The Federal Trade Commission (FTC) announced on September 23, 2014 that it recently completed a nationwide advertising review that resulted in warning letters to more than 60 advertisers. The review, termed “Operation Full Disclosure” by the FTC, targeted companies that failed to make proper disclosures in their television and print advertisements. In particular, the FTC sought out ads where important information needed to prevent consumers from being mislead was either contained in the fine print or otherwise hard to locate.
The FTC has consistently stated that advertisements must clearly and conspicuously disclose material information to consumers. Simply put, “consumers should be able to notice disclosures easily; they should not have to look for them.”
The FTC provided some examples of targeted conduct: