Critics of the FTC's Ad Substantiation Program Argue That

Critics of the FTC's ad substantiation program argue that:

A) ad substantiation has been proven unnecessary as long as the advertising industry is self-regulating.
B) ad substantiation is not needed because most advertisements make very legitimate claims.
C) ad substantiation will result in advertisers resorting to puffery to avoid the need for claim verification.
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.