Digital Wealth Academy
Not a pyramid - but sold by an operation that publishes no entity, no address, no terms and no earnings data.
A course whose main utility is the right to resell the course, from a seller you cannot identify.
Can you actually make money with Digital Wealth Academy?
No, and the first reason is that there is nobody to answer for it. No legal entity, no registration number, no address, no terms page and no footer links of any kind on the site, with checkout routed through an unrelated third-party domain. No income disclosure has ever been published, and when a consumer watchdog asked the principal to substantiate the advertised outcomes, she did not respond.
The loudest criticism of this model is wrong, though, and the report should say so plainly. On the two-prong test the FTC actually uses, only the first prong is met. There is no downline, no override on anyone else's sales and no multi-level compensation of any kind. This is not a pyramid scheme and it is not an MLM. Real course material is delivered and some of it has genuine instructional value.
The proposition has also quietly changed. The original version was true master resell rights and the reseller kept 100%. The current version is an 85% affiliate arrangement in which the operator retains 15% of every downstream sale, permanently. That is a material change to the core offer and it is not what the earlier marketing described.
What is being bought is the resale license rather than the teaching, because the teaching is free or nearly free elsewhere. Two resales at $422.45 returns the $497, which is exactly why the pitch works. What nobody publishes is the denominator - how many buyers ever make one sale - while thousands of resellers push identical modules into the same feeds at a price only they can discount.
typical tier; you then resell the identical course
- A named legal entity with a registration number, an address and a jurisdiction. Selling business education for several hundred dollars from behind no disclosed company at all is the whole finding in this file.
- A terms page. There is no refund policy, no governing law, no dispute mechanism and no company to serve, which is why this scores worst on terms of anything graded here.
- Substantiation for the earnings claims, or removal of the claims. Income claims are effectively the entire marketing proposition and the principal declined to support them when a watchdog asked.
- Disclosure that the original 100% master resell rights offer is now an 85% arrangement with a permanent 15% retained by the operator, stated where a buyer sees it before paying.
That call is computed, not chosen - the rule reads three of the nine published dimension scores and is printed on the methodology page. It describes this company's plan and the figures it publishes about the people already in it. It is not a prediction about you, and nothing on this site is advice.
Legal status
NOT A PYRAMID under the two-prong test - there is no downline and no override. The exposure is disclosure and income claims, not structure.
Confidence: Medium
Primary sources fetched directly where possible. Everything we could not verify is listed at the bottom of this page by name.
Follow the money
A digital marketing course sold with master resell rights: you buy it, and you acquire the right to sell the identical course and keep most of the revenue. It sits at the center of the faceless-marketing cohort that has dominated short-form video since 2023.
The structural question deserves a direct answer, because the loudest criticism of this model is wrong. Applying the two-prong test the FTC actually uses, only the first prong is met. There is no downline. There is no override on anyone else's sales. There is no multi-level compensation of any kind. This is not a pyramid scheme and it is not an MLM, and reviews that say otherwise are reaching for the nearest available label rather than the correct one.
The more defensible criticism is narrower and more interesting. This almost certainly falls outside the current Business Opportunity Rule, because the seller does not supply outlets, accounts or customers - which is precisely why the FTC voted in January 2025 to propose expanding that rule to cover business coaching, alongside a new earnings-claim rule. Neither proposal is final. The model exists in a gap that a regulator has publicly identified and has not yet closed.
And the model has quietly changed in a way most reviews have not caught up with. The original version was true master resell rights - you kept 100%. The current version is an 85% affiliate arrangement in which the operator retains 15% of every downstream sale, permanently. That is a material change to the core proposition, and it is not what the earlier marketing described.
Where a $497 resale goes
The current 85% arrangement, not the original 100% MRR
| Product | Price | Pays |
|---|---|---|
| Core course bundle The main product. Digital marketing, branding and funnel instruction, delivered as recorded modules. |
~$497 one-time |
85% on resale |
| Resale license The actual asset being bought. Without it the course is priced far above comparable instruction. |
included — |
— |
| Community access A large hosted community. The principal's own profile lists it as free, which complicates the revenue arithmetic. |
included — |
— |
| Upsell tiers Additional bundles and templates. Pricing is inconsistent across sellers because every seller sets their own. |
variable one-time |
varies |
Who runs it, and what they ran before
Identified as the operator. A consumer-watchdog investigation established that she earned six figures with a multi-level marketing company in 2021 - which sits awkwardly against the origin story used in the marketing. Asked to substantiate the advertised outcomes, she did not respond.
No company name, registration, jurisdiction or responsible officer is disclosed anywhere on the site or in the checkout flow. For a business selling business education at several hundred dollars, that absence is material.
Registered address
Not disclosed
No legal entity, no registration number, no address, no terms page, and no footer links of any kind on the site. Checkout routes through an unrelated third-party domain. That is not a gap in our research - it is the finding.
The veteran's checklist
Eight questions that decide whether this is a business or a transfer mechanism. Same eight, every review.
| Question | Answer |
|---|---|
| Who legally owns it? |
RED
Not disclosed. No entity, no registration, no address. Principal identified as Rachell Medero.
|
| Where is it incorporated? |
RED
Unknown and unverifiable. No jurisdiction stated anywhere on the site.
|
| Regulatory action, ever? |
OK
None. No FTC or state action and no adjudicated finding against this operation.
|
| Published income disclosure? |
RED
None. The operator declined to substantiate her advertised results when a watchdog asked.
|
| What does it take to break even? |
WATCH
Two resales at 85% returns your purchase price. Nobody publishes how many buyers make even one.
|
| Do I own the list? |
WATCH
You own whatever audience you build. You do not own the product, the license terms or the platform.
|
| Can I get a refund? |
RED
There is no terms page, so there is no stated refund policy and no entity to ask.
|
| Merchant play or miner play? |
RED
Miner. The product's primary market is people who intend to resell it.
|
What has to be true for you to get paid
| To cover | You need |
|---|---|
| Recover your own $497 | 2 resales at 85% $422.45 each |
| Earn $2,000/month | ~5 resales per month, sustained indefinitely, into a saturating market |
| Know the conversion rate | No data published none by the operator or anyone else |
| Verify the community claim | Not possible the count does not reconcile with claimed revenue |
Read this twice
Two resales returns your money, which is why the pitch is persuasive. What the arithmetic cannot show is the denominator: nobody publishes how many buyers make even one sale. The market is also visibly saturating - the same course, with the same modules, is being sold simultaneously by thousands of resellers into the same short-form feeds, all of them competing on the identical product at a price only they can discount.
Run your own numbers
Drag the sliders. Nothing here is stored or sent.
85% of a $497 resale. One-off, not recurring - nothing compounds. No conversion data exists from any source, so set the ad-spend slider to whatever you would actually risk and read the net figure honestly. Your own subscription cost of $0/mo is included.
What it costs to replace this yourself
What the same instruction costs from sources that publish who they are. The community is the part hardest to replicate; the curriculum is not.
| What they sell you | What you'd use instead | Your cost |
|---|---|---|
| Digital marketing fundamentals | Free platform academies and long-form video | $0 |
| Branding and positioning modules | Two standard marketing books | $30 once |
| Funnel and email instruction | Vendor documentation and free courses | $0 |
| Short-form content strategy | Free creator-platform resources | $0 |
| Community and accountability | A paid niche community with a named operator | $20–50/mo |
| The resale license | No equivalent - this is the actual product | — |
| Total as sold ~$497 once |
Total, built yourself $30 + $20–50/mo |
Price-to-value
The instruction is not scarce. The resale license is the entire premium, which means the honest description of what is being sold is a license to sell the license - and that is a materially different purchase from the one the marketing describes.
Three operators, five horizons
Probability of cumulative net profit
Hover any point for median, top decile and bottom quartile.
Typical buyer
Buys it, posts to a small following
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 14% | −$497 |
| 6 mo | 18% | −$400 |
| 1 yr | 20% | −$300 |
| 3 yr | 14% | −$600 |
| 5 yr | 10% | −$800 |
Committed reseller
Daily content, paid ads, treats it as a business
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 18% | −$2,400 |
| 6 mo | 26% | −$3,000 |
| 1 yr | 30% | −$2,000 |
| 3 yr | 18% | −$6,000 |
| 5 yr | 12% | −$9,000 |
Established creator
Large existing audience promotes it
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 52% | +$3,400 |
| 6 mo | 48% | +$6,000 |
| 1 yr | 36% | +$4,000 |
| 3 yr | 16% | −$9,000 |
| 5 yr | 12% | −$16,000 |
Methodology note. MODELED, with low confidence, because nothing exists to calibrate against - no income disclosure, no conversion data, and community-size claims that do not reconcile. The declining curve for an established creator is not a commission mechanic; it prices in audience exhaustion and the reputational cost of having sold a resale license to your own followers, some of whom will not recover their money.
Where you are actually allowed to promote this
Platform policy reads, not verifications. Check every one before you spend a dollar - enforcement changes faster than the written policy does.
Red flags and green flags
Red flags
121No legal entity is disclosed anywhere
2No terms of service exist
3No income disclosure, and a refusal to substantiate
4The origin story is contradicted by the record
5The model quietly changed from 100% to 85%
6The community-size claim does not reconcile
7The product's primary utility is the right to resell it
8The market is visibly saturating
9It sits in a regulatory gap a regulator has publicly identified
10Platform risk is concentrated and severe
11Personal liability transfers to every reseller
12You cannot evaluate the seller before paying
Green flags
61It is not a pyramid scheme and the review should say so
2Real course material is delivered
3No downline, no recruitment quota, no rank ladder
4No autoship, no ongoing fee, no ongoing obligation
5No securities component
6No regulator has acted against it
We would like to be wrong about this
Upward
- Publication of a legal entity, registration number, address and responsible principal.
- A terms of service page with a refund policy, governing law and a dispute mechanism.
- An income disclosure showing what buyers actually earn, and substantiation for the outcomes used in advertising.
Downward
- Any FTC or state consumer-protection action, or finalisation of the proposed Business Opportunity Rule expansion in a form that captures this model.
- Evidence that the retained percentage has increased, or that a second tier has been introduced.
- Platform enforcement removing the primary distribution channel.
Grade is F, and not for the reason most critics give. The structure is defensible. The disclosure is not.
Be precise, because precision is what makes the criticism stick. This is not a pyramid scheme. There is no downline, no override, no multi-level compensation. Anyone telling you otherwise has reached for a label rather than reading the model. The instruction is real, the material is delivered, and no regulator has found against this operation.
The problem is everything you cannot see. There is no company name. There is no registration. There is no address. There is no terms page, which means no refund policy and no governing law and nothing to enforce. Checkout goes through a domain with no stated relationship to the seller. There is no income disclosure, and when a watchdog asked the operator to substantiate the results in her own advertising, she did not answer. You would be paying several hundred dollars, and then reselling on behalf of, an operation you cannot identify.
For a reseller the calculation is worse still, because the liability moves to you. Every claim you make about earnings is yours under the endorsement rules, with no substantiation available from anyone. You would be selling a resale license to your own audience, into a market where thousands of people are selling the identical modules, with no data on what any of them earn. If you want to teach digital marketing - and it is a genuinely teachable skill - teach it under your own name, with your own materials, from an entity a buyer can look up. That is a better business and it is not a harder one.
Learn the skill, skip the license
The instruction is available free from platform academies and two standard books. The premium here is the resale right, not the teaching.
Buy community from someone you can name
Paid niche communities run $20–50 a month from operators with a real entity, a refund policy and a findable address. Same accountability, none of the counterparty risk.
Never resell on behalf of an unnamed entity
Under 16 CFR 255 the income claim is yours. Making it for a seller with no registered identity, no terms and no earnings data is the worst version of that trade.
Teach under your own brand
The audience for beginner digital-marketing instruction is enormous and genuinely underserved. Own the content, own the entity, own the list - and you own a business rather than a license somebody else can revise.
Nine dimensions, weighted
Dimension profile
Further from center is better. Hover any point.
Hard caps that bind here
The lowest binding cap wins, regardless of the weighted arithmetic.
What we read
Every source below links to the document itself. Tier 1 is a primary record - the company’s own plan, policy or disclosure, a court filing, a regulator’s decision or an SEC filing. Tier 2 is a self-regulatory or secondary regulator record, tier 3 reporting or academic work, tier 4 an open-market price comparison. Where a document can be moved or withdrawn, an archived copy is linked beside it. If a link is dead when you try it, that is a correction we want.
- digitalwealthacademy.co - official landing page ("I've taught over 130,000+ students"; no footer, terms, privacy or refund links)
digitalwealthacademy.co - product pages, pricing, checkout flow, absence of terms and footer links
Not established by this document: The checkout itself is an off-domain link from a single CTA button and no terms of service, privacy policy, refund policy or company identification exists anywhere on digitalwealthacademy.co, so there is no such document to link - the absence is the finding.
- Digital Wealth Academy 3.0 - Skool listing showing the paid entry price ("Entry requires a $497 minimum (pre-tax)")
Published community membership figures and the principal's own community listing
Not established by this document: Published membership figures are mutually inconsistent across the company's own surfaces - 120,000+ (TINA.org, Aug 2025), 130,000+ (digitalwealthacademy.co and reseller funnels) and 137,100 (the third-party community platform listing, Aug 2026) - and none is auditable.
- "Rachell Medero/Digital Wealth Academy" - TINA.org investigation, 18 August 2025 (prior Monat "6-figure earner" claim; substantiation request went unanswered)
Consumer-watchdog investigation establishing the principal's prior multi-level marketing earnings and the unanswered substantiation request
- "FTC Proposes Rule Changes and New Rule to Deter Deceptive Earnings Claims by Multilevel Marketers and Money-Making Opportunity Sellers" - FTC press release, 13 January 2025 (Commission vote 3-2)
FTC vote of 13 January 2025 proposing expansion of the Business Opportunity Rule (16 CFR 437) to business coaching, and a proposed earnings-claim rule - neither final
- Business Opportunity Rule - Notice of Proposed Rulemaking, 16 CFR Part 437, Project No. R511993, 13 January 2025 (PDF)
- Earnings Claim Rule - Notice of Proposed Rulemaking, 16 CFR Parts 437 and 462, R111003, 13 January 2025 (PDF)
- 16 CFR Part 437 - Business Opportunity Rule, current rule text (eCFR)
- In re Koscot Interplanetary, Inc., 86 F.T.C. 1106 (1975) - FTC Commission Decision Volume 86, pp. 1106-1202 (PDF)
FTC v. Koscot Interplanetary two-prong pyramid test, applied to the resale structure
- FTC, "Business Guidance Concerning Multi-Level Marketing" - quotes the Koscot two-prong test at 86 F.T.C. 1106, 1181
- buydigitalwealthacademy.com - reseller funnel selling DWA 3.0 at $497 with an advertised 85% reseller commission and a "130,000+ students" claim
Reseller listings and pricing across short-form video platforms
Not established by this document: Individual TikTok and Instagram reseller posts are ephemeral, account-scoped and frequently deleted, so no stable short-form-video listing could be cited; the linked reseller funnel and marketplace listing are the closest durable evidence of reseller pricing.
- eBay listing 166927865275 - "Digital Wealth Academy (DWA) Course with Master Resell Rights (MRR) PLR", US $497.00
What we could not get
- The operating legal entity, its registration, jurisdiction and responsible officer
- Total buyers, conversion rates and what any buyer actually earns
- Claimed revenue figures and how they reconcile with published membership counts
- Whether the retained percentage differs across tiers or has changed again
- Whether the underlying course content is originally authored or licensed from a third party
- Any refund practice, since no policy is published
Not advice
This is independent analysis for decision-making, not legal, financial or investment advice. Allegations reported by third parties should be verified against primary court and regulatory records before any decision.
Researched by Claude. Reviewed by an editor.
Every report is researched and written by Claude, Anthropic’s AI assistant, from the company’s own plan documents, policies, terms and regulatory file - then reviewed before publication by Rob Fore, who checks the sources and the stage-label on every allegation.
- Nine weighted dimensions, published with their weights
- The editor checks the evidence and cannot change the number - the build rejects any page whose grade does not reconcile to its own arithmetic
- Every affiliate position we hold is disclosed on the report it touches
- No company has paid for a grade, and no report carries an affiliate link
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Digital Wealth Academy - frequently asked
QIs Digital Wealth Academy a pyramid scheme?
QHow does master resell rights work at Digital Wealth Academy?
QWho owns Digital Wealth Academy?
QDo people actually make money with Digital Wealth Academy?
QIs master resell rights legal?
Author, editor and publisher
This report was researched and written by Claude, Anthropic’s AI assistant, working from primary documents - Digital Wealth Academy’s own compensation plan, its policies and procedures, its terms of service, its income disclosure statement where one exists, and its regulatory and self-regulatory file. It was scored against nine weighted dimensions that are published in full, with their weights, on the methodology page.
Before publication it was reviewed by Rob Fore, who checks every source link, every figure against the document it came from, and every allegation against its stage-label - an investigation is not a finding, a warning letter is not an enforcement action, and a filed claim is not a verdict.
The editor does not set the grade. The published score is the weighted composite of the nine dimension scores, and the build refuses to emit a page where the two disagree by more than 0.06. A grade moves when the evidence moves it and not otherwise.
Rob Fore has marketed online since 1996, wrote Online MLM Marketing (2014), and is CEO of Listech Inc, the Nevada corporation that publishes this site. He holds affiliate positions in companies graded here - including LiveGood, which this site grades D, SendOutCards, which it grades C−, and the Home Business Academy, which it grades B−. Those positions are disclosed on the reports they touch, and changed nothing on this page.
About the author and our conflicts · Contact the editor · Corrections: corrections@opportunitygrade.com
Tell me if this grade changes
Digital Wealth Academy is graded F as of July 27, 2026. Grades move when the evidence moves - a new income disclosure, a regulatory action, a rewritten compensation plan. Leave your address and you will get one email if this one does.
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Corrections
Every factual claim on this page is sourced, and the ones we could not stand up are named in the unable to verify list above. If something here is wrong, we want to know, and we would rather hear it from Digital Wealth Academy than from a reader.
Write to corrections@opportunitygrade.com. Point at the specific sentence and send the document that contradicts it - a plan document, a filing, an income disclosure, a policy page. We will check it against the primary source, correct the page if it is wrong, and say in the report that it was corrected and when. A grade moves if the evidence moves it.
This address reaches a person, not a form. We do not require a takedown demand, an NDA or a lawyer to accept a correction, and we do not remove a report because a company disputes its conclusion - only because the underlying facts turn out to be wrong.