Tags: Consumer Protection Franchises, Business Opportunities, and Investments January 14, 2004 Discusses the Commission’s analysis of compensation based on personal consumption by members of a multi-level company’s sales force and the legal significance of consent orders the Commission has entered with pyramid scheme operators. Documents Staff Advisory Opinion Letter from James A. Kohm to Direct Selling Association (95.43 KB) Chairwoman Edith Ramirez Response to Direct Selling Association's Letter