Templates

The Review Request Template Pack

A guide working with a client on the water, photographed by Calder Mountain Lodge in AKCalder Mountain, AK
A morning's work with Calder Mountain Lodge.
Short answerA disclosure is not clear and conspicuous if a consumer must click a hyperlink or hover over an icon to see it. It has to be unavoidable.
Key takeaways
  • 16 CFR 465.4 prohibits providing compensation or other incentives in exchange for, or conditioned expressly or by implication on, a review expressing a particular sentiment.
  • 16 CFR 465.1(c)(4) makes a disclosure in an interactive electronic medium unavoidable, and expressly not clear and conspicuous if a consumer must click or hover to see it.
  • 16 CFR 465.2 reaches misrepresentations that the reviewer exists, that they used the service, or of their experience, on a knew or should have known standard when disseminating.
  • 16 CFR 465.5 requires an officer, manager, employee or agent's material relationship to be disclosed, with a stated exception for generalised solicitations to purchasers.
  • 16 CFR 465.7(a) prohibits unfounded legal threats, intimidation or knowingly false public accusations used to prevent or remove a review.
  • A plain request that offers nothing, goes to everybody, and conditions nothing on sentiment sits outside all of it.

Give a client a discount, a prize entry or a box of flies anywhere near a review request and you have created a material connection that has to be disclosed. The guide says so, and it says so whether or not you asked for the review in return.

Which settles the design of a review request before you write a word of it. The safe version asks and offers nothing. The version that offers something requires the reviewer to disclose the connection clearly and conspicuously, which they will not do, which leaves the exposure with you. Below, the endorsement guides are read on what an endorsement is, what it must reflect and when a connection is material, and then the templates follow. Guidance is amended, so verify the exact current position with the agency before running anything at scale. Nothing here is legal advice. The rest of the template pack sits under the running the business hub.

Four review asks, and what each one creates
AskMaterial connection?
Plain request, nothing offeredNo
Ten dollars off the next trip for a reviewYes
Entry into a draw for reviewersYes, the possibility of winning a prize
A box of flies given afterwards, no review requiredYes, regardless of whether one was required

What does the rule prohibit outright?

Paying for a review that expresses a particular sentiment.

Section 465.4 of Title 16 makes it an unfair or deceptive act or practice, and a violation of the part, for a business to hand over money or any other inducement in return for a review expressing a particular sentiment, or on a condition to that effect whether stated outright or merely implied, and it makes no difference whether the sentiment sought is favourable or hostile.

Note that this is a rule rather than a set of guides, so the question is not how a disclosure should be worded but whether the practice is permitted at all.

Note also the words or by implication. An offer framed as a thank you for a kind word is conditioned by implication on the sentiment, and framing does not rescue it.

And the prohibition runs both ways, covering negative sentiment as well as positive, which reaches paying anybody to write badly about a competitor.

Part 465 is carried on the eCFR, with its source recorded as a rule published in the Federal Register on 22 August 2024 at 89 FR 68077.

Why an incentive is a poor trade anyway is covered in the discount scripts piece.

A guide at work during a trip, photographed by STM Fly Shop & Guide Service in CASTM Fly Shop, CA
A day's work with STM Fly Shop & Guide Service.

What does clear and conspicuous mean here?

Unavoidable, and a link does not count.

Section 465.1(c) defines clear and conspicuous as easily noticeable, meaning difficult to miss, and easily understandable by ordinary consumers, and then sets out five specific requirements.

A visual disclosure must, by its size, contrast, location, the length of time it appears and other characteristics, stand out from accompanying text or visual elements so that it is easily noticed, read and understood.

An audible disclosure must be delivered at a volume, speed and cadence sufficient for ordinary consumers to hear and understand it.

And the one that matters most online: in any communication using an interactive electronic medium such as social media or the internet, the disclosure must be unavoidable, and it is not clear and conspicuous if a consumer must take any action, such as clicking a hyperlink or hovering over an icon, to see it.

Which disposes of the standard practice of putting a disclosure behind a more link.

How the site copy should be structured is covered in the site anatomy piece.

What counts as a fake review?

Three misrepresentations, and one of them is subtle.

Section 465.2(a) makes it a violation for a business to write, create or sell a consumer review or testimonial that materially misrepresents, expressly or by implication, that the reviewer exists, that the reviewer used or otherwise had experience with the product, service or business, or the reviewer's experience with it.

The third limb is the subtle one, because a real client writing about a real trip can still be presented in a way that misrepresents their experience.

Section 465.2(b) extends it to a business purchasing a consumer review, or disseminating or causing the dissemination of a testimonial, which the business knew or should have known materially misrepresented any of those three things.

Knew or should have known is the standard, so publishing a review you had reason to doubt is within it.

Which makes the selection of what you publish a substantive decision rather than a presentational one.

Why the underlying record matters is covered in the chargebacks piece.

The incentive buys less than it costs. Offering $25 off a next trip to every reviewer, on 90 trips a season with a 30 per cent response, is 27 reviews at $675 of discount. A plain unincentivised ask, sent promptly and personally, commonly reaches a similar share of clients at $0, because the request is easy to honour and the trip was good. And the incentivised version produces reviews that require a disclosure to be compliant, which means 27 reviews each carrying a caveat the reader can see. Spending $675 to make your own reviews less persuasive is a poor trade.

89 FR 68077The Federal Register citation recorded as the source of the rule on the use of consumer reviews and testimonials, published 22 August 2024.Source: 16 CFR part 465, source note
A guide at work during a trip, photographed by Big Salmon Outfitters in MTBig Salmon, MT
From a day on the water with Big Salmon Outfitters.

What about a fake follower count?

Buying or selling them is separately prohibited.

Section 465.8 makes it a violation for anyone to sell or distribute fake indicators of social media influence which they knew or should have known to be fake and which can be used to materially misrepresent influence or importance for a commercial purpose.

Paragraph (b) applies the same treatment to purchasing or procuring such indicators, on the same knowledge standard, where they materially misrepresent influence or importance for a commercial purpose.

For a guiding operation that reaches buying followers or engagement on a page used to attract bookings, which is a marketing decision some people still make.

It also reaches the reverse: a service offering to sell them is within the same provision.

Section 465.9 adds that the provisions of the part are separate and severable, so a stay or invalidation of one does not disturb the others.

Why an audience built on real interest performs better is covered in the boosted posts piece.

What if you or your staff write one?

It needs a disclosure of the relationship, unavoidably placed.

Section 465.5(a) makes it a violation for an officer or manager of a business to write or create a consumer review or testimonial about the business that fails to have a clear and conspicuous disclosure of their material relationship to it, unless in the case of a testimonial the relationship is otherwise clear to the audience.

Paragraph (b)(1) extends the same position to a business disseminating a testimonial by one of its officers, managers, employees or agents without such a disclosure, where the relationship is not otherwise clear and the business knew or should have known of it.

For a one-person operation the relationship to yourself is obvious and the provision matters most where somebody who works for you writes something.

A sub-guide praising the operation on a public profile is a testimonial by an agent, and the disclosure question attaches to it.

The rule contains stated exceptions, including for generalised solicitations to purchasers to post testimonials about their experiences, which is why a plain broad ask to clients is a different thing.

How the arrangement with that person should be documented is covered in the first sub-guide piece.

What about suppressing a bad review?

Two separate prohibitions, and one covers how you respond.

Section 465.7(a) reaches anyone who responds to a review with a baseless legal threat, a threat of violence, intimidation, or a public accusation they know to be false or make recklessly, where the object is to stop the review being written in the first place or to get it taken down, and it applies whether or not something else is put in its place.

Which reaches the reply that accuses a client of lying, and it reaches the threatening letter about defamation sent to somebody who wrote a genuine bad review.

Section 465.7(b) separately addresses a business misrepresenting that reviews displayed in a part of its own site dedicated to reviews represent most or all of those submitted, where reviews are being suppressed based on their ratings or negative sentiment.

It carves out suppression based on criteria applied equally, which is how a genuine moderation policy remains available.

For a guiding operation the practical rule is that a testimonials page showing only the good ones is fine unless you represent it as everything you received.

Why a factual public reply beats a defensive one is covered in the liability insurance piece.

No compliance opinion is offered here. Whether a particular request, disclosure or reply satisfies the rule depends on wording and placement, and each platform imposes its own terms on top. Confirm the current requirements with the agency and read your platform's own policies before running anything at scale. Not legal advice.

Does a company-run review page count?

Only if you do not dress it up as independent.

Section 465.6 makes it a violation for a business to materially misrepresent, expressly or by implication, that a website, organization or entity it controls, owns or operates provides independent reviews or opinions, other than consumer reviews, about a category of businesses, products or services including its own.

Which is aimed at the practice of running an apparently neutral comparison site that happens to rank the operator's own business first.

A testimonials page on your own site is not that, because nobody reading it believes it is independent, and the provision turns on the misrepresentation rather than on ownership.

Where it becomes a live question is a separately branded best guides on the river page run by one of the guides on it.

The safe position is that anything you control should be visibly yours.

Why the site should say plainly who is behind it is covered in the guide bio piece.

Does a plain ask stay outside all of this?

Yes, and that is the point of the templates below.

A request that offers nothing, is sent to everybody, and does not condition anything on the review being favourable, creates no compensation, no incentive and no sentiment condition.

It also produces no material relationship to disclose, because the client is a client and nothing else.

Which means the entire compliance surface described above disappears the moment you stop trying to buy the review.

That is an unusually clean outcome for a regulatory question, and it is worth taking advantage of.

Everything below is written on that basis: ask, offer nothing, and route complaints to yourself.

How the same discipline applies to referrals is covered in the shop partnerships piece.

The plain ask, by message

Short, specific, and nothing offered.

Send it the evening of the trip or the morning after, while the day is still the most recent thing that happened.

Text: Good day out today. If you have a minute, a short review helps other people find me more than anything else I do. Link below, and no worries either way.

Email subject: Today on the river. Body: Thanks for coming out. If you would leave a couple of lines about the day, it genuinely helps, and here is the link. If anything was not right, reply to this instead and I will sort it.

Note the last sentence. It routes an unhappy client to you rather than to a public page, and it does so without conditioning the ask on the review being positive.

That distinction matters, because asking only happy clients is a different practice from giving every client a private route to complain.

What the follow-up sequence should look like is covered in the rebooking pack piece.

The ask for a repeat client

Different, because they have already reviewed once or never will.

A client on their fifth trip either reviewed you years ago or has decided not to, and repeating the same request is noise.

Text: You have fished with me more than most. If you ever feel like updating that review with something about this year, it would mean a lot. Only if you feel like it.

The updating framing works because it gives a long-standing client something new to say and gives you a recent dated review rather than an old one.

It also avoids the awkwardness of asking somebody twice for the same thing.

And it offers nothing, which keeps it outside the material connection question entirely.

Why recency matters on a public profile is covered in the profile setup piece.

The ask after a difficult day

Do not make it.

A day where the fishing was poor, the weather turned or something went wrong is not a day to ask for a review, and the temptation is to ask anyway because the client was gracious about it.

The better message acknowledges the day and asks nothing: Tough conditions today and you handled it well. I would like another go at that water with you, so let me know when.

That produces a rebooking conversation rather than a review, which is worth more, and it does not put somebody in the position of writing something kinder than they feel.

A review written out of politeness is not the honest opinion the guides require, and everybody involved knows it.

Which is a compliance point and a decency point arriving at the same answer.

How the weather conversation should run is covered in the weather cancellation piece.

What if a review is unfair?

Reply once, factually, and move on.

A public reply is read by future clients rather than by the reviewer, which changes what it is for.

Template: Thanks for the feedback. We fished the upper section on a rising river and the conditions were against us, and I offered to move the day when the forecast changed. I am sorry it did not work out and you are welcome back.

Note what it does not do: argue, blame the client, or restate the terms.

One factual reply reads well to a stranger and a defensive one reads badly however correct it is.

And an operation with a documented record of the day can write that reply from evidence rather than from memory.

Where that record comes from is covered in the chargebacks piece.

Where should reviews be asked for?

One place, chosen deliberately.

Splitting requests across three platforms produces three thin profiles rather than one credible one.

Pick the platform your clients actually search, ask everybody for that one, and let anything else accumulate on its own.

Which platform that is depends on your water and your market, and it is answerable by looking at where your existing enquiries come from rather than by guessing.

Concentrating also makes the recency question manageable, since one profile with steady dated reviews reads better than three with gaps.

And it makes the ask simpler, which raises the response rate more than any incentive would.

How to establish where enquiries originate is covered in the channel share piece.

Where does this go wrong?

Five ways, and the first is the discount.

Offering anything of value near a review request, which creates a material connection requiring clear and conspicuous disclosure regardless of whether a review was required in return.

Running a prize draw for reviewers, which the guide names directly as the possibility of winning a prize.

Asking only the clients you expect to be positive, which is a different practice from giving everybody a private route to complain.

Quoting stitched-together fragments, which the guide treats as rewording that distorts, and doing it inside quotation marks makes it worse.

And publishing undated reviews from years ago as though they describe a current operation.

How the client FAQ should handle expectations is covered in the client FAQ piece.

What the intake form should capture is covered in the intake form piece.

What is the working pack?

Three messages, one platform, nothing offered.

Send the plain ask within twenty four hours of every trip, with the private route to complain included in the same message.

Send the updating ask to long-standing clients once, not annually, and only where they already reviewed you.

Send nothing after a difficult day except a rebooking offer.

Offer no discount, no gift, no draw and no early access, since every one of those is named in the guide as a connection requiring disclosure.

And publish reviews whole and dated, on one platform, replying once and factually to anything unfair.

The rule cites its authority as 15 U.S.C. 57a, and the rule as published appears at 89 FR 68077.

How the season announcement should be worded is covered in the season announcement piece.

How this was checked. The prohibition on paying or otherwise inducing a review that expresses a particular sentiment, whether sought outright or on an implied condition, and whether the sentiment is favourable or hostile, comes from 16 CFR 465.4. The definitions of business and celebrity testimonial, and the definition of clear and conspicuous as easily noticeable and easily understandable by ordinary consumers, together with its five requirements covering the means of communication, the visual characteristics that must make a disclosure stand out, the volume, speed and cadence of an audible disclosure, the requirement that a disclosure in an interactive electronic medium be unavoidable and the express statement that it is not clear and conspicuous if a consumer must take any action such as clicking a hyperlink or hovering over an icon to see it, and the requirement of understandable diction and syntax, all come from 16 CFR 465.1. The prohibitions on writing, creating or selling a consumer review or testimonial that materially misrepresents that the reviewer exists, that the reviewer used or otherwise had experience with the product, service or business, or the reviewer's experience with it, and on purchasing a consumer review or disseminating a testimonial which the business knew or should have known materially misrepresented any of those matters, come from 16 CFR 465.2. The prohibitions on an officer or manager writing a consumer review or testimonial about the business without a clear and conspicuous disclosure of their material relationship, and on a business disseminating a testimonial by an officer, manager, employee or agent without such a disclosure where the relationship is not otherwise clear and the business knew or should have known of it, together with the stated exceptions including that for generalised solicitations to purchasers to post testimonials about their experiences, come from 16 CFR 465.5. The prohibition on misrepresenting that a website, organization or entity a business controls, owns or operates provides independent reviews or opinions other than consumer reviews comes from 16 CFR 465.6. The prohibitions on responding to a review with a baseless legal threat, a threat of violence, intimidation, or an accusation known to be false or made recklessly, where the object is to stop the review being written or to have it taken down, whether or not something else replaces it, and on misrepresenting that reviews displayed in a portion of a business's own site dedicated to reviews represent most or all of those submitted where reviews are suppressed based on rating or negative sentiment, together with the carve-out for criteria applied equally, come from 16 CFR 465.7. The prohibitions on selling, distributing, purchasing or procuring fake indicators of social media influence on the stated knowledge standard come from 16 CFR 465.8, and the severability provision from 16 CFR 465.9. Part 465 was read on the Electronic Code of Federal Regulations on 26 July 2026, where its authority is recorded as 15 U.S.C. 57a and its source as a rule published at 89 FR 68077 on 22 August 2024. No platform's own review policies were read, no state statute was consulted, and every message template above is an illustrative draft rather than legal wording.

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What the rule prohibits outright, what clear and conspicuous actually requires, and the three messages worth sending

Can I offer a discount for a review?

16 CFR 465.4 makes it an unfair or deceptive act or practice and a violation of the part for a business to pay or otherwise induce a review expressing a particular sentiment, whether sought outright or on an implied condition, favourable or hostile. This is a rule rather than a set of guides, so the question is whether the practice is permitted rather than how to word a disclosure.

What about a prize draw for reviewers?

The same provision reaches other incentives conditioned expressly or by implication on a review expressing a particular sentiment. An entry offered to people who leave a review is an incentive, and framing it as a thank you does not remove the implied condition. The safe design offers nothing at all.

What does clear and conspicuous actually require?

16 CFR 465.1(c) defines it as easily noticeable, meaning difficult to miss, and easily understandable by ordinary consumers, then imposes five requirements. A visual disclosure must stand out by size, contrast, location and duration; an audible one must be at a sufficient volume, speed and cadence; and in an interactive electronic medium it must be unavoidable, with the rule stating expressly that it is not clear and conspicuous if a consumer must click a hyperlink or hover over an icon to see it.

What counts as a fake review?

16 CFR 465.2(a) covers writing, creating or selling a review or testimonial that materially misrepresents, expressly or by implication, that the reviewer exists, that they used or otherwise had experience with the service, or their experience with it. Paragraph (b) extends the same to purchasing a review or disseminating a testimonial the business knew or should have known misrepresented any of those things, which makes what you choose to publish a substantive decision.

Can I publish a review my sub-guide wrote?

16 CFR 465.5 requires a clear and conspicuous disclosure of the material relationship where an officer or manager writes a review or testimonial, and where a business disseminates a testimonial by an officer, manager, employee or agent whose relationship is not otherwise clear and which the business knew or should have known of. There are stated exceptions, including for generalised solicitations to purchasers to post testimonials about their own experiences.

How should I respond to an unfair review?

Factually, once, in public. 16 CFR 465.7(a) prohibits using a baseless legal threat, a threat of violence, intimidation, or an accusation known to be false or made recklessly, in response to a review and in an attempt to prevent it being written or to have it removed. A reply that accuses the client of lying, or a threatening letter about a genuine bad review, is within that.

Is a testimonials page showing only good reviews a problem?

Not in itself. 16 CFR 465.7(b) addresses misrepresenting that reviews displayed in a portion of a business's own site dedicated to reviews represent most or all of those submitted, where reviews are being suppressed based on rating or negative sentiment, with a carve-out for criteria applied equally. So a curated testimonials page is fine unless you represent it as everything you received.

Sources & methods

  1. 16 CFR part 465, the rule on the use of consumer reviews and testimonials, read on the Electronic Code of Federal Regulations for the definitions in section 465.1 including business, celebrity testimonial and the five-part definition of clear and conspicuous with its requirement that a disclosure in an interactive electronic medium be unavoidable and its express statement that a disclosure requiring a click or a hover is not clear and conspicuous; for the prohibitions in section 465.2 on writing, creating, selling, purchasing or disseminating reviews and testimonials that materially misrepresent the reviewer's existence, their use of the service or their experience; for the prohibition in section 465.4 on paying or inducing reviews of a particular sentiment, sought outright or on an implied condition; for the insider review and testimonial provisions in section 465.5 and their stated exceptions; for the company-controlled review website provision in section 465.6; for the review suppression provisions in section 465.7 covering baseless legal threats, threats of violence, intimidation and recklessly false accusations, and the misrepresentation of displayed reviews as representing most or all of those submitted; for the fake social media influence indicator provisions in section 465.8; and for the severability provision in section 465.9.
  2. The Federal Register citation recorded as the source of part 465, being a rule published on 22 August 2024, cited so the rule as promulgated can be read alongside the codified text.
  3. 15 U.S.C. 57a at the Office of the Law Revision Counsel, cited as the authority recorded for part 465, being the Commission's rulemaking authority in respect of unfair or deceptive acts or practices.

Every figure here is traced to a named public source and checked against it. Licensing, tax, and fee rules change. Verify your state’s current rules with the agency directly before you count on any number here.

Evan Knox
Written by

Evan Knox

I build booking websites and run the ads and search for owner-run fishing guides, one operation per stretch of water. My first guide client, Bowman Fly Fishing, grew its revenue 4x in a year from that work. Field Notes is where I put the straight numbers on the business of guiding.

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