I hope I didn't sound like I was suggesting people wait. My hope was to explain that filing a lawsuit may not accomplish much, but seeking help from the FTC and state attorneys general might be a bit more productive. For example, although the regulators might not be able to get any money back, they can ask for orders that prohibit the individuals involved in BFL from ever being owners of similar businesses in the future (depending on the laws in your particular jurisdiction).

As for timing, I would think you should file any complaints with regulatory agencies sooner rather than later.

No legal approach here is going to be entirely satisfying, but I think if you're going to act you should focus energy in ways that may accomplish more in the end.

I should also state here that I'm not representing anyone, not providing legal advice, and you should be aware that there are laws that can limit your rights to file a lawsuit if not filed within a certain time. Filing complaints with FTC or attorneys general will not extend the deadlines the law imposes. (I hate sounding like a lawyer, but my malpractice carrier would crap if I didn't say that stuff.)