The FTC Tells Coaching Buyers to Demand One Specific Page. Could You Produce Yours?
Federal consumer guidance tells buyers to ask for a one-page disclosure and an earnings claim statement before paying. Most sellers have never made one.

The Federal Trade Commission has advice for anyone about to pay for a coaching program. It is worth reading from the other side of the checkout page.
Step one: ask the seller for a copy of the legally required one-page disclosure document.
Step two is the part that should tighten a few throats. The document has to say whether the seller is making a claim about how much money you can make — and if they are, they must also give you an earnings claim statement.
Then the tell the agency hands buyers: if the seller says anything that contradicts what's in their disclosure document or earnings claim statement, that's a sign of a shady operation that you should steer clear of.
What's on the page
Five items. Identify the seller. Disclose certain lawsuits or legal actions involving the seller or its key personnel. State whether there's a cancellation or refund policy and what the terms are. Say whether an earnings claim is being made — if so, a separate earnings claim statement follows. And provide a list of references.
Timing matters more than content. The seller has to hand it over at least seven days before you sign a contract or pay anything.
Seven days. Not seven minutes after the webinar close.
And on earnings claims, the rule text is blunt. A seller may not make an earnings claim unless it has a reasonable basis at the time, has written materials substantiating the claim in its possession at the time, makes that substantiation available on request to the buyer and to the Commission, and furnishes an earnings claim statement.
Read that again with your sales page open. The screenshot of the $41,000 month counts as a claim.
Does it apply to you?
Honest answer: maybe not yet, and that's a lawyer's question, not a blog post's. The Business Opportunity Rule covers business opportunities as defined.
But in January 2025 the agency moved to widen it. The proposal would expand the Business Opportunity Rule to cover money-making opportunities, such as business coaching and investment opportunities, which claim to assist consumers in building a business or otherwise earning income. The rule would be renamed the "Business and Money-Making Opportunity Rule."
One alternative floated in the notice is the broad one: replacing "business coaching opportunity" with "coaching opportunity," defined as any program, plan, or product that is represented to train or teach a person how to make or increase earnings.
That is a net wide enough to catch most of this industry. It also drew a dissent — Commissioner Andrew N. Ferguson dissented, joined by Commissioner Melissa Holyoak — and Ferguson now leads the agency, which makes the rulemaking's future genuinely uncertain.
Enforcement isn't uncertain.
The penalty isn't a fine. It's a ban.
In 2017, seven individuals and eight companies agreed to settle FTC charges over a coaching operation and accepted a ban on selling business coaching services and work-at-home opportunities. One order carried a $27 million judgment partially suspended on payment of $1.6 million; another, $29 million suspended on payment of $200,000.
A 2018 settlement over a scheme operating as Coaching Department and Apply Knowledge imposed a $19,214,950.40 judgment and barred five marketers and their companies from selling business coaching programs and investment opportunities.
In the Digital Altitude case, the FTC charged that consumers were told they could earn "six figures" within 90 days. Some individuals lost more than $50,000.
The recurring charge in these complaints is not bad teaching. It's falsely promising clients were likely to earn substantial income.
The 2026 version of the warning
The agency's current buyer-facing alert is aimed squarely at the modern funnel. If a program promises guaranteed income, large returns for little work, or says it has a "proven system to make money," the FTC says it's likely a scam. It also warns that glowing success stories could be fake or misleading, and that positive reviews may come from made-up profiles.
That language describes copy currently live on thousands of legitimate sales pages.
So here's the exercise. Open a competitor's checkout, or your own. Count the income numbers. Then ask whether the substantiation file exists, and whether anyone could produce it in a week.
Sources
- Vetting a business or coaching opportunity before you buy in — Federal Trade Commission
- How to spot and avoid business coaching scams — Federal Trade Commission
- Bogus business opportunities — Federal Trade Commission
- 16 CFR Part 437 — Business Opportunity Rule — eCFR
- FTC Proposes Rule Changes and New Rule to Deter Deceptive Earnings Claims by Multilevel Marketers and Money-Making Opportunity Sellers — Federal Trade Commission
- 16 CFR 437; Business Opportunity Rule; Notice of Proposed Rulemaking — Federal Trade Commission
- Defendants Involved in Selling Business Coaching Programs Settle FTC Charges — Federal Trade Commission
- Defendants Who Took Part in Business Coaching Scheme Settle FTC Charges — Federal Trade Commission
- Defendant Who Took Part in Business Coaching Scheme Agrees to Settle FTC Charges — Federal Trade Commission
- FTC Puts Pedal to the Metal to Release Proposed Rule on MLM Earnings Claims, Changes to Business Opportunity Rule — Kelley Drye Ad Law Access
- MLM Regulations USA 2026: FTC Rules & Compliance — FlawlessMLM
Editor’s note: Ran it because the gap between what sales pages claim and what sellers could document is the industry's quietest liability — and the FTC publishes the checklist for free.
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