Are forward-to-a-friend forms legal?

The FTC released a detailed rulemaking extending the CAN-SPAM act yesterday.  It specifically addresses the legality and liabilities of offering tell-a-friend forms on your web site.

As you know, I've been on of the biggest proponents of using a tell-a-friend on every page of your web sites. To me there is nothing more honest and genuine than a regular consumer who wants to share your stuff with their friends.  You should make it as easy as possible.

The FTC ruling seems to say that:

• Companies that offer tell-a-friend forms are not at risk under the CAN-SPAM act.  They are just providing a routine conveyance, similar to the forward button on an email program.
• Consumers are not at risk because the presumption is that these are personal emails between friends that just happen to use a company's form.
• If the company pays the consumer, that's a different story.  Then the company may be responsible for inducing spam.

Here is the document.

Disclaimer: I am not a lawyer and I don't speak for WOMMA in any way.

Please comment with your interpretation.