When I work with a start up or an existing MLM company to help them achieve a program in compliance with the multitude of state and federal laws and regulations applicable to their specific products and sales plan, it is my practice to issue a formal legal opinion letter.  Samples of portions of these opinions, which vary depending upon whether the company's Distributors are selling the company products directly at a retail price, or alternatively are buying product at wholesale for resale.  My legal opinions to MLM companies are private opinions to the company owners and management.  There are several important purposes served by my providing these legal opinions, namely:
 

1. Each opinion details the specific complaisance which impact on the specific sales plan of the company and explains the law applicable to each compliance. 
    
2. The opinion refers to specific compliance requirements that must be continuously maintained and those compliances requiring future implementation. This important knowledge cannot be effectively conveyed verbally.
    
3. The company receives the information about its required compliances in a letter, not by way of a vague verbal assurance, and can refer to the letter in the future to understand the compliances required of the company as their sales plan content and/or wording changes occur.
    

In my experience in representing MLM companies over the past 40 plus years, I have found that the more understanding my clients have as to what the required compliances are, and their *why" and historical background, the more effective they are in maintaining the compliances.

• Sample Legal Opinion - Retail
  
  
  
• Sample Legal Opinion - Wholesale