FTC Compliant Endorsements & Testimonials
filed in Uncategorized on Nov.16, 2009
One of the biggest issues surrounding the new FTC Guides going into effect Dec 1st is the use of endorsements and testimonials, and specifically atypical results in your sales copy.
Joel Comm mentioned a good example in his recent webinar regarding the new FTC guides – a true testimonial he had received from one of his ebook customers:
“after reading your guide I went from making a thousand dollars a day to making 10 thousand dollars a day”
A glowing testimonial indeed, and one that would serve Joel well in his sales copy, but certainly not FTC compliant…
Key Issue: Atypical Results
One of the key issues in complying with the new guides regarding testimonials & endorsements is the use of atypical results. Obviously not everyone is going to make $10,000/day using Joel’s methods, so the testimonial above serves as a good example of an atypical result.
The FTC is not saying that you cannot use atypical results under their new guides, but simply that they must be qualified. You can no longer get by with a generic disclaimer such as “results not typical” or “results may vary”.
This does not affect endorsements or testimonials that don’t mention results. I have a glowing endorsement from Willie Crawford for my Fast Cash Strategy that remains complaint, and serves as a good example:
You can click through to read the other endorsements and testimonials on that page to see a good example of the wording you can use – wording that isn’t affected by the new FTC guides either by mention of results or by needing to be ‘current’.
Requirements For Using Atypical Results
There are 2 major requirements for using testimonials that reflect atypical results. One is that it must be current, meaning the person who wrote that testimonial is still experiencing those same results using your product or service.
The second requirement is that those results be qualified. This means you need to include the reason they achieved atypical results using your product or service.
If you have results-based testimonials on your sales pages, you need to contact each person to make sure they are still current and accurate. And if so, you’ll need to modify those testimonials to include more information.
In the case of Joel’s testimonial above, an addition is needed that explains why this buyer achieved such great results. Obviously he already had multiple websites or a lot of work invested, as he was making $1,000/day when he read the guide. But according to the FTC, the obvious needs to be made even more obvious.
An example the FTC gave in their original documents back in October was for a diet pill. The atypical result was along the lines of “Sally lost 100 lbs in 6 months with our product”. That’s not compliant. But if it said “Sally lost 100 lbs in 6 months taking our product, working out for 6 hours a day, and eating nothing but raw vegetables” – that IS compliant. See the difference?
Creative Idea For Using Atypical Results In Your Sales Copy
Before you go removing all of your glowing testimonials and settle for the fact that your conversion rate is going to tank, thanks to the FTC (glass half empty mindset)… consider the ways you can use these new guides to your advantage.
Get in touch with each of the people who wrote those testimonials, and find out if the details are still current. Are they still achieving the same results, using your methods or your products/services?
If so, ask them for a quick interview on how they achieved such exceptional results. It can be a text interview that you do via email, they can submit a video testimonial with the details, or you could conduct an audio interview.
Install a blog on the same domain as your sales letter, specifically for these interviews, and create a new post that features each customer and their personal testimonial for your product or service.
On the actual sales page you could display a glowing testimonial that reads:
“after reading your guide I went from making a thousand dollars a day to making 10 thousand dollars a day” find out how John did it!
Each blog post will contain the text, audio or video testimonial in detail – qualifying their results and making it FTC compliant. That post will then link back to the sales letter (”return to the ABC page”), which will ultimately give you some very nice internal linking structure as an SEO bonus.
New FTC Guides = New Marketing Opportunities
Instead of falling for the hype & scare surrounding the new FTC guides for endorsements and testimonials, look at this as a bright new opportunity. It really opens the door for more creative options and more creative marketing styles.
I think this could be a great thing.
Think about it: if consumers feel more protected, and are fed more realistic results and less hype, they’ll be less skeptical. And less skepticism will ultimately result in higher conversion rates.
In the process of making sure that your sites and sales copy are FTC compliant, consider creative ways to increase trust and make a better connection with your target market. Let them see the potential that your method, product or service as – in a true light.
Best,

Original post by Lynn Terry and software by Elliott Back
