CFA and the National Consumers League submitted the following comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) published by the Federal Trade Commission (FTC). Both groups strongly support a trade regulation rule by the FTC that prohibits false, misleading, and unsubstantiated earnings claims. The comment letter states that the rule should be crafted to explicitly cover companies that continue to escape Commission regulations, like MLMs, gig economy companies and for-profit schools, and require covered entities to provide a minimum of two years of substantiated data before making positive earnings claims.