Do you reward consumers for liking you on FaceBook?

funny  businesswoman dreaming on white background
 
If you answer ‘yes’ to that question, if may be considered a paid endorsement that should be disclosed on your Face Book page.  The Federal Trade Commission [FTC] has recently updated its Endorsement Guide FAQ.  The FAQ were updated to reflect questions received by the FTC and to cover the ‘trending and topical.”  The updated FAQ do not reflect changes in the rules, but rather interpretive guidance regarding application of the existing rules to social media and advertising trends.
 
Topics touched on in FAQs include:

  • Blogging product reviews
  • YouTube view reviews
  • Informational Employee FaceBook page
  • Celebrity tweet endorsements
  • Television product placements

 
 
Here are several FAQ for the FTC guides about to make endorsement disclosure:
 
If I upload a video to YouTube and that video requires a disclosure, can I just put the disclosure in the description that I upload together with the video?
No, because it’s easy for consumers to miss disclosures in the video description. Many people might watch the video without even seeing the description page, and those who do might not read the disclosure. The disclosure has the most chance of being effective if it is made clearly and prominently in the video itself. That’s not to say that you couldn’t have disclosures in both the video and the description.
 
Would a button that says DISCLOSURE, LEGAL, or something like that which links to a full disclosure be sufficient?
No. A hyperlink like that isn’t likely to be sufficient. It does not convey the importance, nature, and relevance of the information to which it leads and it is likely that many consumers will not click on it and therefore miss necessary disclosures. The disclosures we are talking about are brief and there is no reason to hide them behind a hyperlink.
 
What about a platform like Twitter? How can I make a disclosure when my message is limited to 140 characters?
The FTC isn’t mandating the specific wording of disclosures. However, the same general principle – that people get the information they need to evaluate sponsored statements – applies across the board, regardless of the advertising medium. The words “Sponsored” and “Promotion” use only 9 characters. “Paid ad” only uses 7 characters. Starting a tweet with “Ad:” or “#ad” – which takes only 3 characters – would likely be effective.
 
To see all the FTC guides FAQ visit the FTC website at:  https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking
 

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