The reviews rule lands Monday. Fix the offer

On Monday the FTC rule on fake reviews and testimonials takes effect. It was finalized in August and the clock on it runs out on the 21st. It reaches the people who buy this work as much as the people who sell it, so if your agency sells reviews or reputation in any form, in house or through a fulfilment partner, the offer needs a read this weekend.

The other thing that happened this month is quieter and will matter longer. AI stopped being a separate product line in the platforms we all run client work in and started showing up as a bundle you switch on.

Two jobs on the same October calendar. One thing to take out of the offer, one thing to put in.

What it forbids, in agency terms

It is short, and worth reading rather than reading about. Read it with your scope document open, because these are lines a deliverable can cross:

• Reviews and testimonials from people who did not have the experience. Written, bought, sold or published. A testimonial assembled out of three customers is covered. So is a quote nobody said.
• Paying for sentiment. Compensation conditioned on a review being positive, or on it being negative. Offering something for any review is not the core target of the rule, but Google and Yelp forbid incentives in their own policies anyway, so it stays off the table.
• Insider reviews without disclosure. Owners, managers and staff reviewing their own employer, and reviews solicited from their relatives, unless the connection is disclosed clearly.
• Review sites that are not independent. A “best dentist in the county” comparison site controlled by one of the businesses it ranks, presented as neutral.
• Suppression. Legal threats and intimidation aimed at getting a review pulled, and presenting a display of reviews as all of them when the negative ones have been held back.
• Fake social proof. Buying followers, views or engagement you know or should know are not real.

The FTC can seek civil penalties per violation under a rule like this. That is the reason this one has everyone’s attention and the earlier guidance did not.

Worth remembering alongside it: non-disparagement clauses in consumer contracts were already unenforceable under the Consumer Review Fairness Act. If a client’s intake paperwork still tells patients not to post about their care, that now sits next to a rule with teeth.

What comes out of the offer

Pull up your services page, your proposal template and the review workflow in your CRM, and go line by line.

1. Gating. If a workflow branches on a star rating and only sends the review link to the people who picked four or five, take the branch out. Ask everyone the same way. This has been against Google’s policy for years and it is now a much worse thing to have in writing in a scope document.
2. A promised number of reviews per month. Change the deliverable to what you control: requests sent, response rate, reply time. Nobody should be signing up to deliver sentiment.
3. Staff review drives. The Friday afternoon “everybody leave the office a five star” push is now a disclosure problem, and it was always obvious to anyone reading them.
4. Incentives of any kind. Gift cards, raffles, discounts for a review. Even where the rule does not reach it, the platform policy does.
5. Testimonial copy you wrote. Audit every client site you built. Each testimonial should trace to a real person who really said it, ideally to a review you can open in another tab. Stock photos next to first names are the ones that get pointed at.
6. Review widgets filtered to five stars and labelled as the company’s reviews. Either show what the filter is, or show everything.

Then tell your partners before they ask. A short forwardable note this week, in their client’s language, is worth ten defensive emails in November. We sent ours on Wednesday.

AI stopped being a separate build

The platform side of the month: GoHighLevel shipped its Voice AI over the summer and has now packaged the AI pieces, voice answering, conversation handling, review reply drafts, content assist, into a bundle you enable per account. Other platforms are moving the same way.

For an agency that changes the shape of the work. In the spring an AI phone answer was a project: an account, a vendor, webhooks, someone who understood all three. Now it is a toggle, and your client’s competitor down the road can flip it too.

So the margin is not in access. It is in setup and supervision, which is the part nobody wants to do.

One commercial warning. These features meter. Voice is billed by usage on top of the platform fee, and a busy home services client can run a lot of minutes in a storm week. Do not sell an AI add-on as unlimited. Set an allowance, meter it, and put the overage in the agreement.

What goes into the offer

The pieces we are selling, and the scope we are selling them with:

• After-hours and overflow answering. Written scope: what the agent may say, what it may book, what it must hand to a person, and what it does when it does not know. Ours hands off on anything clinical, anything about money owed, and anything where the caller sounds upset.
• Speed to lead. A missed call that gets a text back inside a minute, a form that gets a reply before the person has closed the tab. This is the least glamorous thing on the list and it moves more booked work than anything else we install.
• Review reply drafting with a human approving. Replies are the business talking, which is fine. Keep every tool that writes text well away from the reviews themselves, and say so in the proposal so the client understands the line.
• A monthly transcript and recording review as a named deliverable with hours attached. Somebody has to read what the agent said and fix the script. Charge for it.

What we would not add: AI written service pages at volume. Google’s spam policies from March put scaled content abuse in writing, and a bulk content deliverable is a slow way to damage a client’s site while invoicing for it.

What to do this month

• Read the rule, then read your own proposal and CRM workflows against it before Monday.
• Delete every rating gate and every incentive from the review process across all accounts this week.
• Audit testimonials on every site you manage and remove any you cannot trace to a real customer.
• Send partners a short note explaining what changed and what you changed, before a client forwards them a newsletter about it.
• Rewrite the AI add-on as setup fee plus monthly with a usage allowance, not unlimited.
• Pick two accounts, turn on after-hours answering with a written scope, and read the transcripts weekly for a month before you sell it to anyone else.

October is a cheap month to make these changes and January is an expensive one. If you resell reviews and reputation work or you are adding AI answering to the lineup, settle the scope and the pricing now, while the rule is news and clients want to hear about it. It is the sort of change we absorb quietly for the agencies we do white-label fulfilment for.