5-Star Fraud: The FTC Targets Law Firms & Property Managers for Review Abuse
No business is too small to be a target. Through a recent FOIA request, we’ve identified ten firms—ranging from boutique law offices to regional property managers—that the FTC recently flagged for review abuses like "gatekeeping" and employee-solicited fake ratings.
In December 2025, the FTC issued warning letters to 10 companies determined to have likely violated the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, which became fully effective on October 21, 2024.
After FOIA requests these letters, detailing the specific firms and their alleged offenses, were recently published on the FTC website. The "on alert" group includes three personal injury law firms, one CPA, and six property management firms.
Compliance Requirements
Within 5 days of their receipt of these letters the companies needed to provide proof of the following:
1. Immediate Mandatory Compliance
Each business was required to respond via email to the assigned FTC staff member within 5 business days of receiving the letter. Their response was required to include:
- Point of Contact: Identification of the specific person or entity in charge of the company's review policies and compliance.
- Reciept Confirmation: Proof that the warning letter was been delivered to that person or centralized entity.
- Remediation Plan A detailed description of the specific actions the business will take to ensure future compliance with the Rule.
2. Remedial Action
The FTC "advised" these businesses to immediately cease all prohibited conduct and take corrective steps, such as:
- Removal: Deleting problematic reviews and testimonials from websites under their direct control.
- Third Party Outreach: Making a "best effort" to have non-compliant reviews removed from third-party platforms like Google or Yelp.
- Process Revision: Ending "gatekeeping" or sentiment-based incentive programs (e.g., gift cards or rent discounts for 5-star ratings).
3. Risk of Formal Legal Action
If no response was received by the FTC or if the FTC gathers further reports of non-compliance, the FTC signaled its intent to file of a federal lawsuit. Because these businesses are now on formal notice, any continued violations carry significant legal risk. Under the Consumer Review Rule, the FTC is authorized to seek substantial monetary damages with penalties of up to$53,088 per violation.
Target Firms and Alleged Offenses
Here are the firms and the banned review practices of which they were accused:
| Business Name | City | Prohibited Practice | Category | |
| Provident CPAS PLC | Tulsa, Ok | Providing a $100 fee discount to customers in exchange for the customer posting a 5-star Google review. | CPA | |
| Glasheen, Valles & Inderman, LLP | Lubbock, Tx | Providing a $50 gift card incentive to employees in exchange for each 5-star review obtained from family or friends who were not clients and had no actual experience with the firm. | Personal Injury | |
| Craig Swapp and Associates | Sandy, UT | Providing a $50 bonus to employees for each 5-star review from non-clients (family/friends), and soliciting reviews at community events from individuals without actual experience with the firm. +1 | Personal Injury | |
| Emerson Straw PL | St. Pete, FL | Providing a $50 gift card incentive to employees in exchange for each 5-star review obtained from family or friends who were not clients and had no actual experience with the firm. | Personal Injury | |
| Somerset Apartment Management, LLC (d/b/a Sandhurst Apartment Management) | Charlotte, NC | Conditioning entry into a raffle for a 50-inch TV on a tenant's submission of a 5-star review, and allowing unlimited raffle entries for each positive review. | Property Management | |
| Weidner Property Management LLC | Kirkland, WA | Conditioning entry into a raffle for a choice of a $500 gift card or $500 rent discount on a tenant's submission of a 5-star review. | Property Management | |
| Hortenstine Properties, LLC (d/b/a Lincolnshire Apartments) | Mattoon, IL | Providing a $15 lease credit to tenants in exchange for the tenant posting a 5-star Google review of the apartment complex. | Property Management | |
| Tec Management, L.C. (Hilltop Towers) | South Ogden, UT | Conditioning a $25 account credit and entry into a raffle for a $300 gift card and 1-year Sam's Club membership on a tenant's submission of a 4- or 5-star review. | Property Management | |
| 10 Stars Property Management LLC | Pinellas Park, FL | Providing lease fee discounts to prospective and current tenants in exchange for their publishing a 5-star Google review. | Property Management | |
| Allview Real Estate | Newport Beach, CA | Providing $10 Starbucks gift cards to tenants in exchange for their publishing 5-star Google or Yelp reviews. | Property Management | |
Analysis and Takeaways
The law firms, while not mom and pops, are mostly local and a few are regional in scope. None are national in scope.
Emerson Straw LLP, a boutique firm, appears to have 7 employees and one main office. Glasheen, Valles & Inderman Injury Lawyers operates 7 locations across Texas and New Mexico with fewer than 40 employees. The largest, Craig Swapp & Associates has 14 offices across Utah, Idaho and Washington with fewer than 100 employees. The property management firms were similar with sizes ranging from a few employees to the largest several hundreds.
While I presume that the FTC is not going out and actively looking for offenders, you are not too small to be targeted if you have been reported to them for review programs that violate "The Rule".
Types of Offenses
The three law firms all were targeted for incentivizing employees (not a problem) to solicit reviews from non customers (the problem) including friends, family and community events. The similarity in their incentive programs are so similar, one has to assume that the idea was promoted at some conference or in a "mastermind group" of some sort.
The property management firms were called out for conditioning their incentives in exchange for a specific star rating.
Incentives, in and of themselves, are NOT against the rule but if incentives are used, then the review must clearly state that they were in place and they can not be predicated on receiving a certain rating. This makes it illegal to incentivize Google or Yelp reviews as there is no mechanism to indicate the incentives. As a note, while incentive are not illegal under the FTC Rules they are against the Terms of Service at most review sites.
The Outcome
The firms that were singled out by the FTC were obligated to quickly put together a remediation plan, attempt to get the offending reviews removed and promise not to ever do this again.
In theory, the FTC would call them out publicly from their bully pulpit to insure broader compliance. However, that really hasn't happened to date. The publicity around these cases were limited to the December press release noting that the letters were sent. However, garnering the names of the offenders and the specific allegations of their behaviors required that a Freedom of Information Act request be filed. And to date there has been no public mention of these firms, let alone public shaming.
The Future of Reviews
The FTC’s current enforcement strategy relies on a "bully pulpit" approach, yet the noise has been surprisingly quiet. Identifying these offenders required a Freedom of Information Act (FOIA) request; the FTC has not engaged in any proactive "public shaming."
If the only consequence for a violation is being asked to submit a "remediation plan," review abuses are likely to continue. With the FTC providing minimal publicity and Google struggling to catch sophisticated fraud, a further decline in public trust regarding review integrity seems inevitable.
You can download the complete set of letters here: