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 filed a complaint against Credit Glory LLC and related entities for deceptive credit repair practices, including false promises, impersonating debt collectors, charging illegal upfront fees, and using negative option billing without consent. A federal court temporarily halted the operation.
The FTC issued a policy statement abandoning disparate-impact liability, stating it will no longer bring claims based on this theory. It also modified compliance obligations for several companies based on past decisions.
The FTC, along with Utah and California, filed a complaint against Hims & Hers alleging the telehealth provider shared consumers' sensitive health information with third-party advertising platforms without consent, and deceived consumers about billing and cancellation practices. The complaint alleges violations of the FTC Act and the Restore Online Shoppers' Confidence Act.
$300K
The FTC alleged that Elite Events and Tickets LLC, doing business as Smart Scalpers, violated the Better Online Ticket Sales Act by circumventing security measures to bypass ticket purchase limits for over 2,400 events, reselling tickets at a profit. The proposed order requires payment of $300,000 (with a total penalty of $10.7 million partially suspended) and permanently prohibits the company and its owners from engaging in such circumvention tactics.
$45.9M
The FTC permanently banned Dennise Merdjanian from the debt relief industry and telemarketing after she and Superior Servicing LLC allegedly ran a student loan forgiveness scam that took more than $45.9 million from consumers. The proposed stipulated order imposes a partially suspended monetary judgment and resolves the FTC's litigation against the remaining defendants.
$16.5M
The FTC charged the founders of Celsius Network with deceiving consumers by falsely promising that cryptocurrency deposits were safe and always available. The founders agreed to pay $16.5 million and are banned from marketing or selling products that can be used to deposit or withdraw assets, among other restrictions.