CFA and CU Comments to the FTC Regarding Updated Guidance for Online Advertising and Disclosures
Donald S. Clark Secretary Federal Trade Commission Room H‐135 (Annex N) 600 Pennsylvania Avenue NW Washington, DC 20580
VIA ELECTRONIC COMMENT SYSTEM RE: In Short Workshop, FTC Project No. P114506
'Dear Mr. Clark:
Consumer Federation of America (CFA), a nonprofit association of some 300 consumer organizations in the United States, and Consumers Union (CU), the advocacy and public policy arm of Consumer Reports®, commend the Federal Trade Commission (FTC) for the excellent public workshop that it convened on May 30 to examine “Advertising and Privacy Disclosures in a Digital World.” What clearly emerged from the workshop was that while the core tenets on which the FTC based its 2000 “Dot Com Disclosures” guidance document have not changed – advertising must be truthful and not misleading, advertisers must be able to back up their claims, and advertisements cannot be unfair – new advertising media such as mobile devices and new advertising platforms such as social media networks raise challenging questions about how to make disclosures clear and conspicuous. To address those questions, the FTC should revise and expand the guidance document.
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