Please feel free to contact me anytime to share your thoughts: +1 612.357.1544 (cell), +1 952.567.6215 (direct), gerry.zack@corporatecompliance.org.
In January, the U.S. Federal Trade Commission (FTC) published two new guides on marketing issues associated with the use of customer reviews.[1] Put this risk area into the ever-growing bucket of things that compliance likely needs to consider.
The guides are just that—guidance. The law itself does not drill down to this level of detail when it comes to false or deceptive marketing and advertising (although it comes close with 2017’s Consumer Review Fairness Act).[2] But they go into a lot more detail than I would have thought, providing insight into what practices the FTC might take issue with and the controls it would want to see companies have. And for those readers working in an area outside the scope of the FTC, the guides might be useful in assessing what the company should or shouldn’t be doing in connection with protecting its reputation.
