The Federal Trade Commission (FTC) has sent warning letters to 10 unnamed companies for practices that may allegedly violate its new Consumer Review Rule. The letters flag potential use of fake or misleading reviews, undisclosed insider endorsements, and suppression of negative feedback. The FTC cautions that violations could trigger enforcement actions and civil penalties exceeding $50,000 per violation.

The Consumer Review Rule is intended to protect the credibility of online reviews, ratings, and testimonials by prohibiting deceptive tactics that distort consumer perception. In the warning letters, the FTC highlights prohibited conduct such as generating or purchasing fake reviews; offering incentives only for positive reviews; allowing employees, executives, or related parties to post reviews without clearly disclosing their affiliation; presenting company-controlled sites as independent review platforms; selectively removing or burying negative reviews; and inflating “social proof” with fake followers, likes, or views.

These letters are among the first notable enforcement steps under the rule and mark a shift from education to active oversight. While the recipients are not identified and the letters are not formal findings of a violation, they serve as a clear signal to the broader marketplace: how companies solicit, moderate, and display reviews and endorsements is now a priority enforcement area.

Why It Matters

Any business that collects, curates, or features consumer reviews, star ratings, testimonials, or influencer content should reassess its practices under the Consumer Review Rule. A focused compliance review, covering incentives, insider participation, moderation standards, and handling of negative feedback, can reduce enforcement risk and help maintain consumer trust in the authenticity of online reviews. Companies that act now will be better positioned as the FTC’s enforcement posture continues to evolve.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Michael Yaghi Michael Yaghi

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile…

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile clients in regulatory enforcement investigations involving all facets of their business, including but not limited to, advertising and sales practices, monthly membership programs, auto renewal programs, telemarketing and telephone solicitations, door-to-door sales practices, and endorsements. Having begun his career as a commercial litigator, he also supports clients throughout litigation, should an investigation move in that direction.

Photo of Zoe Schloss Zoe Schloss

Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated…

Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.