Effective April 1, 2010, the Federal Trade Commission's Free Credit Reports Rule will require new prominent disclosures in all online advertisements for "free credit reports." Any site marketing free credit reports will be required to include a disclosure across the top of each page stating:
THIS NOTICE IS REQUIRED BY LAW. Read more at FTC.GOV.
You have the right to a free credit report from AnnualCreditReport.com
or 877-322-8228, the ONLY authorized source under federal law.
The disclosures must also include a clickable button to "Take me to the authorized source" and clickable links to AnnualCreditReport.com and FTC.GOV.
In response to the FTC ruling, Credit.com is implementing new guidelines for our credit report offers. To ensure compliance, all affiliates running credit report offers are required to update marketing copy and remove any language containing the words "free credit report" or similar term. The FTC rule covers any ad for a credit report "that is represented, either expressly or impliedly, to be available to the consumer free of charge" if it is in any way tied to the purchase of a product or service.
For affiliates using banner ads, please be sure to login to your affiliate account and download the newly approved banners. If you choose to use your own banner ads, you must remove all references to a "free credit report" as defined by the FTC's new rule.
In order to meet the April 1st deadline, we will begin conducting a thorough compliance review on all affiliate sites starting March 23rd. Failure to comply with the new guidelines will be deemed a breach of your affiliate agreement and any sites that are not in compliance will be shut down on Monday, March 29th. We appreciate your support in ensuring that we all meet the new requirements by the mandated deadline.
Download the full details on the FTC's Final Rule here. You can also read more about the new disclosure requirements along with sample placement examples here.
Stay tuned for more information and updates as we work our way through implementing the changes as required by the FTC.
If you have questions regarding these changes, please contact your account manager.
This new law is very confusing for affiliates.
You note above "To ensure compliance, all affiliates running credit report offers are required to update marketing copy and remove any language containing the words "free credit report" or similar term."
So what if I am an affiliate, who markets on my site the keyword "online credit reports", without saying anything about free? Is the disclosure still required on my site, even though the site I am directing traffic too is offering free credit reports and has the disclosure required by law?
I don't quite understand how it effect the affiliate's site who does not use the term "free", but who is driving traffic to a free credit report offer that has the disclosure.
Can you provide any insight?
Posted by: John | 03/27/2010 at 10:42 PM
I also have another question. Freecreditreport.com seems to be taking the approach of now charging customers $1 for the credit report. http://www.freecreditreport.com/pm/default.aspx
Does this get around the new disclosure law since it is not a free credit report anymore? If I am an affiliate that is marketing this product should I have the new disclosure on my site or can I ignore it now since freecreditreport is charging a $1?
Posted by: John | 03/27/2010 at 11:10 PM