What do Risk Management and Compliance have to do with Small or Home-based businesses. Take for example the typical web site owner who sells several products on their site. What Compliance issues do they face? Plenty! Is this web site owner compliant with the FTC? If the products are information based and they claim income estimates they fall under the rule of "Forward Looking Statements," a rule developed for the stock trading industry. If you offer such products you should be aware that the FTC does not look kindly upon wild claims of making a fortune or how to make $5,000 a day. In essence what I'm saying is that you need to be your own Risk Manager and Compliance Officer and evaluate each affiliate's product claims. Honest salesmanship will and should always be the mainstay of how we conduct ourselves and our web site businesses. I'm sure that many of you have seen many abuses of the advertising medium on the Internet. While I do not consider myself nave I do believe that as a provider of information and opportunity products, so called, I owe it to my customer base to adhere to a consistent level or standard of operation. In effect I am my own Risk Manager. I need to do my own due diligence on each product that I provide. I have tried most of what is provided on my site by affiliates. Therefore I can attest to the credibility of the product. There will always be someone who finds exception to your site or your product offerings. This is when you need to protect yourself and at the same time be in compliance with the Federal and State Governments. It's not my intention to overly complicate doing business on the Internet but to point out that conducting business on the Internet is just like conducting any other business. Honesty and integrity must always prevail. The fine line between salesmanship and disinformation may only be a simple choice of words. I would also point out that most people do not react to straightforward sales pitches. In fact it has been proven that most people buy a product based on more emotion than need. Is it wrong to say that "you can earn huge sums of cash" or "Take the dream vacation you've always wanted," from a compliance standpoint these claims are debatable but not illegal. However stating that "We guarantee that you can make up to $10,000 a day," Is still not illegal but highly improbable. It's not illegal because the language "up to" is used. That essentially says that you can make anywhere between $0 and $10,000 per day. If I were the compliance officer for this website business I would argue that the former statement is severely misleading and although technically not fraudulent it doesn't present the best customer experience. The best rule of thumb, if it sounds to good to be true it is. |
