> To maintain the integrity of the authentication factors, it is essential that it not be possible to leverage an authentication involving one factor to obtain an authenticator of a different factor. For example, a memorized secret must not be usable to obtain a new list of look-up secrets.
And further:
> Methods that do not prove possession of a specific device, such as voice-over-IP (VOIP) or email, SHALL NOT be used for out-of-band authentication.
(Which is good for some of them, as they're notoriously flaky).
Again, 2FA isn't an account recovery process at all; it's a reason you need account recovery.
To get a general sense of where we're at as an industry with this, look at the process for what happens when you lose an AWS 2FA secret:
https://docs.aws.amazon.com/IAM/latest/UserGuide/id_credenti...
Your reading of the FTC text seems to be that you think the FTC has conflated account recovery with 2FA, but I don't think that's the case. Instead, my read is that they're suggesting that password breaches can be rendered moot points by requiring 2FA for accounts, so that the compromise of a password would not require an account reset in the first place.
But technical language aside: a requirement that CafePress fully adopt 2FA also doesn't make sense, because its users will not fully adopt 2FA. The users that can't 2FA are the interesting case here, and the thing I'm calling out.