Endorsement exposure

northlight

as of 2026-10-15source: pasted CSV, SHA-256 2b1b22d98036b9ac11 posts after identity collapseftc-endorsement v1

In scope for the ceiling

$265,440

5 posts the pack settled as in scope, at $53,088 each.

Unresolved

$159,264

3 posts the pack could not settle. What the same arithmetic reaches if every one of them turns out to be in scope.

The two figures are never added together. 3 posts no row reaches, 1 post awaiting a declaration, counted in neither.

What the ceiling assumes

The ceiling multiplies posts by $53,088, the maximum civil penalty codified at 16 CFR § 1.98(d) for Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. 45(m)(1)(A). Section 5(m)(1)(A) reaches conduct that a party already knew the Commission had held unfair or deceptive in a litigated cease-and-desist proceeding — the penalty-offense route. Whether that authority attaches to this organisation is a fact the engine cannot see: it has no way to know whether a Notice of Penalty Offenses letter or an existing order sits behind it. 16 CFR § 255.0(a) says: "The Guides in this part represent administrative interpretations of laws enforced by the Federal Trade Commission for the guidance of the public in conducting its affairs in conformity with legal requirements." They are not a penalty provision of their own. 16 CFR § 1.98 states: "The following maximum civil penalty amounts apply only to penalties assessed after January 17, 2025, including those penalties whose associated violation predated January 17, 2025." Read the figure as a ceiling on arithmetic, not a forecast.

How the posts were counted

  • One post whose verdict is T counts as one chargeable violation.
  • Post identity is the canonical URL and the brand together, so tracking-parameter variants of one link collapse to one post.
  • The same content cross-posted to two platforms is two canonical URLs and counts twice.
  • The same post claimed by two brands counts once per brand.
  • Posts awaiting a declaration are counted in neither figure.

The posts

One block per post, after tracking-parameter variants of a link collapse to one. The letter is the verdict: T in scope, U the pack could not settle it, F no row reaches it. Under each is the row that decided it and the text that row quotes.

https://instagram.com/p/CxA1northlight

northlight · @marla.builds · instagram · published 2026-04-11

$53,088 · one post, one chargeable violation

caption nothing found · on-screen notRead · transcript notRead

ftc-255-5-no-disclosure-in-any-channel · DRAFT · effective 2023-07-26

A connection is established and no disclosure term was found in any channel the engine could read. Section 255.5(a) requires the connection to be disclosed clearly and conspicuously; section 255.0(f) defines that as difficult to miss and easily understandable by ordinary consumers. Text absent from every readable channel meets neither.

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://tiktok.com/@deshawnmakes/video/7311220098

northlight · @deshawnmakes · tiktok · published 2026-05-02

$53,088 · one post, one chargeable violation

caption nothing found · on-screen nothing found · transcript nothing found

ftc-255-5-no-disclosure-in-any-channel · DRAFT · effective 2023-07-26

A connection is established and no disclosure term was found in any channel the engine could read. Section 255.5(a) requires the connection to be disclosed clearly and conspicuously; section 255.0(f) defines that as difficult to miss and easily understandable by ordinary consumers. Text absent from every readable channel meets neither.

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

ftc-255-5-gift-no-disclosure · DRAFT · effective 2023-07-26

A free or discounted product was received and no disclosure term was found in any channel the engine could read. Example 7 under section 255.5(b) puts a gifted lathe squarely inside the rule: the endorser should clearly and conspicuously disclose receiving it for free.

If a significant minority of viewers are likely unaware that the influencer received the lathe free of charge, the woodworker should clearly and conspicuously disclose receiving it for free, a fact that could affect the credibility that viewers attach to the endorsements.

16 CFR § 255.5(b)(7) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://reddit.example/r/woodworking/comments/1abc/best_planer

northlight · u/nl_tools_kev · blog · published 2026-03-19

$53,088 · one post, one chargeable violation

caption nothing found · on-screen notRead · transcript notRead

ftc-255-5-no-disclosure-in-any-channel · DRAFT · effective 2023-07-26

A connection is established and no disclosure term was found in any channel the engine could read. Section 255.5(a) requires the connection to be disclosed clearly and conspicuously; section 255.0(f) defines that as difficult to miss and easily understandable by ordinary consumers. Text absent from every readable channel meets neither.

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

ftc-255-5-employee-no-disclosure · DRAFT · effective 2023-07-26

The endorser is an employee of the seller and no disclosure term was found in any channel the engine could read. Example 8 under section 255.5(b) says the poster should clearly and conspicuously disclose their relationship to the manufacturer, and extends the same duty to employees posting reviews on retail sites and review platforms.

Unbeknownst to this community, an employee of a leading home robot manufacturer has been posting messages on the discussion board promoting the manufacturer's new product. Knowledge of this poster's employment likely would affect the weight or credibility of the endorsements. Therefore, the poster should clearly and conspicuously disclose their relationship to the manufacturer.

16 CFR § 255.5(b)(8) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://instagram.com/reel/CyPaidLabel

northlight · @thefinishroom · instagram · published 2026-06-08

$53,088 · one post, one chargeable violation

caption nothing found · on-screen nothing found · transcript nothing found

ftc-255-5-no-disclosure-in-any-channel · DRAFT · effective 2023-07-26

A connection is established and no disclosure term was found in any channel the engine could read. Section 255.5(a) requires the connection to be disclosed clearly and conspicuously; section 255.0(f) defines that as difficult to miss and easily understandable by ordinary consumers. Text absent from every readable channel meets neither.

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://youtube.com/watch?v=Kz9CaptionOnly

northlight · @thefinishroom · youtube · published 2026-05-21

$53,088 · one post, one chargeable violation

caption 1 found · on-screen nothing found · transcript nothing found

found: #ad full teardown on the channel · caption · opening

ftc-255-0-f-disclosure-outside-the-endorsement-channel · DRAFT · effective 2023-07-26

The endorsement runs in the video and the only disclosure sits in the caption beside it. Section 255.0(f) says a disclosure for a representation made through audible means should appear in at least the audible portion, and through visual means in at least the visual portion. Example 3 puts the same point sharply: a disclosure in the closing credits would not be clear and conspicuous.

If a communication's representation necessitating a disclosure is made through visual means, the disclosure should be made in at least the communication's visual portion; if the representation is made through audible means, the disclosure should be made in at least the communication's audible portion; and if the representation is made through both visual and audible means, the disclosure should be made in the communication's visual and audible portions.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

A disclosure during the show's closing credits would not be clear and conspicuous.

16 CFR § 255.5(b)(3)(i) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://instagram.com/reel/CyToolOnly

northlight · @saltandpinegoods · instagram · published 2026-06-14

no dollars · the pack could not settle it

caption platform tool only · on-screen notRead · transcript notRead

ftc-255-5-platform-label-is-the-only-disclosure · DRAFT · effective 2023-07-26

The platform declared the post paid, and the only disclosure text the engine found is the platform's own tool. Section 255.5(a) requires the connection to be disclosed clearly and conspicuously and section 255.0(f) says what that means, but neither settles whether a platform's built-in label carries it alone. This row returns unresolved and prints the reason.

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

the only disclosure found is the platform's own paid-partnership tool. Whether that tool, standing alone, is difficult to miss and easily understandable under section 255.0(f) is a question about how one platform renders one label, and the Guides do not answer it.

https://instagram.com/p/CzHashBlock

northlight · @marla.builds · instagram · published 2026-07-02

no dollars · the pack could not settle it

caption 1 found · on-screen notRead · transcript notRead

found: …working #shoptour #cabinetmaking #maker #ad · caption · hashtag_block

ftc-255-0-f-disclosure-in-trailing-hashtag-block · DRAFT · effective 2023-07-26

A disclosure was found, and it sits inside a trailing run of hashtags. Section 255.0(f) says that in an interactive electronic medium the disclosure should be unavoidable. The Guides do not say whether a hashtag block clears that bar, so this row returns unresolved and prints the reason rather than charging the post.

In any communication using an interactive electronic medium, such as social media or the internet, the disclosure should be unavoidable.

16 CFR § 255.0(f) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

the disclosure sits inside a trailing block of hashtags. Section 255.0(f) asks for a disclosure that is difficult to miss and, in an interactive medium, unavoidable, and the Guides do not settle whether a hashtag block clears that bar. Whoever settles it is looking at how the post renders on the device it was seen on.

https://x.com/deshawnmakes/status/1799112233

northlight · @deshawnmakes · x · published 2026-08-04

no dollars · the pack could not settle it

caption nothing found · on-screen notRead · transcript notRead

ftc-255-5-material-connection · DRAFT · effective 2023-07-26

The gate. Section 255.5(a) reaches a post only where a connection exists between the endorser and the seller that might materially affect the weight or credibility of the endorsement. A declared connection of paid, gifted or employment establishes one; so does a platform's own paid-partnership label. A declared connection of none denies one, and no row in this pack reaches the post.

Verbal statements, tags in social media posts, demonstrations, depictions of the name, signature, likeness or other identifying personal characteristics of an individual, and the name or seal of an organization can be endorsements.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

an “endorsement” means any advertising, marketing, or promotional message for a product that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

connection was not declared for this post — the operator has not said whether one exists

https://instagram.com/p/D1NoConnection

northlight · @marla.builds · instagram · published 2026-07-19

no dollars · no row in the pack reaches it

caption nothing found · on-screen notRead · transcript notRead

ftc-255-5-material-connection · DRAFT · effective 2023-07-26

The gate. Section 255.5(a) reaches a post only where a connection exists between the endorser and the seller that might materially affect the weight or credibility of the endorsement. A declared connection of paid, gifted or employment establishes one; so does a platform's own paid-partnership label. A declared connection of none denies one, and no row in this pack reaches the post.

Verbal statements, tags in social media posts, demonstrations, depictions of the name, signature, likeness or other identifying personal characteristics of an individual, and the name or seal of an organization can be endorsements.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

an “endorsement” means any advertising, marketing, or promotional message for a product that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

https://instagram.com/p/D2Disclosed

northlight · @thefinishroom · instagram · published 2026-08-09

no dollars · no row in the pack reaches it

caption 1 found · on-screen notRead · transcript notRead

found: #ad Northlight sent me the new stain line a… · caption · opening

ftc-255-5-material-connection · DRAFT · effective 2023-07-26

The gate. Section 255.5(a) reaches a post only where a connection exists between the endorser and the seller that might materially affect the weight or credibility of the endorsement. A declared connection of paid, gifted or employment establishes one; so does a platform's own paid-partnership label. A declared connection of none denies one, and no row in this pack reaches the post.

Verbal statements, tags in social media posts, demonstrations, depictions of the name, signature, likeness or other identifying personal characteristics of an individual, and the name or seal of an organization can be endorsements.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

an “endorsement” means any advertising, marketing, or promotional message for a product that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

This row reaches the post, and no other row in the pack caught what was read in the channels that carried text.

https://instagram.com/p/OldPost2022

northlight · @marla.builds · instagram · published 2022-11-04

no dollars · no row in the pack reaches it

caption nothing found · on-screen notRead · transcript notRead

ftc-255-5-material-connection · DRAFT · effective 2023-07-26

The gate. Section 255.5(a) reaches a post only where a connection exists between the endorser and the seller that might materially affect the weight or credibility of the endorsement. A declared connection of paid, gifted or employment establishes one; so does a platform's own paid-partnership label. A declared connection of none denies one, and no row in this pack reaches the post.

Verbal statements, tags in social media posts, demonstrations, depictions of the name, signature, likeness or other identifying personal characteristics of an individual, and the name or seal of an organization can be endorsements.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

an “endorsement” means any advertising, marketing, or promotional message for a product that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser.

16 CFR § 255.0(b) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return.

16 CFR § 255.5(a) · 16 CFR Part 255 - Guides Concerning Use of Endorsements and Testimonials in Advertising · retrieved 2026-09-10

the post was published 2022-11-04, before this row's provision took effect on 2023-07-26

Awaiting a declaration

No connection is declared for these posts and no platform label reports one, so no row in the pack reaches them. They carry no verdict, no rule row and no dollar, and they are counted in neither figure above. The wording under each link is what put it there.

https://tiktok.com/@saltandpinegoods/video/7399881122

northlight · @saltandpinegoods · reads like: link in bio, use code, thanks to

Hand ensign a two-column CSV of url and connection, rerun it with --declarations, and every post above rejoins the scan.

The pack that read these posts

FTC Endorsement Guides - disclosure of material connections, version 1, last verified 2026-09-10. 7 rows, and every one of them ships marked DRAFT: no lawyer has read a row in this pack. It sits here rather than in a footnote because it governs every verdict above.

Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. 45(m)(1)(A)—$53,088;16 CFR § 1.98(d) · 16 CFR 1.98 - Adjustment of civil monetary penalty amounts · effective 2025-01-17 · retrieved 2026-09-10

https://www.ecfr.gov/current/title-16/chapter-I/subchapter-A/part-1/subpart-L/section-1.98

The receipt

Every verdict, rule row, quoted sentence and figure above is also written to receipt.json, a canonical JSON document named by the SHA-256 of its own bytes. Change one character of it and the name stops matching.

fb52a33a127e974ff7fe1921a74f14dcd6099a531cb55fc065ef173e08c9cd14

receipt name: SHA-256 of the canonical receipt · issued 2026-10-15 · DRAFT: no lawyer has reviewed this rule pack

2b1b22d98036b9ac70183355b72349290306db27ea9f90e439d2bb3832512bdd

SHA-256 of the CSV this brief was built from · 13 rows for northlight

unsigned

No signing key was set when this brief was built, so it carries no signature. The receipt name above still fixes its contents.

https://disclosebrief.vercel.app/verify-receipt