Business Opportunity Rule #535221-00063

Submission Number:
Stephen Barrett
Initiative Name:
Business Opportunity Rule

I have followed the MLM marketplace for nearly 30 years and examined the offerings of hundreds of MLM companies. I am shocked and disappointed that the FTC has decided to exclude MLMs from the Business Opportunity Rule. More people are affected by misleading MLM claims than by any other type of health product marketing. The vast majority of newly recruited MLM distributors do not make significant income, a fact that MLM recruiters do not disclose. In addition, few if any health-related products have a legitimate market because they provide no significant benefit, are grossly overpriced, or both. Meaningful disclosure, which might deter millions of people each year from wasting their time and money by signing up as distributors, would cost very little. Moreover, the FTC lacks both the willingness or the resources to attack misleading claims by hundreds of companies on a case-by-case basis. I notice, by the way, that although the FTC’s analysis responded to every other comment that I saw, it did not mention or respond to my original comments about the basically fraudulent nature of the MLM industry.