Commission alleges that well-known Victory titles fail to disclose paid advertisements
Under Siege
It's hard coming home.
Fully 27 percent of military veterans report that they have had a difficult time returning to civilian life. Injuries, traumatic experiences, combat duty and strained marriages are just some of the factors that undermine a return to "normal" living.
Programs sponsored by the military, including Transitional Assistance Programs (TAP), provide help and guidance for veterans returning home. Nonetheless, half of returning veterans are not working in their desired career and/or they are finding no meaning in their current work environment – an indication that the skills and experiences of veterans are not always leveraged well in their new societal roles. More serious are statistics on rates of depression and post-traumatic stress disorder, a condition that is experienced by one in five recent veterans.
Re-Entry
Victory Media, Inc. (Victory) is a company that steps into this problematic gap and helps returning veterans reintegrate into civilian life. Victory owns several media outlets, including print magazines G.I. Jobs, the Guide to Military Friendly Schools, and Military Spouse. These publications, and the online tools that accompany them, offer "specific, 'how-to-advice' on everything from choosing a college to writing a resume to interviewing to industry and career highlights." These magazines are distributed in military bases, hospitals and TAP centers.
Central to Victory's business is its online Matchmaker search tool, which helps veterans find postsecondary schools that are "military friendly" – a tag that Victory developed based on its own school surveys and other data. Advertisements for the tool promise to match the applicant with these postsecondary schools.
Fog of War
The Federal Trade Commission (FTC), however, has taken a skeptical stance on Victory's claims. In an October 2017 complaint, the FTC alleged that Victory has received payment from various colleges and other educational institutions to appear as "military friendly" schools in its search engine. Specifically, the FTC claims that since mid-2015, Victory has included schools in its Matchmaker tool only if the institutions paid to be featured there, including schools that did not score high enough on the company's survey to qualify as military friendly.
The Commission also alleges that Victory received payment to endorse individual institutions in a variety of online articles, emails and other communications. The FTC claims that disclaimers, when available, were hidden at the bottom of many screens of text and even then, the disclaimers did not clearly disclose the arrangement between Victory and its advertisers.
The Takeaway
The FTC complaint accused Victory of misrepresenting its Matchmaker tool, misrepresenting the independence of its endorsements and failing to disclose material connections between itself and its advertisers. As the FTC continues to focus its enforcement efforts on compliance with the Guides Concerning the Use of Endorsement and Testimonials in Advertising, compliance with the Guides has become increasingly important.
Shortly after the complaint was filed, Victory and the Commission entered into a proposed settlement that prohibited misleading representations regarding paid promotional content and required disclosure of paid endorsements by advertisers. Additional compliance, record keeping and monitoring requirements were included.
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