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 referred a complaint against REPS & Company Inc. and company executives, alleging they bypassed ticket-issuer security controls and purchasing limits to acquire millions of tickets for resale. The complaint was filed by the Department of Justice, and the case will be decided by the court; the press release does not report a penalty or other remedy imposed.
The FTC sued Digital Forensics Corporation LLC and affiliated defendants, alleging they misled sextortion victims with promises of investigative and monitoring services that often were not provided, and used fake positive reviews. A federal court granted the FTC’s request to temporarily halt the defendants’ activities; the complaint remains for the court to decide.
The FTC alleged that Greenway Auto Group advertised vehicle prices thousands of dollars below the amounts consumers actually paid and used mailers falsely suggesting recipients had won cash prizes. Greenway agreed to an order requiring transparent pricing and prohibiting deceptive prize mailers and other misrepresentations; the press release does not state a monetary penalty.
The FTC sent warning letters to 24 large healthcare services companies, cautioning that incomplete, inaccurate, or untimely pricing information for scheduled medical care may be unfair or deceptive. The letters urge recipients to review their price-disclosure practices and take corrective action; they announce no fine or formal order.
$1.9M
The FTC alleged that Premier Franchising Group LLC and Franchise Fastlane LLC made deceptive and unsubstantiated claims about the Premier Martial Arts franchise opportunity and violated the Franchise Rule. The proposed settlements require the companies to pay a combined $1.85 million to compensate franchisees, prohibit certain misrepresentations, and require Franchise Rule compliance; certain franchisees may also cancel their agreements without penalty.
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.