The FTC review rule turns reputation work into evidence work. A seller should be able to show how reviews were requested, moderated, incentivized and corrected.
Why reputation files matter
Many sellers treat review management as a marketing task. The FTC rule changes the tone of that work. A brand should now expect questions about who requested reviews, whether buyers received incentives, how negative reviews were handled and whether insiders or agencies influenced ratings.
The strongest file does not try to make every rating look clean. It shows a real process. It keeps campaign briefs, agency instructions, incentive terms, moderation rules and correction logs. That file helps a business explain honest mistakes before they look like a pattern.
Review controls to keep
A reputation file should start with the request language. If a seller asks only happy customers to post public reviews, filters out negative feedback or pays for endorsements without clear disclosure, the business creates a record problem. The risk increases when an outside agency runs the campaign without written rules.
Suppression creates a second risk. Deleting abuse or spam can be legitimate. Removing ordinary criticism because it hurts conversion is different. The seller should keep a moderation log that shows the reason for removal and the person who approved it.
| Activity | Evidence to keep | Risk if missing |
|---|---|---|
| Review request | Email or message template | Selective solicitation may be hard to explain |
| Incentive | Disclosure and campaign terms | Paid feedback may look hidden |
| Moderation | Removal rule and approval log | Suppression claims become credible |
| Agency work | Written instructions and audit trail | Vendor conduct becomes brand risk |
Case pattern for agency drift
A seller hires an agency to improve product ratings. The agency sends messages after support tickets close and asks happy customers to post public feedback. Negative feedback goes into an internal form. Nobody writes down the rule, and the campaign manager only reviews the final rating movement.
The seller may see the project as customer success. A regulator or platform may read the same record as selective review generation. The fix is not a slogan about authentic reviews. The fix is a written review policy, vendor instruction and periodic sample check.
Cleanup checklist
Brands should audit live review programs before a platform, competitor or regulator raises the issue. The audit should include internal teams and vendors. If a vendor cannot explain how reviews were collected, the brand should pause the campaign until the record is clean.
A practical review audit takes one product line and traces the path from buyer contact to public review. The team should save the exact messages and incentive terms used in that path.
- Inventory all review campaigns and vendors.
- Keep buyer request templates and incentive terms.
- Ban employee, family and agency reviews unless rules allow and disclosures are clear.
- Record moderation reasons for removed reviews.
- Correct campaigns that route only positive buyers to public pages.
Thirty-day field test
A useful test is to put one live order, one active listing and one supplier file beside this briefing. The team should walk through the records as if a platform reviewer, customs officer or buyer asked for proof tomorrow morning. The exercise should produce a short gap list, not a presentation. Each missing record needs an owner, a due date and a business decision if the record cannot be obtained.
Do not wait for a perfect compliance system. Pick the highest-risk product in the category and test the file with the people who would answer the real request: sourcing, logistics, finance, marketplace operations and customer support. If those teams give different answers, the company has found the risk before an outside reviewer does. That is the value of the exercise.
Keep the record of the test in the same folder as the order or listing. A short note with the reviewer name, date, missing evidence and final decision gives the next reviewer a starting point. It also stops teams from repeating the same conversation after every customer question, route change or platform notice.
Set a review rhythm after the first pass. Thirty days is enough for an initial cleanup, but supplier changes, product edits and route changes should reopen the file. The rule is simple: when the commercial fact changes, the evidence file changes with it.
The team should keep a change log beside the evidence. It should say which document changed, who approved the change and which live product, route or supplier record was affected. That log turns a pile of files into a working control because later reviewers can see the decision path instead of guessing why an old record was replaced.
- Choose one product or shipment that is still active.
- Ask who owns each evidence item and where it is stored.
- Compare the public claim with the internal document.
- Record the business action if evidence is missing.
- Repeat the test after the next supplier, route or listing change.
Does the FTC rule only affect U.S. brands?
U.S. enforcement matters most for U.S. commerce, but cross-border sellers that target U.S. customers should treat review controls as part of market entry.
What should a seller document?
Document review requests, incentives, moderation criteria, takedown reasons and corrections when a campaign or agency creates risk.
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