What do you think about this?
"Earlier this week I told you that we are making some changes to our affiliate policies. The first and biggest change is required by the FTC. They informed us that our review affiliates (that is any affiliate doing a review of our course on their site) were not in compliance. Literally, not a single one. That sure took us by surprise!
What that means is that if you have a review on your site, and you think that you have a proper FTC disclosure, you actually don't and we need to get you in compliance right away.
We can help clear up the confusion, but if you have a review of any course on your site, you will have to change your disclosure right away (by December 17).
We have put together a short document that spells out the new requirements very clearly. You can find them here: Legacy Learning Systems Disclosure Requirements. Affiliate Disclosure Requirements and Examples
You will notice that some of the rules are totally new, including that your disclosure will now have to be in colored text, appear above the fold, and not rely on a clickable link. Other requirements also apply that you've probably never heard before. Again, if you have a review on your site of any of our courses, you MUST read this and get your site into compliance.
Take a look at the information here: Legacy Learning Systems Disclosure Requirements
Where did these requirements come from?
They are based primarily on the following:
December 2009 FTC Disclosure Guidelines
FTC disclosure guide from May 2000, which the FTC has told us is still very much in effect.
Our direct conversations with the FTC.
We recognize that most popular interpretation of the 2009 FTC Disclosure Guidelines is that having a short disclosure or link to a disclosure at the bottom of the review page is adequate. The FTC has told us that it is not. It is quite possible that the FTC will be cracking down on this industry wide, so I also suggest making these same changes to all of your review sites, not just the ones that promote our products".