FTC affiliate disclosure framework
Public-facing summary of the operational compliance standards Migration Concierge LLC
holds itself to under FTC 16 CFR Part 255 (Endorsement Guides). Full operational document
in compliance/ftc_endorsement.md.
The material connection
Migration Concierge operates as an affiliate / referral partner of multiple licensed professionals. The material connection is the per-lead or revenue-share compensation we receive from partners on completed transactions. Per FTC 16 CFR §255.5, this material connection must be disclosed clearly and conspicuously to users.
Where the disclosure appears
- Site-wide footer on every page.
- A dedicated /disclosure page with full compensation bands.
- At every per-recommendation context in the discovery chat before any partner-routing recommendation.
- In the lead-capture confirmation email, with the routing decision attached.
Compensation does not influence recommendation
Routing rules are documented in the public partner registry and are based on state availability, fit, and licensing — not on referral fee size. Users may decline routing at any time and instead receive concierge-only guidance.
Endorsement honesty
We do not publish testimonials we have not personally verified, do not pay for reviews, and do not use simulated household personas. When we cite case-study outcomes (after first paid corridors), they will be anonymized and source-cited to actual ledger entries.
Operational gates
- Disclosure-language pre-review by counsel before each compensation-band change.
- Annual review of every active partner agreement against FTC + state requirements.
- Per-state insurance lead-gen + real-estate referral gates documented separately at /compliance/insurance and /compliance/real-estate.