National Advertising Division Recommends Guideline Clarify Annual Recurring Revenue Claim

New York, NY – September 24, 2025 – While BBB National Programs' National Advertising Division concluded that Guideline, Inc.'s claim that it had“nearly $140 million ARR” reflected a calculation method that was not uncommon, the National Advertising Division (NAD) recommended Guideline modify the claim to include a clear and conspicuous disclosure indicating the method it used to calculate ARR (Annual Recurring Revenue).

Human Interest Inc., the challenger, and Guideline each provide 401(k) programs to small and medium-sized businesses. Human Interest brought the challenge under Fast-Track SWIFT, an expedited challenge process designed for single-issue advertising cases brought to NAD.

The challenged claim appeared in a highlighted box on Guideline's 2024 Year in Review (YIR), reading“~$140M ARR,” followed by text describing revenue growth and a footnote explaining that“Guideline calculates ARR by the following formula: ARR = sum of subscription and AUM revenue in December x 12 + new bookings backlog.”

NAD reviewed whether the Guideline's ARR calculation was misleading because it reflected a practice that is not commonly accepted. In the record, NAD found no authoritative definition of ARR for purposes of advertising and concluded that it was not demonstrated that Guideline used an uncommon method of calculating ARR, such that it could not be deemed ARR in the context of the challenged advertising.

But NAD also recognized the potential for ambiguity and the lack of an authoritative definition of ARR as a reason for a clear explanation of how the term is used by the Guideline. Therefore, NAD recommended that Guideline modify the“nearly $140 million ARR” claim to include a clear and conspicuous disclosure indicating the method it used to calculate ARR.

In its advertiser statement, Guideline stated it“will comply with the NAD's decision.”

All BBB National Programs case decision summaries can be found in the case decision library . For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive . Per NAD/NARB Procedures, this release may not be used for promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than 20 globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create fair competition for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.

About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and promoting fair competition for business.

Name: Jennie Rosenberg
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