News & Analysis as of

FTC Endorsement Guidelines

Arnall Golden Gregory LLP

A ‘Psy Op’ in Indie Rock: Do ‘Fake Fan’ Campaigns Violate Advertising Law?

Key Takeaways - Undisclosed “fake fan” campaigns present clear FTC risk under Section 5 and the Endorsement Guides, particularly where material connections between marketers and content creators are hidden....more

Kilpatrick

Better Business Bureau Supports Brands & Influencers With New Influencer Certification Program

Kilpatrick on

The rise of influencers and creator-driven content has fundamentally reshaped online marketing. Brands increasingly turn to influencers to reach audiences in authentic, engaging ways, but this new trend is not without risk....more

Kelley Drye & Warren LLP

Institute for Responsible Influence Launches Certification Program

Last year, NAD released its Influencer Trust Index: Consumer Insights 2025. Although the data showed high consumer engagement with influencers, it also showed that many consumers are suspicious of influencer campaigns....more

BakerHostetler

Certified to Influence: A New Self‑Regulatory Lever in Influencer Compliance

BakerHostetler on

Influencer marketing has outgrown its early days of buried “#sp” tags and fuzzy disclosure practices. It’s now a core advertising channel driving billions in spend—and, unsurprisingly, continues to draw scrutiny from...more

Loeb & Loeb LLP

What Brands, Agencies and Creators Need to Know About the New Responsible Influence Certification Program

Loeb & Loeb LLP on

This week marks an important new chapter in the self-regulation of advertising in the United States. Yesterday, the Center for Industry Self-Regulation's Institute for Responsible Influence (IRI) announced the launch of a new...more

Foster Swift Collins & Smith

FTC Disclosure Rules for Influencers: What You Need to Know

Whether you are an influencer with a million followers or a thousand, if you endorse brands or products, you are required to abide by the Guidelines set forth by the Federal Trade Commission (“FTC”) when making...more

Sheppard

FTC Disclosures Still a Focus in Interactive Media

Sheppard on

The Federal Trade Commission’s (FTC) advertising disclosure rules for “material connections” are not new. The FTC has long required that advertising contain clear and conspicuous disclosures of endorsements and other material...more

Morrison & Foerster LLP - Class Dismissed

Under Review: FTC Puts Companies on Notice with Consumer Reviews Rule Warning Letters

On December 22, 2025, the Federal Trade Commission (“FTC”) announced it had sent warning letters to 10 companies regarding possible violations under the Consumer Reviews and Testimonials Rule (“Rule”). Although recipients...more

Troutman Pepper Locke

FTC Warns Companies Over Deceptive Online Review Practices

Troutman Pepper Locke on

The Federal Trade Commission (FTC) has sent warning letters to 10 unnamed companies for practices that may allegedly violate its new Consumer Review Rule. The letters flag potential use of fake or misleading reviews,...more

Pierce Atwood LLP

Recent FTC Warning Letters Remind Companies of Obligations Regarding Consumer Reviews & Testimonials

Pierce Atwood LLP on

The Federal Trade Commission (FTC) recently sent warning letters to 10 companies advising them of possible violations of its Consumer Review Rule (the “Rule”), which became effective in 2024 and prohibits certain unfair and...more

Kelley Drye & Warren LLP

Center for Industry Self-Regulation Launches Institute for Responsible Influence

This week, the Center for Industry Self-Regulations launched the Institute for Responsible Influence, an entity whose first key initiative will be a certification program designed ​“to elevate transparency, strengthen...more

Hinch Newman LLP

5 Star Analysis FTC Investigating Fake Google + Yelp Reviews

Hinch Newman LLP on

The Federal Trade Commission and State Attorneys General are aggressively investigating the use of fake or false consumer reviews and testimonials – including AI-generated reviews – on consumer review platforms like Google...more

Loeb & Loeb LLP

FTC Issues First Wave of Warning Letters Under New Consumer Review Rule: Key Lessons for Brands

Loeb & Loeb LLP on

In August 2024, I wrote about the Federal Trade Commission's then-new Consumer Review Rule (Adieu, Fake Revie(u)w), which is designed to preserve the authenticity of online reviews and prohibit companies from suppressing...more

Kelley Drye & Warren LLP

FTC Warns Companies of Potential Violations of the Consumer Review Rule

Kelley Drye & Warren LLP on

On December 22, 2025, the FTC announced that it had sent letters to ten companies warning them of potential violations of the agency’s Consumer Review Rule....more

Kelley Drye & Warren LLP

NAD Addresses Disclosures on TikTok Shop

Procter & Gamble filed an NAD challenge against Blueland, arguing that influencers promoting Blueland’s cleaning products on the TikTok Shop did not adequately disclose their connection to the company....more

Dorsey & Whitney LLP

Creator Earns Commission on TikTok: New Guidance on Effective Influencer Disclosures

Dorsey & Whitney LLP on

Earlier this year, we blogged about effective influencer disclosures on Instagram. Our attention is now on TikTok with the help of a recent decision from the National Advertising Division. On October 13, 2025, the NAD...more

Kilpatrick

Reflections on the 2025 NAD Advertising Law Conference

Kilpatrick on

The recent 2025 NAD Conference provided a deep dive into many areas of advertising law. While a few sessions discussed the obvious hot-button topic of the year—artificial intelligence—there were many other timely topics...more

Loeb & Loeb LLP

NAD Finds Brand Responsible to Try to Cause Take Down of Influencer's Social Media Post It Didn’t Pay For

Loeb & Loeb LLP on

The National Advertising Division (NAD) recently looked at a complaint over a social media video posted by an influencer. The interesting thing about this case is that the brand didn’t ask for the video to be posted, and the...more

Kelley Drye & Warren LLP

NAD Considers Material Connection Disclosures on LinkedIn

Agendia made two posts on LinkedIn that linked to articles in which Dr. Nathalie Johnson touts Agendia’s genomic test to evaluate early-stage breast cancer over Genomic Health’s competing test. Genomic Health filed an NAD...more

Kelley Drye & Warren LLP

Influencer Lawsuit Dismissed on Procedural Grounds

In 2022, Alin Pop was scrolling through his Instagram feed, when he found influencers promoting Luli Fama swimwear. ​“Pop followed what he believed to be the honest advice of the influencers,” and purchased some products for...more

Kelley Drye & Warren LLP

NAD Decision Leaves Unanswered Questions about Content Creator Disclosures

P&G filed an NAD challenge against Dr. Squatch over posts that the company’s influencers and content creators made on TikTok. These creators participate in the TikTok Shop affiliate program through which they can earn a...more

Kilpatrick

NAD Puts VKTRY Performance Insoles’ Claims to the Test—And It’s No Shoe-In for Superiority

Kilpatrick on

The National Advertising Division (NAD) recently delivered a pointed reminder to the athletic gear and consumer products industries: if you want to advertise superior performance, you’d better have the science to back it up....more

International Lawyers Network

The Rise of Class Actions in Influencer Marketing: What Brands Need to Know To Protect Themselves 

Class actions targeting prominent brands using influencers to advertise their products on social media are on the rise, accusing brands and their influencers of failing to properly disclose paid endorsements....more

Morgan Lewis

Influencer Marketing Class Actions on the Rise: Common Themes & Key Takeaways

Morgan Lewis on

A wave of class action lawsuits targeting influencer marketing practices has emerged in the first half of 2025, signaling what could be a popular trend in consumer class action litigation. With demands for substantial...more

Coblentz Patch Duffy & Bass

Beyond the FTC: Consumer Class Actions Are Redefining Influencer Marketing Risk

The influencer marketing ecosystem has evolved into a multibillion-dollar engine of digital commerce, delivering measurable ROI to brands across industries. However, as the industry matures, so too does the legal landscape...more

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