CFBAI_ProgramBackgrounds_4-28-2020

Fast-Track SWIFT

The Fast-Track SWIFT (Single Well-defined Issue Fast Track) expedited filing process was developed to meet the compelling need for quick resolution of truth and transparency issues that arise in digital advertising. This time-sensitive process reviews the prominence and/or sufficiency of disclosures in influencer marketing and native advertising as well as other advertising truth and transparency issues that do not require complex claim substantiation.  

Decisions in 20 Business Days 

Use of the Fast-Track SWIFT process will allow parties to receive an NAD decision within 20 business days from the submission of payment and the initiation of the case (i.e., the time that the advertiser receives the challenge). All case decisions for SWIFT challenges are stored in the Online Archive, much like standard NAD challenge case decisions. Digests, which include a brief summary of resolved cases posted publicly in our  Newsroom as they become available.  

 

 

Eligible Claims 

Fast-Track SWIFT challenges are limited to a single issue. Claims that may be worded slightly differently but still convey the same message can be brought in a single challenge. Initially, NAD will only accept three types of claims for consideration in a Fast-Track SWIFT challenge:  

 

  • The prominence or sufficiency of disclosures including disclosure issues in influencer marketing, native advertising, and incentivized reviews 

  • Misleading pricing and sales claims 

  • Misleading express claims that do not require review of complex evidence or substantiation such clinical or technical testing or consumer perception evidence 

 

As the program develops, NAD may determine that additional types of claims are appropriate for a SWIFT challenge. 

 

 

Initiating a Fast-Track SWIFT Challenge 

Challenges are submitted via the Fast-Track SWIFT online portal  and must include: 


  • The advertiser’s contact information, including identifying the correct person to whom the challenge should be directed 

  • A copy of the challenged advertising and the date(s) and platforms(s) the challenged claim appeared 

  • A brief description of the facts showing how the advertising is likely controlled by the advertiser 

  • Exhibits to support the argument that the challenged claim is not substantiated (if applicable) 

  • A brief statement as to why the challenged claim is appropriate for the SWIFT process (e.g., it fits within the categories defined as appropriate for SWIFT review, etc.).  

  • All briefs should be limited to five pages and five exhibits (with a limit of five pages each). See “Filing a Complaint,” section 2.2(B) of the Procedures

 

The filing fee must be received by NAD before the 20-day countdown clock will begin on the challenge. 

 

 

SWIFT Case Decisions

Decision

First Three NAD Fast-Track SWIFT Cases Resolved by Government Agency Referral, Modified Claim, and Administrative Closure

Within one month of BBB National Programs’ National Advertising Division (NAD) launching the NAD Fast-Track SWIFT (Single Well-Defined Issue Fast Track) challenge process earlier this spring, the goal was initiation to decision in 20 business days. 
Read more
 

 

 

Frequently Asked Questions