Companies, such as gig economy firms and for-profit colleges, sometimes solicit consumers by promising a certain income or lifestyle. According to the Consumer Federation of America, “these promises frequently turn out to be false and unsubstantiated.” [1] In response to this problem, in May 2022, the Federal Trade Commission (FTC) issued an Advance Notice of Proposed Rulemaking (ANPRM) Regarding Deceptive or Unfair Marketing Using Earnings Claims.
