The FTC Gets Specific on Influencer Material Connection Disclosures
A few weeks ago we blogged about the FTC’s warning letter writing campaign to brands and influencers about disclosure of material connections on Instagram. At that time, the FTC had only released sample letters – one for celebrities, athletes and other influencers and another for marketers.
This week, the FTC released copies of the 90 letters, which include screenshots of the Instagram posts that the FTC found troubling. In reviewing the letters and posts, we gleaned a few more tips for our loyal readers:
- As we noted in our first post, the FTC doesn’t think #partner is enough, but what about “#[YourBrandsName]_Partner”? The warning letters indicate that the FTC likely thinks that’s an effective disclosure. Note initial caps in the hashtag and the underscore between the brand name and the word partner.
- A lot of people have been asking if a more specific thank you would be enough even if #thankyou[Brand] is not a clear disclosure. Based on the letters, the FTC doesn’t think so. The letters pointed out that even a post that says Thanks @[brand] for these [products] “is probably inadequate to inform consumers of a material connection because it does not sufficiently explain the nature of your relationship to the company; consumers could understand a ‘thank you’ simply to mean that you are a satisfied customer.”
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