RVDA Attends FTC Internet Advertising
If you advertise or sell over the Internet,
and it is hard to be competitive in this day and age without a web
presence, be aware that the Federal Trade Commission (FTC) is looking at
changes to modernize its online disclosures guidance to keep pace with
On May 30, RVDA’s Director of Legal
& Regulatory Affairs Brett Richardson attended an FTC full-day
workshop in Washington, entitled "Advertising and Privacy Disclosures in
the Digital World." This workshop was intended to provide guidance to
the public concerning the FTC’s advertising requirements and to
solicit input from the public for updates to the FTC’s existing
online advertising guidelines, "Dot Com Disclosures" (DCD).
The original FTC guidelines (downloadable
developed back in 2000, as the Internet was just coming of age, and
before the advent of social networking and smart phones and their apps.
"What a difference a decade makes. When Dot Com Disclosures was issued,
who could have imagined the world we live in now?" said FTC Commissioner
The FTC is
expected to formulate new guidelines and RVDA and its allies, including
NADA, will actively work to make any new rules as least onerous as
possible for motor vehicle dealers. RVDA member
dealers can help support these efforts through a voluntary
contribution to the association's advocacy
Here for more
It appears the FTC
will be addressing some new areas in its upcoming guidelines. Generally
speaking, the FTC will likely address two broad categories impacted by
new technology: (1) what is expressed and (2) what is collected. How do
traditional "clear and conspicuous" standards play out on a small mobile
device such as a smartphone? How can advertisers effectively disseminate
disclosures on such devices?
A greater concern
expressed by the FTC and consumer groups is the development of consumer
online (and sometimes offline) behavior tracking. This permits
advertisers to customize specific ads to targeted consumers, which might
be very profitable for companies selling this data, buta consumer
privacy nightmare. There was talk about the FTC pushing industry to
develop a framework for implementing do-not-track mechanisms that would
allow Web users to opt out of behavioral targeting and other online
data-collection across a broad network of advertising firms.
The FTC hosted
several panels on various subjects related to online advertising.
However, it seems that most panelists and the FTC itself would prefer to
see that industry self-regulate itself by creating best practices for
If you have
comments or questions about FTC advertising requirements, please contact
RVDA’s Brett Richardson at email@example.com.