Let’s play…
Is this ad headline FTC-safe or not, based on the Rules that went into effect today, December 1, 2009?
“How To Make $10,000/mo”
Seeking fearless person
who loves meeting people
and selling cool health product.
Seeking fearless person
who loves meeting people
and selling cool health product.
Go ahead and say yes or no. And tell why, given what we know about the FTC rules and the PDF link there. It’s not straightforward, by the way. Hehehe.
Interesting way to put it. Technically, you could say this ad does not say you WILL make $10,000. It only offers to tell you how it can be accomplished. Ethically, it seems you should be obligated not only to explain how the pay plan could yield that much money, but also to give some explanatory data — how long it takes on average to reach that goal or how many people actually make that goal and/or the average income of people who reached the rank you just described as resulting in that income.
HOW TO is not a testimony so I would think that is ok. (haven't read the FTC rules thoroughly so this is a guess)
Hi Kim,
YES . . .I would say it should meet FTC-safeness…
1. It's clearly an "AD" (not a TESTIMONIAL).
2. The AD clearly states 3 criteria necessary in order to qualify.
OK..What's the correct answer?
I'd have to say that it does not.
The headline implies (even if it conditions who can apply) that if I join, I will make 10K.
The MLM companies say the same thing: "we'll show you a way". Later they say "it's a way, not a sure thing".
A small difference would make this a better one: "I make 10K a month"
If you're fearless who loves selling, I can teach you what I did". There. No hidden promises.
Yes its compliant. It's not a claim, it's purely hypothetical. It doesn't say anyone can do it and mentions a requirement("fearless". Over all it's more instructional than hype-driven.
re: previous post of gt. If it stated "I make…" it then becomes a testimony whereby the ad would also need to state the average income of the reps. At least that is my understanding. Using 'How To' imo, puts it out of the testimony category which I would think would make it 'safe'. Guess Kim will let us know the correct answer.
Cathy, joinblair, Oscar – you are right.
The statement, "I make/made $10,000 in 3 months" (pick a time frame) makes it a testimonial. And subject to the FTC rules.
If that is done in front of a group to encourage them to spend money and sign up for the business, it cannot be made without also adding "and the average person makes $X in their first 3 months."
The statement as it is – "How to make $10,000" is not a testimonial, so it doesn't fall under the Rules as they are now written (link in the post.)
It is a how to. And the solution is arithmetic.
It requires that the speaker/ad writer KNOW how to make $10,000/mo.
"How to make $10,000" means you need to know how many customers and/or recruits you need, and that means you need to know what the company pays you for each one so you can work backwards.
Lots of networkers don't know those numbers. Sometimes because the comp plans are ridiculously complex, other times because they just never thought about it.
I am not a lawyer or a judge. So, I don't know if it is legal. However, I want to recruit people based on realistic possibilities. For me, this ad implies the realistic possibility for most people to make $10,000 a month if they join the team. If you look at the results for the company and most people do earn $10,000 a month, then this is a great ad. If you look at the results for your company and most people are not earning $10,000 a month then I believe this is an attempt to generate interest by misleading prospects.
I don't want to be in a situation, regardless of the legality, where I have to tell a frustrated team member that in reality only 1 out of 100 or 1 out of 1000 people make $10,000 a month.
Hi Kevin – You wrote "However, I want to recruit people based on realistic possibilities. For me, this ad implies the realistic possibility for most people to make $10,000 a month if they join the team."
Most will not. But with this ad they will see HOW that is to be done, precisely, arithmetically.
My point with this ad was to show that big money ads are still possible if done right.
If one sits down with someone who responds to this, and DOES THE MATH, then the person who responded to the ad – the one who wants to earn $10k/mo or see what it takes – will see what they need to do.
Say you show them they earn $20/ customer order of $100, and they want to bring in customers. They'd have to bring in 500 $100 orders, or 250 $200 orders, personal front line orders – to earn that. If they make $100 on a $500 recruiting package, they can figure in some of those and reduce the number of customer orders they'd need.
If a person is clearly shown how many orders they need to bring in to earn anything over $1,000/mo, I don't imagine very many folks will think, "oh that sounds easy."
That is the point of this sort of ad. To be required to show the math of what it takes to earn ANY amount.
One can also do ads for other numbers – "How to earn $300/mo" is the same type. You have to show precisely the ways it can be done with customer and recruit orders.
(I know there is downline $ available, but a person cannot depend on others at first, so I prefer to show them what THEY need to do to bring in whatever amount of income they seek to earn.
This kind of ad is like giving directions from LA to NYC. No one is saying that the direction giver has done it or not, only that this is the way.
A business like ours has MANY appeals, much more than the money. I used this income e.g. because recruiters have led with big money, and now, finally, the feds are making that stop.
Writing ad copy for different kinds of appeals – besides the money – is what we're doing in a current Recruiters class for right now.
I've never believed leading with the money is the best way to market our business – but it can be done if done honestly in a way such as this. There are lots of other fun options, for the big money too. Think: "So you think you're a one percenter?" Hehehe…
One problem – according to my surveys, most networkers do not understand how they make money and cannot explain it in words a 13-year old can understand.
That is a bad thing and causes others to stay away. "Sharing" is not an answer anyone in sales expects to hear when they ask, "So how do you make money with this thing?"
Longer answer than I expected. Sigh.
🙂
Great post Kim, and I enjoyed the long answer it covered every thought I was having.
Yes, I can see now how my headline is a testimony. I'll add "I make 10K/Month where most people lose 150$". If you love… etc. To make it cool with the FTC.
I was thinking about how I come across to my listener, less about the FTC (since we don't have it in Israel).
I personally prefer someone who's done it to someone who just "knows what to do". You know the old saying… "Those who can't do – teach".