Why “Value Stacks” on Coaching Sales Pages Can Be Illegal
One of the most common sales page structures in the coaching industry is the “value stack”:
- List the program components
- Assign a high “value” to each one
- Create a convincing “total value”
- Then offer the “real” price
Conceptually, anchoring value is a legitimate sales practice.
Legally, however, most coaches execute this in a way that the Federal Trade Commission (FTC) now considers misleading — and outright illegal.
In fact, two major developments have made this a high-risk area for coaches:
- Coaches are being taught to artificially inflate value or “make up numbers.”
- Software tools like AI funnel builders are auto-generating fake values and fictional bonuses.
This post breaks down what’s legal, what isn’t, and how to talk about value in a way that is both compliant and persuasive.
Why Fake Program Values Are Now Under FTC Scrutiny
Between 2023 and 2024, the FTC actively cracked down on misleading pricing across online coaching, digital products, health programs, and business offers.
Their concern is simple:
Coaching buyers are often emotionally vulnerable — especially in the areas of health, weight loss, and business earnings.
When a buyer sees:
- a huge “deal,”
- a massive supposed discount,
- or a list of bonuses worth 10X the purchase price,
they may believe they’re getting a once-in-a-lifetime opportunity and ignore the fact that the program may not be a fit for them.
This combination — high hopes + artificially inflated value — is what makes these tactics misleading under consumer protection law.
Illegal Value Stacks: What Coaches Are Commonly Taught
Two major issues are widespread:
1. AI tools auto-generating fake values
Some funnel builders now create:
- made-up “value” numbers
- inflated prices
- fake bonuses
- false scarcity
These have no basis in fact and no connection to your real offer.
Using them is illegal.
2. Coaches being told to multiply value artificially
Some high-level industry leaders instruct coaches to:
- assign arbitrary values to Facebook groups, worksheets, or calls
- inflate numbers to make the total value appear 10X the purchase price
- attach dollar amounts to things they’ve never sold individually
This also violates FTC guidelines because it misrepresents what is being sold.
If you’ve ever been told to do this, you’re not alone — but you do need to stop.
The Legal Standard: Truthful, Accurate, and Not Misleading
The FTC’s longstanding rule:
Your marketing must be truthful, accurate, and not misleading.
Here’s what this means for value stacks:
- You cannot assign a dollar value to something you’ve never sold at that price.
- You cannot claim a “discount” unless the original price was genuinely offered.
- You cannot imply that a bonus is worth $1,500 unless real buyers have paid $1,500 for it.
- You cannot list inflated or fictional value to psychologically push buyers over the line.
Even if “everyone else is doing it,” the law does not care — misleading value claims are illegal.
How to Handle Bonuses Legally (Without Numbers)
Just because you can’t make up prices doesn’t mean you can’t talk about value.
In fact, bonuses can be incredibly powerful — if they are strategic, relevant, and truthful.
Here’s how to do it legally:
Use bonuses to fill gaps that help clients get results
For example, if you teach sales call conversion:
- Bonus #1 could help clients get more discovery calls booked.
- Bonus #2 could help them maximize leads who say “no.”
These bonuses support the result your program promises — without needing an arbitrary dollar value.
Describe value without assigning a price
Instead of “$1,500 value,” say:
“This bonus helps you overcome the #1 obstacle that stops coaches from getting results in this program.”
Or:
“Designed to help you implement faster and with more confidence.”
This communicates real value — not fake pricing.
If you have sold an item separately, you may use the real price
Instead of “valued at $497,” you can legally say:
“Previously sold for $497.”
This is far more compelling — and absolutely compliant, because it is factual.
Legal vs. Illegal Value Stacks (Quick Test)
Ask yourself these questions before publishing a value stack:
- Have I ever sold this component on its own at the price listed?
- Is this discount real, or am I inflating the original price?
- Would a reasonable consumer interpret this as misleading?
- Am I padding value to overcome objections instead of explaining actual benefits?
- Would someone buy differently if the “true” information was disclosed?
If the answer to any of these is uncomfortable, rewrite the value section.
Why Fake Values Hurt Your Brand (Not Just Your Compliance)
Beyond the legal exposure, inflated value stacks also:
- Lower trust with prospects
- Attract the wrong-fit buyers
- Create resentment when clients realize the “bonus” is a PDF
- Increase refund and chargeback risk
- Damage your reputation with more sophisticated consumers
Transparent value attracts aligned clients and leads to better results.
What To Do Next: Clean Up Your Sales Page
Review:
- every “value” attached to a bonus
- every “total value” line
- every “normally priced at…” claim
- every “limited time” discount
- every number that implies false scarcity or inflated pricing
Then remove anything:
- fictional
- exaggerated
- based on a template
- AI-generated
- or unverified
You’ll sell better — and more legally.
Coming Up Next: The Legal Rules for Testimonials
Value stacks are just one area where the FTC is cracking down.
Another major risk area is testimonials and social proof — especially when they involve earnings, health results, before-and-after claims, or hand-picked success stories.
Your next video in this series will walk through the sneaky illegal mistakes coaches commonly make with testimonials.
If you want to keep your sales pages compliant (and persuasive), be sure to watch that one next.
Want Help Getting the Legal Foundations Right?
Before selling any coaching program, you also need:
- a privacy policy
- terms & conditions
- a legal disclaimer
- a compliant client agreement
- correct refund + billing terms
If you want step-by-step help implementing these—fast—get your free legal course, Legal in a Weekend, linked below the video.
