“A Buttload of Money”: The Income Claims Behind a Wellness-Patch MLM Come Under Scrutiny

In a recruiting video posted to YouTube in May 2025, Gina Merritt told a room of prospective sellers they were about to make “a buttload of money,” and that she could not wait to help them reach a rank paying “$25,000 or more a week.” Her husband, Steven, told the same audience the money would keep arriving “even if you don't show up,” comparing it to a spigot throwing hundred-dollar bills. According to a federal complaint, those were not isolated flourishes but a pattern DOCUMENTED across the couple's recruiting pitches for a multilevel marketing company called LifeWave.

The Merritts are not obscure names inside the MLM's ecosystem. Complaint records describe them as senior-level participants who market themselves under the branding “This is It” and who claim roughly 250,000 people in their downline of LifeWave Brand Partners. LifeWave itself, a company that sells adhesive wellness patches marketed for pain relief and other health benefits, was not named as a defendant. Only the Merritts, as individual promoters, face the federal order.

What the complaint alleges

According to the FTC's complaint, the Merritts repeatedly told prospective and current Brand Partners that they would, or were likely to, earn substantial income from selling LifeWave's patches and recruiting new participants.DOCUMENTED The complaint cites specific recruiting-meeting language, including claims that “multiple, multiple, multiple, multiple people” on the Merritts' team earned more than $25,000 a week. Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, said in the agency's announcement that the Merritts “used inflated earnings claims to entice potential participants to join LifeWave when in reality most people did not earn any money.”DOCUMENTED

The complaint contrasts those claims against LifeWave's own published income disclosure statement for 2024, a document distributors are required to have access to. That statement shows that of registered and active Brand Partners, only about 21 percent received any commission payment at all during the year for sales made in 2024.DOCUMENTED Put differently, close to four out of five active participants earned nothing. The average annual payout across all active Brand Partners was $651 before expenses — a figure that includes the small number of top earners who pulled the average upward.DOCUMENTED

How the pitch was built

MLM enforcement lawyers who track these cases note that the Merritts' case follows a recognizable structure: senior-level distributors, rather than the company itself, becoming the face of aggressive recruiting language, while the parent company's own compliance materials contain disclaimers that are technically accurate but rarely seen by the people being recruited in a live meeting.REVIEWED The FTC's complaint notes that while the Merritts occasionally included earnings disclaimers in their promotional materials, the agency alleged those disclaimers were often presented in smaller, less prominent print than the income claims themselves — undermining their value as a corrective.REVIEWED

The product at the center of the recruiting pitch is LifeWave's line of adhesive patches, marketed as delivering various health and wellness benefits without ingesting any substance. Independent reviews of the product line have found no verified clinical evidence supporting the claimed benefits, though those product-efficacy claims are separate from, and not the direct subject of, the FTC's income-claims complaint against the Merritts.REVIEWED

What the settlement requires

Under the proposed order settling the FTC's allegations, the Merritts are permanently restrained and enjoined from making deceptive or misleading income claims in connection with LifeWave or any similar opportunity.DOCUMENTED Future income claims are permitted only if they are truthful, supported by competent evidence, and provided to prospective participants upon request — a formulation the agency has used in other MLM cases to avoid banning legitimate compensation disclosures outright while blocking baseless promises.

The order's most distinctive term is not financial. It requires the Merritts to notify people already in their downline about the FTC's action and about the restrictions the order imposes on future earnings claims.DOCUMENTED For distributors whose recruiting reputation depends on projecting success, having to tell one's own recruits that regulators found the underlying income claims deceptive carries a reputational cost that a fine alone would not.

Of active LifeWave Brand Partners in 2024, fewer than four in every hundred earned $25,000 in a year — let alone in a week.

Why this case matters beyond LifeWave

The FTC brought the Merritt case as one of several MLM-focused actions the agency pursued in the same month, part of a broader enforcement push under Bureau of Consumer Protection Director Christopher Mufarrige targeting income claims made by individual senior distributors rather than only the parent corporations that license their compensation plans.REVIEWED Because MLM compensation structures reward existing distributors for recruiting new ones, senior participants have a direct financial incentive to inflate what a new recruit can expect to earn — an incentive the FTC's order attempts to blunt by making individual recruiters, not just companies, legally accountable for what they say in a recruiting meeting.

For consumers evaluating a similar opportunity, the case is a reminder that a company's own required income disclosure statement, when one exists, is frequently a more reliable predictor of likely earnings than anything said from a stage or in a private message. In this case, that document was public before the recruiting claims were made — and it told a story the recruiting language did not.

What the case does not decide

It is worth being precise about what the FTC's action against the Merritts does and does not establish. The order does not find that LifeWave the company violated federal law, since LifeWave itself was not named as a defendant and the settlement binds only the Merritts as individual promoters.REVIEWED Nor does the order make any finding about whether LifeWave's patches provide the health benefits the company markets them for — that question is separate from, and outside the scope of, an income-claims case focused narrowly on what recruiters told prospective distributors about likely earnings.REVIEWED

What the order does establish, going forward, is a concrete and enforceable ceiling on what the Merritts specifically can say to a recruit about expected income. Any future earnings claim they make must be truthful, supported by evidence, and available to a prospective participant on request — a standard that, if followed, would have prevented the recruiting-meeting language cited in the FTC's complaint from ever being spoken in the first place. For an industry built substantially on live recruiting pitches, translating a paper compliance standard into what is actually said in the room remains the harder, ongoing enforcement challenge the case leaves unresolved.

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