Multi-Level Marketing And “Direct Selling” Companies Received Over $100 Million in PPP Money Despite False Claims About COVID-19 Treatments And Charges Of Deceptive Marketing SUMMARY: An Accountable.US analysis found that while hundreds of thousands of small businesses have closed across the country, direct selling companies – which frequently utilize predatory multi-level marketing practices – received over $106.4 million in PPP loans. Several companies receiving these PPP loans have been warned by the Federal Trade Commission (FTC) about unlawful claims regarding the health benefits of their products in combatting COVID-19 and the amount of income participants could receive. These include: • Zurvita, Inc., which received $1.39 Million in forgivable PPP money just weeks after receiving an FTC warning letter regarding social media posts that "unlawfully advertise that certain products treat or prevent [COVID-19]." • Pruvit Ventures, Inc., which received $719,251 in forgivable PPP money just over a week before receiving an FTC warning letter regarding claims about its products effectiveness against COVID-19 and misrepresenting how much its business opportunity participants are likely to earn. • Total Life Changes, LLC, which received $977,200 in forgivable PPP money just over a week after receiving an FTC warning letter regarding claims about its products effectiveness against COVID-19 and misrepresenting how much its business opportunity participants are likely to earn. Two other companies receiving PPP loans have previously been cited for deceptive marketing and predatory business practices: • Vemma Nutrition Company, a direct seller that received $227,500 in PPP money, was ordered to pay a $238 million fine that would be partially suspended with a smaller payment and the surrender of certain assets, while also prohibiting business practices that created a pyramid scheme. • Neora, LLC, a company that received $2.5 million in PPP money, was sued by the FTC in November 2019 for operating as a pyramid scheme, while "deceptively promot[ing]" its supplements as cures for Alzheimer's disease, Parkinson's disease, and other neurological conditions and ailments. The fact that so much money went to this industry is particularly troubling when 25% of adults and 46% of adults with lower income have reported having trouble paying their bills. Members of minority communities reported even larger numbers with 43% of Black respondents and 37% of Hispanic respondents reporting difficulties paying bills. These businesses’ ability to access PPP came after the Direct Sellers Association lobbied Congress to include measures beneficial to the industry in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and any future stimulus relief. 1 Multi-Level Marketing Is A "Distributions And Compensation" Method For Direct Sellers That Often Leaves Participants Spending More Money To Participate Than They Will Make Through Selling Products Or Recruiting Individuals – 99% Of People Involved In An MLM Company Are Estimated To Lose Money. Multi-level Marketing (MLM) Is A "Distribution And Compensation Method" For Direct Sellers, With Many Predatory MLM Companies Compensating Its Salesforce For "Recruiting New Participants" As Opposed To "Selling Products And Services To Customers." Multi-level Marketing Is A "Distribution And Compensation Method" For Direct Sellers. "Direct selling encompasses a variety of distribution methods; multilevel marketing is one type of distribution and compensation method. Multi-level marketing is a type of direct selling recognized by the Federal Trade Commission and used by hundreds of companies, including some of world’s best-known consumer brands." [Direct Selling Association, accessed 09/21/20] Predatory Multilevel Marketing Companies Typically Compensate Its Salesforce For "Recruiting New Participants, Instead Of For Selling Products And Services To Customers." "It is not synonymous with pyramid schemes, illegal business operations, unless the multi-level marketing company compensates members of its salesforce primarily for recruiting new participants, instead of for selling products and services to customers." [Direct Selling Association, accessed 09/21/20] 99% Of People Participating In MLM Companies Are Estimated To Lose Money. According To The Consumer Awareness Institute, 99% Of People Who Participate In MLM Companies Lose Money. "Multilevel marketing companies (MLMs) like Beachbody, which rely primarily on distributors like Baker instead of salaried staff to sell goods and services, have long been eyed with suspicion by regulators, and for good reason. The Consumer Awareness Institute, whose research has been posted on the website of the Federal Trade Commission (FTC), found that 99% of people who participate in them lose money." [Time, 07/09/20] At Least 78 Direct Selling And Multilevel Marketing Companies Received $106.489 Million Total In Forgivable PPP Money. At Least 78 Direct Selling And Multilevel Marketing Companies Received $106.489 Million In Forgivable PPP Money. Company Date of PPP Loan Notes Loan Amount Thirty-One Gifts, LLC 6/26/20 $10,000,000 Member of DSA Listed as a top 100 direct seller by Plexus Worldwide, LLC 4/4/20 $6,760,000 Direct Selling News Younique, LLC 4/9/20 $6,600,000 Member of DSA Nature's Sunshine 4/14/20 $5,370,000 Member of DSA Products, Inc. Jeunesse, LLC 4/13/20 $5,270,000 Member of DSA Listed as a top 100 direct seller by ASEA, LLC 4/16/20 $5,000,000 Direct Selling News Hy Cite Enterprises, LLC 4/10/20 $4,950,000 Member of DSA 2 ACN Communication 4/14/20 $4,660,000 Member of DSA Services, LLC Regal Ware, Inc. 4/27/20 $4,180,000 Member of DSA Business description matches a Truvision Health, LLC 4/14/20 $2,740,000 typical MLM Neora, LLC 4/8/20 $2,510,000 Member of DSA Smart Circle Business description matches a 4/9/20 $2,160,000 International, LLC typical MLM Business description matches a Stella & Dot, LLC 4/28/20 $1,950,000 typical MLM OneHope, Inc. 4/14/20 $1,930,000 Member of DSA NeoLife International, 4/15/20 $1,870,000 Member of DSA LLC PartyLite Gifts, Inc. 4/30/20 $1,770,000 Member of DSA World Financial Group 4/7/20 $1,760,000 MLM Group Premier Designs, Inc. 4/11/20 $1,750,000 Member of DSA Has been referred to as an MLM by Unicity International, Inc. 4/10/20 $1,650,000 the Consumer Awareness Institute Kynect Serviceco, LLC 4/14/20 $1,650,000 Member of DSA Kyani, Inc. 4/13/20 $1,610,000 Member of DSA Labeled an MLM by Le-Vel Brands, LLC 5/3/20 $1,570,000 TruthInAdvertising.org Zurvita, Inc. 5/1/20 $1,390,000 Member of DSA Labeled an MLM by Perfectly Posh, LLC 4/10/20 $1,380,000 MLMcompanies.org Younique Foundation 4/9/20 $1,370,000 Member of DSA Origami Owl Parent, LLC 4/14/20 $1,080,000 Member of DSA Enagic USA, Inc. 4/16/20 $1,070,000 Member of DSA Carico International, Inc. 4/13/20 $1,020,000 Member of DSA Total Life Changes, LLC 4/15/20 $977,200 Referred to as an MLM by the FTC Business description matches a Plunder Design, LLC 4/10/20 $902,800 typical MLM Reliv International, Inc. 4/20/20 $862,000 Member of DSA Business description matches a Close To My Heart, Inc. 4/27/20 $847,712 typical MLM Business description matches a Chalk Couture, LLC 5/3/20 $822,000 typical MLM Business description matches a Life's Abundance, Inc. 4/13/20 $755,000 typical MLM Send Out Cards, LLC 4/12/20 $732,682 Member of DSA Symmetry Financial Has been referred to as an MLM by 4/29/20 $730,900 Group, LLC the Consumer Awareness Institute Business description matches a New U Life Corporation 4/14/20 $727,962 typical MLM Listed as a top 100 direct seller by Pruvit Ventures, Inc. 4/15/20 $719,251 Direct Selling News Univera, Inc. 4/10/20 $670,691 Member of DSA Has been referred to as a CBD Zilis, LLC 4/15/20 $607,495 MLM company Noonday Holdings, LLC 4/9/20 $570,950 Member of DSA Business description matches a Ruby Ribbon, Inc. 4/27/20 $527,446 typical MLM Listed as a top 100 direct seller by Seacret Direct, LLC 4/13/20 $526,600 Direct Selling News 3 Team National, Inc. 4/14/20 $522,322 Member of DSA Business description matches a Yoli, LLC 5/3/20 $513,210 typical MLM Purehaven, LLC 4/28/20 $498,944 Member of DSA Listed as a top 100 direct seller by Nikken, Inc. 5/3/20 $468,557 Direct Selling News Business description matches a Peach Innovations, Inc. 4/27/20 $429,928 typical MLM 1-800 Wineshop.com, 5/1/20 $423,570 Member of DSA inc. Gano Excel (USA), Inc. 4/14/20 $413,750 Member of DSA Listed as a top 100 direct seller by Vida Divina, LLC 5/1/20 $396,125 Direct Selling News Immunotec Research, 5/11/20 $353,700 Member of DSA Inc. Vantel International 4/14/20 $349,990 Member of DSA Pearls in the Oyster, Inc. BBB.org complaints have referred Dot Dot Smile, LLC 5/3/20 $341,217 to them as an MLM 5Linx Holdings, Inc. 4/13/20 $333,289 MLM Has been referred to as a CBD Wakaya Perfection, LLC 4/27/20 $315,700 MLM company Business description matches a Rain International, LLC 4/15/20 $300,000 typical MLM Sabika, Inc. 4/10/20 $295,900 Member of DSA SimplyFun, LLC 4/28/20 $281,500 Member of DSA Has been referred to as an MLM by TraVerus Global, Inc. 5/9/20 $272,485 the Consumer Awareness Institute Has been referred to as a CBD Vasayo, LLC 4/14/20 $272,322 MLM company Business description matches a Piphany, Inc.