A request for input, not a final rule

The Federal Trade Commission announced September 24 that it is seeking public comment on how online platforms may facilitate government and business impersonation scams. The advance notice considers changes to its impersonation rule, other rulemaking and nonregulatory approaches. It addresses advertising practices across search engines, social platforms and digital marketplaces. The announcement does not create a new final compliance obligation.

The agency is examining platform practices

Issues raised include advertiser vetting, monitoring, investigation and removal of fraudulent advertisements. The FTC says the comment period runs for 60 days after publication in the Federal Register; businesses should check that publication before relying on a filing deadline. The process creates an opportunity to provide evidence about how scam advertising works and how proposed interventions would affect legitimate activity.

Prepare examples that someone else can verify

For retailers whose identity is copied, and media businesses selling or buying advertising, our recommendation is to retain a structured record of suspected impersonation. Useful fields include the ad’s visible content, destination, platform reference, observation time and any report made to the platform. Keep personal information out of broadly shared evidence collections. A consistent record is more useful for escalation than disconnected screenshots with no context.

Give customers a reliable route back

Businesses can also review how a confused customer would locate the real support channel from their own website. Make account and payment instructions consistent across official properties and ensure support staff know how to escalate impersonation reports. Those are practical operational steps, separate from predicting the outcome of the FTC proceeding. For companies considering a comment, concrete evidence about detection, response times and recurring failure points will be more informative than treating a proposed review as though its final requirements were already settled.

Sources & further reading

Our practical suggestions are editorial guidance. Verify applicability against current source and vendor instructions.

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