They're not onerous, but it may require some quick modification to your websites to comply.
The regulations covered two broad areas:
Testimonials and Endorsements; and
Bloggs, Twitter, et al.
There remains a "green light" for testimonials that were unsolicited and uncompensated (by ANY consideration that other folks don't get).
If you pay or solicit a testimonial it's still easy, but you've got to disclose what you did.
If you GIVE an endorsement, you've got to protect yourself by doing "due diligence" about the product you endorse. The more recognizable the person or organization is, the more due diligence you have to do.
If you SOLICIT an endorsement, you've got to disclose what you did to GET the endorsement. If it was nothing, say it was nothing. If it was "compensation" then a general term of "cash or other consideration" may suffice.
As to blogs: if the blog is paid for or self-serving (like this one) then you've got to say so. It's called a Disclosure and Disclaimer. You can put it in a separate page via hyperlink prominently displayed (not hidden). Disclosures don't have to be onerous. Check out the one I use for my promotional page: www.internetlawcompliance.com/dnd.html.
The FTC is trying to get us website operators to disclose "connections" between internet activity that is not readily apparent. If your site pays bloggers, it's not illegal. You've just got to say you pay bloggers to promote your site. I enjoy doing it myself.
Jack Campitelli, J.D. is the author of the Internet Law Compliance System (www.internetlawcompliance.com) that is a very comprehensive "kit" for 98% of website owners to become instantly compliant with all relevant laws and comes complete with licensed forms.
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