The FTC settled allegations against Steven and Gina Merritt, high-level participants in the LifeWave MLM company, for making false and unsubstantiated earnings claims to recruit workers despite most LifeWave participants earning little to no money. The stipulated final order prohibits the Merritts from making deceptive earnings representations and requires them to notify their downline participants of the order's prohibitions. No monetary penalty was imposed.
The stipulated final order permanently prohibits the Merritts from making deceptive or unsubstantiated earnings claims related to any business venture, including misrepresenting potential participant earnings, actual earnings of themselves or others, reasons for low participant earnings, or any other material fact about a business opportunity. All earnings claims must be substantiated with written evidence at the time they are made, with such evidence provided to interested individuals upon request. The Merritts must also notify all their downline MLM participants of the FTC’s allegations and the order’s prohibitions on deceptive earnings claims.
In-house legal teams should review all agreements with multi-level marketing (MLM) partners, affiliate marketers, and business opportunity vendors to ensure strict prohibitions on unsubstantiated earnings claims. Key clauses to audit include marketing representation warranties, indemnification provisions for deceptive advertising, requirements to provide written substantiation of all earnings claims, and mandatory income disclosure statement attachments. Additionally, agreements with MLM participants should include clauses requiring prompt notification of regulatory enforcement actions and compliance with FTC marketing guidelines to mitigate liability for downstream deceptive conduct.
Entity
Steven and Gina Merritt
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/04/ftc-takes-action-against-high-level-mlm-participants-who-deceived-workers-about-amount-money-they
Merritt Complaint
https://www.ftc.gov/system/files/ftc_gov/pdf/Merritt-Complaint.pdf
Merritt StipulatedOrder
https://www.ftc.gov/system/files/ftc_gov/pdf/Merritt-StipulatedOrder.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"FTC Takes Action Against High-Level MLM Participants who Deceived Workers About the Amount of Money They Can Earn"
"April 27, 2026"
"Federal Trade Commission"
"order settling the FTC’s allegations"
"Steven and Gina Merritt, senior-level participants in a MLM called LifeWave"
"The FTC alleged in a complaint that Steven and Gina Merritt, senior-level participants in a MLM called LifeWave, deceived consumers about the amount of money they could earn from selling products and recruiting new participants for the company, which sells health and wellness products."
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.
The FTC rescinded its 2021 Policy Statement on Breaches by Health Apps and Other Connected Devices, which had purported to apply the Health Breach Notification Rule to health apps and connected devices that collect consumer health information. The rescission follows the Commission's 2024 update to the Health Breach Notification Rule, which already covers health apps and connected devices like fitness trackers, and implements an executive order directing agencies to eliminate obsolete guidance documents. No company was charged or penalized; this is a deregulatory action.