tools sales in his "leg" comprised 2/3 of his income (*) -- and his leg accounted for perhaps 1/3 of Amway's direct sales volume. Former high-level Amway distributor turned whistle-blower Eric Scheibeler, author of the exposé book Merchants of Deception, describes the tools business as still being in full swing in the 1990s even after many, many complaints (*). When he complained to Amway corporate, Amway shut off his income and told him to discontinue contact with distributors he was revealing the fraud to (*). In 2002, Amway terminated the distributorships of 6 large distributors who loudly complained about not receiving their fair share of the tools business from their uplines; 12 others resigned, protesting that Amway should have canned the abusers, not those who simply complained about the abuse (*). In 2004, Dateline NBC did an exposé on Amway/Quixtar (Amway began calling itself Quixtar in North America in 1999 [*]) in which a high-level distributor was unwittingly caught on tape admitting that 3/4 of his income came from the motivational tool business (*). Rogue high-level distributors also encouraged disregard for the 10-customer rule; in 1998 Louisiana newspaper The Advocate quotes Larry Harper, a senior manager of Amway’s distributor relations section, acknowledging that bonus checks get paid to distributors who have no retail sales and that it was up to the Direct Distributor to decide if this rule should be enforced (*). In spite of any defections, Amway's sales still grew fantastically.

Returning to 1979, the FTC had ruled an entire industry legal based on the premise that MLM could avoid front-loading its distributors with items they could not sell. This did nothing to prevent the false advertising of the business opportunity that drove participation without regard for the sale of products, evidenced by the statistics I quoted and plain old common sense. I once again repeat the FTC's description of a pyramid scheme from Koscot:

A pyramid scheme is "characterized by the payment by participants of money to the company in return for which they receive (1) the right to sell a product and (2) the right to receive in return for recruiting other participants into the program rewards which are unrelated to sale of the product to ultimate users" (*).

Amway co-founder Jay Van Andel had admitted in 1982 that he had little power over distributors who made false claims, but in that same year legislation was conveniently passed that got Amway -- and the MLM industry -- off the hook for it anyway, as you'll see in the next section.

1982's IRC §3508: Lobbyists push bad legislation to reclassify specific employees as independent contractors for their own benefit

In the late 1970s, MLMs and other companies had witnessed a pattern of the Internal Revenue Service fining into bankruptcy companies which had misclassified employees as independent contractors (ICs), a misclassification which was costing the IRS revenue. Congress temporarily halted the IRS's inquisition and attempted to clarify worker classifications with its 1978 Tax Act Section 530 (IRC section 3401) safe harbors provisions (*, *), but MLMs were still in a state of panic. Ruling their independent contractors as employees would destroy the very basis of MLM, that of individual business opportunities. In 1982, the IRS added Internal Revenue Code Section 3508, which conveniently gave a statutory exemption to two groups of workers: real estate agents and direct sellers. §3508 in effect only muddled the difference between independent contractors and employees, and I have no doubt lobbying by the MLM and real estate industries had everything to do with it. This was certainly the case in 1996 when the newspaper lobby got Senator Bob Dole (R-KS), who happened to be running for president, to put a rider on the minimum wage bill that excluded newspaper carriers from all of the labor laws, making them permanent independent contractors (*, *). Democratic President Bill Clinton signed it into law that same year (*). The biggest problem with §3508's exemptions is that it directly conflicts with the IRS's criteria for being an independent contractor. The one-sided non-compete and non-solicitation agreements that independent contractors in the afore-mentioned industries are forced to sign (they have no authority to negotiate what they're agreeing to) are clearly against the laws of free enterprise that a true independent contractor enjoys. Legitimate ICs, by the IRS's and other regulatory agencies' own criteria, come to their clients pre-hatched -- they already present themselves as professionals in their fields; are usually incorporated; have business and professional licenses; assume responsibility for taxes, workers' comp, insurance (E&O, health, dental, vision, etc.), expenses (advertising, overhead), and legal liability (bonded); are hired on a per-project basis and are paid upon completion of the project; can realize a profit or suffer a loss in their business; may perform services for as many clients as they wish with no restrictions; come with all tools necessary to complete jobs; and do not perform work for clients which can impact the success or continuation of the clients' businesses.

That last point is crucial. MLM's success or continuation depends on the services these workers provide; remove these workers, and the business must grind to a halt! And it works in reverse too -- take away the company, and these workers' "businesses" vanish. The last point is also significant in that MLM law directly conflicts with it, actually requiring the MLM to rely on the generation of sales and enrollments exclusively by distributors and not by company "employees" (*). (This is to satisfy the "Howey Test" of 1946, mentioned in the "Koscot" section of this article, which determined that a regulable security existed when "a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party" [*].)

The impact of IRC §3508 on affected industries can be seen in complaints about those industries which have chosen to take advantage of §3508's exemptions:

  • Newspaper carriers (*). Newspapers have a long history of paying "paper boys" to deliver papers. However, with today's laws against child labor, they have been forced to deal with a more demanding workforce pool. Some hire actual employees, but many newspapers have decided to take advantage of §3508's exemptions and classify newspaper carriers as independent contractors. They either allow the carrier to buy and resell the newspapers at a set price or pay a commission per paper delivered. Carriers at these newspapers bear all expenses, including wear, tear, and insurance on their own automobile; reporting taxes; health insurance; etc. Although the advertised high wage looks pretty good to new carriers, they find that when all expenses are deducted from the "business", they are working barely above minimum wage -- or even at a loss! Many newspapers charge the carrier a "complaint fine" several times the retail cost of the paper when a customer complains about a wet, torn, misplaced, late or missed paper. This is particularly problematic when the newspaper requires the carrier to bear the costs of bags and rubber bands for the papers (without rubber bands, the papers are difficult to throw), and paper theft is commonplace in apartment complexes. Carriers complain of being pressured to ignore traffic laws in order to get deliveries done on time, since their route is assigned by the newspaper. They burn through automobile brakes, gasoline and headlights, and face robbery and carjacking in the wee hours of the morning. When they are injured slipping on icy driveways or bitten by dogs, they are told it's their own problem (*). As ICs, they face obstacles unionizing for better working conditions (*).
  • Real estate agents. Some real estate businesses stick to the now-safe method of hiring agents as "independent contractors" and advertise to attract as many new agents as possible in an agent-mill fashion, arguably in order to gain access to the agent's leads, which often consist of friends and family. These new agents, making a lesser percentage of commissions than an experienced agent, make a few sales and often end up leaving the business for lack of income; the annual turnover rate for agents is high. Agents complain about operating their own "businesses" and having to pay for advertising, desk fees, insurance, taxes, etc., yet their brokerage exercises control over things more typical of an employer-employee relationship, like adding the brokerage to their auto insurance policies as second insureds or requiring the agent to increase their coverage. These brokers often advertise to attract far more new agents than the market will bear (*), allowing new agents, who require fewer hours of training than even a hairdresser (*), to sink or swim. Escalating consumer complaints against California RE agents coincide with a 44 percent increase in the number of agents between 1999 and 2004 (*). Some comments from real estate agents regarding the above model:
    • "The reason brokerages use new agents like puppy mills is they know most people getting into real estate are not coming from a business background but from a 40 hour 9-to-5 collect-a-paycheck crowd. [...] The owner/broker knows that everyone knows someone in their sphere that will net them a couple of deals before they die out with no more leads." (*)
    • "With the huge 95%+ fall out rate of new agents in the first 2 years that is how brokerages bring in commissions from the built in sales most agents have..." (*).
    • "We joke about part timers as 'they have a real job' on the side" (*).
    • "Most of the new agents that are flooding the market now are in search of a quick buck and think they will be a millionaire in a year. Statistically, each 'temp agent' will do less than a few deals in a year. Then they go back to corporate America" (*).
    • "The state considers us employees. We are only independent contractors under IRS's eyes" (*). The writer refers to the California Labor and Workforce Development Agency, which has taken the position that a RE agent is nearly always an employee for workers' compensation insurance purposes - but that is only California.
    • Agents carrying all expenses and generating all leads wonder why they have to split commissions and pay a broker for desk space at all! Fault lies in the law, which requires RE agents to be sponsored by a broker who may abuse his role.
  • Direct sellers. Complaints similar to both classes above. This is a vague class, as it's the employer's choice whether or not to classify the worker as a direct seller. This last class is pertinent to MLMs and is particularly wrong-headed in that ICs may only write off their many expenses if they show a profit for 3 out of 5 years according to the IRS (*); the vast majority of MLM participants never net a cent and thus do not qualify for writing off "business" expenses. Direct sellers include mostly single-level and multi-level (MLM) direct sellers, travel agencies, and insurance and financial services companies. The infiltration of MLM and its elements into the insurance industry is even more challenging, since the FTC does not oversee that industry (*).

The above industries, including MLM, were given specific exemptions with the passage of IRC §3508 and its amendments. However, there isn't a whole lot stopping lobbyists from adding other industries to that list, particularly ones where the misclassification of independent contractors is already rampant. Keep in mind that IRC §530 was intended to provide companies temporary relief against the IRS's 1970s crusade against employee misclassification, which was robbing it of revenue. In 1988, the IRS resumed its crusade (*). Industries wishing to continue misclassifying their employees as independent contractors must push to get their industries added to IRC §5308 or remain in a race against the IRS's fining them into bankruptcy. These industries tend to prey not on successful salespeople but on relatively naive work forces that they must train, consisting of the un- or undereducated, recent college graduates, stay-at-home moms, immigrants, and disenfranchised workers. (According to the Direct Selling Association, the average direct seller is a married woman between 35-44 with at least some college education [*].) Messengers and couriers, delivery drivers, taxi drivers, auto rental agents, car salespeople, model and talent scouts, and others not currently included within IRC §3508 could all face possible reclassification if lobbying is successful, or could be counted among the vague "direct sellers" category if courts set such precedent.

So why do MLMs and other like employers misclassify workers as independent contractors when those workers should quite clearly be classified as employees of the company? Because it's cheap and lessens legal liabilities. Companies that hire independent contractors generally avoid employer obligations under many state and federal laws (*). For example:

  • Reasonable accommodation and return to work obligations under disability laws do not apply.
  • Anti-discrimination obligations to protected employee classes (e.g., age, race, sex, national origin, ancestry, disability, medical condition, sexual preference, religion, etc.) are not a concern (though independent contractors are protected under sexual harassment laws).
  • No collective bargaining or union issues.
  • No employee benefits to extend, such as medical insurance, pension, stock option and other equity plans.
  • No disability insurance, life insurance, sick pay and vacation pay.
  • The worker is not part of the work force for workers' compensation insurance purposes.
  • Leaves of absence, such as Family and Medical Leave Act and pregnancy disability leave, are not required.
  • Tax and trust fund obligations (e.g., income tax, unemployment insurance, state disability insurance, paid family leave, employment training tax, Social Security and Medicare) are of little concern.
  • Unemployment insurance benefits are not owed.
  • Wage and hour laws (e.g., minimum wage, overtime, rest periods, vacation pay on termination, etc.) do not apply.
  • Plant closure and mass layoff notice laws are not a worry.
  • Wrongful employment termination and related causes of action do not exist.
  • Advertising and prospecting, transportation, professional licensing, office expenses, insurance, and legal expenses are borne not by the company but by the independent contractor.

In short, IC's are a cheap labor force, paid only when they make a "sale" and without normal employee overhead.

And finally, there was one more positively critical reason that the MLM industry wanted to ensure that its ICs remained so: legal liability. With 1982's IRC §5308, MLM could safely shield itself from liabilities incurred by abusive yet lucrative distributors, like those who operated the "tools businesses" in Amway. Again I quote:

"They're NOT our employees and we can't tell them or enforce things beyond a certain degree" (Jay Van Andel, co-founder of Amway, 1982 [*]).

Note the year.

MLMs proliferate in the 80s & 90s

With the 1979 FTC v. Amway case "clarifying" the rules under which the FTC would tolerate MLMs, and with the 1982 IRC §3508 "clarifying" direct sellers' classifications as independent contractors, the 1980s and 1990s saw a proliferation of MLMs (to the left is a partial list) and other industries (as mentioned above) that adopted MLM-like compensation structures to reap the same benefits. DSA memberships shifted from single-level to multi-level quite significantly after 1982, so it must pay [guess who?] for "direct sellers" to go MLM:

  • In 1970, less than 5% of DSA members were multi-level (as opposed to tradtional single-level); the Direct Sellers Association got its name only two years before in 1968. See the DSA's history here.
  • In 1990, 25% of DSA members were multi-level;
  • By 1996, over 70% of DSA members were multi-level;
  • By 1999, 77.3% of DSA members were multi-level;
  • By 2000, 78% of DSA members were multi-level;
  • By 2009, 97% of DSA members classified themselves as multi-level. I arrived at this figure by searching "single-level" [6] vs "multi-level" [197] in DSA's public member directory, then just divide 6 by 197 for the percentage = 3% single. Also, some of the 6 "single-level direct sellers" likewise appear to be misclassified, as their compensation structure fits the multi-level model despite what they list, so the percentage may be even higher. For instance, Avon and Mary Kay's compensation plans were once listed as single-level, and now the compensation plan is blank.

What enabled MLM's 80s/90s proliferation? More favors, of course, and a relatively quiet FTC. Indeed, during the Republican-led mid-1980s, the FTC actually sent representatives to MLM industry meetings and even extolled the virtues of MLM (*).

  • The single largest soft money donation then on record to any political party was $2.5 million from the Amway Corporation to the Republican Party in the final weeks of the 1994 election (*), (*). A 1996 letter from Republican National Committee Chairman Haley Barbour to Amway co-founders DeVos and Van Andel read: "Your generosity in 1994 clearly was a major factor in the historic Republican capture of majorities in the House and Senate".
  • According to the consumer watchdog group Common Cause, Amway and affiliated donors made soft money contributions to the Republican National Committee totaling $4,147,000 between January 1, 1991 and June 30, 1997 (*). From 1994 to 1996 Amway gave $366,000 to Republican Party causes and candidates, and it employed Roger Mentz, who was the Assistant Treasury Secretary for Tax policy in the Reagan Administration, as its tax lobbyist" (*). Amway had tried to get a $283 million loophole for itself passed in 1996 as an amendment to the minimum wage bill, but Sen. Byron Dorgan (D-ND) shot it down (*); then House Speaker and Amway supporter Newt Gingrich (R-GA) sneaked it back into a bill at the last moment in 1997 (*). The payoff was ultimately seventyfold.
  • A 1997 Texas newspaper article entitled "Congress Distributes a Tax Break to Amway" pointed out that five Republican House members at the time were Amway distributors (Sue Myrick [R-NC], Jon Christensen [R-NE], Dick Chrysler [R-MI], Richard Rombo [R-CA], and John Ensign [R-NE]). It further stated that "their informal caucus meets several times a year with Amway bigwigs to discuss policy matters affecting the company. [...] House Majority Whip [and later indicted House Majority Leader] Tom Delay (R-TX), a onetime Amway salesman, also remains close to the company." Myrick was a co-sponsor of DSA-backed HR 1220, which would effectively legalize pyramid schemes if passed.
  • A 1998 Mother Jones magazine article reported that Sue Myrick owes her election to Amway -- almost half her total campaign funds came from Amway people, urged on by the voice of George Bush himself and distributed via distributor Dexter Yager's internal voicemail (Amvox) campaign (*), (*), (*), (*); this may have violated campaign laws. Myrick wasted no time once in office in 1996 co-sponsoring the home-office deductibility bill, which allows tax write-offs for independent contractors who use their homes as offices -- a purported boon for Amway distributors. The day before Amway's $1.3 million funding of GOP convention coverage was revealed, Senator Bob Dole, who paid tribute to Amway founder Richard DeVos at a Republican party fundraiser only 1 week before, announced his support for the home-office deduction, as well as for an increase in health insurance deductions for the self-employed -- another measure purportedly benefiting Amway distributors. The same Mother Jones article also states that Reps. Bill Redmond (R-NM) and Heather Wilson (R-NM) also received Amway funding in 1996.
  • In 2000, Amway was the second largest contributor of “soft money” to the Republican National Party with contributions totaling $1,138,500; Amway was second in donations only to Reynolds Tobacco. The Orlando Sentinel reported that Amway co-founder Richard DeVos said: "People ask me sometimes why I support Bush. I've been a friend to the family for a long time. I give the max. People talk about buying access, but all I can tell you is that politicians know the people who support them" (*).
  • In 2004, the Republican 527 committee "Progress for America" received money from Amway founders Richard DeVos and Jay Van Andel, who each chipped in $2 million" (Newsweek, "The Secret Money War," September 20, 2004 [*]). In the last three weeks leading up to the November 2, 2004, election, Progress for America Voter Fund (PFA-VF) outspent the next largest spending Democratic 527 group three-to-one on political ads, buying $16.8 million in television and radio ad time (*).
  • In May 2005, former Amway President Dick DeVos, son of co-founder Richard DeVos and one of the wealthiest people in Michigan, and his wife Betsy DeVos, former chairman of the Michigan GOP, were listed as two of the largest campaign contributors of the 2004 election. Just days later, Dick announced that he would run against Michigan Governor Jennifer Granholm in 2006 (*); he lost.
  • The MLM-political entanglements get even uglier, touching the Federal Trade Commission itself. As president, George W. Bush appointed Timothy Muris (2001-2004) to head the FTC. Muris’ last job before chairing the federal agency that regulates multi-level marketing was as an attorney with the antitrust division of the firm Howrey, Simon, Arnold and White, LLP. The antitrust division of Howrey counts among its largest clients the Amway Corporation. While Muris was with Howrey and while he was in charge of the FTC, his former partners in the antitrust division at Howrey represented Amway Corporation in a class action lawsuit initiated by Joe Morrison, a former Emerald-level distributor, in the US District Court for the Southern District of Texas in 1998 (*). The suit charged that the recruitment program of Amway is an illegal pyramid scheme and was referred to mandatory arbitration as outlined in Amway's distributor agreement, so we may never know the outcome of the case. And Amway's insider influence in the Bush administration FTC extends beyond Chairman Muris. When the multi-level marketing company Equinox International, an Amway clone, was prosecuted for pyramid scheme fraud by the FTC during the Clinton administration, one of Equinox’s expert witnesses, David Scheffman, testified against the FTC and on behalf of the scheme (which was later shut down as part of a settlement). Scheffman argued that the Equinox business model was not a pyramid scheme. His claim was largely based on the assertion that Equinox operated just like Amway. Muris subsequently appointed this same David Scheffman as the FTC’s new Chief Economist (*, *).
  • Amway is also aligned with the fundamentalist Christian wing of the Republican party and has been accused of mining trusting Christians. In her book Amway Motivational Organizations: Behind the Smoke and Mirrors, Ruth Carter notes that "conservative Christian leaders James Dobson, and formerly Jim and Tammi Bakker have been staunchly pro-Amway, and claim friendships with Amway founders and high-level distributors. Reverend Jerry Falwell, who received massive donations from Amway leaders, issued statements on the internet and through Amway's voice messaging system supporting Amway against its critics. Dexter Yager, mentioned above with regards to the motivational business, reportedly gave a whopping $100,000 to the Rev. Falwell's Liberty University in Lynchburg, Virginia (*). Author Charles Paul Conn, president of Lee College, a small Christian college in Cleveland, Tennessee, has written six books about the Amway business, and was a favored speaker at Amway conventions for a number of years; and a number of entertainers and motivational speakers support the Amway business (*). According to Amway whistleblower Eric Scheibeler's Merchants of Deception (*), "You were either a Republican Christian or you would become one if you maintained any level of involvement [in Amway]. There was a constant level of conservative political promotion and religious services at seminars." Scheibeler also noted that many high profile individuals from outside the corporate world of Amway lent their credibility, both indirectly and directly, which was used to drive recruitment. Such figures included George Bush Sr., George W. Bush, Ronald Reagan, Gerald Ford, Senator Rick Santorum, Jack Kemp, Mary Lou Retton, Jerry Falwell, Billy Zeoli (president of Gospel Films Inc.), Charles Stanley, Robert Schuller, Dave Thomas, Dennis Waitely, Zig Ziglar, Oliver North, and Newt Gingrich. Because of the conservative Christian messages touted at seminars and the fact that high-level distributors discouraged their downlines from associating with "loser" outsiders, including family, Amway gained a cult-like reputation. Some distributors even used their church congregations for recruiting, earning them the derogatory title of "Amway Christian" (*). At least one Amway official hinted at an admission of the problem -- a 1985 Forbes Article reports: "Last year DeVos and Van Andel brought in William Nicholson, former president Gerald Ford's appointment secretary, to reorganize Amway. Nicholson says the firm is cleansing the sales force, and there is a new approach, downplaying evangelism and cultism and emphasizing real sales training instead" (*). Outside of Amway, this strategy of some MLMers worked so well for recruitment that Dr. Jon Taylor, President of the Consumer Awareness Institute and author of the anti-MLM website www.mlm-thetruth.com, even found it necessary, based on his experience with MLMs infiltrating religious congregations, to warn MLM-heavy Utah's Mormon population against MLMers out seeking recruits from among them (*).

Clearly some in Amway, the Mother of all MLMs, saw the potential in aligning themselves with others who believed in American free enterprise and Christian values -- and then abused those relationships. I'm certain that many religious leaders and politicians are thankful for the financial support but don't understand the entire reasons behind the causes and legislation they're then asked to push on behalf of their benefactors. And then again, some probably know full well what they're doing.

1994-1996's NuSkin case: FTC begins new crusade against pyramid schemes

The Democratic presidency of Bill Clinton from 1993-2001 released the hounds on MLMs, pyramid schemes, and "business opportunity frauds". FTC Chairman Pitofsky (D) noted the meteoric rise in "business opportunity" frauds about which consumer complaints surged in the 1980s and 1990s (*), and in April 1995 he began soliciting public comments about the possible inadequacy of the Franchise and Business Opportunity Rule (the "Franchise Rule"). He described the biz op problem in a February 1996 warning to consumers thusly: "Lured by deceptive promises of independence and easy income, many would-be entrepreneurs are jumping into the arms of con artists who claim: 'we are not just selling you a business, we put you IN business'", further calling the problem "epidemic"(*).

During his six-year tenure, while still forumulating criteria for a possible new Franchise Rule, he successfully applied the FTC Act and Franchise and Business Opportunity rule to fine many MLMs and like businesses into bankruptcy. The cases involved MLMs as well as promoters selling "franchises" of vending machines, pay telephones, medical billing, and envelope-stuffing schemes.

In 1994, the FTC went after NuSkin alleging unsubstantiated claims for the income opportunity and products. A regime change occurred in the FTC in 1995 when Democratic President Clinton replaced the Republican Steiger with the Democratic Pitofsky as FTC Chairman. In 1997, NuSkin paid a $1.5 million civil penalty to settle the case but came under scrutiny for continuing to disobey the 1994 FTC Order against it -- with the FTC failing to enforce the Order and assess further consequential penalties (*). But it would be disingenuous to be critical of FTC Chairman Pitofsky as being too soft, as he proved quite the pitbull for the remainder of his term until Republican President George Bush replaced him with Timothy Muris in 2001. The MLM industry did begin to note the pattern under Pitofsky: MLMs were ambushed, with the FTC often gaining injunctions that froze assets as it fined the targeted MLM for FTC violations, often to the point of bankruptcy and without the MLM ever admitting guilt.

NuSkin also sold products under the names of Pharmanex, Big Planet, Photomax, and IDN (Interior Design Nutritionals). In 2005 and 2006, Nu Skin communicators (based in Utah), aided by the DSA, lobbied for state legislation (SB 182) removing the requirement for direct selling to "legitimate end customers" ("personal use") in Utah's Pyramid Scheme Act -- and got it.

1996's Omnitrition case: FTC challenges "personal use"

In 1996 the FTC under Pitofsky (D) began revisiting the issue of chain-recruiting in the aftermath of a 1994 civil class action suit against Omnitrition (Webster v. Omnitrition International [*]). The case boiled down to the suspicion that most distributors were simply selling to their own downlines based on Omnitrition's misrepresentations that all participants had an equal opportunity to get rich by building endless downlines, which had already been noted by the FTC as deceptive because it was impossible due to market saturation. Omnitrition defended that its compensation program was similar to Amway's; the court found that the existence of the Amway Safeguards was at a minimum no good without enforcement. The court also reinforced via an in dicta opinion (statements made by the court but not part of the holding itself) that the amount of focus a company places on retailing versus recruiting is a key determinant of whether or not it is a pyramid scheme (*) (same as was established in 1975's Koscot), i.e. sales to persons who are participants in the company's compensation program do not qualify as "retail sales" for purposes of satisfying the Koscot test. Regarding Koscot:

"[...] recruitment with rewards unrelated to product sales is nothing more than an elaborate chain letter device in which individuals who pay a valuable consideration with the expectation of recouping it to some degree via recruitment are bound to be disappointed (Webster v. Omnitrition International [*])"

And now Omnitrition's in dicta language which referenced Koscot:

"[...] plaintiffs have produced evidence that the [Amway] 70% rule can be satisfied by a distributor's personal use of the products. If Koscot is to have any teeth, such a sale cannot satisfy the requirement that sales be to 'ultimate users' of a product." (Webster v. Omnitrition International [*])

The case settled out of court, but the Direct Selling Association (DSA), an association of direct distribution companies, recognized the potential for the in dicta opinion on "personal use" to impact the MLM industry and filed a 1996 amicus brief (friend of the court) in support of Omnitrition. Now, the old DSA c. 1990 whose MLM members only comprised 25% of its membership roster would have had little reason to defend "personal use", as their majority traditional single-level direct sellers had as their end users consumers exclusively outside the scheme; there was no incentive for end users to participate in order to buy products. The new DSA c. 1996 clearly had a majority of MLM members now who had a stake in sales to participants inside the scheme; in fact, the DSA argued in its ignored amicus brief:

"... consumption by participants of direct selling companies' products is a natural and appropriate element of direct sales. [...] It is an axiom of direct selling that a company must successfully market its products to its own distributors if it is to have any hope that its distributors will successfully market its products and its opportunity to others. [...] Sales to distributors and their use of a plan's products can be crucial to the success of a bona fide direct selling company (*)."

The DSA was arguing in essence that the court's attack on "personal use" based on the Koscot test was an attack on the very structure of MLM based on a "misunderstanding" of how MLM worked. The problem that Koscot recognized with "personal use" was that those at the bottom of a saturated MLM, comprising mathematically in fact the vast majority of MLM members, should of necessity be selling retail to nonparticipants since the incentive to recruit was no longer present. The DSA was arguing that the Koscot test did not apply to unsaturated MLMs. The DSA seemed to have a point, but the problem then with an unsaturated MLM with a focus on "personal use" was that it risked triggering onerous laws regulating "buying clubs" (also called buyer's or merchandise clubs) that could impede business (*), including registration with the state (usually the Attorney General), the posting of a bond, the payment of registration fees, establishing trust accounts or escrow accounts for prepayments of fees collected from buyers (*), and, sometimes, complying with a requirement that savings claims made by the buying club must be based on price comparisons with area retailers comparing like items; violators of these myriad and inconsistent federal and state laws could be faced with severe penalties, including injunctive action. Because the risks substantially decline below a minimum investment level, statutes defining business opportunities contain minimum initial investment threshold exemptions; the FTC's Franchise and Business Opportunity Rule of the time stated the minimum threshold as $500.00. Take note of that amount, as it will come back to haunt the MLM industry later!

In order to avoid the onerous restrictions involved with being classified as a buying club, MLM had to eliminate all recruiting based on the attractiveness of buying wholesale. Thus the only reason a new recruit would join an MLM had to be based on the business opportunity, an opportunity that may not be viable because MLM by its very structure has no controls to determine at what point market saturation occurs. The court was correct in attacking MLM's structure (again); a prevalence of "personal use" among MLM distributors was definitely evidence that the income opportunity drove endless chain recruitment, i.e. recruiting was emphasized over retailing.

The Omnitrition court affirmed that the Koscot test was necessary, though it never explicitly noted the buying club connection and thus failed to fully understand exactly why the Koscot test was necessary. The court also affirmed that the Amway safeguards were still sound but emphasized that they needed to be enforced in order to be a defense. However, a second look reveals that Amway itself could not have been enforcing the Safeguards. Recall this quote:

"The average monthly BV [Business Volume] of Amway distributors in fiscal [...] 1973­74 [...] was about $33 a month. Much of this amount is consumed by the distributors themselves rather than resold. [...] Many of them consume large amounts of the products every month. [...] We note that this figure is not 'retail sales', but Business Volume ­­ that is, the retail value of the products purchased for resale to consumers and sponsored distributors, and for distributor home consumption, which was stated before, constitutes a large portion of all sales of Amway products." ( FTC v. Amway, 1979 [*])

Only about 25% of Amway distributors as of that case sponsored new distributors (*). Clearly it wasn't for lack of trying, since buying club appeals were out and the biz op was the only reason to participate.

In affirming the use of a definition that excluded self-consumption of products from the "retail sales" requirements of the Koscot case, the Sixth Circuit endorsed the position taken by the FTC and the Omnitrition court, and specifically pointed out that a basis for the Koscot case was the extensive self-consumption of products by the scheme's participants rather than actual retail customers. The court concluded:

Given the district court's instruction that a pyramid exists when a program's rewards relate to recruitment, not product sales, the jury necessarily found the possibility of saturation when it found that the defendants ran a pyramid scheme: "The presence of this second element, recruitment with rewards unrelated to product sales, is nothing more than an elaborate chain letter device in which individuals who pay a valuable consideration with the expectation of recouping it to some degree via recruitment are bound to be disappointed." Omnitrition, 79 F.3d at 781 (quoting Koscot). (*)

1996's Fortuna Alliance case: FTC reinforces retailing over recruiting

In May 1996 the FTC pursued Fortuna Alliance on grounds that although it appeared to be offering consumer benefits services, in reality it was selling positions in an opportunity with the right to secure others to do the same. (Recall that 1975's Koscot case found that selling positions in an opportunity constituted a security.) The FTC also charged that Alliance was inducing consumers to join the scheme with false income claims. (*) In February 1997 Alliance settled, agreeing to repay around $5.5 million in redress to consumers. In the final settlement, Fortuna Alliance was permitted to pay commissions on the sale of goods and services, but it was strictly prohibited from paying commissions on membership fees or dues, because those purchases were of "business centers".

However, Fortuna Alliance violated the FTC's Order and dragged its feet with repayment, moving assets and operations offshore in a Fortuna II scheme, claiming:

"One of the most important changes in Fortuna Alliance II will be that the company will maintain its operations off-shore from each and every country where it will do business. This means that a 'raid' by a governmental agency which put Fortuna Alliance out of business without a warning or a trial to prove guilt of any kind, will never happen again." (*)

The FTC pursued Fortuna Alliance once again in October 1997, and after being charged with contempt, Fortuna finally complied with the Order and paid. In any case, MLMs took notice as the FTC was able to effectively shut down, even only temporarily, MLMs suspected of being pyramid schemes before the crimes were ever proven in a court of law. They also took note of the prohibition against paying commissions on membership fees or dues, as some MLMs selling discount buying, travel, and consumer benefits packages also took note of the FTC's prohibition against paying commissions on membership fees or dues, though in the Fortuna Alliance case the prohibition specifically referred to dues related to purchases of "business centers" (which constituted unregistered securities).

1997's Jewelway case: FTC formulating criteria for Biz Op Rule review

In 1997 the FTC ambushed MLM Jewelway, alleging it was an illegal pyramid scheme that emphasized recruiting over retailing. Jewelway, its assets frozen under temporary restraining order, agreed under duress to exactly the language that had been so dangerous in Omnitrition: Jewelway 's sales revenue must come "primarily from retail sales" to nonparticipants (*). In addition, Jewelway agreed to some very onerous restrictions in order to enforce compliance so Jewelway could continue its business. Among other things, the settlement required Jewelway to:

  • disclose the percentage of all representatives in the program who have received a particular reward (e.g., a specific income level, car or home allowance, vacation package) at the time a claim is made regarding income potential or likelihood of earning other types of rewards;
  • implement a 90 day "cooling off" period, under which the purchaser of JewelWay's jewelry cannot join the company as a representative for 90 days;
  • review all representatives' advertisements before allowing the ads to run;
  • obtain from each new representative a signed verification form, which the defendants must review before depositing any of the representative's money, to ensure that none of the prohibited claims were made (if the defendants do not receive a completed verification form from a consumer, the purchase price must be refunded).

(The above rules will later be the foundation for the FTC's 2006 Proposed Business Opportunity Rule.)

Note that the above requirements infringed upon the rep's independent contractor status by exerting control over the method in which he ran his "business" (in case he wasn't already restricted enough). The message sent was clear: Jewelway could now be held responsible for infractions by its distributors. It also set the stage for independent contractors to possibly challenge their status as employee misclassification. Jewelway filed for bankruptcy around 1999 (*).

1997's World Class Network case: More of the same

World Class Network was a multi-level marketer of travel agent credentials that the FTC charged with running a pyramid scheme which drove recruitment by misrepresenting its services and income opportunity. WCN's own records indicated that only about 4 percent of the more than 51,000 purchasers earned more than $1,000 in commissions in 1996, and that more than 35,000 of the network members received no commissions at all last year (*). Similar to Jewelway, the FTC required among the stipulations in its consent judgment that WCN:

  • implement a program under which consumers could receive refunds of 100 percent of the purchase price within 45 days of the date of purchase, and 90 percent within 46 to 90 days of the purchase date;
  • implement a 90 day "cooling off" period for sales of travel tutorial kits under which the purchaser cannot become a travel agent or a distributor for 90 days;
  • obtain from each purchaser a written verification form ensuring that the prohibited claims were not made before depositing any of the purchaser's money;
  • review all distributors’ advertisements before allowing the ads to run;
  • disclose, in connection with any earnings claims made, the number of purchasers who made at least the amount claimed and the percentage of total purchasers who earned that amount.

(Note once again how these rules will later form a foundation for the FTC's 2006 Proposed Business Opportunity Rule.)

1998's Futurenet case: FTC retreats a step on "personal use"

Since 1996's Omnitrition case, the MLM industry was on somewhat thin ice regarding "personal use." In Futurenet's case, the FTC alleged that, like Fortuna Alliance, the Futurenet program was a pyramid scheme in which individuals made money by recruiting others who paid "training" fees to purchase "positions". In the JewelWay case, the majority of the sales revenue approach had been applied to the entire company, but in Futurenet, the majority sales revenue approach was applied to individual distributors, i.e. compensation to the individual distributor must be based primarily on retail sales. This time it allowed that retail sales could also include reasonable distributor "personal use" purchases not to exceed $30/month (service contracts) or $360/year (single purchase items) (*). This deterred inventory loading, the bugbear of the Omnitrition case, but removed the consumer protections against "closed system" buyer clubs in which distributors were encouraged to buy, even in small amounts, only to participate in the endless chain commissions. This new standard only led to more FTC micromanagement and confusion.

Of note here is that the FTC did approve the payment of the recruitment (training) fees, a practice heretofore consistently condemned as one of the hallmarks of a pyramid scheme -- but commissions on recruitment could only penetrate one level deep (*).

1999's 2Xtreme case: FTC questions "closed system" buying clubs

Of note in this case is the fact that 2Xtreme Performance International sold training materials, a practice vaguely approved of in Futurenet, but the FTC took notice and disapproved this time because the training materials were required as mandatory purchases in order to earn 2Xtreme commissions. The training materials (and commissions paid on them) served only those within the MLM (a closed system), had no value to those outside and were even of questionable value to those inside -- the Dallas BBB had received many complaints a year before from consumers who complained they lost money because of income misrepresentations and dodgy buyback policies. Also of note is this comment by Jodie Bernstein, Director of the FTC's Bureau of Consumer Protection: "[The 2Xtreme] scheme produced the same results all pyramids do: most consumers lost their money" (*). Suddenly, it looked like the only criterion for the FTC to prove that an MLM was a pyramid scheme was to simply prove that most participants lost money. Of course, proving this was far more difficult than it sounds on the surface, but the FTC was gaining some momentum in prosecuting pyramid schemes.

2000's Equinox International (Trek Alliance): FTC finds Amway defense inadequate again

In a case culminating in 2000, the FTC charged Equinox International with being an illegal pyramid scheme. The founder invoked the Amway defense and the FTC again found it again inadequate without enforcement. Without admitting any wrongdoing, he settled, liquidating assets of about $40 million to satisfy the terms, as well as being barred for life from ever again engaging in MLM operations (*).

2001's BigSmart case: FTC again finds "independent contractor" defense inadequate

According to the FTC, Bigsmart.com claimed that customers would make "substantial money" by participating in the company's e-tail program. The FTC alleged that Bigmart.com's claims were false and were intended to recruit more participants to buy the welcome pages (*).

In May 2001 BigSmart settled with FTC, paying $5 million in consumer redress. Of note is the fact that BigSmart, like so many MLMs before it, attempted to blame its independent contractor work force for the violations (*), which you might recall backfired in 1997's Jewelway case. Two of the promoters were previously high-level distributors with Equinox International (mentioned above)(*).

2001's Skybiz case: FTC finds 96% of participants lost money

In May 2001 the FTC charged that Skybiz was a classic pyramid scheme in which promoters misrepresented the income opportunity and products. Evidence showed at least 96% of participants lost money in the scheme. The 2002 settlement provided for $20 million in redress to consumers and barred the promoters from participating in or encouraging others to start another MLM for a specified number of years (*). I believe this was Democratic FTC Chairman Pitofsky's last significant case against pyramid schemes; President George W. Bush replaced him with Timothy Muris (R) in June.

2001-2009: FTC goes relatively silent regarding MLMs

You might remember George W. Bush (R) appointed pro-MLM Timothy Muris in June 2001. Below is a chart indicating the above-mentioned FTC lawsuits and during whose administration they occurred. Note how the FTC went relatively quiet on MLMs after Muris's appointment and throughout the subsequent Republican-led chairmanships.

FTC Chairmen Designated by the Presidents from 1975 to 2009 (*):

  • 1970-1973 (R) Kirkpatrick ---- initiated Koscot
  • 1973-1975 (R) Engman -------1975 Koscot, and Amway investigation begins
  • 1976-1976 (D) Dixon (Acting)
  • 1976-1977 (R) Collier
  • 1977-1981 (D) Pertschuk------1979 Amway concludes
  • 1981-1981 (R) Clanton (Acting)
  • 1981-1985 (R) Miller
  • 1985-1986 (R) Calvani (Acting)
  • 1986-1989 (R) Oliver
  • 1989-April 1995 (R) Steiger--------- 1994 NuSkin (but FTC failed to adequately enforce the Order)
  • April 1995-May 31, 2001 (D) Pitofsky-------- Charged with being pyramid schemes: 1996 Omnitrition; 1996 Fortuna Alliance; 1997 Jewelway; 1997 World Class Network; 1998 Futurenet; 1999 2Extreme; 2000 Equinox; 2001 Bigsmart; 2001 Skybiz. Also conducted enforcement sweeps of allegedly fraudulent "business opportunities" like Projects Telesweep, Buylines, Missed Fortune, Vend-Up Broke, and Biz-illion$ (*).
  • June 2001-2004 (R) Muris
  • 2004-2008 (R) Majoras
  • 2008-2009 (R) Kovacic
  • March 2009-present (D) Jon Liebowitz

It's very possible I've missed mention of actions above, but most sources I read seemed to agree that the above cases were the most significant regarding MLMs.

In 2003, spurred into action by the FDA, Muris did initiate regulatory actions against an MLM called Seasilver for making false and unsubstantiated claims -- but he did not allege it ran a pyramid scheme. Muris did appear to have teeth when he put a stipulation in the consent order that if Seasilver failed to pay the $3 million owed to consumers in redress, it would trigger a penalty increase to $120 million (*), and he did enforce it when Seasilver failed to comply. Seasilver was forced into bankruptcy (*). Otherwise, the FTC remained fairly quiet on MLMs for seven years of Republican rule.

You will recall that previous FTC Chairman Pitofsky (D) noted the meteoric rise in "business opportunity" frauds in the 1980s and 1990s and had instigated a 1995 regulatory review of the Franchise and Business Opportunity Rule. Though he had prosecuted "franchise" and MLM promoters of "business opportunities," establishing in 1997's Jewelway and World Class Network cases some guidelines under which such business opportunities should be permitted to operate, the job of actually revising the Franchise Rule fell to successor after successor as the Rule remained in question.

In April 2006, the FTC under Chairman Deborah Majoras (R) followed up and issued the Initial Proposed Business Opportunity Rule (IPBOR), which included many of the base criteria Pitofsky had outlined. The original 1978 Franchise Rule had covered only business opportunities and franchises in which the buyer's initial purchase was $500 or more, as that was believed to cover most get-rich-quick schemes of the time, but the new proposed Rule would also cover MLM business opportunities, erasing the $500 minimum payment requirement that had previously classified the opportunity as subject to the Rule.

When the FTC solicited public comments, the vast majority of the 17,000 comments came from the MLM industry (*), urged on by the DSA to send form letters objecting to the Rule. These commenters urged the Commission to narrow the scope of the IPBOR, to implement various safe-harbor provisions, and/or to reduce the required disclosures. For instance, DSWA (Direct Selling Women's Alliance) stated these reasons, which are rather representative of the industry, as their primary objections:

  • The required disclosure and earnings statements and the required list of all distributors who have cancelled their distributorship in the previous last two years may cause the sponsoring process to become cumbersome and difficult. (Ya think?!)
  • These requirements may create unnecessary alarm and concern about the legitimacy of the profession and your business opportunity to prospective distributors. (Unnecessary?!)
  • The proposed seven day waiting period between receiving the disclosures and enrollment would likely cause a potential distributor to lose their enthusiasm for joining your company. (God forbid a prospect actually THINKS about a business decision that could sink them into massive debt over time.)
  • The costs of complying with the requirements would increase expenses to the company which may be passed on through the selling price of goods or services we offer. (You've GOT to be kidding.)

Only a handful of comments were submitted by non-MLM companies and industry groups; 85 congressmen also objected to the Rule (*), urged on by DSA & MLM interests. Of this there is no doubt; see this letter and this letter from senator Mel Martinez [R-FL]; he received donations in the past from Richard Devos of MLM Amway. (Athough he lives in Michigan, Devos owns Florida's Orlando Magic sports team and was named by the Orlando Sentinel as #15 of the "25 Most Important People in Central Florida [*].) See also this letter from senator Mike Crapo [R-ID] on behalf of MLMs Stampin' Up and XELR8. Those are but a few.

On March 18, 2008, the Direct Selling Association (DSA) and MLM lobby scored a major victory when the FTC, now under Chairman Kovacic (R), announced that it was seeking to modify the Proposed Business Opportunity Rule to exempt MLMs (*), as they determined the potential harm to that industry could outweigh any benefit in preventing fraud. This is completely at odds with a 2007 letter from the FTC under Majoras to Senator Martinez which stated:

"The requirement to provide this disclosure document would cover all types of business opportunity sellers, including those employing the multi-level marketing - or 'direct sales' - model. In the Commission's enforcement experience, fraudulent businesses have often passed themselves off as legitimate companies that use this business model" (*).

The FTC will never put any teeth in the Biz Op Rule if it continues to bow to lobbying by every industry that fears that telling the truth about their "income opportunities" will (rightfully so!) impede their ability to conduct and even continue their businesses. I am incredulous that MLMs are permitted to continue skirting laws of even basic common sense using vagaries; indeed the only reasons they are not considered franchise opportunities is that they do not "sell the opportunity" - though they may sell a product, specifically a kit, that "informs" the prospect how to conduct his business - and the initial purchase price is less then $500. The fact of the matter is that recruiting is done face-to-face largely with friends and family members for a reason, with participants being not only taught but TRAINED by their uplines to "duplicate themselves", and then "helping" (read: training) recruits to do the same. MLMs can't assign territories without triggering laws that risk their independent contractor sales force being classified as employees either - but that also forces the largely inexperienced and unsophisticated sales force to market blindly and inefficiently without regard to inevitable market saturation. As 1975's FTC v Koscot noted:

"[...] even where rewards are based upon sales to consumers, a scheme which represents indiscriminately to all comers that they can recoup their investments by virtue of the product sales of their recruits must end up disappointing those at the bottom who can find no recruits capable of making retail sales." (FTC v. Koscot Interplanetary 86 F.T.C. 1106, 1975) (*)

... and 1979's FTC v Amway noted:

The complaint alleges that distributors are not long likely to recruit other distributors because 'recruitment of additional participants must of necessity ultimately collapse when the number of personal theretofore recruited has so saturated the area with distributors or dealers as to render it virtually impossible to recruit others.'"(FTC v. Amway, 1979) (*)

The business model itself is the problem. In 2005, Dr Jon Taylor of www.mlm-thetruth.com did an evaluation of the compensation systems of some 150 MLMs and concluded that only three -- Avon, Pampered Chef, and Stampin' Up -- rewarded retailing over recruiting. When I checked that list again in 2009, the total MLMs evaluated had grown to over 250, and only Pampered Chef passed Taylor's compensation structure test, and even then that one was rated as only better than the rest. Dr Taylor also conducted a statistical analysis of income disclosures made by 10 representative major multi-level marketing (MLM) companies and the largest of all MLMs, Amway/Quixtar; results revealed that, on average, more than 99% of all MLM participants never realize ANY net income (*) from rebates, commissions or bonuses [...] and in fact LOSE money (*). The "intolerable potential to deceive" pointed out in the 1979 Amway case has only proven all too real.

It is my hope that the good, trusting people who are participating or considering participating in an MLM will find this article and take it to heart, as my only purpose in writing it was for purposes of helping them protect themselves. It is also my hope that regulatory agencies, including the FTC, will finally understand how they've been snowed and move towards stronger regulation of the MLM industry. They can continue fining offenders into bankruptcy after the vast majority of the damage is done, but far better would be regulations targeted at ensuring consumers receive all material facts up front so they can make truly informed choices before the brainwashing begins.

President Barack Obama's new FTC Chairman as of March 2009 is Jon Liebowitz (D). You may contact the FTC and other regulatory agencies and your state's Attorney General by using the links listed on this page.



IV. Complaints Against MLMs Outside the Financial Services Industry

Your firm may not call itself an MLM, but if it utilizes any MLM practices (commission-only direct sales to mainly friends and family, bonuses to recruit others; and baser practices such as ongoing training programs and training materials that recruits are pressured to pay for, cattle-call interviews/inductions, misrepresenting the average income of reps to attract recruits, a cultic atmosphere that discourages "negative influences", etc.), it may share something in common with the following companies: a similar pattern of complaints.

This list is by no means exhaustive regarding companies or lists of complaints against them, but it's quite a large list in itself. Company links go to their official sites for balance. Some websites are now defunct, whether the site operator simply lost interest or was sued to force site closure or remove specific information. As with most any defunct website, you can use the Internet Archive "Wayback Machine" at http://www.archive.org to view historical captures.

  • ACN, Inc. - (sells telecom services)
    • Exposing the Truth About ACN MLM. Alleges: misrepresentation of business opportunity, average (expected) incomes, chances of "success"; cult mentality; promotion of abuse of friendships.
    • Scam.com message board thread (Archived, so not all pages may show.) Long thread alleges: high pressure sales tactics; salespeople seem desperate; deceptive advertising; only way to make money is to recruit; cult mentality; high dropout rate; inferior products, training, and customer service.
    • The Millenium Project (archived) has a page on ACN. Alleges: deceptive advertising; Canadian regulatory authorities charged ACN with illegal pyramiding; Australian authorities ruled ACN an illegal pyramid; ACN apparently attempted to silence website with SLAPP suit.
    • MLMWatchdog.com has a page on ACN with the headline: "MLM ACN Australia Shortest Launch and Shut down in History". Site is Pro-MLM.
  • Amway / Quixtar / Alticor / Team of Destiny - (sells variety of products; its old staple was soap/detergent)
    • The Skeptic's Dictionary. Page critical of Amway. Note allegations of: fantastic income appearances represented to recruits at rallies; only the "elite" will succeed; recruit's income increases are based on overrides on his sales force; reference to cult-like mentality or atmosphere; "Friends & Family List" is main "prospecting" tool.
    • mlmSurvivor: Amway vs. Critical Websites. Mentions examples of alleged SLAPP suits in which Amway continued naming critical websites as defendants in an apparently unrelated case, ultimately forcing those critics to close their sites.
    • A 1986 FTC Order determined that Amway had violated its 1979 FTC Order against making earnings claims for its distributors without disclosing actual average gross income figures.
  • Avon - (sells cosmetics)
    • A 7/1/2004 PRNewswire article discusses a recent court case which accuses Avon of "channel stuffing", or artificially boosting its financial bottom line by charging for and shipping unordered products to sales representatives. Suggests an allegation of misrepresentation of realistic average (expected) income and artificial boosting of sales figures. In August 2004 the California Court of Appeals dumped the case but then reinstated it on appeal in May 2005. I can't seem to find any updates past that.
  • Discovery Toys - (sells educational toys)
    • This iVillage thread (archived; not all pages may display) contains a few complaints implying misrepresentation of realistic average (expected) income, discomfort of friends and family as sales targets. Most of the pro-company posts sounded to me like people in the early "emotionally charged" stages common to MLMs and almost invariably include their Discovery Toys websites, appearing to use the message board in desperation for recruiting or sales.
  • Equinox International / Trek Alliance / Advanced Marketing Systems / BG Management - (sold water filters)
    • This 1996 Santa Clara Valley Metro article recounts (though rather sensationally) several stories of failed reps who alleged: cult mentality; misrepresentation of realistic average (expected) income; heavy debts incurred by travel and other expenses encouraged in a "fake it till you make it" program; music before group interviews is purposely loud to discourage conversation (negativity).
    • Was shut down by FTC in April 2001 as an illegal pyramid scheme; the Trek Alliance version was shut down in 2003.
  • Excel Telecommunications / Vartec Telecom - (sells long distance service)
    • This ComplaintStation.com thread (archived, as website since shut down) alleges: misrepresentation of realistic average (expected) income. Note the replies by Excel supporters, which boil down to the usual: "You have a bad attitude"; "You didn't try hard enough".
  • Health-Mor / FilterQueen - (sells vacuum cleaners & air purifiers)
    • This blog alleges: misrepresentation of job description; recruits must provide own first 10 leads before receiving any from company; abuse of trust relationships in selling to friends & family; misclassification of employees as independent contractors.
  • Herbalife / Newest Way to Wealth - (sells vitamins)
    • This complaint describes one woman's experience, which alleges: front-loading of expensive inventory with a misleading refund policy; a cult atmosphere; misrepresentation of realistic average (expected) income; sales to friends and family (the only sales she made); high-pressure recruiting tactics.
    • Herbalife settled a 1986 lawsuit filed by the California Attorney General. Allegations included questionable claims made for products.
    • Related companies or divisions are Big Planet, Pharmanex, & Photomax.
    • Cockeyed.com has an amusing article in which the author muses about Herbalife's MLM format, market saturation, and the many "Lose Weight Now - Ask Me How" type signs distributors plastered (illegally) all over Sacramento.
    • RickRoss.com, a website dedicated to the study of "destructive cults, controversial groups and movement" like Heaven's Gate and the Skinheads, includes a page on Herbalife.
      • A testimonial reads: "My husband and I spent over $8,000 in this business through inventory, promotions, 'trainings,' travel, and marketing. We [...] feel that it was the obligation of Herbalife [...] to inform us of all the costs [...] before having us sign. Herbalife's promotional materials are clever. The costs are in the decision packets behind all the wonderful testimonials, but the numbers were either played down about costs and/or over inflated for profits. And everyone was high on 'personal development tapes'." (*)
      • In the 1997 case of Fallow v Herbalife, Herbalife was successfully prosecuted for breach of contract when it cut off a distributor's income (effectively terminating him) and reassigned his extensive downline to his upline. Of note: "Herbalife went to great lengths to inform its Distributors that they are 'independent contractors', and not employees, with freedom to run "their own business." (Review the "Independent Contractor" section of this site!)
  • Mannatech - (sells nutritional supplements)
    • RickRoss.com, a website dedicated to the study of "destructive cults, controversial groups and movement" like Heaven's Gate and the Skinheads, includes a page on Mannatech. Some articles:
      • A 2007 Wall Street Journal article demonstrates a few cases where Mannatech's independent contractor sales force make spurious health claims based on Mannatech's own published testimonials as well as at "Mannafest", a yearly meeting for distributors that approaches a religious revival in tone. (Mannatech's founder is very religious; "manna" is the food God miraculously supplied to the Israelites in scripture.)
      • A 2007 ABC News 20/20 segment points out that Mannatech's products sell so well that 'Forbes" magazine named the company [...] one of the fastest growing companies of 2006. (But note how they're doing it!) The sales reps even coached potential recruits on how to work around legal restrictions. For instance, they cannot claim the product cures or treats anything, but they can say "'I think I have something that will help you with your cancer" (because the statement is framed as the rep's own opinion). Note that sales associates are legally liable for any spurious claims they make, even if they're simply repeating what the company has told them.
    • In February 2009 Mannatech settled a 2007 lawsuit brought by the Texas Attorney General in which it was charged with exaggerating health claims. Mannatech to pay $4 million in consumer redress and $2 million for AG's investigation costs.
  • Mary Kay - (sells cosmetics)
    • See post #2 in this rather scathing ComplaintStation.com thread (archived, as website since shut down) -- allegations are exaggerated but may be pared down to: misrepresentation of realistic average (expected) income; sales to friends and family; "warm chatter" with strangers to generate leads; encouraging front-loading of inventory "to succeed" (earn promotion levels) and high-pressure sales tactics; salespeople must pay to go to cultic pep rallies.
    • MKSurvivors is a Yahoo group; you need a Yahoo ID to sign up to read. "We deal in facts about issues, income and the realities of this business [...] we are a very diverse group of men and women all with a goal to expose the truths about this 'opportunity' as well as MLM's."
    • The Pinking Shears is an anti-Mary Kay website created by the founder of the MKSurvivors Yahoo group.
    • Edumacation.com has a message board section on Mary Kay. Allegations are all the usual: front-loading of inventory; high pressure to recruit and make continuing (unnecessary?) purchases to earn sales rewards; marriages harmed when cultic atmosphere causes front-line MK reps to dig the family into escalating debt behind partners' backs; unauthorized credit card charges; abuse of personal relationships; MK runs secondary "tools" business similar to Amway; misrepresentations about actual earned incomes. MK defenders counsel failures: "You didn't work the business hard enough."
    • A 2002 Law.com article says a jury in Texas hit Mary Kay Inc. with an $11.2 million verdict, including $10 million in punitive damages, for firing a sales manager disabled by cancer, who, the company contended, was not an employee but an independent contractor. May challenge IC status for all salespersons.
    • Update on Mary Kay v. Woolf: The 2002 decision was overturned. Woolf was determined to be not an “employee” under Texas law and thus not entitled to protection under California’s anti-discrimination statute. Note that "The 5 Red Flags of Product-Based Pyramid Schemes" alleges that Texas is among those states that inadvertently passed deceptive DSA-promoted legislation that effectively "legalized the worst pyramid schemes of all -- those that are product based."
  • Melaleuca / The M.O.M. Team - (sells health products)
    • This mlmSurvivor.com article alleges: misrepresentation of turnover rate.
    • This RipOffReport.com page contains allegations of: misrepresentation of realistic average (expected) income, cult-like atmosphere, straining of relationships when selling to family and friends, obscuring the name and/or nature of the business because of prior bad publicity. Defenders use the same rote defenses ("you didn't try hard enough", "you're a negative person and I'm a positive one", citing company-provided propaganda).
  • New Vision International - (sells dietary supplements)
    • A 1998 FTC Order decided that it made unsubstantiated claims about one of its products. Two principals were formerly with International Heritage, Inc. (IHI), a company prosecuted by the SEC on allegations of being an illegal pyramid scheme.
    • This peculiar page includes a New Vision recruit writing "We ignored the 'walk on the beaches of the world with us' scenario that our sponsor regurgitated and took a realistic look at the effort involved, the return, and the risk." Implies misrepresentation of realistic average (expected) income. Defense is the usual, implying those who failed "didn't try hard enough".
  • NuSkin / Big Planet / Pharmanex / Photomax Studios - (sells health & beauty products, photo services)
    • This Complaints.com post alleges front-loading of expensive inventory with a misleading refund policy; misrepresentation of realistic average (expected) income.
    • A 1994 FTC Order ordered NuSkin to stop making questionable claims about its products and income/success representations.
    • The FTC determined NuSkin had continued the same violations in a 1997 FTC Order.
  • Prepaid Legal Services - (sells a sort of "legal insurance policy")
    • RipOffReport.com's page on the company includes allegations of: misrepresentation of realistic average (expected) income; misrepresentation of turnover rate; nondisclosure of expected expenses; cult-like meetings; products of questionable worth.
  • World Perfume - (sells perfumes/colognes)
    • This page alleges that Scentura Creations is the same company, another incarnation, or at a minimum very closely related.
    • This RipOffReport.com page includes many allegations indentical to the points made on this site (though I read it many months after having written this site): misrepresentation of realistic average (expected) income and job duties; corporate sidestepping of legal responsibility by using recruits' "independent contractor" status; sales to friends and family during "training"; shutting down critical websites; cult-like atmosphere; encouraging front-loading of inventory; nondisclosure of expected expenses; cattle call interviews; obscuring the name and/or nature of the business because of prior bad publicity.

V. Complaints Against Specific Financial Services Companies

Mention of these companies does NOT imply they are running a scam! Many have received many of the same complaints as the MLMs above; this is by no means an exhaustive list of such firms and complaints against them. Website owners/contributors are sometimes angry and sensationalistic, feeling very betrayed by their firm; I expect the reader to weed out bias and simply look at the pattern of similar complaints, and to note just in general that the firm has generated enough ill will as to earn such vocal critics at all. Do your own research and don't forget to search the message boards here and on this site's "Networking" page -- you may just find something on your own company.

Company links go to their official sites for balance. Some websites are now defunct, whether the site operator simply lost interest or was sued to force site closure or remove specific information. As with most any defunct website, you can use the Internet Archive "Wayback Machine" at http://www.archive.org to view historical captures.

  • AFLAC
    • Indeed.com's Jobs Forum participants allege:
      • "The only money I spent was $38 for my business card in the first four months. I have since spent several thousand by choice as I am in business for myself. [...] You have to understand that you are starting a business - not just getting a job." (This person should read the "Independent Contractor" section of this site!)
      • "If you work a little, you will more than pay for [your insurance license]. Plus you can write it off." [No, that isn't necessarily true!] "You are an independent agent. It's an entrepreneur job. Having your own business means putting some [...] money into it at first." (Same as above.)
      • "[...] new hires shouldn't be paying out of pocket to train unless they have bought into a bona fide franchise." (This person, an experienced salesperson, gets it.)
      • "All they're doing is trying to fish unhappy losers, brainwash them [...] by using words like 'be your own business' or 'you're a professional entrepreneur', or 'make residual income', 'be rich and retire early', 'financial security'... etc."
      • "As far as a "pyramid scheme job", I've never seen a "pyramid scheme job" make it as high on the Forbes 500 list as they have..." (Another person who should read this site and understand just how scams do exactly this!)
      • "Employee turnover rate is over the top, [...] and then YOU OWE AFLAC, because they advance you the commissions." (Advance on commissions = LOAN!)
      • "If you last 1 year, you have done better than 95% of all hired agents. You MUST have another job to pay your bills."
      • "They will tell you that the saturation is less than 5%, but I found this to be misleading. All of the successful agents [...] got into Aflac 10 years ago when there were plenty of new accounts to open! Now it is very difficult, if not impossible, to find a big account that has not seen or heard of Aflac."
      • "AFLAC has a good product. They just need to get organized and stop hiring anyone that has a pulse. I own a business and have AFLAC, but I still have 3 or 4 different people come in a month to try an schedule an appointment."
      • "You have to find your own prospects, and so many people have tried to sell AFLAC that employers are hounded continually by AFLAC. [...] The market is SATURATED with AFLAC sales people."
      • "If it is your ONLY source of income, don't do it. There are more agents than fleas, saturation is an understatement."
  • Ameriprise Financial (formerly American Express Financial Advisors [AEFA])
    • Amexsux.com. I found a number of complaints on the "Financial" and "Employee" message boards alleging all the usual. A small sampling:
      • Thread 1. "You have to sit through a sales pitch. It's very 'pyramid-schemesque' where they try to show you million dollar earners and the great opportunity and wow you while making you question your own instincts."
      • Thread 2. "This kind of job is not rewarding unless you like working 80 hour weeks and getting a salary (18,000) which turns out in fact to be a draw system--not a salary."
      • Thread 3."AmEx advisers in the field, however, say that entry-level advisers are experiencing close to 100% turnover and that the newly established franchisee advisers are essentially subsidizing the entire product sales system."
      • Thread 4. "After working there, I realized that the business model at AEFA was about as close to a pyramid scam as a legit company can get. For example: A main focus of a managers duties where to dial resumes off of monster.com, jobsearch.com, etc. [...] to constantly get new advisors in the door. Many of these new advisors where totally unqualified. As a matter of fact,we hired one guy who didn't even finish highschool."
      • Thread 5. Also alleges that New England Financial is doing the same.
      • Thread 6. "[You pay] the license study marterials out of your own funds, around 3 grand. This is a glorified sales job! [...] You have to be willing to bring your own leads." Another person wrote: "The managers, recruiters, etc. are using you for your natural market [friends and family]. The turnover rate for new advisors has to be very high. At the office I interviewed at, they have group orientations or career previews every week. Recruiting is non-stop."
    • Jobvent users have posted a few interesting comments:
      • "[AEFA] are hiring constantly yet you never see anyone stay very long. You have to pay an 'admin' fee of up to $300 just to start and that is after you pay to get licensed through your state. I heard all sorts of claims about free leads (union leads) and how everyone was making over 100K a year but I never met anyone who actually grossed that."
      • "They tell you when they hire you that you will receive 70 leads a week. I got 50 my first week, 35 my second week and zero my third week. I think I finally got 70 my 4th week, but about 20% of them had no phone numbers. Oh, and they give the same leads to more than one agent!"
    • Some posters on MyMoneyBlog write:
      • "[Ameriprise] hires kids off the street because those kids have parents that just might have ... money. So, kids are hired and told to go after their ‘natural narket’. I have seen terrible, expensive portfolios set up by ‘advisors’ that was a close friends or a relative of the client. And when the client questioned the advisor about the fees (that I had to tell them about–the trusted advisor/friend/relative never did!!), the trusted friendly advisor turned ugly. Ameriprise does not ‘advise’. They sell… they find a way to fit what makes them the most money into the client’s ‘plan’."
      • "The recruiters for this position are [...] more aggressive than any other job/position I have ever applied for. I do not possess a college degree, but I have extensive sales experience. I asked [the Ameriprise recruiter] how do I obtain clients in my first month assuming I know nothing? He told me I would have to contact my “natural market” ie, family, friends, people I trust. In other words, I know nothing, but I should take people whom I know and use them for their money and possibly mis-invest it? It was such an obvious scam."
    • To Ameriprise's credit, they do have a page on their website explaining how their three different types of financial advisor positions are compensated. I am curious if the "salary" they advertise is still a draw.
  • American Income Life
    • Scam.com. This thread presents both sides from people who have worked for AIL. Some negative claims concern high turnover, brainwashing those who wish to leave into believing they've "failed"; managers making higher commissions on recruits less than 6 months old (discouraging retention because company keeps commission trails); promises of "unlimited income" that rarely pans out while recruits are suckered into paying for everything including rah-rah conventions in exotic locales; the company encourages recruits to put the job over their family; all the usual. One AIL defender amusingly says: "after 10 years with the company i can retire!! yeah thats right retire so while the rest of you work till your 65 i'll be 40 on some tropical island". One complainant only learned about his "independent contractor" status when he attempted to claim unemployment!
    • What's Up With American Income Life? (Archived) Contact insurance investigator Mark Colbert at www.markcolbert.com or email him.
    • RipOffReport.com. Below are a few; search the site for more. Note that AIL is a member of RipOffReport's Corporate Advocacy Program; they pay RipOffReport for their "investigation" and "approval" as a company consumers should "have confidence in". I personally appreciate RipOffReport's value as a site where consumers can read about complaints about companies, but I am very highly suspicious of the website owner then charging these same companies for cleaning up their record there.
      • Page 1. "They tell me [to] bring a check for $150 for the book and training. [...] After numerous months of not making any money, wasting my gas, money on food, and my time and my life, [I begin to think] these people lied to me. They make you think your an independent contractor but in fact you're not."
      • Page 2. Poster describes how during his initial interview the interviewer wasn't interested in his past experience but called him a "go-getter". Second interview was a cattle call with 10 other people during which a presentation was made that only talked about how much money they could make. "The classes, books, licenses, background check and fingerprinting ran a whopping $447 total."
      • Page 3. "I recently graduated from college [...] and was offered a job with this company. I was told their average agent makes $50,000 to $70,000 their first year with some agents earning $100,000. My job offer was revoked after I asked [...] how many people were successful."
      • Page 4. "Long story short, between the 80 hour work weeks that robbed [my family] of our time together, the ragged out car [from all the travel to sales calls] and the $10,000 credit card bill, I can't decide how they SCREWED us the worst."
      • Page 5. "They said the fee for the class was $250. [When] I told them that I had a school near me that is $100 less, [they lost interest] in me."
      • Page 6. Poster complains of working 80 hour weeks, killing his car with the frequent travel, paying for food and lodging when going to sales conferences, and never made the income the company (mis-?)represented. "I drained my account based on a promise, all I had to do is follow their method. I followed their method and was set back at least $3000 for my trouble."
    • A JobVent user writes:
      • "I was a sales agent in Burnaby (BC, Canada) for about 7 months. I finally had to leave because of all the dishonest practices of the company and because of the cult mentality. My biggest problem is that my mentors when coaching me and everyone else in the office would instruct us to lie to the union members about many aspects of what we were doing in order to get the sale. [...] When I was hired they said they were very picky about who they hire but the truth is they will hire anyone willing to pay the course fees up front. Even more the people doing the hiring have little to no experience and work are paid commission based on how many people they hire! The also don't tell you that 99% of agents quit in less than a year having made very little money. [...] They had me training new agents after I had only been selling for about a month. I had no real experience. Most of the people I trained quit before they even got the chance to sell anything."
  • Edward Jones
    • Edward Jones.info (archived) British site. Info is for UK, USA, & Canada. According to this source, Edward Jones pressured the host into closing the site.
    • RegisteredRep.com's Forums have some interesting comments:
      • "In short, these market conditions are exposing the shortcomings of the Jones business model. I believe there will be significant changes to that model by this time next year. It's basically a pyramid scheme that has been outed." (*)
      • "[Edward Jones is] not a pyramid scheme in a pure sense [... ] but not too far off either. 'Recruiting' like minded people. 'Bonus Brackets' and 'LP Returns' and other phony mumbo-jumbo to get you a bigger cut of the action as your tenure, success, and loyalty to the firm grow over time. Then, there's the entire indoctrination of the spouse and family. The continued brainwashing that goes on that only EDJ is right and just. Others firms are somehow morally corrupt, and Jones FAs have to go out and save the bluehairs from the evil competition. All the while, those at the top (GPs) are raking it in. The relatively few tenured brokers are getting profitability bonuses and LP payments which are essentially other people's money getting funneled to the top. I'm convinced the whole thing was contrived by a marvelously intelligent evil genius." (*)
      • "That was one of my biggest complaints with Jones. I signed up for a 60/40 split, and they were taking 15 to 20% off the top, and THEN splitting with me 60/40. Not cool." (*)
      • "I think what angers ex-Jonesers the most is 2 things. 1. EJ sells you on the opportunity to have your own business, when in fact it is far from it. 2. EJ also claims that the FA's are the only profit center making an FA feel that the 60% going to Jones is going for expenses and/or partnership, when in fact it is far from it. I will be the first to admit that I was making a career change and jumped in without a full understanding of the business in general and the business of EJ and that is completely on me." (*) (I would disagree with his final statement.)
      • "When you are at Jones, you are told it is BETTER than being at a wirehouse, and BETTER than being [independent]. Expectations are set so high that once people realize it is not vastly superior, and in many ways about the same as a wire, and definitely no better than being [independent], with lots of kool-aid culture, you feel a little schmucked." (*)
    • A Vault.com user has this to say:
      • "I guess after 25 years in business, I was flattered they had any interest in me at all. What was about to begin would unravel my family, personal, and financial life to the point of almost vengeful retaliation. I was "homeschooled" on one of their company laptops. This 2 1/2 months of studying for the series 7 test left me with little time for anything else. A year later, I found out I could have taken the training for $400 on the internet. All of the recruiting literature that was shown to me was later explained to me by my attorney as being spurious (symbolic) and had nothing to do with the actual working conditions that I could expect. In other words, when Jones says that you will "likely" be in an office in 4 months, they can take 10 years if they want. When they tell you that you will have an assistant, it means you have to damn near walk on water to get one. When they say that the AVERAGE broker makes $140K per year, it means that there are about 100 brokers who make over a million annually out of the 9000+ brokers and pull the average up and way out of proportion for the average person. Jones talks about their Funnel System for marketing. After a year, you realize that you are actually in THEIR funnel. It was common knowledge that if you tried to open a new branch as a new broker, you would fail, and so would the next 2 brokers who followed. With Jones, they own all of the accounts, so you can't take anything with you if you stay in the business. I opened 40 accounts in 8 months, and never opened an office. I was digging a huge hole financially with the pittance of a salary I was on quickly coming to an end. Still not in an office, I went to another institution and left Jones. After my license transferred, they sued me for $75,000 for "training costs". Remember the $400 for series 7 on the net? I was caught in the oldest scheme in modern history. They never actually expected me to succeed, just paid me enough to open accounts, gather assets, then drag their feet on their promises. The most insidious part of the whole slimy mess is the part in their Employment agreement called an Integration Clause. It basically means that anything they said, did, or represented in any way is now B.S. An interesting statistic: Last year Jones trained 1200 brokers, and 1150 of them left, leaving behind all of the assetts that they had gathered, under the threat of being sued for 75K each for training costs. I was lured out of a 25 year old business to pursue what turned out to be a pack of lies and broken promises. Many of the people who started with me went broke and were living on credit cards. Here's one more nauseating caveat: The broker who recruited me won a trip because of my hiring."
    • Edward Jones Can Be A Great Place To Work - If You Last! Article by L.M. SIXEL of Chron.com includes these quotes:
      • "[Edward Jones] is so focused on growth [...] that it doesn't do enough to retain the brokers it already has."
    • Attorney General Lockyer Files Major Securities Fraud Lawsuit Against Edward Jones. From the California Attorney General's website.
    • California Attorney General Settles Edward Jones Lawsuit (2008).
  • Independent Capital Management (ICM)
    • A JobVent user says the following about Independent Capital Management:
      • "When you get hired, they slap on the 'financial services specialist' tag. But in reality you're just a telemarketer. [...] I just feel cheated because ICM advertises that they're something they're not. [...] They basically flat out lied to me. During my time there, i did not receive one cent! They make you pay for your exams ($410) and do not give you a buffer salary to live on while you study for them. [...] Just like a used car salesman office, you have to record on an dry-erase board for all to see how much you sell every week. But how can anyone produce when they can only sell crappy funds to their friends and family. I hope you have a LARGE AND RICH circle of friends to swindle...so you can 'produce.' They won't fire you because you cost them nothing to be there. They give you a desk and a phone and you call your friends and family and then their friends and family. In addition, why are there constant ads for openings at ICM on monster/careerbuilder? The turnover is ridiculous. [...] No wonder they slap on the AIG label after you're hired, otherwise this position would have no credibility to potential prospects. The introduction script that you pitch to prospects is 5% centered on ICM and 95% centered on AIG."
  • Northwestern Mutual Life (NML)
    • Riverfront Times. "Training, he says, consisted of the new agents' listing the names and contact information of 200 friends and family members and rehearsing a scripted sales pitch for variable insurance."
    • nmlcomplaints.com (archived) Includes negative testimonials. New grads should see the "NM Internship Program Facts" (archived) section:
      • Many schools exclude NM from recruiting for interns on their campuses altogether. Numerous other schools are taking a critical look at the company’s internship program to determine whether or not allowing NM to recruit is worth the potential risks to students, as well as the school. The issue? NM grossly exaggerates the likely income potential and is not forthcoming in pointing out "business expenses" that interns have to pay that are beyond licensing costs. Also, there is the chance that an intern's commission (income) may be reversed when policies are cancelled -- even after the internship has ended. Many students find themselves in the position of having to borrow money from family members or friends to pay NM's management for the experience. NM's supporters offer a uniform knee-jerk reaction to former interns’ claims: They state that these individuals “couldn’t keep up” and more commonly, “didn’t have what it takes.”
      • Colin Braybrooks from Ashville, North Carolina said:“I just went through the NMFN sales training program, but when it came time to sign a contract with them, I said "no thanks". Why? Because what they promised did not match up with what I wanted to do. By way of background, I am an attorney and have worked in the home office of a major insurer for a number of years. I wanted to make a career change to get into financial planning. I am a CLU and a ChFC. The training I received was 100% sales training. No product training. When you finish sales training, you start dialing for dollars. Nobody wants to receive a telephone call from a life insurance agent. Selling whole life insurance today is probably the hardest product to sell. But NMFN's relentless emphasis is on whole life sales. I also realized that their sales training was highly unethical. They want you to sell their insurance as an investment, which is forbidden under state insurance laws. I could not believe what I heard in the sales training school from seasoned agents ‘teaching’ us the ropes. There were nine people in my sales training class. Seven were in their early twenties, basically right out of college with no clue about life. Another older ‘career changer’ and myself rounded out the class. We both decided not to sign contracts to become NMFN representatives. But these young kids are very impressionable and do not know enough to challenge what they are told. For instance, NMFN wants the agent to focus on their "dividend". But the training they provide implies that the dividend is paid from day one and is a much better ‘buy’ than any other ‘investment’. ‘Why put your money in the stock market when you can get a 7.7% return from NMFN?’ Again, this presentation is not only VERY deceptive, it’s illegal.”
    • An email I received reads: "This website has been shut down by order of US Circuit Judge Larry J. McKinney on July 27, 2006." The lawsuit is discussed in an article in The Milwaukee Journal-Sentinel. If Northwestern Mutual's allegations are true, then this is a textbook case in how NOT to aid those with ostensibly legitimate complaints.
    • A JobVent user writes:
      • "I interviewed for an 'internship' with Northwestern Mutual recently. The job title was "Financial Representative". When I got there, she explained this was actually a sales internship. She said we would have 100 names and we would call them and sell them insurance, annuities, etc. I asked if these 100 names were people who already expressed interest in NWM or if it was cold calling. She responded that this list would be compiled by the interns - our friends and family!! She said I didn't even have to come into the office - I could make the phone calls from my home! Then, if I got a bite, I would come in and sit in the meeting room while some higher person made the sale. I would get a small percentage of the profit, and NOTHING ELSE. ONLY COMMISSION. Basically, if your OWN family doesn't pay them, you make nothing! You'd be better off hitting up your grandma for money all summer long, cut out the middle man."
    • Another Jobvent user writes:
      • "I worked for this company for 6 months before I figured out it was a scam. Got suckered in by the '"internship' which is their word for stealing your commissions by having you sell insurance to your family members. [...] they say you get a weekly paycheck but its just an advance and if you leave you have to pay it back. I guess it depends on what office you work in but mine was a turnover MACHINE! I think I saw 50 reps come in the door for every one who made a decent living."
  • Primerica Financial Services (PFS) / AL Williams
    • DMOZ Business Opportunities>Opposing Views>Primerica. A list of critical sites. Some may no longer be in operation.
    • "So What's With Primerica?" (archived) includes this page (archived) describing the author's allegations regarding how Primerica recruits and (mis?)-educates its reps.
    • RipOffReport.com has a many pages of complaints/defenses on Primerica. Below are a few. Note that Primerica is a member of RipOffReport's Corporate Advocacy Program; they pay RipOffReport for their "investigation" and "approval" as a company consumers should "have confidence in". I personally appreciate RipOffReport's value as a site where consumers can read about complaints about companies, but I am very highly suspicious of the website owner then charging these same companies for cleaning up their record there.
      • Page 1. "I have seen my best friend be lured by the promises of 'wealth' and 'financial freedom'. He has been convinced that anyone that does not like Primerica is not worth having in your life. He has been TOLD to attend church and join church organizations for the 'contacts' and to improve his reputation. I have heard cult horror stories that don't compare to the brainwashing my best friend has received from Primerica."
      • Page 2. "Primerica milked me for a list of my friends and family, with the promise of a 'pie-in-the-sky'-type of career. Once my list dried up, Primerica was GONE, baby! I'm *STILL* waiting for my first paycheck from this band of gypsies, some ten years later. [...] No reimbursement for the test, no loans, no splitting commission for turning over my list of contacts, no *NOTHIN'*!!!"
      • Page 3. Very long thread, be patient while it loads as it is worth the read. Original poster describes being cold-called about her resume; being offered a 'job' at which she would be expected to start at zero even though she had a Master's degree; company reps were vague about responsibilities, products, and how money is made; company appeared 'cultic'.
    • A JobVent user writes:
      • "You 'own your own business.' That means you are an "independent contractor" that has to assume ALL of your own benefits! Most Primerica reps do this on the side and use the bennies from their REAL jobs (or their spouse's job if they have one). [...] You work (hassle people) at all times... usually nights/weekends/holidays because that is the only time that people that have REAL jobs are available. [...] If you recruit enough people you get to be an RVP (Regional Vice President). [...] All that means is that you were able to recruit enough hapless family members to this lost cause. The RVPs that I know of wore crappy clothes, drove P.O.S. cars, and were slimy used car salesmen hucksters. They were NOT the 'rich' people I was led to believe were running the place."
    • Another JobVent user writes:
      • "I showed up for the interview and it was me and over 20 other people. Apparently he liked all of them as well, and for the same interview. You got to love his time management skills. [...] The only ones getting rich are the ones at the top who are making money off of your friends and family. The problem for you (or me) is you will eventually run out of family and friends. In the meantime they reap the benefits. [...] It is really a genius idea if you think about it. You advertise for jobs, troll online jobsites, invite a massive amount of people for interviews [...] and then hit each one up for possible customers."
    • Another JobVent user writes:
      • "I went on my 'interview' only because the person calling said it was for Citigroup and not Primerica."
    • Another JobVent user writes:
      • "The work environment in the office is scary. It's like a constant brain-washing to convince people that what your doing is righteous."
  • Trilogy Financial Services (TFS)
    • Blogger Evelyn Baker attended a seminar for Trilogy Financial Services and wrote this article in which she described its presentation as identical to Primerica's, i.e. multi-level marketing like Amway; she feels MLM is code for "pyramid scheme". I'm not the only person noting the negative similarity problems between some companies in the financial services industry and MLM.
    • A JobVent user says the following about Trilogy Financial Services:
      • "This is a terrible company to work for. You initially get hired on as an Investment Executive, but, you don't really get paid. You PAY THEM to work there and you ultimately PAY for all of your licenses and certifications. The training they promise you in hiring is redundant. And they threaten your job on a daily basis. So, no salary, they take 60% of any of the business you bring in and no benefits. Most of the "Financial Advisors" complain to fellow co-workers on a daily basis about not making enough money, yet put up a fake front to business associates and prospects. Most of the Managing Partners and Training Managers do not hold higher degrees. They expect you to work 80 hour weeks and to prospect unless you are sleeping. Beware with this company, as at first it appears really nice and a great opportunity, however, their mottos are 'fake it until you make it'."
  • World Marketing Alliance / World Financial Group (WMA/WFG) / National Lending Corp. (NLC) / Aegon Financial Group World
    • xWMA.org (archived).
      • Attorney Dan Feder was at one time: "investigating a possible nationwide class action against WFG, as it seems to me that current and former brokers/salespersons may be [misclassified as independent contractors and thus] entitled to employee benefits, worker's compensation, health insurance, and other benefits."
      • Law firm James Hoyer were at one time: "investigating complaints about misrepresentations in the sale of life insurance policies by World Marketing Alliance. Some consumers have stated that they thought they were buying annuity, savings or investment plans [and] felt tricked when they learned they had purchased variable universal life insurance policies." (It is illegal to sell insurance as an investment instrument.)
    • WFG-Offline (archived). Be sure to see the MONEY magazine article (archived).
    • RipOffReport.com has some complaints/defenses on WMA/WFG. Search the site for more.
      • Page 1. Very detailed article with references.
      • Page 2. Aaron claims: "My aunt works at WFG headquarters and she files everyone who comes through the company. She sent me a fax and 85% of the people who pay the $100 don't get their licenses, and of the 15% who get them, 90% leave within the first year and half of the remaining 10% leave in year 2. You don't have to be a rocket scientist to figure out that's about 1% success rate."
    • Ted DeCorte's Eclectic Mouse Experience se Experience (archived) implies that Zillionaire.com (offline) / DotPlanet.com (offline) was a biz op used as a "lead-in" to promote the securities and investments offered via WMA.

VI. Books on the Financial Industry

Just a few, feel free to suggest some. If you're really on a budget, you can try getting them from ebay. Links below go to Amazon.com, which has used books for sale as well.


VII. Other Links


Submit a link or correction / Report a dead link

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