The Federal Trade Commission has issued warning letters to 10 unnamed companies over practices that may violate its new Consumer Review Rule. The letters flag concerns around fake or misleading reviews, undisclosed insider endorsements, and the suppression of negative feedback. According to the FTC, violations of the rule can result in civil penalties of more than $50,000 per violation.

For marketing, compliance, and brand teams, this marks a clear shift. Online reviews, testimonials, and social proof are no longer just reputation tools. They are now a front line compliance risk.

What Is the Consumer Review Rule?

The Consumer Review Rule is designed to protect the credibility of online reviews, ratings, and endorsements. Its goal is to stop deceptive tactics that distort how consumers perceive a product or service.

Under the rule, companies are expected to ensure that the reviews and endorsements they collect, display, or promote reflect genuine customer experiences and are not manipulated for marketing advantage.

What the FTC Is Flagging

In its warning letters, the FTC highlighted several practices that may violate the rule. These include:

• Generating or purchasing fake reviews and testimonials

• Offering incentives only for positive reviews while discouraging honest or negative feedback

• Allowing employees, executives, or affiliates to post reviews without clearly disclosing their relationship to the company

• Presenting company controlled sites as independent review platforms

• Selectively removing, hiding, or burying negative reviews

• Inflating social proof with fake followers, likes, or views

These tactics, even when used to “polish” a brand’s image, can now trigger regulatory scrutiny.

Why These Warning Letters Matter

These letters represent some of the first visible enforcement steps under the Consumer Review Rule. While they are not formal findings of a violation, they signal a shift from education to active oversight.

The message to the broader market is clear. How companies solicit, moderate, and display reviews and endorsements is now a priority enforcement area. This applies not only to ecommerce brands, but also to SaaS companies, fintechs, healthcare providers, and any business that relies on testimonials or influencer content.

Who Should Be Paying Attention

Any business that collects, curates, or features:

• Customer reviews and star ratings

• Testimonials on websites or landing pages

• Influencer or affiliate endorsements

• Social proof such as follower counts or engagement metrics

should reassess its review and endorsement practices under the Consumer Review Rule.

Marketing teams often own these channels, but compliance and legal teams are now increasingly expected to be involved in how this content is approved, displayed, and maintained.

Key Compliance Risks for Marketing Teams

The biggest risk is not just obvious fraud, such as buying fake reviews. It is also the gray areas that often go unchecked in fast moving marketing workflows.

For example, employee advocacy programs, influencer partnerships, and automated review collection tools can easily introduce undisclosed relationships or biased incentives if they are not carefully monitored.

Even moderation practices can become a liability if negative reviews are systematically hidden or removed in a way that misrepresents overall customer sentiment.

How to Reduce Enforcement Risk

A focused compliance review can help teams stay ahead of potential issues. This should cover:

1. How reviews and testimonials are collected, including any incentives offered

2. Whether insiders, affiliates, or partners are clearly disclosing their relationship to the brand

3. How negative feedback is handled and displayed

4. Whether social proof metrics accurately reflect real engagement

Documenting these processes and building review and approval steps into your marketing workflows can help demonstrate good faith compliance if regulators come knocking.

What This Means for the Future of Digital Marketing

The FTC’s move underscores a broader trend. Marketing claims, whether in ads, on websites, or in reviews, are increasingly treated like regulated statements. What your brand shows the public must match what is actually happening behind the scenes in your tech stack and content systems.

As enforcement continues to evolve, companies that invest in compliant marketing operations now will be better positioned to move fast without taking on unnecessary regulatory risk.

Final Takeaway

Online reviews and endorsements are powerful growth tools, but they now sit firmly in the compliance spotlight. The FTC’s warning letters serve as an early signal that deceptive or loosely governed review practices can carry serious financial and reputational consequences.

For marketing and compliance teams alike, the takeaway is simple. Authenticity is no longer just a brand value. It is a regulatory requirement.