Dawn Dunn’s False Earnings Claims

The Mary Kay ladies can’t  help themselves. Despite the FTC pretending to care about false earnings claims and Mary Kay Inc. pretending to crack down on earnings representations, national sales director Dawn Dunn makes false earnings claims.

A May, 2020 letter to all national sales directors said that no earnings claims were to be made. NONE. The social media guidelines issued by Mary Kay say that there should be no posts referencing specific dollar amounts that a person can make. No dollar amounts shown, period.

But maybe the rules don’t apply to nsd Dawn Dunn. See her handout below, promoting that Directorship is the way to make lots of money. Let’s start out with the fact that almost all of the numbers on Dawn’s sheet are wrong. She can’t even do simple math for 1/3 ordering or $450 times the number ordering. Based on her bad math, every single “estimated gross” number below is overstated.

But even worse is just how Dawn is lying about the reality. She knows that 1/2 of the unit will not be ordering $450. With a unit of 35, a director is lucky to meet the minimum production of $5500 wholesale. To get there, she likely has to place an order for products she personally does not need. I would challenge Dawn to look at her area and pull up the REAL stats for her directors over the last 10 years and show us the numbers. Show us how many directors were terminated for not making minimum production. Show us how many actually made it to the levels of production she shows below for each unit size. I think we’d see that it’s almost no one.

Sure, Dawn thinks she’s in the clear here because she said these are “examples” and “results will vary.” No, Dawn, you don’t get to lie about the reality and then give a disclaimer to make it seem like you’re on the up and up.



  1. And of course the disclaimer, “…results achieved will vary from person to person based on individual effort” is worded so that your inevitable failure isn’t the result of the system being hopelessly against you. Or crappy math inflating the numbers.

    No, as usual, FAILURE = YOUR FAULT for not putting in the effort.

    • The only way you’d get a recurring recruiting bonus for a unit of a fixed size is via churn. According to her table, to hold a 100 member team, she and her unit will be recruiting 6 new members per month, which is 72 per year. That’s 72% churn. Wowza.

      Also. I am curious how 1/3rd of 100 equals 42. MK math I suppose.

      Oh…”personal recruiting commission”…that must be commissions from front-loading new recruits. Nice-sounding term, though.

  2. Even if these numbers were accurate (which we know they are not), they are not that impressive. A gross profit of $86,964 for managing a unit of 100 people?!?! Moreover, this is gross income, so it doesn’t account for expenses. But even if there were minimal expenses (which, once again, we know is not the case), $86,964 is the income for an entire year? In a real job (gasp), a director-level position with 100+ people reporting under them will make a salary that meets/exceeds $86,964, and there is no deduction for expenses. So, I guess my takeaway is that… even if I actually believe such income claims (and I don’t), MK is simply not that enticing of an opportunity.

    • And remember how few units even get to 100 active members. Very, very few do. So this is the best of the best. And they’re still not making the executive income that is promised.

    • Statistically speaking, you need to recruit and maintain at least 249 people in your downline before your start to produce a true business profit in MLM.

  3. All this shows is that the majority of their “income” comes from recruitment. I can’t remember the exact percentage that the FTC dictates that where the income which comes from recruiting makes it a pyramid scheme, possibly 80%.

    It’s easy to see that at the alleged higher unit count, Mary Kay is operating as a pyramid scheme. The lower populated ones are just on the side of legitimacy.

    • It’s too bad there isn’t any valid data on “sales” to legit customers, not just wholesale orders to the company. Sure, there’s the “weekly accomplishment sheet,” which is glossed over during your “training.” But if it could be revealed how little product is sold to customers, it would be telling. That’s my opinion, based on 21+ years of anecdotal accounts within the “business.”

    • When they’ve ordered $600 wholesale within their first 3 months. Ideally you snag them and get that $600 wholesale in the bag immediately so you don’t have to keep following up. The longer between the snag and the order, the less likely it is that she will become “qualified.”
      The company pays $50 to consultants for each qualified recruit they bring in, and $100 to directors for any new qualified recruits in their unit.

  4. It pisses me off how they represent what they will make from “sales”. The reality is, most of that product they order will be sold at a discount, used as a giveaway to entice a potential recruit, or gather dust on the shelf.


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