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Compliance Archives - INTEGRISHIELD

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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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[As published in Beauty Link Magazine by AACS]

Student outcomes are an increasing focal point for accreditors and the U.S. Department of Education (DOE). The final chapter in the student life-cycle now demands more detailed reporting than ever before.  If collecting accurate information from recent graduates has become a challenge for your team, then you are not alone.

This article will share insight on how your institution can prepare for the changing environment and improve your employment verification process.

Regulating Accountability

Back in late 2016 Democratic Senators Elizabeth Warren (D-MA), Dick Durbin (D-Ill) and Brian Schatz (D-HI) introduced new legislation aimed at improving the college accreditation process.

The Accreditation Reform and Enhanced Accountability Act (AREAA) would address strengthening accreditation standards and requiring accreditation agencies to be more responsive to allegations of misconduct.  Under the act, the Department of Education would be empowered to require accreditors to consider a variety of student success metrics when determining eligibility — including “retention rate, graduation and payment rate, transfer rate, student earnings after graduation, and job placement rates.” —. The DOE is currently prohibited from setting such standards.  Accreditors would also be required to respond more quickly when their certified colleges come under federal or state investigation or face lawsuits for “fraud or abuse, deceptive practices, or material harm to students enrolled.”

AREAA would also restrict “conflict of interest” in the accreditation process by prohibiting individuals holding administrative and other roles, or individuals with financial stakes in an institution, from being involved in the certification process of that school. The bill also bars federally registered lobbyists from participating in that same certification process.

Increased pressure on accreditors may result in increased pressure on your school team to produce more detailed graduate data. To help simplify the process, consider dissecting your employment verification into three phases.

Phase One – Preparing for a Changing Environment

The Information for Financial Aid Professionals (IFAP) website provides federal regulatory context when gathering your placement rates. For details, you can do a search of:  IFAP Consumer Information Disclosures at a Glance, CFR 668.41(d) and 34 CFR 668.14(b)(10). Schools must make available to current and prospective students information regarding the placement in employment of, and types of employment obtained by, graduates of the school’s degree or certificate programs.

Also, schools must identify the source of the placement information, plus any timeframes and methodology associated with it.

When an institution advertises job placement rates as a means of recruiting students to enroll, it must make this data available to prospective students; at or before the time the prospective student applies for enrollment.  Here are a few items that need to be made available:

  • The most recent data regarding the graduate’s employment if relevant to the field in which they obtained their degree.
    • Remember to include any applicable methodology in obtaining this information
  • The most recent available information regarding the types of employment obtained by graduates, such as full-time, part-time, contract, etc.
    • Must also include any applicable methodology in obtaining this information
  • Any other information necessary to substantiate the truthfulness of the advertisements from the point of view of the “reasonable” consumer, including, but not limited to:
    • Applicable Student/Graduate Testimonial Affidavit
      • Express vs. Implied Claim substantiation
    • Privacy Policies and Terms
    • Sufficient Evidence to Support the Advertising Claim (i.e. survey results, etc.)
    • Consumer Disclosure Information
  • Relevant state licensing requirements for the profession which the course of instruction is designed to prepare students.

Phase Two – Third Party Verification

With an understanding of the regulatory environment, the next phase explores four simple ways to go the “extra mile” in providing detailed reporting of employment verification. While assisting in placement can be a struggle, proper reporting is just as important to validate the hard work it takes to assist individuals after graduation. Whether you work in-house or with a third-party verifier, remember to record all follow-up attempts and verifications of the following areas:

Job Description

A job title is not always enough to collect. Titles can sometimes be vague; even when they are not, they cannot completely define an individual’s role in employment. For example, a cosmetology graduate working at a beauty salon does not necessarily prove the individual is utilizing the skills learned during his or her program.  Identifying the graduate’s tasks or responsibilities can more clearly relate education to professional status.

Hire Date and Duration

A hire date can validate the education an individual received. Showing that hire dates are within a reasonable amount of time following program completion offers relevance in the education choice made by the individual.

Contact Information

Always cite your sources. If you are meeting with a supervisor that is verifying the employment of one of your graduates, get their name. If you are talking to them on the phone, be sure to record the phone number that you used to reach them. This information is crucial in the event of an audit, as the auditor will most likely be utilizing that same information you collected during your graduate employment verification process.

Get Employer Feedback

Employers may offer some constructive criticism on your modules. For example, maybe there are newer standards employers seek during the hiring process. This feedback can help enhance your programs, keeping them up-to-date with the trends of the industry, and keep your graduates best prepared when trying to enter the workforce. Feedback can also help with maintaining employer relations, especially being alerted to any potential openings that employers may have that can be filled by your graduates.

But what happens when you have an unverified graduate? One major obstacle when it comes to graduate reporting is actually finding them. Some third-party verifiers can help with this process and expand on your own efforts with access to new employment databases. On the other hand, if you encounter a graduate with an “unemployed” status, it is important to have a process for following up with these individuals. Whether the communication is done in-house or through a third-party, you may consider providing placement assistance or additional time to seek employment.

Occasionally you will find graduates who are not going to work in their field for a valid reason, such as active military duty or continued education. A Waiver of Placement, indicating that said graduate does not wish to OR is unable to pursue employment in regards to the field in which they obtained their degree, should be recorded for these individuals. An example to consider: If a massage therapy student graduates with a certificate in Massage Therapy, but later is steadily and happily employed in accounting, then a waiver of placement would apply because he or she would most likely not be using the earned certificate in Massage Therapy. Remember to collect details on timeframe and written & electronic signatures for your records.

Phase Three – Data for Institutional Improvement

Finally there are several changes you can make in this phase to improve your graduate data. Start with refining graduate questionnaires to address report “buckets”. Layer questions to collect as much information as possible. Offer multiple choices and prioritize most important information at the beginning.

If you are using a third-party, make sure this relationship is clear to all graduates and develop a formal methodology statement on how you gather graduate information for your accreditor. Obtain signatures of approval for contacting a graduate’s employer during the exit process. Explain the “why” to help improve your process for confirming and processing your graduates. Be openly communicative with students on the information you want to collect, why it will be collected and any confidentiality requirements.

As regulators and accreditors focus more on the final chapter of the student life-cycle it is important to start optimizing your process now to gather more accurate graduate data. Hopefully these three phases will serve as a starting point to help your team navigate through the challenges of employment verification. Whether you manage this process in-house or through a third-party vendor, it’s time to prepare for the changing environment and be vigilant with your compliance.

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Donald Trump is the President-elect of the United States. Now what? Well, one thing people keep questioning: “What does this mean for education?” Those who have followed the debates know Trump has been vague over what his major actions might be, but plans to mention his intentions in the near future. Answering most of the questions, his co-chair, Sam Clovis has taken over information regarding higher education, college costs, student loans, and accountability.

Student loans remain a major concern with many Americans. Trump believes local banks should be lending to local students. Therefore, he wants to move the government out of lending and restore that role to private banks. He wants colleges to play a role in determining loan worthiness on factors beyond family income, ensuring that colleges and universities have “skin in the game” when it comes to student loan default. For example, under this plan colleges should not be admitting students without confidence they will graduate in a reasonable time frame and find jobs.

One question that keeps arising: “How can borrowers save under Trump’s student loan repayment plan?” If campaign promises are upheld, some borrowers who took out federal student loans and use an income-based repayment plan may come out on top. No plan is ever perfect; the administration’s proposal comes with trade-offs. Additionally, borrowers will have higher monthly payments under the new repayment plan, but would have their student loan debt forgiven sooner. Here are some of the details:

  • Borrowers contribute 12.5 percent of their income if they chose a repayment plan instead of 10 percent required under current repayment plans.
  • After 15 years in a repayment plan, borrowers could have their debt forgiven.
  • Currently, borrowers in repayment plans have to wait 20 years or 25 years to have their loans forgiven

Now, this plan may sound like an amazing idea, but how will he be able to succeed? Trump can do this without Congress. When it comes to creating a new repayment plan for federal student loans, this doesn’t require Congress to act. The Department of Education created new repayment plans under the Obama administration, Ex. Revised Pay As You Earn (REPAYE). “This could be implemented entirely through the regulatory process,” said Mark Kantrowitz, publisher and vice president of strategy at Cappex.com, which connects students with colleges and scholarships.

Trump’s campaign plan is to encourage colleges to focus on serving students who can succeed, but there are always risks. He has noted student loans must be significant enough for the lenders changing the way colleges decide whether to admit students and what programs they offer. This is what Trump’s co-chair had to say on the situation: “If you are going to study 16th-century French art, more power to you,” Clovis said. “I support the arts. But you are not going to get a job.”

The President-elect’s plan comes in to help higher education. The Republican platform calls for new systems of learning, including technical institutions, online universities, lifelong learning, and work-based learning in the private sector. Although Trump has been vague when it comes to this topic, there is a plan and his plan is to succeed.

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Today, regulatory scrutiny, politicizing industries and consumer activists have brought significant changes to how we market to and sell our products.  Lead flow is down in many industries, conversion from third-party marketing has dropped and compliance expenses are up.

So how do we pivot away from this story line and connect the gap between lead conversions and compliance data?

  1. Put compliance first to confidently work all leads.
  2. Collect detailed lead data.
  3. Remediate instead of wasting a lead and/or source.
  4. Make integrated marketing decisions.

We dive into the strategy behind each of these points in the latest April 2017 issue of FeedFront Magazine.

Click here to continue reading the full article on “Conversions vs. Compliance”.

You’ll learn how to integrate and have both because being compliant with marketing regulations doesn’t mean your lead generation should suffer.

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What opportunities are you missing for them to work together?

Businesses have the opportunity to gather and analyze data at an increasing rate.  Whether it is customer conversion data, compliance or call center functions, these databases are typically housed in separate locations and the data is rarely integrated.  How do businesses tie this information together to find actionable intelligence and make sound business decisions?  Let’s take a look at some opportunities you may be missing if you are experiencing the gap left between conversion and compliance data.

Years ago when leads were flowing in and volume was king, compliance wasn’t much of an issue—or at least one we spent much time on.  Sales were up, reps could cherry pick, and most marketers didn’t have a real understanding of third party lead generation.  They liked getting thousands of cheap leads.  Skip to today, regulatory scrutiny, politicizing industries and public outcry have brought significant changes to how we market to and sell our products.  Lead flow is down in many industries, conversion from third-party marketing has dropped and compliance expenses are up.

So how do we pivot away from this storyline?  I spent nearly 10 years talking to businesses about how to improve lead volume and quality to increase sales.  Many times the first response was “just shut it off”.  As an owner or employee committed to doing what is best for the business, it’s easy to lean heavy on the compliance side, or toward what’s best for conversion.  It doesn’t have to be one or the other. Whichever way you lean, no one wants to continue a path toward extinction—so change we must.  Change the way we think about, and act on, the data we have.

  1. Put compliance first to confidently work all leads you get your hands on. Check your audit process to see if it includes all aspects that would make a lead contactable and compliant upon receipt.  IntegriShield found that 9% of an advertiser’s infractions are from missing, or non-compliant, consumer consent and disclosure language.

Waiting to see if a lead is compliant until after you get doesn’t really help you.  Examine all the lead pages you own and are affiliated with to ensure they have compliant Opt-In language. Otherwise, you end up returning the leads or eating the costs.  It could also result in a good traffic source being shut off for something easily fixed.  If a lead slips by and you do work it, the fines and potential civil penalties could put you out of business.

  1. Collect all the lead data you can. Some of the basics include:
    • Lead Type
    • Vendor
    • Affiliate Codes
    • Referral URL
    • Campaign
    • Date
    • Form or Call In
    • Customer Data
    • Status
    • Price
    • Consumer Consent Authorization
    • Lead Integrity Data

You’ll need objective data to make good marketing decisions. If you don’t have all of your data aggregated, this will take more time, but it can still be done.  Better yet, ask your service providers if they can integrate with other systems.

  1. Scrub and remediate instead of wasting a lead or a source.By this point you’ve been proactive and tried to ensure all your vendor pages are compliant.  You may find many leads come from pages you had no idea exist.  It’s not uncommon nor is it something that has to be shut down.  You will likely never know all the affiliate, publisher, and traffic channels your lead generators enlist at any given moment in time.  Audit the URLs the leads are coming from and if they are not compliant, make them compliant.

Keep your lead channels open if at all possible.  If the site is misleading or you see any bait and switch tactics, that’s when you shut it down.  Don’t mess around with bad actors.  There is too much risk in the current regulatory environment.  We have found that 28% of total advertiser infractions are due to misleading content on URLs and 6% contained banned terminology.

Beyond marketing content, it’s also important to maintain customer files.  Scrub customer data to ensure contact compliance.  Don’t just remove it.  About a month before a lead would be scrubbed out, send a notice to see if he or she would like to stay opted in and if so, restart the clock on them.  Even if only a small percentage opts back in, sales will know who is still engaged and you maintain as many leads active as possible.

  1. Make integrated marketing decisions.Direct Marketing is not a magic button.  It’s a series of decisions based on metrics using good data and then repeating each day, week, month, and year.  Combine the data to look at all channels and their outcomes—both conversions and compliance risk.

Tie conversion metrics to integrity and compliance scores to determine beginning allocations each month.  And remember, you can control your risk. Keep the lead pipeline open by being specific and eliminating offending publishers, but keeping the vendor “live” for all the quality sources they use.  If a vendor is not delivering, partner with them to adjust messaging to fit the types of channels they use to drive your traffic.  One set of posting instructions is easy, but it’s not always effective.

Businesses depend on lead volume and quality to drive sales.  The current trend of fear-based decision making needs to become strategic, educated decision making.  Implement compliance processes, follow them, and seek solutions before eliminating potential sales.  The tools, data, and ability to regulate your marketing exist.  With increased vulnerability has come increased control if you don’t shy away from integrating strategies.

Gayla Huber

President, IntegriShield

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Have you ever received a “free” lead in your inbox?  Depending on your personal experience, you may initially think it’s a free lead to let you sample what a particular lead generator can do for you. Or you may not even know how you actually got the lead.  What do you do?  Do you contact this prospect?  Your decision on how to handle the inquiry will determine how much the lead could cost you in the end.

There are a few variables to consider before deciding to contact a “free” lead.

  1. Do you know where the lead came from? Even if the lead source is listed, it’s important to know how it was generated to result in a consumer providing their information.  Did he or she know they were inquiring specifically for a product from your brand?  While you may not be able to track back the full path, at a minimum, check out the referring URL to ensure no bait and switch tactics were used.
  2. Did the consumer consent to contact, and in what forms? If you received a consumer’s contact information, it’s important that they consented to be contacted.  Because the lead is free, let’s make the assumption you did not provide authorized consent language. You must be able to answer…
    • What language was used?
    • Did they consent to be contacted by your business or only the lead generator?
    • Did the lead get to opt-in for TCPA consent specific to your business?

It’s important to have these answers because fines can add up quickly when it comes to consumer consent violations.

  1. Can you get access to the data collection of consent? You should also have access to opt-out data as it pertains to the consumer opting out on the lead generator side.  This is just as important as knowing if consent language and opt-in were available on the inquiry form.  Businesses are subject to fines and potential litigation for not observing opt-out requests.  This would also be helpful in opening up the option to email the consumer.  Email does not require prior consent, but once someone unsubscribes or opt-outs, a business can no longer email them unless he or she opts back in.  Without control of the consent language and the data being collected, emailing could be risky as well.

Businesses hold lead generators to higher standards today and justifiably so considering the regulatory environment.  Any source of a lead is subject to scrutiny and not knowing is not a defense.  Before you decide to contact that “free” lead, calculate the possible fines and don’t let it costs your brand money or its reputation.

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[As published on LeadsCon.com]

On August 1, 2016, The FTC’s inflation increases for maximum civil penalty amounts go into effect. You can find the Federal Register Notice containing all of the statutes and amounts here. With penalties increasing, from $16,000 to $40,000 in some instances, it’s time again to look at your business objectively and determine what risks you are willing to take. Here are some areas, business owners and caretakers of brands need to evaluate for exposure.

Police Those Who Try to Exploit Your Brand

Your business is not responsible for what others do if you are not affiliated with them. Unfortunately, that’s not enough to keep us off the regulator radar these days. Whether you are the advertiser or the lead generator, understand the pitfalls that can occur when using third parties. Objectively ask yourself, do you know everything your affiliates or publishers are doing to market on your behalf? Take it a step further and question if you think they know everything their network is doing. No one is 100% error free online, all the time. The mere appearance of not “playing by the rules” could shine a spotlight on your business where infractions could be uncovered.

An unauthorized publisher can put you at risk for regulatory scrutiny or lead to an investigation. If a consumer can’t spot a fraudulent representation of your brand online, then regulators won’t be able to notice at first glance either. It’s critical right now to monitor and enforce standards for your brand’s presence on the Internet. Create a paper trail documenting your efforts to discover and remediate infractions.

Every business is unique, but here some things you can do internally:

  1. Keep an inventory in a database or even a spreadsheet of your proprietary and authorized third party URLs.
  2. Set up a monthly audit process to review all URLs for brand, regulatory, and consumer consent compliance.
  3. Review the user path to ensure nothing was misleading up to the form and consumer consent was collected in the correct places.
  4. Take screen shots with time/date of infractions.
  5. Email the screen shots along with a request for remediation to the third party.
  6. Store all emails back and forth concerning the remediation.
  7. Schedule a quarterly Internet audit looking for domains and URLs not authorized by your brand and follow the same paper trail and remediation process.

Be Proactive Against Those Who Seek and Exploit Violations

From consumer disclosures and consent language online to contact strategies and database maintenance, leave no stone unturned when it comes to ensuring compliance. There are opportunistic individuals who target certain industries and put themselves in a position to file a complaint or take legal action. You need to get ahead of them.

Look for and monitor all forms of disclosures, consent, privacy policies, terms and conditions, and any other industry specific data or content required. It’s a common mistake to only search for where it exists on the web. Yes, we want to make sure what we know and see is unaltered, but don’t forget to look for instances where these forms have been omitted—which is a tougher search.

Contact maintenance strategies need to be reviewed and followed. Reactive responses to violations will result in fines and suits. It may surprise you how easy it is for individuals to create the exact scenarios that equip them to file a civil suit against a business. Do Not Call (DNC) violations under section 5 of the FTC Act have increased to $40,000 per instance. If you weren’t following DNC best practices, it’s time.

Despite your efforts to maintain industry compliance on a daily basis you may feel exposed on many fronts. The regulatory scrutiny has found its way into many business operations and expense columns with seemingly no reprieve. To help mitigate risks everyone must take an active role and reduce exposure. Lead generation as an industry is strong. Remember, you are not only equipped to be successful while being compliant, but you are in a good position to write the narrative.

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This spring LeadsCon invited IntegriShield out to their annual performance marketing conference in Las Vegas to present on unauthorized landing pages and self-regulation.

In between sessions, they caught up with our President Gayla Huber to learn more about the state of compliance violations in higher education and other industries.

Watch the interview below to hear from Gayla and LeadsCouncil’s Michael Ferree as they scratch the surface of industry compliance.

To learn more about how compliance trends impact your business, email info@integrishield.com or call 888-547-7110.

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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 FCC Chairman, Tom Wheeler, has requested a 

https://integrishield.com/vlog-text-messages-and-the-fcc-2/https://integrishield.com/vlog-text-messages-and-the-fcc-2/https://integrishield.com/vlog-text-messages-and-the-fcc-2/https://integrishield.com/vlog-text-messages-and-the-fcc-2/ domain list .

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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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All marketers are familiar with the wide-sweeping TCPA legislation that has been consumer focused regarding unwanted calls and text messages. Now, the FCC wants to close loopholes and has indicated more restrictions are on the horizon.

Are you unsure of the impact this may have on your organization? Watch the short 4 minute clip below as IntegriShield President Jennifer Flood answers the questions we frequently get from marketers and clients.


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In the past year, for-profit schools in Minnesota have been coming under increased scrutiny. The state’s Office of Higher Education has created a new watchdog which sends out “secret shoppers” to monitor whether schools are misleading or dealing honestly with prospective students. Schools giving misleading information about job-placement rates or how much money graduates could earn in their field are just a couple of examples that would raise concerns with these shoppers.

The new state watchdog has started to compare notes with Minnesota State Attorney General’s Office.   This this office can suspend or shut down a school that gives students misleading information, including institutions that a court or government proceeding concludes they have engaged in fraud or misrepresentation.

Monitoring your staff can shield your institution from potential fines and penalties. Some areas to proactively monitor for compliance may include:

  • Scripts: Providing scripts for your representatives to follow enables them to touch on key benefits of your institution and direct the conversation toward enrollment.
  • Citing Statistics and Job Placement: When a prospect inquires about job placement or expected salaries, statistics provided must be accompanied by an official source such as the Bureau of Labor Statistics. Employment can never be promised.
  • Financial Aid: Not every student will qualify for financial aid. It is important to provide this clarification and transfer prospective students to a financial aid representative to receive further information.

Get more tips for analyzing and improving the performance of your admission staff, email Shawn Graybill or call 888-547-7110 today.

Minnesota Increases Scrutiny of For-Profit Colleges

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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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Professionals in the education industry gathered earlier this June for the annual APSCU Convention. Hopefully you were in attendance and took advantage of the unique opportunity to collaborate with the sector’s leaders and executives. Whether you attended our breakout session or received a free compliance audit at our booth, we thank you for taking time to meet with the compliance experts at IntegriShield.

Did you catch our posts on social media about the golf ball cannon? We had the privilege of sponsoring a hole in the pre-conference golf tournament, hosted by the Imagine America Foundation (IAF). We are thrilled to announce our efforts helped to raise over $3k in student scholarship funds for IAF.

During the conference, a dialogue was ignited within our session on “A New Look at Big Data in EDU.” Presenting with Pinnacle Career Institute, we talked to a packed room about new technology that can make us better and faster with our operations in the classroom and from an administrative perspective. Attendees also learned how schools are becoming equipped to better track hundreds of graduates from enrollment through employment verification.

As a vendor we are constantly developing new products for schools to better serve students. What can you do to defend the EDU industry and advocate for the sector? Don’t wait until the 2016 conference to start these discussions. Message usand we’ll share new ideas to overcome challenges and help you understand what your institution’s growing role is in compliance and education. You can also request a free electronic copy of our APSCU presentation slides.

We look forward to speaking with you again soon!

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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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Since it’s onset in 1995, the Federal Trade Commission (FTC) has amended the Telemarketing Sales Rule (TSR) (opens in a new window) several times in order to respond to developments in telemarketing schemes. The amendments allow for liability for third parties. For example, education lead generators that have provided “substantial assistance or support” to any seller while knowing, or consciously avoiding knowing, that the seller or telemarketer is engaged in activity in violation of the TSR.

What do these amendments mean for lead educators and for-profit schools?

  1. The TSR covers calls made with multiple purposes, if one of the purposes is the sale of goods or services. So, companies who use robocalls to sell goods or services risk violating the TSR.
  1. Liability is broad under the TSR. Liability is not limited to the company that made the calls. It’s also illegal to “provide substantial assistance or support” to a seller or telemarketer when you know or consciously avoid knowing they’re violating the Rule. The TSR makes it clear that “but I wasn’t the one doing the dialing” isn’t a defense.
  1. The states and feds are united in the fight against illegal telemarketing. The FTC, Department of Justice, and State Attorney Generals remain committed to working together to protect consumers from illegal telemarketing.

How can you avoid a violation?

  • Make sure the prospective inquiry gives the educational lead generator company express written permission to call, even if their telephone number is on the national Do Not Call Registry.
  • The educational lead generator or school will not require any purchase of goods or services in order to obtain student consent.
  • Written consent must include the student’s telephone number and signature.
  • The student will receive phone calls as a result of submitting the Request for Information (RFI) form on the educational lead generator’s website (or other collateral) and checking the box that gives express permission.

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One of the prominent marketing uses in the education industry today is the use of testimonials to endorse a school. The power of a testimonial shows that success at a particular school not only can happen, but that it has happened. Using case studies to show the effectiveness of an institution’s training program certainly speaks volumes to individuals considering the lengthy commitment of returning to school.

Testimonials can go so far as to endorse a school that they can easily be used to mislead and entice individuals with exaggerated or false claims. Due to excessive use of testimonials the FTC has written guidelines on the dos and don’ts to shape education marketing compliance. Here is a list of guidelines to comply with when using testimonials in marketing materials:

  1. If a testimonial endorses a service and the result for that endorser was not a typical result, the advertiser must disclose the expected results of that service
  2. Any transaction that is made between an advertiser and the endorser must be disclosed in the advertisement
  3. Endorsers not representing “actual customers” must be adjoined with a disclaimer stating the testimonial is not from an actual customer
  4. Testimonials have timetables. If an endorser provided a testimonial at a time when they were an actual user, the testimonial must still reflect a “current” opinion of that endorser
  5. Wording cannot be distorted to endorse an advertiser

Testimonials are important as they serve as a connecting point between a successful user and a potential user. Staying in compliance for use of testimonials is just as important and can be followed given thoughtful consideration.

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Happy New Year! Looking back, 2014 was an exciting year for IntegriShield. We more than doubled our client base, grew our team significantly, expanded our software services and developed some fantastic new products for our clients. Relationships were strengthened as we continued to listen to our clients and understand the political and regulatory climate in which they operate. As with anything, we must look back to find our lessons, take note, and MOVE FORWARD!

Access to Results-Driven Experts

We have an exceptional team of professionals that work for IntegriShield—each is dedicated to the client’s needs and finds a solution to every problem. That is true professionalism and I am very grateful for the group that continues that make this a successful company. Many of them have been with the company since its inception, and the new faces have helped drive us harder into 2015. We have a culture in our company that lets the individual choose and create his or her career path. If you can think it, you can achieve it!

Setting Goals with Integrity and Innovation

Our success thrives on producing results for clients and we are on pace for 60% growth across the board. While these 2015 goals are aggressive, I remain confident that we will hit them. We can do this in the following ways:

  1. Put the client first.

We build solutions for our clients. If we continue to put them first and listen to different needs of each client, both parties will be destined for success.

  1. Continue to learn.

IntegriShield is also a consulting company providing insight for clients and others in the industry. We find opportunities to collaborate with thought leaders to enrich in the industries we serve. Visit our Webinars (opens in a new window) page to find out more!

  1. Go above and beyond.

Anyone can do just enough to get by, but IntegriShield has always been driven to do more. Work harder. Put in that extra hour. Do more research. Build one more product. We do not compete—we win.

IntegriShield has all of the tools necessary to put us over the top, which is an experience we are pleased to share with our clients. After careful preparation, the company is ready to absorb rapid growth. The processes are in place and the right staff dedicated to driving success is ready. I’m excited for 2015 and honored to be on board with them.

All The Best,

Jennifer Flood

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Over the last couple of weeks, articles have surfaced shedding light on lead generating practices that are less than exemplary. Many in the for-profit sector are concerned and unsure how to move forward. With the recent scrutiny of the industry, it is important to make sure that you are doing your best to protect your organization. IntegriShield can offer helpful tips and information to keep your organization safe.

Watch for our webinar regarding fraudulent lead generation and how you can protect your organization coming in January.

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October 30th marked the release of the final version of The Education Department’s “Gainful Employment” rule. The long awaited ruling has been a topic of much discussion and is still being contested by the Association of Private Sector College and Universities (APSCU).

While the debate ensues, here are some takeaways from the ruling:

1. Career programs are no longer accountable for their cohort default rates. The cohort default rate represents the percentage of borrowers defaulting on their student loans.

2. Instead, career programs will be weighed only for their graduates’ debt-to-earnings ratios. The debt-to-earnings ratio measures the ability of a borrower to manage payments and repay debts based on their income.

3. The Education Department expects nearly 1,400 programs to fail the rule in the first year. Programs that fail the test on multiple reviews will not be able to award federal aid to students.

The For-Profit college sector has already taken action against the Education Department. APSCU officially filed suit against the Department’s Gainful Employment ruling last week. The suit asks that the United States District Court declare the regulation unlawful and set aside the regulation.

A briefing schedule is expected to be set in the next few months.

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Your admissions staff is the face and voice of your institution, the first people to speak with your prospective students and inform them about the excellent opportunities that your school offers.  What training and initiatives are you taking to ensure that they are making every effort to bring more students in the door?  How are they answering questions surrounding compliance-related topics that have gotten so many schools into trouble?

Monitoring your staff can lead to a significant increase in conversion rates and shield your institution from potential fines and penalties.  Some areas to monitor may include:

  • Scripts: Providing scripts for your representatives to follow enables them to touch on key benefits of your institution and direct the conversation toward enrollment.
  • Setting Follow-up Appointments: With each individual communication, a representative should be scheduling the next step with the prospective student whether it be a follow-up phone call or inviting them in for a campus visit.
  • Citing Statistics and Job Placement: When a prospect inquires about job placement or expected salaries, statistics provided must be accompanied by an official source such as the Bureau of Labor Statistics. Employment can never be promised.
  • Credit Transferability: Credits will never transfer 100 percent of the time, and it is essential to clearly state that credits are subject to review by the school and cannot be guaranteed.
  • Financial Aid: Not every student will qualify for financial aid, and it is important to provide this clarification and transfer prospective students to a financial aid representative to receive further information.

Monitoring your admissions team to pinpoint areas in need of improvement is essential to overall business productivity. Not only are you able to protect your institution from the price of noncompliance and making false guarantees, you are also helping increase enrollment numbers and therefore directly amplifying your institution’s revenue.

To learn more about analyzing and improving the performance of your admissions staff, contact our Sales Team at sales@integrishield.com or call (816) 994-1313 today.

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In an attempt to bring order and transparency to the crowdfunding industry, a website named CrowdsUnite was created in 2012. Crowdfunding encourages investments in small and mid-sized businesses by allowing groups of investors to network and raise money for startup companies. It surfaced after the Jumpstart Our Business Startups (JOBS) Act was signed in 2012. However, funding efforts from non-accredited investors pose a threat to the new opportunities for businesses. With over 700 global platforms available, it can be a challenge for an individual to validate trustworthy funding sites.
CrowdsUnite creator, Alex Feldman, has since introduced consumer reviews to help combat this issue. Going on two years their website thrives with a 10% monthly growth rate of unique visitors. In the past year IntegriShield has also heightened efforts to bring the importance of brand equity to the forefront. The success of CrowdsUnite backs the importance of consumer review sites and exemplifies how such sites can make or break a company.
“Consumer review sites, such as CrowdsUnite, can be a great resource for consumers but more importantly can act as a platform to build a company’s brand equity,” noted Jennifer Flood, IntegriShield’s Managing Director. “One false or inflammatory review can severely damage a company’s brand equity, which is why my team stresses the importance of monitoring review sites for our clients.”
In response to a high-demand for compliance monitoring, IntegriShield launched Infringement Detection alongside a suite of successful compliance monitoring services. Click here to get started learning the best practice for your company to monitor your brand equity or copyrighted and trademarked material.

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The FTC joined forces this week with the Obama administration’s fight against private sector colleges. The agency released new guidelines this week in hopes to crack down on deceptive advertising, promotions, marketing and sales made by private sector colleges featuring vocational programs.

The new guidelines followed the tip sheet recently released by the FTC to help veterans better scrutinize private sector colleges, in hopes the same guidelines can help all students.

Seven of the eight comments received by the FTC submitted by numerous accrediting agencies were in favor of retaining the guidelines noting, “Many instances of fraud in the industry and urged that the guides be strengthened and enforced more vigorously.” APSCU however commented against retaining all guidelines, suggesting rather retain the guidelines only for unaccredited or unlicensed institutions stating that the guidelines were unnecessary, “and would create additional burdens for institutions that are licensed by a stat or accredited by a DOE recognized accrediting agency.”

Overall the Commission proposed four modifications to the guidelines including:

  1. Guides addressing misrepresentations of salaries, job placement, completion rates and time frames.
  2. Guides addressing misleading statements indicating that a program would render a student eligible to take a licensing exam.
  3. Guides stating that misrepresenting a student’s admissions test score as a deceptive practice, hindering their success to complete the program.
  4. Guides to address transfer of credits, assistance to language barriers, source of funding for student loans and crime statistics.

The FTC’s new guidelines went effective November 18th 2013. Contact IntegriShield today and make sure your institution is in compliance with the new guidelines.

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Maintaining the integrity of brands online has become a difficult task for many companies with limited resources and expertise of online copyright infringement. The internet offers an enormous platform for third-party websites to infringe upon privileged material for the purposes of financial gain. Isolating infringing material online and enforcing timely action to remove infringing items from Internet Service Provider’s websites can be tedious and inefficient. Brands with online presence are at risk of having their privileged material copied, recorded, or imported causing significant financial losses.

Bloombergi reported, in June 2013, that a man named Li Xiang plead guilty to copyright conspiracy in Wilmington, Delaware resulting in a sentence of 12 years. The government estimated that Xiang’s web-based business infringed upon a total retail value of over $100 million in software products from U.S. based companies, and sold to customers all over the globe.  Xiang operated out of Chengdu, the capital of the Sichuan providence of Southwest China.

Case U.S. v. Li, 10-cr-112, U.S. District Court, District of Delaware (Wilmington).

In August, 2013, The New York Timesii published an article explaining the extensive copyright infringement of the Metropolitan Transportation Authority. The MTA is North America’s largest transportation network based in New York, and issues approximately “600 notices a year for copyright infringements to protect trademarks on trainline logos and other system imagery” (Flegenheimer, M.T.A.)iii. All of the MTA’s subway, rail, and maps are copyright protected, and violators range from desperate artists to the upper echelons of the online retail industry. The MTA’s licensing income is a heavily needed source of revenue for the New York transportation system’s bottom line, but the authority has not been able to place a precise value on its losses from copyright infringement.

Copyright infringement in the digital era poses a great risk for brands to protect their privileged material online from anonymous users around the world. Companies need the right resources, time, and expertise to protect themselves and their bottom lines.


ii http://www.nytimes.com/2013/08/24/nyregion/c-train-cafe-the-mta-may-put-up-a-fight.html?_r=0

iii Flegenheimer, Matt. “M.T.A. Guards Against Copyright Infringement.” The New York Times. 23 August

2013. Web. 4 November 2013.

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Accreditation agencies are cracking down on inaccurate job placement figures and claims made by private sector colleges. Just in the last few months numerous colleges have fallen victim in Federal Trade Commission and Department of Education accusations. Resulting in large fines and loss of accreditation needed for federal financial aid. In August 2013 Career Education Corp. settled a $10.25 million settlement with the New York attorney general for allegedly inflating job placement rates. Are your institution’s job placement rates accurate and up-to-date? Avoid the large penalties and ensure your figures meet accrediting agency standards by utilizing a third-party unbiased employment verification service.

IntegriShield’s Employment Verification service seeks and contacts all graduates to verify employment and provide up-to-date and accurate post-graduation employment information for clients. IntegriShield’s verification experts collect all information based on client needs and accrediting body standards, to guarantee the correct information is provided for annual accreditation audits. Tracking graduates is a time consuming task that is crucial for accurate reporting. IntegriShield provides weekly and monthly reports tracking the number of employed students, unemployed students, reasons for unemployment and number of waived placements to save your Career Service Department time and money.

Providing inflated or inaccurate graduate employment information is detrimental to your school’s accreditation standings, reputation and finances. Contact IntegriShield today to ensure your graduate employment information meets the expected standards.

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Telephone Consumer Protection Act 2013 Updates: Are you Prepared?

Effective October 16, 2013: the Federal Communications Commission’s rules implementing the Telephone Consumer Protection Act.

The Federal Communications Commission’s TCPA rules will require “prior express written consent” before a business may:

  • Send advertising or telemarketing text messages using an “automatic telephone dialing system”;
  • Initiate an advertising or telemarketing phone call to a mobile phone number using an ATDS or an artificial or prerecorded voice;
  • Initiate a telephone call to a residential line for commercial purposes (unless those commercial purposes do not introduce an advertisement or constitute telemarketing).

The FCC’s new rules will also eliminate the “Established business relationship” exemption no longer relieving advertisers of prior unambiguous written consent requirement also, effective on October 16th. In most instances, only “prior express consent” is required. Prior written consent should be a clear and conspicuous disclosure requesting the consumer’s consent to be contacted.

What This Means for Companies?

Advertisers will be held responsible for all unsolicited telemarketing and autodialed calls and messages. Each unsolicited call or message will now require prior written consent from consumers that must be maintained by the advertiser for at least for four years.

Proof of internet provided consent includes but is not limited to:

  • Email, website form, text message, telephone key press, or voice mail
  • Website pages that contain consumer consent language and fields.
  • Associated screenshot of the consent webpage as seen by the consumer where contact information is collected.
  • Complete data record submitted by consumer with time and date stamp.

The TCPA enables individuals to file lawsuits against companies that place telemarketing calls or use autodialers without prior consent from the consumer. The FCC’s definition of “autodialer” is very broad leaving many advertisers unknowingly at risk. Once effective the majority of the “opt-in” language that you are currently using will not meet the new rigorous cell consent standards. Penalties range from $500 – $1,500 per unsolicited call or message. October 16th is right around the corner, IntegriShield can ensure that your company is prepared.

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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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