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Advice Archives - INTEGRISHIELD

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“Turn left in 100 feet-”

“Make a U-Turn-“


Sound familiar? We’ve all been there. As thralls to technology, we tend to put our faith in the ‘GPS machine’ when going somewhere, now low and behold you didn’t make it to Grandma’s house. Instead, you ended up at a truck stop in the middle of nowhere and the pump doesn’t take cards.

Similarly, you have probably put your trust into online technology as well – and ended up in the wrong place, and now it’s too late. They’ve got your information. The phone calls have started. You might even be wondering why you’re getting several calls from people that you never remember giving your information to in the first place.

Chances are, you’ve encountered what the industry is terming, “Black Hat SEO tactics” which utilizes different techniques designed to trick not only search engine crawlers but consumers too. This results in the visitation of sites that you think are what you want. In reality, someone has mimicked the site you wanted, collected your information on their contact form, turned around and sold your information to any number of businesses.  In that same way, as you would plug a location into your GPS to find a destination, you do a similar practice when you enter for a certain phrase or term in an online search engine.

You may be asking yourself: Why does Black Hat SEO exist? Is someone policing these sites? Why did this happen to me? Well, it all comes down to one simple, cliché fact: There’s money to be had.

Three main goals for Black Hat SEO:

  1. Drive traffic onto a specific webpage.
  2. Collect your information.
  3. Sell your information.

Utilizing these sneaky techniques allow these “Black Hatters” to drive you to the pages they want. Not the site you intended.  Oftentimes, their tactics are so covert, it makes them almost unrecognizable as anything except what they’re trying to portray and what you’re looking for.

How to Spot a ‘Black Hatter’ – Methods to Their Madness

  • Hidden Text/Keywords/Links– This is when some web copy is made a text color that can’t be seen when viewing the webpage, as it blends into the background. These instances can cause you to click on hidden links as well.
  • Cloaking– A website owner creates certain information in their code which allows you to see it on a search engine, but does not actually display on the webpage you are visiting.
  • Social Network Spam– This is when web owners put multiple links on social media pages and posts.
  • Link/URL Buying– A website owner purchases links and industry branded URLs to syphon off more traffic from the original brand.

Can the Real Brand Please Stand Up?

All of these techniques make it difficult for the average prospective consumer to feel good about whom they’re sharing their information with, and which sites are legitimate. While Black Hat SEO techniques are not recommended and viewed negatively, some web admins will do the unthinkable and go the extra mile to include hidden techniques to gain more views and traffic on their webpage! The end resulting in the consumer being mislead, their private information sold many times over, and often the real brand losing credibility to their prospects. Having the man power to locate, research, find and nail these culprits aren’t typically within a brand’s personnel bandwidth. Therefore, the trend to combat them has been to contract with third parties who do this on their behalf, and on a continual basis. After all, new content is created every day.

Surfing the web can get pretty dicey nowadays. *In fact, since 2016, on average in education for every 12 websites found, at least 1 of them contains a violation under the Federal Trade Commission (FTC), Department of Education (ED) or Consumer Financial Protection Bureau (CFPB). That ratio is even higher within the finance industry where 1-in-4 sites contain a FTC, CFPB violation – all of which are deceptive to consumers and eat away at the integrity of legitimate brands.

If you have a site, you think warrants investigation, let us know by emailing: verify@integrishield.com.

*Information based on total client data.

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(As originally published in Career Education Review)

Email marketing is an important strategy to maximize your marketing ROI. Unfortunately, many schools don’t adequately monitor authorized and unauthorized email traffic. IntegriShield hosted a recent compliance webinar with guest speaker Adam Schimsa of LashBack. Our conversation explored regulations and best practices surrounding email marketing.

In a recent webinar survey, only 29% of respondents reported feeling very confident that their organization and its affiliates are following CAN-SPAM regulations. While there are plenty of ways to run into fines and litigation for compliance violations, this article will explore the important layers of email compliance that can help protect your brand and bottom line – plus we’ll share other elements to monitor.

What is CAN-SPAM?

The CAN-SPAM Act of 2003 outlines rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have you stop emailing them. What it does not do is require prior express consent. This makes email an extremely viable option for marketers who did not receive consent for text or calling. If your school’s email marketing campaign violates CAN-SPAM regulation it could quickly add up to costly fines.

Basic requirements:

  1. Don’t use false or misleading header information. Identify the person or business who initiated the message.
  2. Don’t use deceptive subject lines. The subject line must accurately reflect the content of the message.
  3. Identify the message as an ad. The law gives you a lot of leeway in how to do this, but you must disclose clearly and conspicuously that your message is an advertisement.
  4. Tell recipients where you’re located. Your message must include your valid physical postal address.
  5. Tell recipients how to opt-out of receiving future email from you. Again be clear and conspicuous on how the recipient can unsubscribe from your emails.
  6. Honor opt-out requests promptly. Any opt-out mechanism you offer must be able to process requests for at least 30 days after you send your message. You must honor a recipient’s opt-out request within 10 business days.
  7. Monitor what others are doing on your behalf. The advertiser is responsible.

Regulations, Obligations, and Common Misconceptions

The Federal Trade Commission (FTC) says you can’t contract away your legal responsibility to comply with the law. So any agreements you have with third parties will not protect you, even if you don’t know what those third parties are doing. Penalties for FTC violations could cost you up to $16,000 for each email.

Many schools that use lead generators tend to think of these as domains where they have a branded page or directory listing. They don’t often consider how the lead was generated on the back-end. Unless the affiliate you are working with does not use email, you probably average about 10 email publishers working with each of your affiliates. Some have more or less and there are always those who generate strictly through organic or paid search advertising. It should be a question you ask during the vetting process.

There are several misconceptions that schools have about email. Many don’t believe they are using much email marketing to be at risk mainly because they are not shown or seeded on the emails that contain their brand. But the odds are you are probably using more than you think, and putting yourself at risk of more exposure than you may be aware. For example, if you’re running a traditional lead generation program with an affiliate and are delivered a genuine, quality lead that is interested in attending your school, he or she may have been driven to the initial lead form by a deceptive brand email generated by one of the affiliate’s publishers. In this case, there is legitimate exposure for the advertiser, the lead generator and all parties in-between.

On the other hand, many schools believe they are protected because they only use trusted partners and practice seeding, which eliminates their concerns. While seeding is important and necessary, it’s important to note your visibility is eliminated once that seed is deleted and you can’t monitor what you can’t see. It’s not worth the risk to rely on assurances.

Regulations to consider when sending email:

  1. CAN-SPAM Basics
    • Content Compliance
    • Unsubscribe Compliance
    • Sending and Data Compliance
  2. California Business & Professions Code
  3. Other State-Based Regulation
  4. Canada’s Anti-Spam Legislation
  5. EDU Standards and Best Practices
    • GE statements
  6. Corporate Policy/Specific Advertiser Requirements
  7. Obligation to Monitor Your Partners

Reasons to Love Email

There are several reasons email marketing should be making a come-back in your school’s marketing program. Year-after-year email has dominated the top spot for marketers in terms of median ROI and usage. According to McKinsey & Company, 91% of all US consumers still use email daily and email prompts purchases at a rate that is at least three times higher than social media.

No required prior consent is another benefit mentioned previously, but remember to keep your unsubscribe list up-to-date.

Common Pitfalls and How to Avoid Them

When marketers are found in violation of CAN-SPAM law, the following are issues that appear frequently in these SPAM cases:

  1. Misused “from” domains, which include third-party domains like @gmail.com prohibit spamming
  2. Misleading friendly “froms”, don’t use generic or misleading friendly from lines such as “Approval Department”
  3. Proxy-registered “from” domains, brands can’t use not-readily-traceable domain names
  4. Misleading subject lines, don’t use subject lines like “Approved” or “Your request has been accepted”

Remember to always consult your legal counsel for advice on how to protect your brand from compliance missteps. The following are common sense steps from non-lawyers.

Do not allow the use of major email provider “from” domains. Misleading subject lines – such as “Approved” or “Your request has been accepted”— are among the most common claims, closely followed by friendly “from” issues. At a minimum do not allow the use of the most egregious, frequently cited terms. Do not allow the use of proxy-registered domains because they are easily identified and addressed.

Compliance vs. Delivery Performance

According to LashBack data, analyzing more than 200 million email messages, the following chart illustrates trends and observations on email quality.

Messages with no compliance issues are 12% more likely to reach the inbox than those with at least one; emails with three or more issues are 34% less likely. Clean, relevant content gets delivered. This may be a shift in mentality for many tenured publishers. In fact, LashBack cites messages that are only missing a postal address makes your content 59% less likely to reach the inbox.

Take a look at the different violation subsets and observations on how often they occur among email marketers.

For Higher Education marketers, the data provided by LashBack in our recent webinar should be enlightening as to how much email is really being successfully delivered in the EDU sector – compared to other industries such as auto, loan, etc. Education messages ranked second by inbox percentage, meaning emails containing the keyword “education” experienced 74% delivery to recipient inboxes. Dating made up the greatest number of messages sent, but not necessarily delivered while Health led with the greatest number reaching the inbox.

  1. Across LashBack’s data since August 2016, mail being delivered to the inbox of Gmail users averaged 31% as compared to 56% for Yahoo and 53% for all other email providers.
  2. Looking at delivery, since August 2016, based on 6 keywords:

Can We Really Monitor?

Yes, we can. Monitoring email requires access to millions of emails daily across numerous internet and email service providers. Outsourcing is really the only way to go. An email monitoring company would have access to pull these emails into a database and filter in various ways allowing you to see what consumers are receiving from your brand. From there you would need to identify violations and research to identify the publisher who sent the email. To make your email monitoring process most effective, look for a vendor that has access to the most email service providers.

Most emails will link out to domains, such as landing pages or other lead gen sites. Publishers often exclude their name on an email which makes it challenging to identify who sent the communication. If you are already monitoring the web through a compliance monitoring company, they should be able to help you tie the publisher back to the affiliate. The benefit to this is not only speedy remediation, but it also gives you insight into your affiliate networks and their publishers.


Email marketing is an important strategy to maximize your marketing ROI. Fortunately, advertisers are becoming more aware of the risk involved with the use of third-party affiliates and publishers. Affiliates themselves are becoming increasingly persistent in their efforts to curb bad actors in their own networks. With businesses’ self-regulation efforts increasing, some marketers are just now getting a glimpse at the infringement and brand violations that exist.

The good news is there are tools to mitigate your exposure and risk, better manage your brand and reduce compliance costs by automating monitoring and remediation. As advertisers, we work hard to build brands. Driving a higher standard, for not only your proprietary marketing, but also for your third-party marketers is crucial to maintaining a positive brand image.

Hopefully you’ve gained new insight to help you better monitor authorized and unauthorized email traffic. As you work to implement more compliance email marketing practices it’s important to keep an eye on other channels that could be putting your brand at risk. Compliance and policy risks are manageable. Practicing a closed-loop compliance process will help protect your brand and bottom line. The information provided does not constitute legal advice. Contact your attorney for more information on the topics presented.

Source: IntegriShield and LashBack (Producer). (2017). Are you ready for a costly lawsuit? Compliance for Email Marketing [Video Webinar]

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We’ve seen them popping up all over the Internet and we’re definitely not happy about it. Sites are promising students with college loan debt, loan forgiveness and complete debt relief. This all sounds great to a student who may be thousands of dollars in debt. However, what these sites are not telling students is that they are charging them hundreds of dollars to fill out government forms that the students can complete for free. Often times it is paperwork to lower monthly payments or to consolidate loans that will lower the student’s monthly payments—not to forgive student loan debt.

These sites have been using Social Media, such as Facebook, Instagram and Twitter, to drive traffic to their pages. They use the name of schools in their post to get users to click to their site.

In March, the Consumer Financial Protection Bureau (CFPB) put in a request to have a federal district court make a final judgement that would shut down a student debt relief scheme. With a ruling in place, this will set a precedent for other similar sites who are operating under the same process.

Here are a few actions you can take to ensure your students and alumni don’t get targeted:

  • Educate
    • Make sure students are familiar with any loans they are taking out for their education.
    • Create documents to inform students of their options when it comes to loan repayment.
  • Communicate
    • Create an e-mail account where students can ask questions about loan forgiveness, debt relief, loan repayment and consolidation.
  • Utilize Social Media
    • Post helpful tips for students and alumni to be able to identify sites that may be scamming them.
    • Post links to legitimate resources for students to get the information and help they need.

Resources for students and alumni:

Student Loan Repayment – https://studentaid.ed.gov/sa/repay-loans

Student Loan Consolidation – https://studentaid.ed.gov/sa/repay-loans/consolidation

Student Loan Forgiveness Programs – https://studentaid.ed.gov/sa/repay-loans/forgiveness-cancellation/public-service

The CFPB has identified student loan servicing as one of its priorities over the next two years. Don’t wait to put a plan in place that monitors your online marketing and ensure your institution is not being misrepresented by unauthorized marketers. Additionally, by being proactive and educating your students you can help minimize the impact of these “debt relief” scams.

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Before large financial institutions evolved in the current banking world, it wasn’t uncommon for individuals that had a good relationship with their neighborhood bank to take out a short term loan.  By definition, that meant borrowing funds for one-year or less for an unexpected expense or to purchase a needed commodity.  Interest rates were typically higher, however banks could make hundreds of loans and earn a small profit on each which added up to a decent profit line.  Paperwork was minimal and, because they had established relationships with their customers, the risk remained relatively low.

Today, the need for these loans is just as common if not greater than before. The landscape has changed dramatically following the introduction of the Dodd-Frank Wall Street Reform and Consumer Protection Act  after one of our nation’s biggest financial crises. Small loans from a community bank now require pages and pages of onerous loan documents and the time involved for the banks to comply with new regulations make the practicability of these offers not worth the risk.  In response, the short term lending market has changed with an increase in higher risk payday loan, title loan, and cash advance lenders.  This has now grown into a $46 billion industry.

With a mandate from Dodd-Frank, the Consumer Financial Protection Bureau (CFPB) has responded to this market with a proposed rule to more clearly define terms, limits, and lending practices to help protect consumers.  While there are concerns expressed by both regulators and industry, the importance of knowing how this impacts consumers and lenders is vital.

The CFPB’s proposed ruling is “aimed at ending payday debt traps”.  Essentially the CFPB proposes to implement regulations that help ensure consumers have the ability to repay their loans and don’t fall into a cycle of re-borrowing at very high interest rates without the ability to ever repay the original loan.  At the CFPB field hearing in Kansas City on June 2, 2016, proponents of the ruling argued that all short term loans are designed to keep borrowers in this never-ending repayment cycle.  However, the industry pointed to supporting data to demonstrate that not only was short term lending essential, but only a small percentage of their customers fall into that cycle.

Well before the CFPB released its proposed rule, industry leaders began executing self-regulation efforts to protect consumers.  Advocacy organizations such as the Online Lenders Alliance (OLA) and the Community Financial Services Association of America (CFSA) formed to establish best practices, eliminate deceptive marketing and advertising, and work closely with regulators and legislators to provide quality products and services to their consumers.

What does this mean moving forward and finding new customers in this space?  The backbone to acquiring new customers has been through the use of lead generators and affiliate marketers.  These are companies that advertise products for a lender, gather potential customer information and then sell the lead to a lender.  As one strategy to advertise services to a wide audience, this can lead to one of two results:

  1. Generate a large volume of customers and provide legitimate leads on a potential borrower.
  2. Unscrupulous companies may use one particular company brand to drive traffic to another company.

In the second case, a customer is deceived into thinking he or she is submitting a request to a particular lender, yet the information never reaches that lender and other companies are provided the lead data instead.

The proposed CFPB rule will undoubtedly place additional restrictions and regulations on this industry, from requiring limits on advertising claims to narrowing the channels available to promote products and services. To sustain and grow the short term lending industry, brands must provide customers a truthful and honest shopping experience that delivers loans to the borrower as intended. As a result, the importance of protecting ones brand from misuse and using technology to remove unwanted and false instances of their brand will be paramount.

Information on the full CFPB proposed ruling can be found here:


Online Lenders Alliance:


Community Financial Services Association of America:


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When most people think of attorneys, they envision John Grisham books come to life though the magic of Hollywood. A well dressed, impressive attorney, arguing in flawless form in front of the jury and providing the final “gotcha” moment that turns the case in their favor and creates the perfect ending. But in reality, the work most attorneys do is all about keeping you from seeing the inside of a courtroom.

Think about it. When circumstances arise where clients have been faced with defending allegations or regulatory infractions and the end result is a favorable outcome due to the diligence and research done by their attorney, aren’t those the best cases where the client is spreading high praise and word of mouth about their attorney? It makes the most sense to seek out an attorney that has all the tools and resources available to them to counter allegations with factual data and evidence to prove that you, as a client, have done nothing wrong.

In the case of brand compliance and digital advertising, the key to avoiding litigation is operating in a Safe Harbor. Safe Harbor guidelines afford protection from liability or penalty under specified circumstances or if certain conditions are met. Typically, in the case of brand compliance, documentation and establishing a defined path to remediation is the key to favorable outcomes.

Here are a few considerations that you or your attorney should think about to make sure your digital advertising is documented, verified, and will be remediated in the case of an infraction.

  • What systems do you have in place to inventory all your content?
  • Do you know who is publishing your content?
  • Do you have a technology solution in place to identify infractions?
  • What documentation are you keeping when infractions are discovered?
  • Are you providing a permanent record of your remediation attempts in order to operate within a safe harbor?
  • When an infraction is identified, do you have adequate resources to remediate the issue?

Being able to answer these questions and document your system and process will help prevent that “gotcha” moment from happening to you.

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Compliant digital content has become a hot topic in many financial blogger circles. We recently sat down with Phillip Taylor, CEO at FinCon, the peer conference for the financial media community, to discuss the industry’s key compliance pain points. Below are the five topics that bloggers need to manage to maintain compliance.

Ability to add URLs and Editorial Content

Financial Bloggers sometimes struggle managing their entire URL inventory because of tedious manual updates required on each link due to content or offer changes. To combat this process you may minimize the number of URL’s or those with editorial content—limiting the potential to drive additional revenue. This does not have to be the case. By using an automated compliance monitor, you can continue to develop and build on the number of URLs and content. Don’t be a slave to the process anymore. Spend time on what’s important: Increasing your presence and growing your revenue.

Credit Card or Offer Feeds

Keeping up with credit cards and their offers can be challenging. Some blogs have lender feeds incorporated directly into their site. While this makes being compliant easier, it can limit the material they want to present to their audience. Others will manually incorporate the information into their sites, which again requires continual discovery and maintenance as these offers can change on a monthly or even weekly schedule. Top industry bloggers have found compliance automation is the key to spending less time on discovery and more time adding blog content.

Content Inventory

With the vast number of contracted publishers, affiliates and free publishers in the market, many bloggers struggle with maintaining an accurate inventory of their content and where it is located. Unlike larger companies or corporations that may hire compliance teams to review and maintain content, bloggers often are on their own to manage this task. Don’t be a slave to spreadsheets anymore. Identify strategies to automate your search for URL lists containing specific brands, content, or links.

Search Phrases and Link requirements

There are many variables on how content can be presented to stay compliant. Do you include links to drive traffic to other URLs? Creating an efficient system to display content regarding links and where they point creates additional challenges to the blogging industry. Compliance automation will not only pick up the link copy as shown on the URL, but can also display where it being directed. To assist with requirements for certain language before and/or after a link, seek technology that is smart enough to search and flag instances of potential deviations to the required content.


Bloggers must be mindful of exact wording and phrasing mentioned with offers. Include additionally required disclosures from other regulatory bodies such as the FTC, FCC, CFPB and State Attorney Generals. A good compliance monitoring partner will have rule sets to help you navigate policy and guidance to mitigate your risk.

Considering these five areas will help bloggers maintain compliance in this growing industry. Take control of your digital content to avoid compliance infractions and protect your brand. As you develop a process to manage this content, remember: consistency is key.

For more information on compliance monitoring, contact IntegriShield at 888-547-7110.

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In 2015 the Federal Communications Commission (FCC) outlined new rules regarding the Telephone Consumer Protection Act (TCPA). This anticipated ruling brought into light the definition of “capacity” with respect to “automatic telephone dialing system”.

Let’s take a look at what this means for your organization and how you can maintain compliance in 2016. We’ll start with the FCC’s definition of the autodialer in the Declaratory Ruling.

Scope and Definition of an Autodialer

equipment which has the capacity

(A) to store or produce telephone numbers to be called, using a random or sequential number generator; and

(B) to dial such numbers. 47 U.S.C. § 227(a)(1) (emphasis added).

The FCC concluded that “the TCPA’s use of ‘capacity’ does not exempt equipment that lacks the ‘present ability’ to dial randomly or sequentially.” Rather, “the capacity of an autodialer is not limited to its current configuration but also includes its potential functionalities.” This clarification of the definition of an autodialer is really important, because it voids the widely adopted strategy of manually dialing mobile phone numbers. If the phone you are using to manually dial mobile phone numbers is still considered an autodialer under the law, it doesn’t matter if you manually dial or autodial the number.

This is especially important in the for-profit school sector as it defines what is considered consent when dealing with TCPA language in respect to prospective students. Not only is it important to gain permission once the prospective students’ identification has been established, it is imperative that there are clear steps and language to opt-out of receiving calls or text messages should the consumer decide no further contact is desired.

To learn more about the ruling and how to maintain your TCPA compliance, contact us at 888-547-7110.

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Every few months, the story repeats itself: Company X suffers a major security breach or unexpectedly enters a legal battle due to an industry compliance violation. Fortunately, there are several steps organizations can take to protect themselves. It starts with creating a “compliance culture”—a workplace operating on a set of policies that foster compliant behavior as everyday best practice.

Click here to read the full IntegriShield’s article as published in Thinking Bigger Business magazine.

This article will help you understand:
– Why a data breach is more than a “tech problem”
– Best practices for handling confidential records
– When and how to implement non-compete and non-disclosure agreements

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The first contact a potential student has with your school can make or break their choice of attendance. Is your admissions team unknowingly causing potential students to get cold feet and not follow through with an interview—or choosing your institution at all? After auditing hundreds of mystery shopping calls, we’ve compiled the list below of the four most common mistakes representatives make during first contact—and how you can avoid them.

  1. Unresponsiveness of Representatives – Potential students that do not get a call back, especially after leaving voicemails, may feel under appreciated. That the lack of response could be an indicator of what to expect after enrollment. It should be top priority for representatives to return phone calls within 24 hours. Remember, you don’t know how many institutions they might be calling to get information.
  2. Over Promising Financial Aid – At some point during communication it is important to disclose the fact that financial aid is only available to those who qualify. Without this disclosure, prospective students could be misled to believe they will receive grants and scholarships to cover tuition costs then discontinue the enrollment process as a result.
  3. Slow Response to Lead Forms – Its best practice to contact potential students submitting a lead form on an institution or vendor’s website within 24 hours. Schools often wait days or even a week to follow up. At this point the inquiry could have changed their mind, lost interest, or chosen a different institution.
  4. Unprofessional Language – Representatives need to walk a cautious line when building a rapport with prospects. It’s acceptable to try bonding with potential students by explaining how proud they were to finish school themselves, talking about their children or families, or even recounting a positive story. https://integrishield.com/your-mistakes-are-giving-prospects-cold-feet/ https://integrishield.com/your-mistakes-are-giving-prospects-cold-feet/ https://integrishield.com/your-mistakes-are-giving-prospects-cold-feet/ https://integrishield.com/your-mistakes-are-giving-prospects-cold-feet/Yet, going into financial comparatives, politics, or the foolish things they did when they were younger could make your prospects feel your institution isn’t serious.

By training your staff to avoid these common mistakes, you can help prevent cold feet and transition more prospective students into enrollments. Remember to monitor brand representatives regularly to help limit your compliance risks.

To learn more about mystery shopping click here.

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Have you seen what’s new in our compliance corner? Each week IntegriShield President, Jennifer Flood, is answering your compliance questions about marketing for lead gen, higher ed, finance and more.

To submit your questions please email Jenn directly or leave a comment below.

Click here to watch more compliance tips from the experts.

To get the latest compliance news delivered straight to your inbox remember to complete the form at the bottom of our website.

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You could be missing tens of thousands in missed revenue every year.

Unauthorized publishers are taking advantage of your brand and your inquiries. Put a stop to it. Watch the clip below to discover what this “free” advertising is really costing you.


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Your company is liable for what others do on your behalf. When your business hires an advertising agency, you might very well be paying for a third-party marketer too—even if nobody told you.

That’s because many agencies will subcontract with third-party firms to handle Internet advertising, landing pages and the digital side of promoting your company. These marketers can help you obtain a huge number of client leads very quickly. https://integrishield.com/fraudulent-advertising-what-nobody-tells-you/ https://integrishield.com/fraudulent-advertising-what-nobody-tells-you/ https://integrishield.com/fraudulent-advertising-what-nobody-tells-you/ https://integrishield.com/fraudulent-advertising-what-nobody-tells-you/They can position your business in front of literally millions of consumers. In most cases you and the third-party are not responsible to each other because a direct contractual relationship doesn’t exist.

So what happens when this third party marketer misrepresents your brand through fraudulent advertising? Click here to continue reading the full article on demystifying third party marketers and what you can do to protect your business.

Originally Published in: Thinking Bigger Business magazine – July 2015 (Vol.24 Issue 7)

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Do you use bloggers and social media to promote your company, school or products? The FTC has released new monitoring method requirements.

Watch as our president, Jennifer Flood, explains how that may impact your organization:

Follow IntegriShield on Twitter and LinkedIn for more compliance news.

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If you have difficulty connecting with graduates for placement verification, you’re not alone. From a recent poll we hosted of a sample of proprietary schools, we found that most institutions spend a significant amount of time in contact attempts to graduates.

Often, graduates may have changed their primary form of contact. When accreditation and Title IV funding hang in the balance, not having the correct information is frustrating.

Poll Results

  • 62% of our sample said that it was difficult to verify employment for graduates 15-25% of the time.
  • 32% said that it was difficult to verify employment for graduates 25-50% of the time.
  • 3% said that it was difficult to verify employment for graduates greater than 50% of the time.
  • 3% said that it was difficult to verify employment for graduates 0-15% of the time.

Next Steps

If verifying employment for graduates in a timely manner is an area of concern, download your Verification Playbook to gain insight on how to improve contact rates and increase accuracy.

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Institutions are under strict scrutiny surrounding their online advertising efforts. But, it’s also imperative for the institution’s website to be in compliance with the standards and regulations set forth by the Department of Education (DOE), Federal Trade Commission (FTC), Federal Communications Commission (FCC), your accrediting body and industry standards. Below is a checklist of points to consider when reviewing the information provided on your website.

Compliant Website Checklist:


  • Visibility of accreditation statement
  • Representation of accreditation – full and complete accreditation information – acronyms and banned terms omitted
  • Easily navigable – at least within one click of the homepage


  • Provide all required criteria expected to be completed prior to enrollment
  • Include all educational requirements
  • Contact information provided for prospective students

Career Services

  • Detailed and clear explanation of offerings that the Career Services department provides
  • No job placement guarantees
  • Omission of banned terms, such as “career placement”

Gainful Employment Disclosures

  • Clear presence of disclosure information
  • Disclosure information is in the required Gainful Employment Disclosure Template developed by the DOE

Financial Aid

  • Qualification rules
  • How applicants can learn about qualifying
  • Financial aid eligibility disclaimer present

Program Descriptions

  • Timeframe for completion listed correctly
  • Program length disclaimer

Program Listings

  • Listings are accurate and approved by the DOE
  • Acceptable states for admissions
  • Citations provided for statistics listed on the page

TCPA Requirements

  • Consent language present on lead form
  • Language must include all components within the FCC definition


  • Must be actual statements
  • Some accreditors do not allow institutions to use testimonials from current students on their website

Stay tuned for our next webinar where we’ll cover this topic in more depth! Get early access to webinar information.  (opens in a new window)

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In America, unemployment is twice as high for those with high school diplomas versus a 4 year college graduate. However, that doesn’t mean high school graduates need to spend the time or money on a 4-year school.

Millions of trade industry jobs are open and ready for those with specific job skills training, some even paying more than the average 4 year college graduate’s starting salary. Those from the baby boom era are coming close to retirement and more of these trade jobs will be available for millennials. There are around 600,000 electrician positions today and half of these will become available within 10 years. Baby boomers will be retiring from trades and America will need more young people trained to take over these positions. However, not enough young people will have the opportunity to gain the proper training due to the removal of vocational programs in high schools.

Thankfully, the private-sector colleges and universities are available to make up for the lack of encouragement high school students are receiving. Private-sector schools are a necessity to educate those in the trades industry since the skills that students learn are job specific and are usually taught by individuals that have worked in the field.

Private-sector schools have strengths over the typical 4-year state school. The faculty members are dedicated to watching their students succeed, often taking extra measures such as tutoring and one-on-one learning. Private-sector schools are focused on helping place graduates in jobs specific to the training they received. Small class sizes and hands-on learning are additional benefits to a student’s experience.

For millennials looking for an alternative to the expense and time of a 4-year state school, take a look into the trades industry. There are many opportunities to gain the job specific training needed and succeed in a fast paced industry.

For more information on the economic impact of trade jobs visit the Association of Private Sector Colleges and Universities’ Knowledge Center.

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In the higher education field, we all know that distance learning is the way of the future. Online learning has provided many people with the access to receive a quality education when, in the past, they have not had this opportunity. However, taking away the face-to-face aspect of education has allowed some individuals to abuse this opportunity. With the increase in the amount of people utilizing online learning, we also see a significant increase in the amount of financial aid fraud that is happening. Groups of people are starting financial aid fraud rings and making off with hundreds of thousands of dollars in Department of Education financial aid funds.

How do they do it?

These groups, which can consist of any number of individuals, submit multiple financial aid applications to schools. Typically, these schools are focused on online learning and have a low tuition cost. The individuals do the bare minimum in the courses they have elected to take to make sure they meet the participation requirements. Once they have received the excess of their financial aid funds, they disappear.

How can you detect this activity?

There are a couple different things you can look for:

  • Multiple FAFSA applications submitted using the same IP address.
  • Multiple FAFSA applications submitted using the same address, phone number, e-mail address etc.
  • Multiple FAFSA applications submitted from the same area with similar household situations (i.e. single parent households with one or more children).
  • Offenders typically pester the financial aid staff for information on when they will receive their funds. They can become aggressive and will threaten to report the person or the school to their congressman or the Department of Education.

How do you handle these situations?

  • Delay the financial aid process for these individuals as much as possible. Select for verification or require participation in online orientations or other lengthy processes.
  • If possible, set up a team of a few people from different departments to specifically identify and handle such cases.
  • Delay the posting of financial aid funds on suspicious students.
  • Report any suspicious activity to the Office of the Inspector General.

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Knowing where and how your school appears is virtually a full-time job in and of itself in the vast community of online marketing. Whether or not your school contracts with a third-party vendor for the purpose of lead generation and online presence, the unauthorized use of your brand is a consistent problem.

Many schools are typically unaware of the extent of their brands’ presence on third-party websites and lead forms. Even institutions that do not buy leads still exist on the web and lead forms are readily available when paired with certain key terms. Unauthorized use of your school name allows room for the possibility of bait and switch techniques.

You might ask yourself:

  • We don’t work with this website, so how heavily is it actually trafficked?
  • How many potential students per month or per year are utilizing the lead form found on this page?
  • Since we don’t purchase online leads, who receives this information?
  • What is done with lead information after it is submitted by the prospective student?

Deceptive advertising is a growing problem in the EDU space, and it is important to stay ahead of the game. A prospective student’s information in the hands of someone else or a competitor is of no use to you and can serve as a direct cut to your company’s revenue.

In order to prevent the possibility of baiting and switching of your brand, it is important to employ routine monitoring to identify how and where your school is being advertised. If you buy leads from online vendors, confirm that sites you find are part of their affiliate networks and that they’re meeting compliance regulations.

To learn more about compliance monitoring and brand management, call 888-547-7110 or email IntegriShield today.

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Recently, LinkedIn announced the launch of University Pages, providing another channel for colleges to reach perspective students. According to LinkedIn more than 200 schools have created profile pages.

The new college profiles will include a breakdown of:

–          Number of alumni on LinkedIn.

–          Main fields of employment for graduates.

–          Top employers of alumni.

–          General student body information.

In addition to University Pages, LinkedIn announced updates to their terms of service, lowering the minimum age for users in the United States from 18 to 14 years of age, allowing high school students to explore schools worldwide. This update, making LinkedIn accessible to high school students, will begin September 12th. Not only will this increase membership, but more so will provide LinkedIn a prime opportunity to reach the younger market.

As LinkedIn’s University Pages expand, so will IntegriShield’s effort to monitor higher education and gainful employment in the social media realm. IntegriShield’s Managing Director, Jennifer Flood commented, “As the internet expands, so does the possibility of non-compliant brand messaging. This is why utilizing a compliance monitoring tool is invaluable to schools.”

For more information please visit:  http://www.linkedin.com/edu/?trk=blog

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Change has been a main focus for the Obama administration from the start of his 2008 campaign, and after Tuesday night’s State of the Union Address it is apparent that change is on the horizon for the for-profit education sector. As the status quo currently stands, access to federal aid is granted through individual accrediting organizations, each holding a separate set of standards and requirements for qualification. web service security . As stated in the supplemental document released by the White House following the address, “the government currently provides more than $150 billion each year in direct loan and grant aid for America’s students.” With the current economic restraints, the administration is going to tighten what some colleges already consider strict regulations to qualify for Title IV funds.

The Obama administration’s proposed changes to the status quo

The President will call on Congress to consider value, affordability, and student outcomes in making determinations about which colleges and universities receive access to federal student aid, either by incorporating measures of value and affordability into the existing accreditation system; or by establishing a new, alternative system of accreditation that would provide pathways for higher education models and colleges to receive federal student aid based on performance and results.

The administration also proposed a new College Scorecard that will require colleges to provide clear and accurate information on transparent levels that have not been reached in past years. This scorecard will in turn provide prospective students another tool as they search for higher education.

What this means for Compliance

For 2013 compliance is going to take a leading role as regulations in higher education are released throughout the remainder of the year. With the outbreak of compliance in 2012 for-profit colleges will have to once again shape up their advertising efforts to ensure Title IV funding.

For more Information and the Full Report:



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Top 5 Compliance Mistakes Your Admissions Staff Could Unknowingly be Making

With the constant changes of brand and compliance regulations, your admissions staff could be violating numerous regulations unknowingly. Make sure your admissions staff are not making these common slip ups.

1)Failing to state that financial aid is only available to those who qualify

  • Even though the majority of the Admissions Department is not trained in financial aid, each time financial aid is mentioned they must state that it is only available to those who qualify.

2)Providing the total length to complete a program

  • There are many variables that factor in to how fast a student can complete a program. Many of these variables cannot be controlled by the school. Even though there is an average length, representatives must state that length pertains to the normal time it takes to graduate. The length of a program cannot be guaranteed.

3)Providing the total program cost

  • Unless your school guarantees a set price for tuition no matter how long the student takes to complete the program, your staff must state that the total cost pertains to graduating in the normal time.

4)Stating that job placement is provided

  • Even though many schools have Career Service Departments, admission staffs must be careful when using the phrase “Job Placement.” We suggest using the term “Career Assistance,” or simply stating that your school does not guarantee job placement.

5)Transfer Credit Discussions

  • Your staff most likely encounters many credit transfer questions throughout the day, and while your admissions staff may feel comfortable discussing credit transfer we recommend they tread lightly. Even if your school has an articulation agreement with another college, we recommend that your staff simply state that credit transfer depends on the accepting school and refer all further questions to the Registrar’s Office.

While these are some of the more common mistakes made, there are numerous additional mistakes that can be made throughout the admissions process. IntegriShield can help protect your company from the disaster that can occur when your school violates regulations. Contact us today for more information.


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"The quality service that IntegriShield provides gives me peace of mind regarding compliance. They work as an extension of my department to identify and resolve any misrepresentation found and serve as a resource to me regarding specific compliance questions. I highly recommend them for institutions who need a partner not a vendor." - Mary Wetzel, Central Penn College


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