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Can I offer a loyalty program for my customers in Vermont? What are the requirements?

Based on the information provided in document [1.1], Vermont law requires that loyalty, award, or promotional gift certificates must clearly and legibly set forth certain disclosures, including a statement indicating that the gift certificate is issued for loyalty, award, or promotional purposes, the expiration date for both the paid value of the gift certificate, if any, and the promotional value of the gift certificate, if any, the amount of any fees that may be imposed in connection with the gift certificate and the conditions under which they may be imposed, and if any fee is assessed against the gift certificate, a toll-free telephone number and, if one is maintained, a website address that a consumer may use to obtain fee information. Therefore, if you plan to offer a loyalty program for your customers in Vermont that involves gift certificates, you must comply with these requirements.

Additionally, Vermont law requires that providers of service contracts issued, sold, or covering property located in the state must file a registration with the Commissioner on a form prescribed by the Commissioner and renew it every three years. Providers must submit a $600.00 fee at the time of registration and at the time of each renewal. [2.1]

If you violate Vermont law, it may be deemed a violation of the Vermont Consumer Protection Act, which allows consumers to bring a private action for any violation of the law. [1.2]

There are no specific requirements for loyalty programs in Vermont beyond the gift certificate regulations mentioned above. However, if you plan to offer a loyalty program that involves managed care organizations, you must have an internal quality management program that includes certain components, as outlined in [6.1].

Source(s):
Jurisdiction

Vermont