Crimes of Persuasion

Schemes, scams, frauds.

Face National Models and Talent - News Reports

Modeling agency out of the picture

A Charlotte-based modeling agency is under a temporary restraining order after the N.C. Attorney General's office complained the firm failed to live up to its promises.

Face National Models & Talent is barred from collecting fees from prospective models until April 21, when it must produce financial documents and a clients list at a hearing. The AG's office has asked for a permanent injunction and refunds for consumers.

The AG's office says Face promises traditional modeling jobs in print and runway work, with pay as much as $150 per hour. The few clients who get work hand out product samples for $15 an hour, the AG's office says.

Face has visited across the country recruiting models since 2001. The agency makes money charging clients to have photo cards made to show prospective employers, usually charging $600 for the shoot and another $400 for copies. The actual cost of producing these cards is less than $40, the AG's office said.

A dozen people filed complaints with the AG's office about Face, while another 57 complained to the Better Business Bureau. Most of the BBB complaints were resolved, though the bureau says Face has an unsatisfactory record. Modeling agencies were the second-largest source of complaints made to the Charlotte BBB last year.

Face says a few customers who had unrealistic expectations have complained.

Miles Levine, an attorney representing Face manager Jennifer Gill, said Face tells clients they are not guaranteed jobs and that most of the work offered is promotional. "They don't mislead customers," Levine said.


Face National claims to visit nine cities in California every year: Bakersfield, Fresno, Palm Springs, Sacramento, San Bernardino, San Diego, San Jose, Santa Barbara, and Santa Cruz.

If you are a resident of CA, and you paid Face National $1,000, you may be entitled for a full refund, and even an extra $1,000 penalty, because it is illegal in the state of California for a talent agency to collect fees for photos.

Miles E. Locker, Attorney for the Labor Commissioner, in a previous ruling, SHAWN ASSELIN vs. ANDY ANDERSON, signed by the State Labor Commissioner, wrote:

It is well established, pursuant to section 1700.40, that a talent agency cannot charge an artist for a photo shoot or for the printing of photographs.

It is even illegal to collect fees for photos. To quote from the Labor Commissioner's Determination that was issued on August 10, 1995 in Valerie Rezin v. Andy Anderson (No. TAC 7-94):

Such charges are unlawful irrespective of whether the agent profits from these charges. The statute is violated anytime an agent collects such fees from an artist, even if the agent transmits the entire fee to another person without retaining any portion as a profit, and even if the agent is not yet representing the artist at the time the fees are collected.

The penalty for collecting fees when they are not quickly returned is tough. Miles E. Locker, Attorney for the Labor Commissioner, also in SHAWN ASSELIN vs. ANDY ANDERSON, wrote:

Labor Code section 1700.40 further provides that a talent agency that fails to reimburse an artist within 48 hours of the artist's demand for reimbursement of any fees that were paid to the agency for the procurement of employment must pay the artist a penalty equal to the amount of the improperly withheld fee if the artist did not procure, or was not paid for, the employment for which the fee was paid.

That means if you paid Face National $1,000, and they refuse to return that money within 48 hours of your demand for your money back, you could collect a $1,000 penalty, in addition to the $1,000 you paid, for a total of $2,000!

According to an online database and one aspiring model in CA, Face National does not have a CA talent agency license. It is a CA labor code violation to do business as a talent agency in CA without a CA talent agency license.

Read a precedent case involving photos where the model won back his money and a penalty.

Email if you want more information about getting your money back.


This web page has more research about Face National Models and Talent than any other website. It contains news clippings, Better Business Bureau reports, comments by leaders, complaints from aspiring models, and a review of the unconventional and controversial Face National modeling business model.

This page is for those who need more than the fine-tuned, aggressive Face National sales pitch and the almost superficial 5 PM news report sound bytes before they decide to quickly part with their money.

While some reporters may have read this page, others unfortunately have not, because they keep failing to ask the right questions.

Your Stories: Modeling Agency Wants More Than A Pretty Face

WOKR-TV 13 Rochester, NY

February 12, 2003

Rochester, NY - The ad says: "Models wanted. Make a hundred dollars a day."

It caught the attention of one woman who was trying to get back into the modeling business. However, she soon found out that the fast money-making deal may not be picture perfect.

Representatives from Face National Modeling Agency travel around the country recruiting models. They have been to Rochester several times.

Heather Mincer went to the company's interviews and at first she liked what she heard. The company has been in Rochester for three days.

She said, "They talk to you like you have the look. [They say] 'You're beautiful and pretty. We can really use you.'"

While the pitch was enough to convince Heather, she soon found out that there was one catch —she had to pay $650 to have her pictures taken.

"They pay the photographer for you, because they know most people don't have $650 on hand. Then you would pay [the agency back in] monthly installments, but you had to give them $180 on the day you signed the contract," she said.

It still sounded good to Heather, but said she saw red flags go up after asking about guaranteed work in Rochester. She then went home and researched the company.

"I went home and went on the Internet and found a lot of information about them," she said.

News Source 13 found several complaints files against the agency on the Web site of the Better Business Bureau in North Carolina.

Heather returned to the agency to get out of her contract and get her money back.

"It says in the contract that they give you that you have three business days to get your money back, so contractually they have to give it back," she said.

The agency refunded her money.

"You have to be very cautious who you use. If they tell you that you have to sign a contract 'today, because we're going to be gone tomorrow,' that should give you a red flag," she said.

The experience has not turned Heather off from the industry. She still plans to try to make it on her own with a local agency.

Experts say potential models should never have to pay money up front for anything when trying to break into the modeling business.

Anyone with questions or complaints about the agency should contact the Better Business Bureau.

Models Beware: Are traveling agencies legit?


Anita Kissée
Idaho's NewsChannel 7

7 Investigation: BOISE CITY

BOISE - The Better Business Bureau called it one of the most popular schemes of 2002 and it seems it's spilling into the New Year. Modeling agencies promising to make you a star.

More than 1,200 people turned out this week in Boise, for their chance at being a model. And while some may ultimately make it big, consumer protection groups say for others, some companies play right to your ego.

Let's face it. Who doesn't secretly dream of being rich and famous, the next Hollywood star?

Claire Roberts, Potential Model: "There's a lot of people that want to be famous or make some money and be involved in this industry."

Claire Roberts included.

Roberts: “I decided to go ahead with it."

Her big break she thought came with a contract from Face National Models and Talent. The company was in Boise searching for the best and brightest. Roberts signed the dotted line but when it came to paying...

Roberts: "I wanted time to think about it. It was a lot of information very quickly."

Nora Carpenter, Better Business Bureau: "The phone at the better business bureau has been ringing off the hook."

Nora Carpenter says Face Models is just one of many vanity-based companies looking to Idaho to make a profit.

Carpenter: "Chances are the contract is written in favor of the company and really doesn't guarantee a job here and let's face it and no one really can guarantee your child, as talented as they are, is going to be the next superstar."

Kary Kilowitz, Face National Models and Talent Scout: "I'm not here to make them famous. I let them know point blank."

Kary Kilowitz scouts for new faces and admits his company has an unsatisfactory record with the BBB: 63 complaints in 3 years.

Kilowitz: "I explain to all my models in my interviews what kind of complaints we have... Our agency doesn't promise we don't guarantee any work and it's even listed in my contract like that."

Face Models doesn't charge models up front but what it does charge for?

Kilowitz: "Our photographers range anywhere from $550 to $650."

While parents aren't required to buy the photo shoot, most do. When in fact, the industry standard is about half that price, $250 to $300. The BBB says if the portfolio is the real emphasis, not career opportunity, future stars should be extra cautious.

Carpenter: "Don't allow your ego to get in the way of making this decision."

Roberts: "I was close. And if I could be close anyone could be close."

The best advice we heard, think with your head not your ego. The BBB recommends you investigate the business side of the modeling industry, talk with local professionals and most importantly take time and don't rush. Most experts say legitimate agencies pay themselves out the work they arrange for you. It shouldn't clean out your savings.

Modeling Agency Hits Treasure Valley for Fresh Faces

By Tami Doty

KCBI News2

Boise, Idaho

January 15, 2003

"I heard on the radio, about this open modeling call." Claire Roberts was like 1,200 other Treasure Valley dreamers... with hopes of getting their big break in the modeling industry. But after signing on with face models, out of North Carolina... she got skeptical.

"I couldn't find any information, and they didn't have any portfolio on hand to show you and I thought that was strange. If you're going to spend 650 dollars on photographs of yourself, that are supposed to be so important, then you better check out the work."

Face National Models and Talent has received an unsatisfactory rating from the Better Business Bureau. But it's not because it's a fraudulent company. Nora Carpenter of the Better Business Bureau of Southwestern Idaho explains. "There's a feeling of high-pressure tactics, sort of a make this decision now or lose this opportunity and that certainly is worrisome."

The agency argues that clients are given other options... and they're not in the business of making anyone a star. Keri Kilowitz says, "I don't promise anyone that I hire, I don't guarantee anybody that I hire, I don't tell them they're going to be on the cover of a magazine. I'm not here to make them famous."

But for some young girls with stars in their eyes, getting involved in this risky business is worth it. Anna Brunello just signed with the agency.
"It is a chance. Every step is a chance and I'm willing to take it with this company."

None of the young models we talked to said they felt lied to by the agency. The Better Business Bureau stresses, the importance of doing research on the company and make decisions with your head, not your ego. For more on the issue, you can go to our website, click on links.... and there's one there for the Better Business Bureau.

Questions About A Modeling Agency

WKRG - News
By Bill Riales

Jan 15, 2003

We've all seen them on the magazine covers, super models who earn millions. Many young girls dream of a modeling career. Some modeling agencies travel the country looking for the next Cindy Crawford. They bring with them promises to get their potential clients work as a model.

Our News 5 investigation cut through the glamour with a look at the truth about some of these agencies. Typically in begins with radio advertising, as it did in Mobile several weeks ago, when Face National Models and Talent of Charlotte, North Caroline came to town. Hundreds of model wannabees, many young enough to have to have their parents in tow, showed up over the two day even.

Many of their stories were similar. "I've had a lot of people behind me, trying to get me to do it, and here I am." said Jessie Phillips. "She told me I had beautiful dimples and a pretty shape." gleamed Tiffany Sanders following her initial interview with a Face representative. Kerry Killowitz, a talent scout for Face told us, "the individuals that we're interested in, that we bring aboard, will actually do some work in this area and in the Pensacola area also, within the next year."

Killowitz said he hoped to sign up about 70 models during his two day stay in Mobile, and he said his agency would try to get them work as models. But we heard from others who say getting work through this agency may be a longshot. Brooke Wood, who now lives in Mobile, signed on with Face over a year ago in Seattle. "They had some pretty big name clients." said Wood. "They had Elle Magazine, some top names, Vogue, so the stars were in the eyes when I got there." But since Brooke signed with the agency, she hasn't worked even once, despite what she says she was told at her interview with these same Face representatives in Seattle. "At that time we were told that we have the potential, he chose us and we should get out pictures taken, with the understanding that its a five hundred dollar put down but its worth it, because there's an 80 to 85 percent chance you could work." said Wood.

In the end, Wood said, the cost for her pictures, along with her composition cards, slick cardboard brochures with multiple pictures and other information, came to almost a thousand dollars. And face offers the photography service for anyone who doesn't have the wherewithal to find their own photographer. Kerry Killowitz said, "We can shoot 40 to 45 models because our photographers will be here for two days, excuse me five days, two photographers. How many will we end up shooting? thirty, thirty-five."

Even if only thirty models were photographed, that would equal about 30 thousand dollars for the agency. The problem is, industry experts say modeling agencies and photographers should be separate entities. Suzanne Massengill, who owns Barefoot Models in Mobile, says while budding models will need pictures, the cost doesn't have to be that high. "It should be under $500." says Massengill. "Your shoots can range between $250 and $300 and your composite cards are about $100 dollars, so that's where you are in our market."

While Kerry Killowitz explained to his crowd of model wannabes that they could use any fashion photographer to take their pictures, Brooke Wood said she was pressured to use the agency photographer. "To my understanding it was to go through his company to get the Face logo on it and the Face name because they'll get the percentage of the work." Wood told us. It's the work that so farm has been elusive to her. Killowitz says, however, his agency is different that others in terms of lining up jobs and models. "National clients hire on a national market." he says. "they want 17 models in Dallas, 15 models in St. Louis, 12 models in Orlando—one call to my agency can represent all of those markets." "It's not going to happen." says Massengill. "They're not going to call North Carolina and ask for Mobile models. they're going to call a local agency and ask for Mobile models.

The operation of this agency has caught the attention of Attorney's General in at least two states; New York and its home state of North Carolina. And in the past 36 months, the Better Business Bureau confirms some 62 complaints have been filed against the agency, prompting New York's A.G. to issue a consumer alert. Killowitz explains, "we have 62 complaints in our BBB over the past three years. I have 87 agency rosters across the country. 62 complaints over the last three years—that's not a lot of complaints." Nevertheless, Massengill and Wood have strong reasons to present their own warnings about Face and other agencies that come to town for a day or two at a time. "The ones that come in from out of town, I think you need to be very skeptical of because obviously they're in town making some money somehow." says Massengill. And Brooke Wood has her own warning. "I don't want anybody going out there and pouring everything they have in there. I did, I borrowed money and have nothing to show for it."

While pictures are important for aspiring models, as Massengill pointed out, the cost doesn't have to be astronomical. In fact, many of the larger agencies are not looking for professional photographs, but many times judge models on simple Poleroid pictures. Those can be sent to agencies for the cost of a stamp.

Also, we spoke with the owner of Face Models in North Carolina and asked if she could provide us with the names of models in the Mobile/Pensacola area for who the agency has found work. She told us she would have them contact us. So far, we have received no calls.

Possible Model Scam

By Sara Morris

"Many people have questions about the Face Model and Talent Agency that was in Cheyenne last week. Last Thursday we aired a story about a woman who said she received legal advice not to sign a contract with Face Model and Talent. She said she found the company to be illegitimate and fraudulent." [MORE]

If you were at the Face meeting in Cheyenne, did they have any residents of Cheyenne attend the meeting and tell you they got work through Face in Cheyenne, or what they earned? Please email your response. In the preceding news report, the company claimed they got models work, but they did not say they got anyone work in Cheyenne! Do they have even have an office in your city?

The website has received more than 35 letters about and from Face National Models and Talent. Face Models and Face staff, and even the president or owner of Face wrote to the site and their letters were posted.

On one day alone, about three letters were sent by the head and employees at Face. Face or its representatives have been aware of and visited the site since early 2002.

A few months ago, the site received a cease-and-desist letter from the attorney of Face National Models and Talent. The cease-and-desist letter challenged the wording and accuracy of statements made by people whose letters were posted on the site because they were upset.

The policy of the site with respect to letters has been to omit the date to protect the models, since agencies are better able to figure out who makes a complaint if they know the date of the complaint. If a model makes a complaint while under contract or when it is still represented by the agency, it is clearly in the model's best interests if the agency does not know and cannot figure out who sent the complaints. This is also why letters are signed with initials or pseudonym initials.

But the attorney's letter challenged this approach indirectly saying some information was inaccurate. It was accurate when it was originally posted. Even though a new website disclaimer now notes the accuracy and relevance of information is not guaranteed, because other websites and the information on them are subject to change without notice, the letters were reviewed after the attorney's complaint, because the site can be updated easily, and its success is dependent on the accuracy of the information made available to consumers.

A specific and direct challenge made in one of the letters to a staff person at Face shortly before the cease-and-desist letter was sent was regarding the price of the photos. This had been an issue from the beginning. The challenge to the Face employee was based on the complaints of several Face models who had written to the site and other sources. The pointed question was why Face charged $1,000?

Through the complaint of the attorney, FACE disputed the price, saying it was $250. The FACE claim itself was then disputed, a copy of the correspondence being sent at the same time to both the head of FACE, Jennifer Gill, and the attorney representing FACE.

Which information is accurate? This is a very important issue because it cuts to the heart of complaints made by consumers against the company. Is it $250 as FACE claimed? Or is it $1,000?

The challenge which claimed the amount Face National charges is $1,000 represented both the cost of photography and comp cards, based on several letters where the models said they paid $1,000 total, $600 for the photography, and/or another $400 for comp cards.

The second person who wrote about FACE said she lost "nearly $1,000." The girl, who was scouted by FACE in Louisiana, said she lost "all of my savings."

The third letter sent to the site about FACE said $1,000 had been spent on photos, $600 for the photography, and another $400 for comp cards:

"Last April (2001), they held open calls at a local hotel (San Jose, CA), and I was chosen to sign a contract with them (one of about 50). I paid for a photoshoot (about $600) for my composite cards, then another $400 for the composite cards themselves." (Letter#3)

"When it came time to order my comp cards, I went and picked up my slides, and did not order any comp cards. So I now have $600 worth of slides —and no modeling career." (Letter#4)

"Yesterday, March 5, 2002, I went to the Marriot Hotel at the Courtyard in Philadelphia, PA, to get my pictures done with a so-called "professional photographer." I have already paid the $600. I cannot believe I did not find this website until today. On April 13, 2002, I am supposed to go to the Holiday Inn in Philadelphia, again to see my pictures, and pay the "recommended" $388 for 150 composite cards." (Letter#5)

"I went to an open call in Portland, ME, and was offered a "contract" with Face. I paid $600 for the photo shoot, and another $400 for comp cards." (Letter#6)

"I paid them almost $1,000, and I never heard from them again." (Letter#9)

"The costs of the photos were $595.... After these pictures were taken, we would have to spend another "recommended" $388 for 150 composite cards. This almost totaled $1,000!" (Letter#14)

Furthermore, the New York State Consumer Protection Board issued a warning about FACE in November 2001, saying they were charging as much as $600 for photography.

FACE itself, according to a published news report, based on an interview with a FACE representative at the FACE office in Charlotte, North Carolina, where the company is based, said the cost was $596.

More recently, in November 2002, a parent inquired about Face National Models and Talent, saying the price they were charging was $599 for photography, and comp cards cost an extra $2-4 each. Typically at least 100 comp cards are printed initially, which could bring the cost of the cards to at least $400. So the total photography expenses for the model to get started at FACE would be $1,000.

Therefore if the price is about $1,000 in November 2002, and it was about $1,000 in November 2001, and consumers have written to say between those times it was $1,000, and FACE has provided no proof to the contrary, there is no reason to believe the price has ever been anything other than about $1,000.

[FACE is welcome to send proof of their prices and models are welcome to scan and send a receipt for their expenses.]

Consumers have stated FACE has its own photographer who is provided and/or recommended, and even strongly recommended.

The comment by a consumer in November 2002 was: "They are really pushing their photographer. She even made the comment that she wouldn't like pictures from another photographer."

Experts and leaders in the modeling industry, however, say there must be a separation of photographer and agency. The BBB said: "Traditional modeling agencies do not require any advance monies from you... The following are warning signs... Agencies that insist you use their photographer."

Consumer protection agencies and the Federal Trade Commission all warn against modeling companies and modeling agencies which are not separated from modeling photographers.

Nina Blanchard, the head of a reputable agency, has said the new model should work directly with and pay the photographer, not the agency.

Industry professionals have also noted reasonable prices for new models. But $1,000 for photos is not seen as a reasonable price. The heads of two agencies have said $300 is more like a reasonable price.

The BBB has included in a list of modeling agency warning signs: "Fees required for expensive photos."

The situation with FACE is there is a conflict of interest and there are high prices. Either a conflict of interest or high prices are a cause for concern, but both a conflict of interest and high prices are a cause for great concern.

It is widely established and widely accepted in the modeling industry agencies are not supposed to make any money from photos. They are only supposed to make money from commission. They are not supposed to get money before models work (photos); they are supposed to get it after the models work (commission).

One complaint from a representative of Face National was that the site had made a reference to Libby Stone, who is the president of a models guild. The FACE rep claimed she contacted Ms. Stone and Ms. Stone said she was not affiliated with The Models Guild in New York, and she does not even have a computer.

It was never stated on this site that Libby Stone is a representative of The Models Guild. The reference to Ms. Stone was made because she is the president of a models guild in the state where Face National is based and because she criticised Face National.

In a published news report, Libby Stone, President, Professional Modeling Guild of North Carolina, said: "What these people do is travel across the country, stay in fancy hotel rooms, advertise and get a bunch of people excited and take their money up front."

Further research showed Ms. Stone has a website for her company and a corresponding email address. So if she has a website and an email address, how did she build the website, and how does she check her email if she doesn't have a computer, as the Face rep claimed?

Not only the complaints from consumers but also further research has not led to one positive report about the company. In every news report and other report about FACE, it has not been positive.

The BBB rating for the company is unsatisfactory, and has been unsatisfactory for many months, and there have been over 60 complaints. Comments by BBB leaders about FACE have also been critical.

News reports have included accusations of fraud against FACE.

And the NY CPB warning was also critical.

The point is there is no indication consumers who complained were isolated cases, and FACE has not substantiated its claims or defended itself with proof to refute any of the allegations.

A letter was sent in August to the director of Face National, a series of specific and related questions, the answers to which would refute allegations and substantiate claims and dismiss concerns about conflicts of interest. Jennifer Gill, however, did not reply.

To memory the site has not received one letter in the last nine months from a Face Model defending FACE or refuting the allegations made against Face except from one model who just happens to be an employee at Face National!

The basic theme in all the complaints by all the sources from leaders to consumers has been related, in one way or the other, to photos.

The basic complaint is consumers pay FACE for photography and comp cards but they do not get work. Consumers have alleged FACE makes money from upfront fees of photography and photography related expenses (comp cards). FACE has not countered this claim. They have not said they make no money from either photography or comp cards.

The head of the BBB where the company is based was asked to elaborate on his claim in a published news report FACE had made some changes but had a long way to go. He declined to say what if any changes had been made, either to prices or practices, but he said they felt the BBB record was an accurate reflection of the company.

FACE claimed on its website to be in 96 cities in America. "Now in 96 cities, FACE plans to increase service to 100 cities by mid 2002." (November 22, 2002)

Yet the BBB profile for FACE says they have only 30 employees. If they have only 30 employees, how can they be in more than 30 cities? At least four of their employees who wrote the site are apparently based in Charlotte, North Carolina.

All of which begs a basic question.

As early as the third letter sent to the site, a model who had received no modeling work through Face asked: "How can they be 'getting me jobs' out here in California when they are based in North Carolina?"

What a question! If a company in California is looking for talent, are they going to call North Carolina? Or would they even know about Face National?

If Face National does not have an office in California near the company, and it is not listed in the local yellow pages, or it does not have a talent agency license in CA, how would a CA company even know Face existed?

And if they don't know they exist, how could they contact Face? If they can't contact Face, how can Face models get work from the company?

(Face National is not even listed in the popular National Directory of Modeling and Talent Agencies.)

Put yourself in the position of a client. You are in San Francisco, for example. You need models. Who are you going to call? Where are you going to go to find whom to call? What company are you going to trust?

Are you going to look at every agency in your state or only every agency in your city?

It still boggles the mind that people sign with an agency which is based in another city and even in another state. Do aspiring models who have the choice of being represented by an agency in their city decide instead to pay $1,000 and get representation with an agency in a distant state, thousands of miles away? Where is the logic there? Where were they expecting to get work? In their city? Or in Charlotte, North Carolina?

The BBB profile did not list alternate addresses for Face. It only listed one address:

Face National Models & Talent
1230 W. Morehead St. Suite 110
Charlotte, NC 28208

A search of the national BBB database for a company by its full name, "Face National Models & Talent," only offered one result, i.e. the Charlotte address.

The FACE website at, at the time of writing, does not show any other business address besides its Charlotte address.

So when Face says it is "in" 96 cities, where exactly is it in these 96 cities? Does "in" imply the company has at least one office, at least one business address, and at least one employee in 96 cities? If it does, what are the other 95 business addresses of FACE outside Charlotte where it is "in"?

FACE Models insists it has a license to do its business in North Carolina. It is not just "Face National Models and Talent," it is "Face National Models and Talent, LLC." When the owner of Face wrote to the site she referred to the company as "Face National Models and Talent, LLC."

But does Face National have a license to do business in all the other cities and states besides Charlotte and North Carolina where it travels and does business?

The modeling industry is regulated by state. There is no federal law which applies to every state; each state can set its own licensing rules for modeling agencies. Not all states have rules, and not all states have the same rules, and not all of the states have the same rules as North Carolina. North Carolina has few rules, much fewer, in fact, than some of the states where it goes to do its business.

While there are no regulations on model and talent agencies in North Carolina, there are regulations in some states where FACE does business. In fact, some of the states FACE visits not only have regulations specific to modeling agencies, they indeed have the toughest talent and modeling agency regulations in America.

FACE claims to be in California, Texas, Illinois, New York, and Florida. These five states have the bulk of modeling jobs available, with Los Angeles, Dallas, Chicago, New York and Miami being primary markets.

While all of these states have strict regulations banning upfront fees in general, some of them also have strict regulations against upfront fees for photos in particular.

More importantly, these states require the talent/model agency to have a license to do business. Not just a business license, but a modeling or talent agency license.

FACE claims Gainesville, FL, as one of its cities where it is "in," along with Tallahassee, FL. The state of Florida requires modeling and talent agencies to have a modeling or talent agency license.

The licensing of talent agencies in Florida is administrated by the Department of Business and Professional Regulation (DBPR). The DBPR has an online database of every talent agency with a license to do business in Florida, so consumers can check to see if an agency has a license.

A search of this database revealed a company with a similar name to Face National Models and Talent (Starz National Models and Talent) has a license. Starz National is based in North Carolina, like Face. The state of Florida listed GASTONIA, North Carolina, as its "Main Address," while Florida gave it a "license location" of BOCA RATON, FL.

A licensee search for a Face, however, did not show it has any place of business or any business address in the state of Florida. Unlike Starz, the talent agency license for Face said, "Out of State," and did not list a business address in Florida, simply repeating its North Carolina business address:

  Main Address: 1230 WEST MOREHEAD STREET
CHARLOTTE, North Carolina 28208
  LicenseLocation: 1230 WEST MOREHEAD STREET
Out of State

If the State of Florida has no record of a physical business address for Face National in the State of Florida, how does Face claim to be "in" both cities in Florida?

And why did the State of Florida give Face a talent agency license if they are "out of state" and do not even have a place of business in Florida?

The Florida Statute, 468.412.10, says: "Each talent agency must maintain a permanent office and must maintain regular operating hours at that office."

How exactly are they going to get modeling jobs for models in Florida, especially when there are already modeling and talent agencies in Florida with staff in the state and with a physical address or place of business, and Face is off in North Carolina?

Talent agencies are regulated in the state of Texas by the Texas Department of Licensing and Regulation (TDLR). Talent agencies require a license. The online TDLR database does not provide an address for Face National in Texas. As in Florida, they are "Out of state."

If this information is accurate, why did the State of Texas give Face a talent agency license if they are "out of state," and do not even have a place of business in Texas? (If they do have a place of business in TX, why is it not listed in the state government database?)

On its website,, under a section entitled "FACE Cities," over 100 cities across America were listed:

  1. Albany, NY
  2. Albuququerque, NM
  3. Alexandria, LA
  4. Austin, TX
  5. Bakersfield, CA
  6. Baltimore, MD
  7. Baton Rouge, LA
  8. Binghamton, NY
  9. Birmingham, AL
  10. Bismarck, ND
  11. Boise, ID
  12. Boston, MA
  13. Buffalo, NY
  14. Burlington, VT
  15. Cedar Rapids, IA
  16. Charleston, SC
  17. Charleston, WV
  18. Charlotte, NC
  19. Charlottesville, VA
  20. Chattanooga, TN
  21. Cheyenne, WY
  22. Chicago, IL
  23. Cincinnati, OH
  24. Cleveland, OH
  25. Colorado Springs, CO
  26. Columbia, SC
  27. Columbus, OH
  28. Corpus Christi, TX
  29. Dallas, TX
  30. Davenport, IA
  31. Denver, CO
  32. Des Moines, IA
  33. Detroit, MI
  34. Dover, DE
  35. El Paso, TX
  36. Evansville, IN
  37. Fresno, CA
  38. Ft. Wayne, IN
  39. Gainesville, FL
  40. Grand Rapids, MI
  41. Great Falls, MT
  42. Green Bay, WI
  43. Greensboro, NC
  44. Greenville, SC
  45. Harrisburg, PA
  46. Hartford, CT
  47. Hattiesburg, MO
  48. Houston, TX
  49. Huntsville, AL
  50. Indianapolis, IN
  51. Jackson, MS
  52. Kansas City, MO
  53. Knoxville, TN
  54. Las Vegas, NV
  55. Lincoln, NE
  56. Little Rock, AR
  57. Lubbock, TX
  58. Madison, WI
  59. Manchester, NH
  60. Memphis, TN
  61. Milwaukee, WI
  62. Minneapolis, MN
  63. Mobile, AL
  64. Montgomery, AL
  65. Myrtle Beach, SC
  66. Nashville, TN
  67. New Haven, CT
  68. New Orleans, LA
  69. Oklahoma City, OK
  70. Palm Springs, CA
  71. Philadelphia, PA
  72. Phoenix, AZ
  73. Pittsburgh, PA
  74. Portland, ME
  75. Portland, OR
  76. Providence, RI
  77. Raleigh, NC
  78. Reno, NV
  79. Richmond, VA
  80. Roanoke, VA
  81. Rochester, NY
  82. Sacramento, CA
  83. Salt Lake City, UT
  84. San Antonio, TX
  85. San Bernardino, CA
  86. San Diego, CA
  87. San Jose, CA
  88. Santa Barbara, CA
  89. Santa Cruz, CA
  90. Santa Fe, NM
  91. Seattle, WA
  92. Shreveport, LA
  93. Sioux Falls, SD
  94. South Bend, IN
  95. Spokane, WA
  96. Springfield, IL
  97. Springfield, MA
  98. Springfield, MO
  99. Syracuse, NY
  100. Tallahassee, FL
  101. Toledo, OH
  102. Topeka, KS
  103. Tucson, AZ
  104. Virginia Beach, VA
  105. Washington, D.C.
  106. Wichita, KS
  107. Wilmington, NC

While 107 American cities were listed, they said they were in 96 cities: "Now in 96 cities, FACE plans to increase service to 100 cities by mid-2002." Presumably, they have not updated their website with the total number of cities. also said: "If FACE models does not operate yet in a specific market, we will still deliver. Within 45 days, we can conduct a model search in any city and provide at least 50-100 models to choose from."

In any case, if you run the math looking at the lower or conservative number, it leads to serious questions about the company.

Face National claims in 96 cities it has 50 models. They also say they can do a model search for a company in any city and find 50 models. One consumer who attended a Face recruiting event reported out of everyone there they recruited about 50 models.

Therefore, if each of the 50 recruits at the "model search" event pays $1,000 for photography and comp cards, the total amount of money taken by Face in one city alone is $50,000.

If all the recruits in each of the 96 cities across America paid Face $1,000 for photography and comp cards, the total amount of money taken from Americans by Face would be $4,800,000.

Significantly, if Face represents as many models as they claim, 50 models in 96 cities, Face National represents 4,800 models. This is a huge number! Indeed, if size is the standard —not the number of offices, but the number of models represented —this amount of models would probably make Face National the largest modeling and talent agency in the United States.

Wilhelmina, widely considered one of the top modeling agencies in America, claims it represents over 1,000 models. The website description for said: "Agent for over 1,000 models, with offices in New York, Los Angeles, and Miami."

Other top agencies like Ford and Elite which represent hundreds of models in top markets have offices in each of the states where they represent models, including New York, Miami, and Los Angeles.

According to the California Division of Labor Standards Enforcement talent agency license database, Ford, Elite, and Wilhelmina, for example, all have business addresses in California, and they all have California State talent agency licenses, too, TA 3582, TA 3410, and TA 3374, respectively.

A similar online search at the online talent agency license database of the State of California did not yield any results for Face National. And yet Face does its business in the state of California, listing on its website nine cities in California as "Face Cities": Bakersfield, Fresno, Palm Springs, Sacramento, San Bernardino, San Diego, San Jose, Santa Barbara, and Santa Cruz.

Does Face National not have a talent agency license in California? If Face does have a talent agency license in the state of California, why doesn't their website include the talent agency license number?

A website is a form of advertising. State talent agency law requires all advertisements to include the talent agency license number. There are California talent agencies which include their talent agency license number on their websites.

The state law says all advertising must contain the agency name, address, the words "talent agency," and license number.

Does FACE not include this information on its website because it does not have a talent agency license in the state of California and it does not even have an address in California?

If FACE represents 4,800 models, and their staff is 30, like the BBB record said, the ratio is 160 models per booker, and that is only if all their staff are bookers (not likely).

Recognizing not only the number of models represented by Face, but the model:booker ratio, the limited number of Face offices or staff across the country, and the competition between agencies, including those who have been established long before Face started, the question that begs being asked is the success rate of the agency in finding its models work.

Jennifer Gill, "managing member" of Face National, was asked the basic and specific questions in August 2002: "How many Face models have received work through Face? What is your success rate?" She did not answer either question.

But it gets even more interesting when you read Face National returns to each city. Every year. said: "FACE revisits each of its cities on the roster once a year." Why? "To update and augment the talent pool."

At this rate Face is doing a new "model search" to collect $50,000-$100,000 somewhere in America on average once every 3-4 days throughout the year! (365 days/107 cities = 3.4)

While both Ford and Elite do one model search every year —Ford, the Supermodel of the World; Elite, the Elite Look of the Year —Face National does a model search about once every 3 days.

How many more Americans pay them $1,000 each time they return? 50? 100? Just for photography and comp cards each year are they taking $5,000,000 - $10,000,000?

If they find/choose 4,800 models/people in one year, how many do they "represent" after two years? Double that? 9,600? Are there 30 employees looking after 10,000 models?

How many of these thousands of Americans actually get work in all these cities where Face has no presence, no office, no address, and no staff? How often do their staff visit the cities? Only when they are there to sign up people for photos?

How many of these people who paid $1,000 got work and earned more than they paid for the upfront fees of photos ($1,000)?

The type of work Face gets its models is "promotional." Promotional "modeling" is the least rewarding type of "modeling" financially; it is at the bottom.

The average rate of promotional work is about $15/hour. But it is not 9-5 for 5 days a week. It could be only two hours at one event. Total $30. Then take off 20% commission, and it is only $24.

How many Face models worked more than 80 hours? That is how long they would have to work at $15/hour to break even and earn $1,000, the total cost of photos and comp cards.

If Face gets 20% commission, and the jobs totalled 83.3 hours, the client(s) would pay $1,250, and Face would take $250, leaving the model with $1,000.

Face paints itself as a promotion company. They don't present themselves as a high fashion agency and they didn't provide proof on their site any of their so-called print models actually got any print work.

It is important to note one key point about promotional "modeling." It is very difficult if not impossible for an agency which only does promotions to be financially successful earning its income exclusively by commissions.

At the standard commission rate of 20%, it is like being paid 20% of $15/hour or $3/hour. That is of course far below the minimum wage.

Meanwhile, modeling agencies, for example, can make 20% on a single $10,000 modeling job, or $2,000.

For the promotions agency to make that same amount of money, one of their models would have to work 666.6 hours ($10,000/15/hour). That would be the equivalent of 16 weeks working 40 hours/week (666.6 hours/40 hours/week).

Consequently, promotions agencies which can never or rarely if ever rise above the lowest promotions level are faced with either sticking to the de facto ethical standard of commissions only, or looking to find alternate sources of income.

One potential supplemental source of income for a promotions agency which is not ethical is modeling photos. It is the easiest thing to set up and the easiest idea to sell to aspiring models; therefore, modeling photos are the first area to study in determining if an agency is making money from models.

Is it any surprise, then, that more than one promotion agency has broken the unwritten rule and earned an income from modeling photos, and one of them even admitted this to the media?

Anyone thinking of signing up with Face National in any city where they have no office, no address, no staff, and no proof they got models work in the previous year; and paying them $1,000 before they get work for photos, for a gamble on the possibility of irregular work at the lowest "modeling" wages, after seeing the conflict of interest, knowing how small their staff is, calculating the model:booker ratio, reading their BBB record, the critical statements of BBB leaders, the lack of a defense from Face, the absence of tear sheets on their website, the refusal of the Face owner to be questioned on TV, the news reports, the consumer complaints, and the New York State warning, and finally this report, is really pushing their luck.

BBB Record in Charlotte, North Carolina

BBB Leadership Statement

New York State Consumer Protection Board Issues Warning

FNMT Accused of Fraud by The Memphis Flyer

Models Beware by The Bakersfield Channel

Misleading Model by Fox 40 News

Investigation Reveals Some Modeling Agencies More Up Front Than Others by NBC 6 News

Beware of fly-by-night talent scouts