Tuesday, December 2, 2014

FEDERAL TRADE COMMISSION 16 CFR Part 255 Guides Concerning the Use of Endorsements and Testimonials in Advertising address the application of UDAAP to their use in advertising.  An advertisement containing an endorsement relating the experience of a consumer on a central or key attribute of the service will likely be interpreted as representing the endorser's experience is representative of what consumers will generally achieve.

Endorsements by "actual consumers

Tuesday, December 9, 2014

The (FFIEC's Guidance) leaves this to the Company: "A financial institution should have a risk management program that allows it to identify, measure, monitor, and control the risks related to social media." "The size and complexity of the risk management