ERSP Recommends Clever Investor Modify Certain Claims for Mentorship Program; Company Agrees to Do So

New York, NY – Sept. 29,  2017– The Electronic Retailing Self-Regulation Program (ERSP) has recommended that Clever Investor modify or discontinue certain claims for the Clever Investor Mentorship Program, the company’s proof of funds subscription service for real estate investors.

ERSP is an investigative unit of the advertising industry’s system of self-regulation and is administered by the Council of Better Business Bureaus. The marketer’s advertising came to the attention of ERSP through an anonymous challenge.

ERSP reviewed email and online advertising claims for the mentorship program, including:

  • “18 year old Hunter teams up with his brother to make real estate a family business . . . Their systems are foolproof and the flow charts eliminated a huge learning curve for us.” [Hunter]
  • “Sean talks how he’s making ‘stupid easy’ money in real estate”
  • “Michelle is on pace to do $350k this year & has a goal of 1.2 million next year! . . . Within a few months I had achieved a six-figure income.”
  • Cody Sperber has flipped over 100,000+ deals worth around $200 Million
  • “If you listen to everything I teach you in the class then I give you my personal promise that you’ll have the ability to make an extra $10,000 in the next 30 days!” [Email Subject: Sorry this might be tough to swallow. Sorry, I gotta be real]

Clever Investor consists of three programs that teach students about real estate investments: Your First Million in Real Estate, The Fast Track Profit System, and the Clever Investor Mentoring. The service is primarily marketed to consumers through email and online ( advertisements.

At the outset of the inquiry, the marketer informed ERSP that it was conducting routine surveys measuring the success of participants, and implementing a new earnings disclosure which included the survey questions and results. ERSP appreciated the marketer’s willingness to conduct surveys of all participants in the Clever Investor programs and voluntarily including the results in a comprehensive disclosure. After review of the survey and disclosure, ERSP recommended that the marketer clearly and conspicuously include the disclosure with all customer testimonials and earnings claims, and ensure the disclosure language presents the material information more clearly and conspicuously to consumers.

Additionally, ERSP recommended that the marketer discontinue making any unqualified earnings claims in its advertising including consumer testimonials, success stories, and representations regarding the success of company spokesperson Cody Sperber. It was also recommended that the marketer refrain from making any claims which suggest that earning money using the Clever Investor Mentorship program is quick and/or easy, and avoid suggesting that there are no risks involved in using the advertised product.

Clever Investor, in its marketer’s statement said, “Clever Investor, LLC is committed to running its business ethically, following industry best practices all in support of its mission to provide the highest quality training programs to its students.”