Josh Zwagil started My Daily Choice in November 2014, a month after finishing a five-year run using an automotive products MLM, Syntek Global, where he climbed to the highest position of Blue Diamond Executive, according to his own LinkedIn page. (Fun fact: After Zwagil left Syntek Global, the MLM filed a suit against its longtime president, John Winterholler, alleging, among other matters, that he went behind the business ‘s spine and contrary to its interests to market and promote a competitor’s products.)

Green Roads didn’t come into the picture until May 2017, as it merged into My Daily Choice and became its flagship product, supplementing the lineup of "supplements " encouraged for everything from weight reduction (Trim green roads 365) to cognitive function (simply, Brain). The idea for Green Roads arrived in the waiting area of a doctor’s office. "I was very ill," Josh’s wife, Jenna Zwagil, stated in a recent interview in which she recounted the visit. She cut gluten from her diet but wasn’t getting better. As she waited to be known for her appointment, she started reading an article on her telephone on "the power of cannabis" in treating psychiatric disorders like hers. When she finished the article, she said, she walked from the workplace without visiting the physician to immediately seek out cannabidiol or CBD.

Within a few hours of attempting the oils (procured from a farm in Kentucky, where Green Roads says it now gets all its CBD oil ) Jenna started to feel much better. Within a week her health started to revive itself. Within a month, she no longer had some symptoms from what she felt as though was a painful disorder.

"There is an answer to your pain, your anxiety, your digestive ailments, whatever people are facing," Jenna said in the meeting, "and that’s kind of been the beginning of Green Roads. "

That is as good a segue as any to our next segment…

While Jenna’s "How I cured my celiac disease" story is inspiring and study into the curative effects of CBD is promising, particularly in the treatment of seizures and other neurological disorders, the FDA is clear: Marketing supplements like having the ability to treat, cure, relieve the symptoms of, or prevent developing ailments is simply not permitted by law. Yet that has not stopped Jenna and distributors from asserting that Green Roads treats a number of ailments, including Parkinson’s, multiple sclerosis, AIDS and cancer, often as an alternative to traditional treatments. In fact, TINA.org has amassed a record of more than a hundred inappropriate and illegal medical claims. They comprise:

"Can Slow Down and Kill Cancer Cells" "[M]y husband had a huge stroke in 47… he now has Parkinson’s as well… his speech is very restricted and his right arm isn’t functional… he had been on this particular herbal oil for a few days along with the change in him is remarkable. " "I have triple negative breast cancer. I’ve been in chemo for more than a year and I have six months to go. … I started taking the drops and I will ‘t believe how fast its own [sic] making my life better.

To date the FDA has only approved one drug comprising CBD and that was only after it was shown to satisfy rigorous scientific criteria. Last November, the FDA sent warning letters to four CBD companies for making unproven health claims. Last summer, Josh Zwagil warned distributors to avoid using words like "cures," "prevents," and "treats" in the marketing of Green Roads products because regulators like the FDA are keeping close watch, the Canadian Broadcasting Company reported. Certainly, that message wasn’t received by all distributors. (See more about the legal problem in the last section of this article.)

When talking the earnings of its distributors, an MLM may not make deceptive use of odd earnings realized only by a few distributors without running afoul of the law. Likewise, a failure to disclose that the structure of a program makes certain that the vast majority of consumers can’t achieve substantial income is deceptive under law.

Josh Zwagil seems to cross these two lines when he claims within an "opportunity" video that those "looking to go all in and build a fulltime revenue " can do so together with his MLM, without revealing what the company’s Policies and Procedures make abundantly clear — that is that most distributors spend more on products than they earn in the payment plan (See next section). Top Green Roads distributor Judy Stallings, who has been introduced at conventions as the "first-ever 250K affiliate," has also used inappropriate income claims to entice people in the MLM, composing on her Facebook page last December:

In case you’ve been thinking of joining MDC/Green Roads — right now is a excellent moment. Because I am the top rated affiliate in the company with less than 6 weeks in… Ready to get to work and help facilitate the daily stresses of paying the bills, getting out of debt or just having a better life in general?

Zwagil’s and Stallings’s misleading earnings claims are only two of the more than 50 cases within an TINA.org sampling. Listed below are a few other people of note:

"Newbies are making $1,000 per month" "$5,000 per month to get whatever… I may not know it ‘s working. You can be too! "

How are these rare people making cash, if what they are asserting is true? The solution may have to do with recruitment compared to product sales. As Josh Zwagil explains in the opportunity video, when discussing how one facet of this reimbursement plan — leap start bonuses — work:

If you enrolled 10 people in the executive bundle, you would earn $100 times 10 — $100 times 10 is $1,000. If those 10 people all went outside and brought two people in at executive, that’s 20 new people — 20 people times $20 is $400. If those 20 people went out and recruited new people and those people went out and recruited people, as you can see the jump start bonuses add up very fast.

Green Roads distributors have also emphasized "the power of recruiting" in order to be successful. But here’s the thing: If making money as a distributor depends upon a person’s ability to recruit other people than market product, the vast majority of distributors will inevitably fail. Moreover, a de-emphasis on product sales opens an MLM to criticism of operating a pyramid scheme.

While distributors discuss getting out of debt and achieving "financial freedom" using Green Roads/My Daily Choice, the businesses ‘ shared 21-page Policies and Procedures says it’s "very possible" you will not earn any money at all as a distributor. In fact, it says that most distributors "earn less cash every month in the payment plan when they are paying to their products. " To put that bluntly, most distributors lose money.

But that’s not the only thing in this telling record — that functions as a binding contract for distributors — which ‘s worthy of your attention, even if it’s buried in the base of the Green Roads and My Daily Choice sites. A few other people, in the sequence they appear:

Distributors are prohibited from making product claims that have not been accepted and/or endorsed by "official Company publications. " In order to be qualified for all commissions and bonuses, sellers must purchase about $200 worth of product every month, or $2,400 worth of product each year. Suddenly, you may start to find out the way nearly all distributors find themselves in the red. Distributors must not speak ill of Green Roads or My Daily Choice, their products, or other distributors, in addition to other companies, including competitors, or their products. While distributors have proclaimed Green Roads’s cannabis products as "legal in all 50 states," and Josh Zwagil has stated that it’s "100 percent legal" to send them across state lines (more about this in another section), the arrangement advises that distributors nevertheless "consult with an attorney regarding the degree of their personal legal liability with respect to their independent companies," noting that "laws differ according to jurisdiction. In addition to shedding the commission, suppliers must also pay all shipping costs, even if it was a client who ordered the product. Seeing medical claims, the contract says: "Under no conditions could [a distributor] prescribe any Product as suitable for a particular ailment. No claims could be made as to therapeutic or curative properties of any Product given by the Company. " As for earnings claims, the contract says suppliers are "prohibited from making false, misleading, or unrepresentative claims regarding bringing potential. " But as of this date of publication, it wasn’t submitted there. Should any legal disputes arise between a distributor and the company, proceeding will take place in Dallas, Texas, where the issue will be resolved by "mandatory, final, binding, nonappealable mediation. " However, if the distributor wins, it won’t be a great victory as damages are "restricted to the amount of products [he or she] has purchased from the company that are in resalable condition. "

If you’d like an notion of just how murky the waters are enclosing the legality of CBD — that, depending on who you ask, is either a "remote cousin" or "sister" to tetrahydrocannabinol or THC, the psychoactive compound in cannabis that, unlike CBD, causes a high — consider the progress of only the past couple of months.

During this time, the FDA announced that it had accepted the "first drug comprising cannabidiol" for epilepsy and a spokeswoman for the DEA, commenting generally on the agency’s reported seizure of hemp consented to get a CBD oil maker in North Carolina, stated that "as far as the national government is worried, CBD oil is prohibited. " That’s two national agencies that have the word "drug" in their titles seeming to contradict each other, only weeks apart. So suffice to say, it’s cloudier than a Cheech and Chong cast party at this time.

What is clear, however, is that the DEA’s classification of all cannabis extracts as Schedule 1 controlled substances. Even as more nations "legalize it," all types of cannabis continue to be illegal under national law. And that’s a problem for Green Roads distributors who must transfer product. As the DEA spokeswoman told the Port City Daily news website in North Carolina, where marijuana is prohibited but decriminalized: "The plant, for human consumption, is prohibited, base line. If you send it — then that’s interstate commerce, that’s trafficking, and so that’s a problem. "

Josh Zwagil doesn’t think so. Referencing a bill that is often cited as evidence that hemp-derived CBD with trace amounts of THC is legal (there are limitations ), Zwagil stated lately:

There’s a 2014 Farm Bill that pretty much states that in the event that you have less than .03 percent THC, that it’s 100 percent legal to send your products across state lines.

Then again: Zwagil also says, by his company’s Policies and Procedures (see above section), that you ought to talk to a lawyer before joining Green Roads as "laws vary according to jurisdiction," that does not make it seem "100% legal. " He also gets the proportions incorrect: it’s.3 percent THC, not .03 percent THC, that further supports the belief that maybe you shouldn’t rely on him regarding cannabis laws.

The bottom line: While Zwagil and distributors imply that hemp-derived CBD is perfectly legal, that’s not the opinion of national law enforcement.

TINA.org achieved to the Zwagils, the business ‘s founders, for comment. Erin McGinnis, Green Roads’s director of compliance, reacted with a statement suggesting that the company is in the process of assessing every item in the above article and every entry in the health and earnings claims databases TINA.org compiled. As of 9/6/18, Green Roads had eliminated 83 of more than 100 health claims and 35 of more than 50 income claims. Additionally, McGinnis stated Green Roads has suspended several distributors and terminated one in response to TINA.org’s findings.

Find more of our policy to multilevel marketing, aka the day job that doesn’t cover, here.

This article was updated 9/11/18.

Multi-Level Marketing — a method of distributing products or services in which the distributors earn money from their own retail revenue and from retail sales generated by their direct and indirect recruits.