Hulsa provides no information on their website about who owns or runs the company.
The company operates in the CBD MLM niche and represents it is based out of Colorado. Not however that the corporate address provided on Hulsa’s website belongs to a UPS store.
To suss out who’s running Hulsa we have to turn to an August 2020 press-release;
Hülsa’s founding team includes Josh Ginsberg, co-founder of Native Roots … and Julian Michalowski, co-founder of California-based cannabis dispensary chain Coastal Dispensary.
Other key leadership includes Jeff Rogers, founding (former) CEO of Kannaway; and David Berck, a top 500 distributor who serves as Hülsa’s President.
Why this information isn’t just presented on Hulsa’s website is unclear.
As far as I can tell Josh Ginsberg doesn’t have any MLM experience. His company, Native Roots, pitches itself as “Colorado’s premier medical and recreational cannabis dispensaries”.
Native Roots has a
173,000 SQFT, this facility enables us to cultivate world-class cannabis, develop concentrated raw goods through CO2 and BHO extraction, and manufacture a variety of finished goods for our customers.
Presumably this ties into Hulsa’s CBD products.
Julian Michalowski again doesn’t appear to have any MLM experience. His company, Coastal Dispensary, is a Californian company offering “high quality, locally-sourced product(s)”.
Jeff Rogers (right) is where we get some MLM experience. Rodgers popped up on BehindMLM’s radar in early 2014, as founder and CEO of Kannaway.
Rogers left Kannaway in 2016 to join Sanki Global as President of its US operations.
I believe that was Rogers’ last MLM executive position until Hulsa.
Interestingly enough I came across a February 24th press-release, announcing Rogers was consulting for Nass Valley Gateway.
Nass Valley Gateway LTD. (a) distributor of top quality, broad and full spectrum CBD products, is pleased to announce it has retained Jeff Rogers as a lead consultant to rollout “Nass Valley Direct,” which is Nass Valley Gateway’s direct sales platform launching in early Q2 2021.
Rogers will design its compensation plan along with its editorial and training content to help NVG sell its new menu of 30 CBD products for humans and pets.
Given this is the same MLM niche Hulsa operates in, sounds like a potential conflict of interest to me.
Prior to signing on as Hulsa’s President, David Berck seems to have made a name for himself in MonaVie.
MonaVie was sold off to Jeunesse in 2015. I wasn’t able to establish what Berck was up to after MonaVie and before mid 2020.
Read on for a full review of Hulsa’s MLM opportunity.
Hulsa markets a range of CBD products.
- Complete Body Lotion – “meet Complete, a meticulously clean nutrient-rich full-body moisturizer”, retails at $119 for a 4 fl. oz. tube (120 ml)
- Sleep Tincture – “count your lucky stars with this proprietary blend of BiBong herbs formulated with our powerful combination of CBD and CBN”, retails at $119 for a 1 fl. oz. bottle (30 ml)
- Relax Tincture – “you may be one dropper away from ushering in a greater sense of calm”, retails at $99 for a 1 fl. oz. bottle (30 ml)
- Relief Salve – “soothe sore muscles and alleviate body aches”, retails at $89 for a 1.7 fl. oz. tub (50 ml)
- Chill Pill – “a tasty mint infused with our scientifically formulated Critical Cannabinoids”, retails at $45 for a box of 30 mints
- Daily Softgels – “a cannabinoid-rich soft gel that supports overall wellness and alleviates anxiety from day-to-day stressors”, retails at $99 for a bottle of 30 softgels (25 mg CBD each softgel)
- Revive Face Moisturizer – “a skin-rejuvenating face moisturizer formulated to soothe tired and stressed skin while minimizing wrinkles and restoring your youthful glow”, retails at $99 for a 2 fl. oz. bottle (60 ml)
Hulsa also sells their product range in a
- $254 Experience Pack – “experience 3 of Hülsa’s most popular products!” and
- $649 Complete Pack – “experience the entire Hülsa collection with the Complete Pack!”
Hulsa’s Compensation Plan
Hulsa do not provide a copy of their compensation plan on their website.
The following is put together from a Hula corporate compensation plan video, hosted by David Berck.
This video was available to the public on Hulsa’s website. For some reason Hulsa removed public access to it about a week ago.
MLM Commission Qualification
To qualify for MLM commissions each Hulsa affiliate must generate 50 PV a month
PV stands for “Personal Volume” and is generated by retail sales or a Hulsa affiliate’s own orders.
To qualify for residual commissions a Hulsa affiliate must recruit two affiliates, one placed on each side of their binary team.
These recruited affiliates must be MLM commission qualified (50 PV a month).
Hulsa Affiliate Ranks
There are thirteen known affiliate ranks within Hulsa’s compensation plan.
Along with their respective qualification criteria, they are as follows:
- Brand Partner – sign up as a Hulsa affiliate
- Qualified Brand Partner – meet MLM commission qualification (see above)
- Momentum Pro
- Black Diamond
- Blue Diamond
- Red Diamond
Hulsa do not provide rank qualification criteria.
Hulsa affiliates earn a commission product sales to retail customers.
Hulsa pays retail commissions as the difference between retail and the wholesale price of products purchased.
Hulsa’s compensation presentation suggests this comes to roughly 30% on one-time orders and 20% on preferred customer orders.
Preferred customers are retail customers who receive a discount in exchange for committing to a monthly order.
Initial Sales Bonus
The Initial Sales Bonus pays 30% on sales volume generated by a personally recruited affiliate’s orders.
The Initial Sales Bonus pays on any orders placed within a newly recruited affiliate’s first 30 days.
Fast Start Bonus
Hulsa’s Fast Start Bonus is a recruitment bonus.
To qualify for the Fast Start Bonus, a new Hulsa affiliate must
- sign up with a Momentum Pack;
- make a manual 500 BV purchase when signing up;
- recruit an affiliate who signs up with a Momentum Pack or buys 500 BV worth of product when recruited; or
- generate 500 BV in retail sales
The Fast Start Bonus is then paid on recruitment of Hulsa affiliates who do the same.
- recruit two Fast Start Bonus qualified affiliates and earn a bonus 25% on generated Initial Sales Bonus volume
- recruit three Fast Start Bonus qualified affiliates and earn a bonus 50% on generated Initial Sales Bonus volume
- recruit four Fast Start Bonus qualified affiliates and earn a bonus 100% on generated Initial Sales Bonus volume
Remember, this is an added percentage of the Initial Sales Bonus volume directly tied to the recruitment (see Initial Sales Bonus details above).
The Fast Start Bonus is valid for a new Hulsa affiliate’s first thirty days with the company.
Note that if an affiliate doesn’t instant-qualify by signing up with a Momentum Pack or purchasing 500 BV of product, the thirty-day counter is not reset if they qualify for the Fast Start Bonus during their first thirty days.
Rising Star Bonus
To qualify as a Rising Star, a Hulsa affiliate must
- qualify for the Fast Start Bonus (see above); and
- recruit four Fast Start Bonus qualified affiliates within their first thirty-days.
Rising Star qualified Hulsa affiliates earn a permanent 100% increase on the Initial Sales Bonus (effective 60% bonus).
Hulsa pays residual commissions via a binary compensation structure.
A binary compensation structure places an affiliate at the top of a binary team, split into two sides (left and right):
The first level of the binary team houses two positions. The second level of the binary team is generated by splitting these first two positions into another two positions each (4 positions).
Subsequent levels of the binary team are generated as required, with each new level housing twice as many positions as the previous level.
Positions in the binary team are filled via direct and indirect recruitment of affiliates. Note there is no limit to how deep a binary team can grow.
At the end of each week Hulsa tallies up new sales volume on both sides of the binary team.
Affiliates are paid a percentage of sales volume generated on their weaker binary team side:
- Brand Partners earn an 8% residual commission rate
- Momentum Pros earn a 10% residual commission rate
- Silvers to Platinums earn a 12% residual commission rate
- Pearls to Emeralds earn a 15% residual commission rate
- Diamonds and Black Diamonds earn an 18% residual commission rate
- Blue and Red Diamonds earn a 20% residual commission rate
Once paid out on, volume is matched against the stronger binary team side and flushed.
Any leftover volume on the stronger binary team side carries over.
Leadership Check Match
The Leadership Check Match is tracked through a unilevel compensation structure.
A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):
If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.
If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.
The Leadership Check Match pays on residual commissions paid to Silver or higher ranked downline affiliates.
Through the Leadership Check Match, a Hulsa affiliate can earn a match on up to seven generations of Silver or higher ranked affiliates per unilevel team leg.
- Silvers earn a 20% Leadership Check Match on one generation of Silvers or higher per leg
- Golds earn a 20% Leadership Check Match on the first Silver generation and 20% on the second per leg
- Platinums earn a 20% Leadership Check Match on the first Silver generation, 20% on the second and 10% on the third per leg
- Pearls earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and 5% on the fourth per leg
- Sapphires earn a 20% Leadership Check Match on the first Silver generation, 20% on the second and 10% on the third and fourth per leg
- Rubys earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth and 2.5% on the fifth per leg
- Emeralds earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth and 5% on the fifth per leg
- Diamonds earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth, 5% on the fifth and 2.5% on the sixth per leg
- Black Diamonds earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth and 5% on the fifth and sixth per leg
- Blue Diamonds earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth, 5% on the fifth and sixth and 10% on the seventh per leg
- Red Diamonds earn a 20% Leadership Check Match on the first Silver generation, 20% on the second, 10% on the third and fourth, 5% on the fifth and sixth and 20% on the seventh per leg
Note if a Hulsa affiliate generates and maintains eight retail customer sales a month, their first generation Leadership Check Match rate increases to 30%.
Affiliate Autoship Commissions
Hulsa takes 40% of volume generated by recruited affiliate orders, and pays it out via a five-level deep unilevel team.
This unilevel team is the same structure used to pay the Leadership Check Match (see above).
- Qualified and Momentum ranked affiliates earn a 40% autoship commission on level 1 (personally recruited affiliates)
- Bronze ranked affiliates earn a 40% autoship commission on level 1 and 30% on level 2
- Silver ranked affiliates earn a 40% autoship commission on level 1, 30% on level 2 and 15% on level 3
- Gold ranked affiliates earn a 40% autoship commission on level 1, 30% on level 2, 15% on level 3 and 10% on level 4
- Platinum and higher ranked affiliates earn a 40% autoship commission on level 1, 30% on level 2, 15% on level 3, 10% on level 4 and 5% on level 5
Remember, the above percentages are percentages of 40% of affiliate autoship volume set aside (e.g. level 1 is 40% of 40%).
Hulsa pays a monthly Lifestyle Bonus to Diamond and higher ranked affiliates:
- Diamonds receive $1000 a month
- Black Diamonds receive $2500 a month
- Blue Diamond receive $5000 a month
- Red Diamonds receive $10,000 a month
Hulsa’s compensation documentation details several Rewards Trips.
- Pearl ranked affiliates receive a 3 day cruise to the Bahamas
- Diamond ranked affiliates receive a 5 day trip to Maui’s Grand Wailea Resort
- Black Diamond ranked affiliates receive a 7-day “celebration at some of the most remarkable destinations the world has to offer”
- Red Diamonds receive a “personalized 10-day trip designed in collboration with First Class travel”
To qualify for the Founders Club a Hulsa affiliate must
- have signed up with or later purchased a Founder’s Pack; and
- qualify at Gold or higher.
Hulsa takes 1% of company-wide sales volume and pays it weekly to Founders Club qualified affiliates.
Note the Founders Club is limited to 5000 affiliates.
$50. Access to a marketing app costs an additional $10 a month.
In addition to the Experience and Complete Packs detailed in the product section of this review, new Hulsa affiliates can add additional packs to their new membership
- Experience Pack – $253 with three Hulsa products and one month app access
- Complete Pack – $639 with one of each Hulsa product and three month app access
- Momentum Pack – $1278 and is basically two Complete Packs + 6 months app access
- Founders Pack – $2456 and is basically four Complete Packs + 12 months app access
Note that even if one of the above packs is purchased, the $50 base Hulsa affiliate fee still applies.
Hulsa presents itself as a faceless corporation, which isn’t a good look for an MLM company.
Despite having founders and executives no information is provided, leaving consumers having to search elsewhere for basic due-diligence information.
This extends to the compensation plan being pulled down, when it should be readily available to the public.
What I was able to analyze focused far too heavily on affiliate autoship recruitment.
It was clear the most incentivized entry into Hulsa was sign up with a 500 BV Momentum pack, set up a 50 PV monthly autoship order and then recruit others who do the same.
There are no retail requirements or bonus incentives. In fact the only time retail mattes is to qualify for a 10% Leadership Check Match first generation raise.
That’s not to be sneezed at but when weighed against the affiliate autoship recruitment bonuses, clearly isn’t going to significantly contribute to overall retail sales.
David Berck himself bluntly states what’s expected of new Hulsa affiliates;
Getting started, of course you’re going to enroll for $50 … you’ll become active, you’ll enroll in autoship, uh which is optional, but that just guarantees that you’re gonna make that 50 BV requirement.
Sign up and set up autoship to qualify for commissions, primarily paid on recruited affiliates who’ve done the same.
Going on about autoship being optional, whilst factual, comes off as a weak attempt at pseudo-compliance.
Such to the extent MLM affiliates do sign up for autoship, it should only be because they are purchasing the products as genuine consumers.
MLM affiliates purchasing products to qualify for commissions is a strong pyramid scheme indicator.
Putting all of this together my gut tells me Hulsa is an MLM company with far more retail purchase volume than retail sales.
This is a problem because an MLM company primarily generating revenue from affiliate purchases, as opposed to or at the cost of retail sales, is operating at a pyramid scheme.
As to Hulsa’s products, it’s no secret that the MLM CBD niche has been saturated for some time. Going hand in hand with Hulsa’s faceless corporation image, it comes off as a bit of a money grab.
Perhaps that’s why Jeff Rogers is already off consulting for what will launch as a rival MLM CBD opp.
By all means if you come across Hulsa’s product line give them a try. Assuming the products come up the same supply chain as that of Native Roots and Coastal, you have two seemingly credible companies behind the venture.
Just don’t fall into the trap of paying a monthly autoship fee, recruiting others who do the same and thinking that’s a legally complaint MLM opportunity.