The 0.035 percent at the top of the slide, and the woman who believed she would get there

Marisol ate lunch in her car because the break room at the assisted living facility smelled like bleach and old coffee, and because in her car she could watch videos on her phone without anyone reading over her shoulder. She was forty-four. She had two kids, one in middle school, one starting community college in the fall. She drove a 2014 Kia with a cracked cup holder. The burrito was from the gas station and it was too hot in the middle and cold on the edges, the way they always are.

The video on her phone was a Facebook Live. A woman she did not know was standing in front of a white Bentley in what looked like a hotel driveway in Miami. The woman was talking about freedom. She used that word a lot. She said she had been where Marisol was. She said her sister had been where Marisol was. She said anyone, anyone, could do this.

The product was patches. Little adhesive circles you put on your skin. The company was LifeWave. Marisol did not really understand what the patches did and she did not need to. The woman on the screen was not selling patches. She was selling the woman on the screen.

This is a story about the people who stand in front of the Bentley. The Federal Trade Commission spent April 2026 going after three of them.

I.

On April 27, 2026, the FTC filed a complaint against Steven and Gina Merritt, senior-level participants in LifeWave. The complaint alleges they used inflated earnings claims to bring people in. The Merritts are not the company. They are the recruiters. The ones at the top of the slide.

LifeWave's own 2024 income disclosure statement, the document the company is required to publish, said something the Merritts' pitch did not say. It said 79 percent of active participants earned no commission payments in 2024. None. Not a small check. Zero.

It said 0.035 percent of participants earned more than $25,000 per week.

Read that slowly. Thirty-five thousandths of one percent. Three and a half people out of every ten thousand.

The Merritts, per the FTC order, are now prohibited from misrepresenting earnings. They have been ordered to notify the people in their downline, the recruits underneath them in the structure, about the FTC's allegations and what the order says they can no longer do.

Picture that letter arriving. Picture the recruit who got it on a Tuesday afternoon after a shift. The same person who put $400 on a credit card for a starter kit, who paid the monthly autoship to stay "active," who bought the ticket to the conference in Phoenix. The same person who is still sitting on a box of patches in their closet.

II.

Two weeks earlier, on April 13, 2026, the FTC announced action against Stormy Wellington. Wellington was a high-level participant in two MLMs, Total Life Changes and Farmasi. Her stage was YouTube and Instagram. The FTC alleged she told recruits they could earn "hundreds of thousands, or even millions, of dollars."

Total Life Changes' 2023 income disclosure said over 75 percent of active participants earned no compensation. At most 0.4 percent earned more than $5,000. Not per week. Total.

Farmasi's disclosure said fewer than 1 percent of active participants earned six-figure incomes.

Wellington is now permanently prohibited from misrepresenting earnings or helping anyone else do it.

The next day, April 14, the FTC announced that the operators of Forever Living, another MLM, would be permanently prohibited from deceptive earnings claims. The FTC alleged nearly 90 percent of Forever Business Owners received no income. The company had used images of luxury cars and large checks to promote the opportunity.

Luxury cars. Large checks. The same set dressing every time. If you have seen one of these videos you have seen all of them, because the set is the product.

III.

I worked in rooms like this. Not patches. Metals. Magazine subscriptions. PSA radio sponsorships. I sold a small-cap blimp stock once. The blimp company did not make blimps. It made stock certificates. I did not understand the distinction for a long time.

The thing about the MLM pitch is not the product. It is never the product. The product is just the thing the recruit has to carry around to feel like a business owner. The pitch is about the pitcher. You watch the woman in front of the Bentley and you do not buy a patch. You buy the idea that you can become her.

The recruiter knows this. The recruiter knows the patches do not sell themselves. What sells is the dream of standing where she is standing. So she does not pitch the product. She pitches the lifestyle. The lifestyle, in turn, requires recruits. Recruits, in turn, require the lifestyle pitch. The machine runs on itself.

The income disclosure statement, the one with the 79 percent line, is the only honest document in the building. The companies are required to publish it. They do. They put it where you have to look for it. The pitch gets the YouTube channel. The disclosure gets the PDF on page nine of the corporate site.

The pitch gets the Bentley. The disclosure gets the silence around the zero.

IV.

Marisol bought the starter kit. She put it on a Visa. She signed up for the monthly autoship, which is the minimum order you have to keep going to qualify for commissions. She went to a hotel ballroom event in Ontario, California, where a man with a headset microphone walked the audience through what he called "the system." She bought a ticket to a bigger event in Phoenix. She did not go in the end. The kids had something.

She tried to sell patches to her coworkers. Two of them bought one box each, out of kindness. She tried to recruit her sister. Her sister said yes because Marisol asked her to.

When the autoship order arrived in the third month, Marisol did not open the box. It sat on the kitchen counter next to the toaster. Her son moved it to the floor. It sat on the floor.

She did not log into the back office for a while. When she did, the commission number was a figure so small she thought it was a decimal error. It was not. It was the number.

She was inside the 79 percent. She had always been inside the 79 percent. The 0.035 percent was a different category of person and the math had never been about her.

V.

The FTC's pattern in April 2026 was deliberate. Three actions in two weeks. All targeting high-level participants, not just companies. Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, has said the agency is committed to pursuing individuals who deceive consumers about earnings.

That is the shift. For years, the enforcement target was the company. The recruiter was a contractor, a "business owner," officially independent, deniable. The agency is now reading that deniability as a feature of the scheme and naming the person on the screen.

The September 2024 FTC staff report on 70 MLM income disclosure statements found common problems: omitting low or no earners, failing to account for participant expenses. In January 2025 the agency announced proposed rulemakings that could allow enhanced penalties for deceptive earnings claims. April 2026 is what enforcement looks like when the rule writing is still in motion and the agency wants to put markers down anyway.

VI.

Marisol stopped opening the app. She stopped going to the team Zooms. The woman who had recruited her started leaving voice memos. Hey girl. Just checking in. We miss you.

Marisol stopped opening those too.

The hardest call was not the one she did not answer. It was the one she did not make. Her sister had bought a starter kit because Marisol had asked her to. Her sister had bought the autoship. Her sister was sitting on her own unopened box, in her own kitchen, in Fontana.

Marisol had become, for one quarter, the woman in front of the Bentley. To one person. Her sister.

That part may be the saddest.

VII.

The Merritts' downline will get a letter. The FTC ordered it. The letter will say that the people they trusted have been ordered to stop saying what they said. The letter will not return the autoship money. The letter will not unship the boxes. The letter will not unrecruit anyone's sister.

The companies will keep operating. LifeWave still sells patches. Total Life Changes still sells whatever Total Life Changes sells. Farmasi still sells cosmetics. Forever Living still sells aloe. The orders constrain the named individuals. The structure underneath is the structure.

Somewhere this week another woman is parked in another lot eating another lunch and watching another video. The car behind the recruiter is white. The check on the slide is large. The patch, or the lotion, or the powder, is incidental.

The 0.035 percent is real. Three and a half people out of every ten thousand earned the number the recruiter promised. The recruiter is one of them. The recruit, almost always, is not.

She thought she was buying a business. She was the customer.