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#WOMMAsummit Session Rewind:

Ground Rules - Preemptively Protecting About FTC Crackdowns

#WOMMAsummit Session Rewind: Ground Rules – Preemptively Protecting About FTC Crackdowns

Featured Speakers: Holly Pavlika (Collective Bias) and Ali Kirby (Collective Bias)

Recap written by Danica Kombol (Everywhere Agency):

The topic of FTC guidelines is widely discussed and frequently in the news. For good reason: 84% of marketers will do an influencer marketing campaign this year. So it’s never been more important for us as marketers to enforce the rules and regulations around disclosure.  You’d be surprised how many brands and influencers are skirting the guidelines and not being clear and conspicuous.  And not only is it unethical, but it can be costly. The FTC can fine you $16,000/day, per post, which can add up to a lot of money very quickly.

There’s a misperception that the FTC is only going after big brands.  However, just last week the FTC sent out 90 letters to Instagrammers.

Key Takeaways:

  • Disclosures should go at the top of any blog post.  And it should be “easily readable.”  Hiding disclosure anywhere but the top is going against the FTC guidelines
  • Good influencer content is “user-generated,” so give them the freedom. Don’t ask them to create an ad.
  • With “platform-specific” posts, there simply is not a lot of room, so you need to be concise in your disclosure. Using #AD is the simplest way to go. However, make sure it’s visible and not hidden among a plethora of hashtags
  • With Facebook Live, the disclosure must be provided at the beginning of the live stream and repeated at the end
  • Like Facebook Live, the disclosure on YouTube should be near the beginning and repeated at the end. Also, bear in mind that it must be both visual and audio
  • Whether you receive compensation or a gift, you still need to disclose. The FTC does not recognize any difference between a gift and cash.  Influencers who are using #hosted for being gifted experiences are not being “clear and conspicuous” – and are not compliant


“If you are creating authentic, quality content, there’s absolutely no reason why you would not want to disclose.”

“YouTube can be the ‘Wild West’ of disclosures.”

“Never dictate copy. If you dictate copy you are flying in the face of disclosure.”

Holly PavlikaReach Out:

Connect with Holly:



Ali KirbyConnect with Ali:





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