An investigation by Oklahoma’s Department of Securities resulted in a recommendation Family First Life be issued with a cease and desist.

As per a
series of August 20th filings from ODS
, the Enforcement Division’s investigation found:

an Oklahoma resident who lost their job during the pandemic enquired about Family First Life in late 2020;

the resident was pitched on insurance leads generating “upwards of $30,000 a month in profit, and was told they could “discontinue the purchase of sales leads at any time”;

based on these representations, the resident signed up as a Family First Life agent in December 2020;

between May 2021 and June 2022 the resident purchased $17,865 in leads from Family First Life;

at some point into the Agency, the resident realized they were only breaking even;

upon contacting Family First Life in regards to their promised income marketing, the resident was encouraged “to purchase larger quantities of sales leads to reach the full potential income advertised”;

marketing supplied to the resident depicted Family First Agents “making upwards of $40,000 per month using their leads and training”; and

at no point has Family First Life’s MLM business opportunity been registered under Oklahoma’s Business Opportunity Sales Act

Asserting violation of Section 806 of Oklahoma’s Business Opportunity Sales Act, ODS has recommended Family First Life be issued a cease and desist.

For reference,
Section 806 of Oklahoma’s Business Opportunity Sales Act
states;

It is unlawful for any person to offer or sell any business opportunity, as defined in Section 802 of this title, in this state unless the business opportunity is registered under the provisions of the Oklahoma Business Opportunity Sales Act or is exempt under Section 803 of this title.

Specific caveats that must be met by an MLM company to be classified as a “business opportunity” in Oklahoma include (Section 802, 3.a.):

(1) The seller or a person recommended by the seller will provide or assist the purchaser in finding locations for the use or operation of vending machines, racks, display cases or other similar devices, on premises neither owned nor leased by the purchaser or seller;

(2) The seller or a person recommended by the seller will provide or assist the purchaser in finding outlets or accounts for the purchaser’s products or services;

(3) The seller or a person specified by the seller will purchase any or all products made, produced, fabricated, grown, bred or modified by the purchaser;

(4) The seller guarantees that the purchaser will derive income from the business which exceeds the price paid to the seller;

(5) The seller will refund all or part of the price paid to the seller, or repurchase any of the products, equipment or supplies provided by the seller or a person recommended by the seller, if the purchaser is dissatisfied with the business; or

(6) The seller will provide a marketing plan.

I’m not really clear on how Family First Life satisfied

🤖 Quick Answer

What is the Family First Life cease and desist action pending in Oklahoma?
Oklahoma's Department of Securities, through its Enforcement Division, recommended issuing a cease and desist order against Family First Life following an investigation. The case involves an Oklahoma resident recruited during the pandemic who purchased over $17,865 in insurance leads based on allegedly misleading income representations, ultimately only breaking even on their investment.

What allegations did Oklahoma's Department of Securities raise against Family First Life?
The investigation found that Family First Life allegedly misled a recruit by promising upwards of $30,000 monthly profit from purchasing insurance leads and claiming leads could be discontinued at any time. The resident, who had lost employment during the pandemic, signed up in December 2020 and spent nearly $18,000 on leads without achieving meaningful profit.

When did the Oklahoma Department of Securities file actions against Family First Life?
The Oklahoma Department of Securities filed a series

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