FTC insider reviews: burn the disclosure into the clip

FTC rule section 465.5 requires a clear and conspicuous disclosure of insider reviews. Burn a disclosure line into the clip with Sume's video captions cues.

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FTC rule section 465.5 says insider reviews need a clear and conspicuous disclosure. If your review video is built with Sume, you can burn a disclosure line into the file with a caption job that uses authored cues. This is a workflow note, not legal advice; read the rule on ftc.gov and ask counsel what wording applies.

What this post relies on

The only legal fact used here is the one read directly from the FTC on 2026-10-03: section 465.5 requires insider reviews to carry a clear and conspicuous disclosure. Definitions, wording and placement are in the rule itself and are not restated.

Facts used (read 2026-10-03)
ItemDetail
16 CFR 465.5Insider reviews need clear and conspicuous disclosure
Sume caption cuesAuthored text with start and end times, no speech-to-text

Burn a line with cues

Standalone video captions take a public HTTPS video_url and return a job-backed captioned video. Passing cues (or segments) with text, start and end in seconds burns exactly that copy at those times and skips speech-to-text. That also makes it the path for silent clips, which otherwise fail as caption_no_speech.

script_text, words, cues and segments are mutually exclusive, so use cues alone for a disclosure line.

curl -X POST https://api.sume.com/v1/video-captions \
  -H "Authorization: Bearer $SUME_API_KEY" \
  -H "Content-Type: application/json" \
  -H "Idempotency-Key: disclosure-001" \
  -d '{
    "video_url": "https://media.sume.com/artifacts/example/review.mp4",
    "style": "black-outline",
    "cues": [
      {"text": "Disclosure: reviewer is employed by the brand.", "start": 0, "end": 8}
    ]
  }'

Placement and readability

Whether a line is conspicuous is a legal question, but you control its look. The design field overrides colours, typography and placement per request, for example placement.anchor_ratio sets the line centre as a fraction of frame height. style: "black-outline" draws white text on a thick black outline. Keep the line on screen for the whole review, not only the first seconds.

Cost and checks

Each accepted standalone caption job captures $0.20 USD for videos up to 60 seconds under the current fixed estimate; confirm in GET /v1/catalog. Burned-in text cannot be removed from the file, so check the first render before you publish and keep the clean source.

Sources

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