How are advertising or programs referred?
There are a couple of ways that advertising can be referred: An ERA member may refer a campaign, a consumer or advocacy group may refer a campaign, or the program attorney may pick a campaign to refer. They may use the IMS or the Jordan Whitney reports to determine program popularity, etc. They will use fair and consistent criteria to decide which campaigns to review based on the numbers of consumers affected, the potential for consumer harm and how egregious the advertising appears to be. ERA does not refer advertising.
