FTC.

01Why this page exists

Most of what you see in a creator's feed is paid for in some form — cash, free product, equity, affiliate commissions, friendly favors. Audiences deserve to know which is which. The FTC's Endorsement Guides spell out how to make that clear. Vault's role as an agency is to make sure every creator we represent and every brand we partner with does it right, every time, on every post.

This page is the standard. It's referenced in the master services agreement Vault signs with creators and in every campaign brief Vault sends to brands.

02Vault's role

Vault is a talent agency. We represent the creator's interests in deals with brands. We are not a content review board, an independent regulator, or a substitute for the creator's own judgment about what they will and won't endorse.

That said, Vault enforces three things on every campaign we book:

• The creator must clearly disclose any material connection in any content where the partnership appears.
• The creator must actually have used or experienced the product before claiming to like it.
• The brand must approve disclosure language and placement before content goes live.

If any of those three break down, the campaign doesn't run.

03What "material connection" means

The FTC defines a "material connection" as any relationship between an endorser and a brand that an audience wouldn't reasonably expect — one that could affect how the audience weighs the endorsement. For Vault creators, the material connections we routinely disclose include:

• Paid partnerships — cash, fee, retainer, or honorarium of any size.
• Gifted product — anything the brand sent that the creator didn't pay full retail for.
• Affiliate links — commissions tied to clicks, sign-ups, or purchases.
• Equity or future-payment arrangements — including SAFEs, options, or revenue shares.
• Family, friend, or employer relationships — if the brand is owned, run, or invested in by someone the creator personally knows, that matters.
• Travel and experiences — press trips, comped tickets, hosted dinners, conference flights.

If you're unsure whether something counts, the answer is: assume yes and disclose. We'd rather over-disclose than risk an FTC inquiry.

04How to disclose

The FTC's standard is "clear and conspicuous." That means a reasonable viewer or reader sees it without effort, in the same way they consume the rest of the content. Vault's enforced rules:

• Plain English. Write it the way you'd say it out loud.
• Up front. In the first three lines of a caption, in the first five seconds of a video, before the "more" cutoff. Not at the bottom, not in a hashtag flood.
• In the same medium. Spoken disclosure for spoken endorsements; on-screen text or caption for visual ones.
• In the same language. If the content is in Spanish, the disclosure is in Spanish.

Vague phrases like "thanks to so-and-so" or "sp" are not adequate disclosures. Neither is a buried #sp at the end of a 30-tag dump.

05Where and how it appears

Acceptable disclosure phrases for Vault campaigns include:

Phrases we won't approve for Vault campaigns:

For platform-native disclosures (Instagram's "Paid partnership" tool, TikTok's branded-content toggle, YouTube's "Includes paid promotion"), creators are required to use them in addition to the in-content disclosure — not as a substitute.

06Brand-side rules

Vault expects brand partners to:

• Allow disclosures — never ask a creator to suppress, hide, or shrink them.
• Approve disclosure copy and placement at the same time as creative review.
• Provide accurate product information — no claims the brand can't substantiate.
• Honor the campaign window — no requests to "leave the disclosure off the first version, add it later."

Brands that pressure creators to under-disclose lose Vault as an agency partner. We've enforced this. We will keep enforcing it.

07Performance claims

If the creator says a product did something specific — "I lost ten pounds in two weeks," "my ROAS doubled," "three out of four people noticed a difference" — that claim must be the creator's own honest experience or be substantiated by the brand with reliable evidence Vault has reviewed.

Atypical results require a clear and prominent disclosure. The phrase "results not typical" in 9-pt gray at the bottom of the screen does not qualify as clear or prominent.

08Authenticity

An endorsement must reflect the creator's honest opinion. Vault creators are required to:

• Have actually used the product or experienced the service before posting.
• Be free to decline campaigns that don't align with their audience or their judgment — without penalty.
• Refuse scripts that put words in their mouth they don't believe.

The creator's name and likeness are theirs. Nothing in a Vault contract licenses a brand to fabricate testimonials.

09Reporting concerns

If you see a Vault-represented creator post that you think violates the standards above — missing disclosure, misleading claim, anything — tell us. We take it seriously, we investigate every report, and we tell the reporter what we did about it.

• Email compliance@vaultmgt.com
• Include the post URL, the creator's handle, and what concerned you.
• We respond within 5 business days, even if the answer is "we looked, we disagree, here's why."

10Resources

The most current source for endorsement guidance is the FTC itself:

• Disclosures 101 for Social Media Influencers — FTC's plain-language guide
• The FTC's Endorsement Guides: What People Are Asking
• 16 CFR Part 255 — full text of the Endorsement Guides

The audience came for the creator. The deal is the creator vouching for the brand. Both sides keep more of what they earned when the deal is told the truth about.