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In page Renewable Energy Certificate (United States):

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Though both sources are properly credited financially, double-counting permits states to report emissions as being up to 50% lower than they actually are, making claims of progress in meeting climate goals dubious.[citation needed] For renewables producers, selling the certificates may be in violation of federal law. Severin Borenstein, director of the Energy Institute at UC Berkeley's Haas School of Business, writes, "If the certificates are stripped off...separately from the electricity, the FTC [Federal Trade Commission] says...it is deceptive for the TPO [third party owner] to advertise or tell solar buyers they are getting 'clean', 'renewable', or maybe even 'solar' electricity with their lease or power purchase agreement."[1]