Critics of the Federal Trade Commission's (FTC's) Ad Substantiation Program

Critics of the Federal Trade Commission's (FTC's) ad substantiation program argue that:

A) ad substantiation has been proven unnecessary as long as the advertising industry is self-regulated.
B) ad substantiation is not needed because most advertisements make legitimate claims.
C) ad substantiation is too expensive to document.
D) the burden of proof for advertising claims lies with the consumer.
E) the burden of proof for advertising claims lies with the Federal Trade Commission.