The Way Out Is In

The nature of this industry is complex. When I entered this field, I knew very little about the people who operated within it, the laws and regulations that encompassed it, or frankly what exactly it meant to fall under the descriptive phrase of “direct sales,” network marketing,” “multi-level marketing,” etc. Those on the outside may […]

So You Received a Notice of Penalty Offenses, Now What?

Roughly 1,100 entities received a Notice of Penalty Offenses from the Federal Trade Commission on October 26, 2021. It’s important to know that being a recipient does not mean you have previously or are currently violating the law. Candidly, it’s not all bad being on the list. The companies that did not make the cut […]

FTC Sharpening Its Regulatory Knives And Preparing For Battle, Puts For-Profit Universities On Notice

The nature of the network marketing industry has evolved over the last several decades with new and innovative business models, yet the regulatory landscape has remained quite stagnant and vague. We are all aware of the landmark cases of Koscot and BurnLonge, FTC v. BurnLounge Case Summary, along with company specific settlements such as Vemma, […]

Invest in Yourself: AMG Capital Alone Will Not Save You

When the Supreme Court ruled unanimously against the FTC in AMG Capital back in April of this year, many flagged this decision as a watershed moment in FTC enforcement. But this is the law we are talking about, and nothing is ever black and white. If it were, there would be fewer lawyers and that […]

Multi-Level Marketing: Life After AMG Capital and the Hope for a Better Future Part 2

In Part 1, we presented our belief that there is soon to be a shifting tide of regulatory attitude from empowering the consumer to now empowering the government. Such empowerment has morphed into the idea that consumers are now unable to protect themselves due to the constant barrage of information, e.g., misleading/deceptive income claims, no […]

The Changing Regulatory Landscape: A New Generation Takes Control Part 1

We have discussed in many of our previous articles the ever-changing regulatory strategy of federal agencies and the virtual impossibility of reading regulator’s minds, especially the Federal Trade Commission (“FTC”), but we have never truly dove into the minutiae of what may be causing this constant shifting of the goal posts. Is it really a […]