My assessment is more that the average consumer won't have any idea that the FTC is going this, so I am not real worried about the downsides.

Not initially, but in time they tend to hear about it. Some shops are bound to brag that their reviews are FTC compliant and unbiased, etc.

So, don’t do anything at all because there will always be an issue with anything you do? Being negative is a weakness.

How about; do things that you can enforce and expect a positive net impact from, do things in a way that will address the dozens of obvious first impression questions that came up here due to lack of specifics. If you’re going to do it, put some thought into its execution and administration.

And most of all, don’t make global generalizations on commentary that is quite specific and on a very particular topic.

They have though. This has been a 2 year process.

https://www.ftc.gov/news-events/news/press-releases/2022/10/...

https://www.ftc.gov/news-events/news/press-releases/2023/06/...

They probably came to different conclusions as you. And I'm sure they have reasons why they left some of that stuff on the original list out. Because they spent 2 years looking at this rather than going with their "obvious first impression questions".

You'll also note from those links that they have already been pursuing some companies over this stuff. So they're probably aware of what they're up against.