Annotation of FTC Guide: How to Make Effective Disclosures in Digital Advertising | Christian Nossokoff | April 20, 2016


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Annotation of FTC Guide: How to Make Effective Disclosures in Digital Advertising

Annotation of How to Make Effective Disclosures in Digital Advertising

By Arielle Weg


-The FTC rules that laws restricting other media also apply online. The FTC laws on endorsement are additions to these general laws for all media outlets. These additions encourage clear, transparent endorsements to protect the audience from reading claims that are paid advertisements.


-This article depicts specifically how to disclose information about payment or relationships to a company. The article includes these as guidelines; use clear language, disclose physically close to the clame on the page, consider the platform of the advertisement to ensure the disclosure is clear, include the disclosure in the ad or at least on the page you are writing the endorsement on, follow specific guidelines for linking to a disclosure, avoid scrolling to get to a disclosure, know research about where consumers will look on a screen, make sure disclosure are before the option to purchase, repeat disclosures as needed depending on website format, keep disclosures separate from lengthy sections such as terms of use, keep disclosures noticeable, and keep disclosures to the format presented (audio disclosure in an audio advertisement).


-The article begins with an explanation of how  these regulations came to be, and how they were processed and fixed over time to be completed in this one comprehensive document.


-The endorsements must follow the three general laws of advertisement; advertising must be truthful and not misleading, advertisers must have evidence to back up their claims, and advertisements cannot be unfair.


-It is the advertiser’s responsibility to ensure that the endorsement from the blogger is truthful and accurate and that the relationship is properly disclosed by FTC guidelines of disclosure.


-The purpose of a disclosure is to make endorsement fair and non-deceptive to the audience. This being said, there are additional guidelines that indicate the disclosure is for the reader, therefore the disclosure must be placed and presented in a way that is as clear as possible for the reader to see, comprehend, and consider when reading the endorsement. The document presents ways to consider if a disclosure is clear to a reader, but understands that every advertisement is different. There is no clear cut law on what qualifies as a “clear and conspicuous” advertisement, but a blogger is required to follow the rules closely as they can.


-The document includes mock advertisements as examples for the advertiser and blogger to consider. These sections repeat details of how to properly disclose information regarding payment or relationships for product endorsement by making a clear disclosure and place in an eye-catching location prior to product purchase. Concepts to consider with including a disclosure is proximity and placement, prominence, avoiding distracting factors to draw the eye away from the disclosure, repeating when necessary, multimedia messages and campaigns and the use of understandable language. Each of these sections include linked examples to avoid any misunderstanding of how a disclosure should be placed on an ad or on a blog page.



FEDERAL TRADE COMMISSION. How to Make Effective Disclosures in Digital Advertising. Federal Trade Commission, Mar. 2013. Web. 04 Apr. 2016.


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April 20, 2016

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Christian Nossokoff

Student at American University

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