The Federal Trade Commission is taking action against a high-level participant in a multilevel marketing (MLM) company over allegations she used false or baseless earning claims to recruit workers, most of whom did not earn any money from the venture.
The FTC alleged in a complaint that Stormy Wellington, who has been a high-level participant in two different MLMs, used deceptive earnings claims to recruit new members to Total Life Changes (TLC) and, more recently, Farmasi.
“Today’s actions make clear that the FTC will go after individuals who deceive consumers trying to earn a living,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “This case highlights the FTC’s ongoing efforts to protect workers from recruiters who misrepresent potential earnings.”
In MLMs, individual participants market and sell the MLM’s products or services and recruit new participants, who themselves will sell the MLM’s products or services and recruit new participants. Wellington was a high-level participant who benefitted from recruiting new members using allegedly false or misleading promises of earning significant income.
In YouTube videos and social media posts, Wellington tried to entice new participants by claiming they could make hundreds of thousands and even millions of dollars, according to the FTC’s complaint. For example, Wellington posted a video on her Facebook page promoting TLC that included a caption stating, “I will help 1000 families make 5-7 figures in the next 90 days to 12 months!”
Wellington spent a decade at TLC, which sells nutrition, wellness, and skincare products, before leaving in August 2025 to join Farmasi, which sells make-up, skincare, and health and wellness products. She allegedly promised new recruits to Farmasi that they can earn big money, saying, “I’m telling you right now, no less than six figures, no less. Repeat that to me. No less than six figures,” and that she will make “60 new millionaires in 2026.”
Despite these claims, in both MLMs most participants made little or no money. In TLC’s income disclosures posted to its website, TLC states that 76.8% of active participants (23,124 people) did not earn any compensation in calendar year 2023, and that, at most, 0.4% of all active participants (113 people) earned more than $5,000. Similarly, Farmasi’s income disclosure statement posted to its website shows that, in 2023, fewer than 1% of active participants earned income in the six-figure range the FTC alleges Wellington promised.
In a proposed order settling the FTC’s allegations, Wellington will be prohibited from misrepresenting or assisting others in misrepresenting how much money others can earn from various business ventures. This includes prohibiting Wellington from misrepresenting:
- Expressly or by implication, including through images of homes, vehicles, purchases, or travel, earnings that participants will or are likely to make;
- The amount of earnings that she or other participants have actually earned;
- The reason participants do not earn substantial compensation; and
- Any other fact material to consumers concerning the business venture.
In addition, Wellington will be prohibited from making any representation, expressly or by implication, regarding the amount of earnings that a participant can expect to earn unless: it is not misleading, she can substantiate in writing the earnings claim when it is made, and she can provide evidence upon request to any individual who expresses an interest in becoming a participant. Wellington also will be required to notify her downline participants about the order’s prohibition on making deceptive and unsubstantiated earning claims.
The Commission vote to authorize the staff to file the complaint and stipulated final order was 2-0. The matter was filed in the U.S. District Court for the Southern District of Florida.
NOTE: The Commission files a complaint when it has “reason to believe” that the named defendants are violating or are about to violate the law and it appears to the Commission that a proceeding is in the public interest. Stipulated final orders have the force of law when approved and signed by the District Court judge.
The lead staff on this matter include Claire Wack and Melissa Dickey in the FTC’s Bureau of Consumer Protection.