Federal Trade Commission and National Advertising Division, Better Business Bureau

1. Federal Trade Commission and National Advertising Division, Better Business Bureau Effective Disclosures in Advertising May 22, 2001

2. Communications Challenges of Disclosure Exposure • Market most appealing offer while providing accurate information to consumer • avoid dissatisfied customers • Oversaturation of information • customer confusion • Complexity of offer • limitations of some media

3. How Do We Overcome This Challenge • Integrated multimedia approach • Identify best role by medium • communication objective • disclosure benefit • Use target insight to our advantage • Electronically savvy target is accustomed to the buy and subscribe proposition

4. Disclosure By Roles of Media The Strategy: Right Medium- Right Information Clear & Conspicuous disclosure provides enough info to stimulate action or close the sale DIRECT MARKETING ( INTERNET & INCOMING TELEMARKETING) Deliver targeted messages and detailed information + generate leads, provides interactive opportunity to answer questions and close sale. 800# prerecorded detailing offer and opportunity to reach live operator, before getting the option to subscribe. Detailed disclosure more fairly provides information for consideration of offer MAGAZINE ADVERTISINGGenerates increased reach and frequency. Affords more time for consumer to absorb detailed information. Call to action provides opportunity to get more information and track interest Electronically Savvy Target TV ADVERTISING Most powerful way to announce new product introduction and illustrate benefits. Call to action drives consumer to other sources for more information and track interest Position offer to consumer & spark interest with topline offer

5. Creative Presentation • Television • Print