Federal Trade Commission Enforcement Action Against Multilevel Marketing Earnings Claims
Federal Trade Commission
The Federal Trade Commission has authorized a complaint and proposed stipulated final order against Stormy Wellington, a high-level participant in two multilevel marketing companies, Total Life Changes and Farmasi.
The enforcement action targets deceptive earnings claims used to recruit workers, with the matter filed in the U.S. District Court for the Southern District of Florida on April 13, 2026.
The proposed order strictly prohibits the defendant from misrepresenting the potential income or actual earnings of participants in various business ventures.
This restriction applies to express statements as well as implied representations, explicitly barring the use of lifestyle imagery, such as homes, vehicles, travel, or luxury purchases—to suggest likely earnings.
Furthermore, the defendant is forbidden from misrepresenting the reasons participants fail to earn substantial compensation or any other material facts concerning the business venture.
To make future earning claims, the defendant must ensure the representation is not misleading, substantiate the claim in writing at the time it is made, and provide this supporting evidence upon request to any prospective participant.
This enforcement addresses the documented discrepancy between promotional recruitment claims and actual participant earnings within the specified multilevel marketing structures.
While promotional materials promised six-figure incomes and the creation of new millionaires, corporate income disclosures revealed that 76.8% of active Total Life Changes participants earned zero compensation in 2023, and fewer than 1% of Farmasi participants reached the six-figure threshold.
Operationally, the order forces a structural shift in recruitment tactics, requiring the defendant to base all future financial promises on documented, provable data rather than aspirational marketing.
The mandate applies directly to the defendant's conduct regarding any future business ventures.
In addition to governing external recruitment advertising on platforms like YouTube and Facebook, the order requires the defendant to actively notify her existing downline network about the new prohibitions on deceptive and unsubstantiated earning claims.
The enforcement action is specific to this individual recruiter and does not outline distinct regulatory penalties for the corporate entities Total Life Changes or Farmasi themselves within this specific filing.
