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Vehicle Protection Plans

Standards of Conduct Appendix B: VPA Guidelines for using the term Warranty in Internet Marketing

A. Background and Scope:

The Vehicle Protection Association ("VPA") acknowledges that consumers often refer to vehicle service contracts as "warranties," "extended warranties" and/or similar terms and, therefore, use such terms when searching for coverage on the internet. The VPA also acknowledges that use of these terms on a website likely increases the website's search engine ranking, thereby increasing its exposure (i.e. the number of consumers that visit the site). The VPA further acknowledges that use of these terms in search engine marketing (i.e. pay per click advertisements) increases a website's exposure and that the amount of text available for such advertisements is limited.

With these considerations in mind, the VPA developed the following Guidelines to provide clarity regarding the permissible and impermissible uses of the terms "warranty," "extended warranty" and/or similar terms, including misspellings thereof, on members' websites. The Guidelines were developed to facilitate members' interests in reaching the largest number of consumers possible while ensuring members communicate with consumers honestly and in a manner that promotes consumer education.

It is the totality of the sales presentation that determines whether the presentation is deceptive. Thus, a member may comply with all of these guidelines per se, but the presentation may still be deceptive.

For purposes of these Guidelines, the singular terms "warranty" and "extended warranty" are used interchangeably with their plural forms "warranties" and "extended warranties."

B. Guidelines:

  • Members may keep URLs they have previously used that contain the word "warranty" so long as the content of the website (including the name used) meets the guidelines below. Newly created websites may not use the word "warranty" in its URL.
  • Members shall not conduct business using a name known to the consumer that contains the word "warranty."
  • Members may use the term "warranty" to refer to the manufacturer's warranty.
  • Members shall not directly refer to the vehicle service contracts they sell as "warranties" or "extended warranties."
  • Members may use a term such as "vehicle service contract" coupled with a parenthetical explanation containing the term "warranty" such as "(f/k/a an extended warranty)" or "(commonly referred to as an extended warranty)" to describe what the member is offering so long as the disclosure requirements outlined in Section C (below) are met. In the context of press releases, articles and/or blogs on a member's website, the required disclosure may be provided clearly and conspicuously in one location rather than on each individual press release, article or blog entry.
  • Members shall use the required disclosures outlined in Section C (below) if they post customer testimonials on their website wherein customers refer to their vehicle service contracts as a "warranty" or "extended warranty."
  • Members may use terms such as "warranty" and/or "extended warranty" to educate consumers on the difference between a warranty and vehicle service contract (e.g. see the disclosure in Section C below).
  • Members shall not indirectly refer to themselves or any company they conduct business with as a "warranty company" or any similar term that containing the term "warranty."
  • Members shall not indirectly refer to their employees or the employees of any company they conduct business with as "warranty specialists," "warranty consultants" or any similar term that contains the term "warranty."
  • Members may use previously recorded audio/visual endorsements from public figures that use the word "warranty" so long as the disclosure requirements outlined in Section C (below) are met. Newly created audio/visual endorsements shall not use the word "warranty" to describe what the member sells.
  • Members may use the terms "warranty" or "extended warranty" for purposes of search engine marketing (i.e. pay-per-click advertisements), so long as the content of their website(s) complies with these Guidelines and the disclosure in Section C (below) is prominently displayed on the homepage of the Member's website.

C. Required Disclosure

If a member uses the term "warranty" or "extended warranty" in any manner that requires a disclosure pursuant to Section B (above), the following disclosure shall be clearly and conspicuously placed on all landing pages where the term is used:

A vehicle service contract (VSC) is often referred to as an "extended warranty," but it is not a warranty. A VSC does, however, provide repair coverage for your vehicle after the manufacturer's warranty expires. A VSC is a contract between you and a VSC provider or administrator that states what is a covered repair and what is not. [Company name] is a marketer of VSCs and does not sell warranties. VSCs sold by [Company name] are agreements between consumers and third party VSC providers, not [Company name].

For purposes of these guidelines, "clearly and conspicuously placed" means:

  • In close proximity to the term that triggers the required disclosure (e.g. "warranty"). Making disclosures at the bottom of the page with or without the use of a footnote is not sufficient. If a landing page contains multiple terms that trigger the required disclosure, the disclosure shall be made in close proximity to the first location where such a term is used.
  • Using bold font that is at least as large as the term that triggers the required disclosure.
  • Using a font color that stands out from the background on which the disclosure appears.
  • Not otherwise obscured by the background, surrounding text, graphics, illustrations, etc.

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