New FTC Rules and Guidelines – Use Your Own Results for a Testimonial

By Karen Brunet | December 9, 2009

typical-results-ftc-rules-2 Do the same rules about “typical results” that apply to customer testimonials also apply when stating your own results?

Here’s another highlight from the interview between Jim Edwards and FTC assistant deputy, Mr. Rich Cleveland that addresses this question.

First a quick recap. If you have a client who gets phenomenal results with your program - results that are not typical - the new FTC guidelines limits your use of those results in testimonials. I discuss this in more detail in a previous post: New FTC Rules and Guidelines - Using Typical Results in Testimonials

You may have seen several emails in the past couple of weeks from marketers that they are taking down their old case studies from the Internet in order to comply with the new FTC rules. This is what I am talking about - phenomenal results that are not typical.

So how do you let your potential ideal client know the incredible results that are possible with your program or product if you don’t know what your client’s “typical results” are?

Solution: Simple. You tell them about your results.

The FTC guidelines about typical results only apply to other people’s testimony about your product. It doesn’t apply to your testimony about your own program or product.

You still have to reveal the circumstances by which you achieved your results so that you don’t mislead. But that should only strengthen your story.

So what would this testimony look like?

Here’s a hypothetical example I came up with based on the FTC’s response during the interview:

“For years I struggled to grow my investment portfolio. But is seemed like as soon as I made a profit, I had a set back that left me worse off than when I started. The stress was awful. I was on the verge of just giving up.

Then one day I tried something new - a combination of steps that I had never before used - and I got a 30% return in 5 days. It seemed too good to be true so I tried it again. The next time, I got a 20% return in 30 days.

During the next 6 months, I increased my portfolio 250%. I didn’t always make a profit on every transaction, but I learned to minimize my losses and increase my gains. And the best part was, I did all this part-time in the evenings and only worked at it about 8 hours a week.

That was 12 months ago, and since then I’ve streamlined the process so that I get even better results working no more than 4 hours a week. My friends begged me to teach them what I was doing. So I created my step-by-step “Invest with Me” coaching program. We’ve been beta testing it, and the results have been very exciting.

Now I’d like to share with you the exact step-by-step process that I used to get returns of 250% or better in 6 months. I can’t promise that you’ll get the exact same results because you’ll be choosing your own investments to make. But I can promise you that I’ll show you in detail everything I did. I won’t leave anything out. And I’ll teach you everything you need to know to repeat the steps on your own.”

The expectation for the reader is that if they are also struggling to grow their investment portfolio and they did the same steps that you did in the same way that you did and put in the same time that you did, then they can expect similar results.

And if you have a good program, then your clients will usually get similar results when they repeat your steps. The clients who don’t get similar results usually skip steps. Or they don’t put in the amount of time they need in order to get similar results.

Personal Observation: This technique of telling your story and using your results is especially beneficial when you are launching a new product or program. At that point, you don’t have “typical results” statistics to satisfy the FTC guideline requirements. But you do have your own statistics to share.

What do you think? Leave a comment and let us know.

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If you want to listen to the entire interview between Jim Edwards and Mr. Rich Cleveland, Assistant Deputy at the FTC, you can hear it here: www.igottatellyou.com/blog/ftc-change-interview.

As always, please note that no legal advice is dispensed in this article or on our website, and any information or opinions shared are for educational and entertainment purposes only. If you want legal advice, please seek the services of an attorney for your particular circumstances.

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