FTC Hearing To Stop Impersonation Fraud Set for May 4 – Get Involved!
The following is a letter sent to the Federal Trade Commission (FTC) regarding the increases in impersonation fraud. The letter was forwarded to us by the IFA, one of the 235 organizations in a coalition of businesses and nonprofits to sign the letter urging the FTC to act quickly to rein in a growing problem.
In fact, we ran a “Scam Alert” article in this newsletter last November urging readers not to be taken in by fake conference attendee lists and hotel reservations for our own conferences, and to deal directly with Franchise Update Media, not any third parties claiming to represent us. Those fraudulent email solicitations, by the way, for both our conferences and others, have only increased since then.
If you’d like to add your thoughts, or simply tune in to watch, the FTC has announced a virtual hearing on impersonation fraud for May 4. And, if you’re interested in requesting up to 5 minutes to deliver an oral statement, or you have written materials to submit into the docket, you must do so by April 14 through the following link. When submitting a request to speak, indicate that you wish to deliver oral testimony at the May 4th hearing.
The full letter, with the list of the 235 signatories, is available here.
March 31, 2023
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Re: Trade Regulation Rule on Impersonation of Government and Businesses, R207000, Docket No. FTC-2022-0064
To the Federal Trade Commission:
We write to you as a coalition of trade associations and professional organizations in the face-to-face business events industry, urging you to proceed expeditiously to a final rule targeting government and business imposters
As the Commission noted in a recent blog post, impersonator scams were the most reported type of scam in 2022, with an estimated $2.6 billion in losses. These impersonation scams have serious economic consequences for businesses, including nonprofits. Notably, reported losses from scammers impersonating businesses grew nearly 50% from 2021.
It has been 3 months since comments were submitted in response to the Commission’s Notice of Proposed Rulemaking (NPRM) on Government and Business Impersonation Fraud, and more than a year since the launch of the Advance Notice of Proposed Rulemaking on this matter.
In that time, impersonation scams affecting nonprofits, including trade shows, have continued to increase. For example, the Consumer Technology Association, which owns and produces CES, has received at least a half dozen reports of impersonation scams using the CES logo, during and in the 2 months following this year’s show. These impersonation scams varied from the sale of false discounted badges to fraudulent websites offering hotel bookings for CES.
Similarly, Exhibitions & Conferences Alliance members have experienced an uptick in event attendee list sale scams. These increasingly sophisticated impersonation scams use copyrighted event names, logos, and fake email signatures to create the illusion that the efforts of the scammers are conducted with the approval of the event organizers and service providers.
Several National Association of Broadcasters (NAB) Show attendees and exhibitors have alerted NAB staff of emails and phone calls from impersonators purporting to sell attendee contact information. One exhibitor received as many as 50 impersonator solicitations and reported that the frequent calls and emails are “overwhelming and hard to manage.” Many NAB Show exhibitors are small businesses that are ill-equipped to handle the apparent onslaught of impersonator solicitations.
Yet another trade association, the American Apparel & Footwear Association (AAFA) reports that in the first 3 months of 2023 alone, its members received more than 75 phishing and impersonation emails and texts connected to its Product Safety Conference in February and its Annual Executive Summit in March. These emails peddled fake contact lists and deployed other techniques, including the unauthorized use of the AAFA logo, in an effort to appear legitimate and lure unsuspecting recipients into fraudulent transactions.
We commend the Commission for its proposed rule targeting government and business imposters, and were pleased that the NPRM included nonprofit organizations in the proposed definition of “business.” With millions of Americans expected to attend in-person conferences and events this year, continued impersonation scams such as those involving hotel bookings, the sale of attendee lists, and event space fraud, remain an ongoing threat to the reputations of each of our organizations.
We implore the Commission to proceed to adopting a final rule as soon as possible.
P.S. – Many of the associations signing this letter have submitted comments in the rulemaking. These contain their more detailed feedback on the proposed rule, including that the FTC should include the limitations of “means and instrumentalities” liability in the text of the rule to make clear that it applies only to entities that have knowledge or consciously avoid knowing that they are making representations being used to commit impersonation fraud.
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