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Travel membership and travel-technology subscription · Unilevel MLM with generational depth

Surge365

Fully operational in 2026, with a clean government file and a functioning compliance desk - attached to a plan in which the only priced, commissionable product is the $499 + $99.95-a-month package that also makes the buyer a distributor, while the consumer portal is free.

Reviewed August 1, 2026 Founded Entity incorporated 27 March 2013 · business start date 2 March 2015 per the Better Business Bureau · still enrolling in 2026 Confidence: Medium-High
D-GRADE
3.3/10
Weighted composite

ACTIVE, CLEAN FILE, NO RETAIL PRICE

The consumer-facing travel portal is free; every front-end commission in the plan is paid on a $499 + $99.95-a-month package that is simultaneously the product, the qualification vehicle and the thing that makes you an earner - and the company’s own rules say your own package counts.

The question you came with

Can you actually make money with Surge365?

NO No - not on the numbers this company publishes

No, and the structural reason is one line: the consumer-facing travel portal is free. The only priced, commissionable product in the plan is the $499 plus $99.95-a-month Travel Technology Package, which is simultaneously the product, the buyer's own qualification vehicle and the thing that turns the buyer into an earner. The qualification rules state that your own package counts.

The company publishes that 67.66% of Surge Business Associates earned no income at all in 2025, and it deserves credit for that, because plenty of its peers publish an average alone. The average earning associate took $1,967.93 gross for the year. Year one on the package costs $1,698.40. That is $269.53 of margin before tax, before travel taken, before events and before advertising, and the disclosure says in its own words that business expenses are not accounted for.

Across everybody the average is $636.37, which is $1,062.03 short of the package cost. No median is published, no rank table, no participant counts and no high and low. In a plan carrying $10,000 century bonuses the distribution is certainly right-skewed, so the result for the typical earning associate is simply not knowable from what is published. Not one rank in the ladder counts customers.

The good column is real and it is not short. There is no government enforcement action against this company, ever. Two self-regulatory cases both closed in its favor with no referral, and the compliance desk demonstrably acts. The refund is five business days, full, and extends to the subscription. The published figures survive an internal consistency check, which means the denominator has not been scrubbed.

What it costs to be in
$499 + $99.95/mo

the Travel Technology Package - $1,698.40 in year one, $1,199.40 thereafter; the $19.95 + $19.95/month Jr. Executive tier exists but does not qualify you to earn overrides

What would have to change
  • A retail price on the commissionable product. While the free portal is what a customer gets and the $499 package is what pays, the plan is selling positions with travel attached rather than selling travel.
  • A qualification rule that does not count your own package. The plan states that the representative's own purchase satisfies the monthly override gate, which is the exact mechanism this dimension exists to test for.
  • A rank somewhere in the ladder that counts customers. Team Builder counts five Junior Executives and five package sales, Regional counts three Team Builders, and Level 1 Marketing Director counts 250 active members.
  • A median next to the average. With $10,000 bonus triggers sitting in the same plan as a $636.37 all-associate average, publishing averages alone leaves the middle of the distribution invisible to anybody deciding.

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.

67.66%
Surge Business Associates who earned no income
the company’s own 2025 income disclosure - and publishing it is a genuine credit
$269.53
Margin between the average earning participant and the package cost
$1,967.93 average active earnings against $1,698.40 in year one, expenses excluded
$0
Price of the consumer-facing Vortex portal
the commissionable product is the $499 + $99.95/month business package instead
$1,199.40
Annual fees waived by "3 & FREE"
awarded for recruiting three package holders, with no customer component at all

Legal status

LEGAL - and unusually clean at the government level. No FTC action, no state Attorney General action, no consent order, no assurance of voluntary compliance, no cease-and-desist, no warning letter and no investor alert naming Surge365 could be located anywhere in eleven years of trading, and no court or regulator has ever found Surge365 to be a pyramid scheme. The two proceedings that exist are self-regulatory rather than governmental: Direct Selling Self-Regulatory Council Case #58-2022, closed 7 January 2022 after the company agreed to comply, and DSSRC Case #173-2024, administratively closed 11 September 2024 in the company’s favor citing its "good faith effort," with no referral to the Federal Trade Commission in either. The regulatory file that does exist belongs to a predecessor enterprise and to a different legal person - see the ownership section, where it is stage-labeled in detail. Separately, and stated precisely: the four US states that register sellers of travel - California, Florida, Washington and Hawaii - could not be queried from this research session, so registration status in all four is unverified. What is verified is that no CST, ST, Washington or Hawaii registration number appears in any Surge365 document retrieved. That is "could not retrieve," not "not registered," and the distinction is deliberate.

Confidence: Medium-High

Primary sources fetched directly where possible. Everything we could not verify is listed at the bottom of this page by name.

What this actually is

Follow the money

An Illinois travel-membership and travel-technology program sold through independent Surge Business Associates on a unilevel plan with six generations of Team Builder depth and three of Director depth. It is fully operational: enrollment is open at both published tiers, the compensation plan in force is stamped "V 2, ©2026," a fresh income disclosure covering all of calendar 2025 is published, executives were promoted in December 2025 and a 2026 National Kickoff Tour opened in Los Angeles on 10 January 2026. This is not a wind-down report.

Several things about it are better than its online reputation, and they belong first. There has never been an FTC action, a state Attorney General action, a consent order or an assurance of voluntary compliance against Surge365 - the government file is empty. The two proceedings that exist are self-regulatory: a monitoring inquiry closed in January 2022 and Case #173-2024 administratively closed on 11 September 2024 in the company’s favor, with no referral in either, after the company removed flagged posts, wrote to the individuals behind the rest, ran daily social monitoring on 48-hour deadlines and updated its income disclosure. The Better Business Bureau records an A+ rating with four complaints in three years and none closed in the last twelve months. The refund right is five business days but it is unconditional and it extends to the monthly subscription. And the company publishes, in plain text on its own domain, that 67.66% of its associates earned no income - a number most of this category will not print.

Then the structure, which is where the grade comes from. The genuinely consumer-facing artifact - the Vortex booking portal - is free, and the company’s own promotional channel calls it "Your Free Travel Portal." The commissionable product is the Travel Technology Package at $499 plus $99.95 a month, $1,698.40 in year one and $1,199.40 thereafter. That package is the product, the qualification vehicle and the earning position at once: the plan’s override gate requires one package enrollment in the calendar month and states that the representative’s own package counts. No rank in the ladder counts customers. And "3 & FREE" waives $1,199.40 a year of fees for recruiting three package holders, with no customer component at all. There is, in short, no retail price on the commissionable product.

The economics follow from that. Against a $1,698.40 year-one cost, the company reports average earnings of $1,967.93 among associates who earned anything - a margin of $269.53 before tax and before any expense, with the disclosure stating in terms that business expenses are excluded - and $636.37 across everybody, which is $1,062.03 short of the package price. Two-thirds earned zero. No median, no rank table and no participant counts are published. Meanwhile the same plan document that produces those averages carries "$54,000 or more in the next 100-Days," a "$1 Million Bonus" and a "$1,200,000 yearly bonus," which is why the self-regulator has twice had to police a field that was repeating what the company wrote.

The ownership record is the last piece and it must be read at its exact stage. The Chief Operating Officer promoted in December 2025 records himself as a former Director of Sales and Marketing at YTB International, which the California Attorney General sued in August 2008 alleging an illegal pyramid scheme, which settled for $1 million in May 2009 with no admission of liability, which settled with Illinois for $150,000 in 2011, and which filed Chapter 11 on 1 March 2013. A settlement with no admission is not a finding; a Chapter 11 is not a finding of wrongdoing; and none of it is a finding against Surge365, a separate legal person incorporated four weeks after that filing and trading from 2 March 2015 - the day after the predecessor’s successor stopped enrolling. What is fairly criticized is that the corporate site discloses none of it, and that the page headed "Founders" shows field distributors rather than owners.

Where each $99.95 monthly subscription goes

Built from the amounts published in the company’s own compensation plan documents. Residual components are the documented maxima at each rank; the retained share is the remainder available for merchant fees, the travel technology license, staff, the campus, reward trips, higher-rank guarantees and margin. No audited accounts exist against which to test it.

77% 12%
Retained by the company (~$76.95)Team Builder residual - $2 × 6 generations ($12.00)Level 1 Director monthly bonus, amortised over 250 actives ($4.00)Director generational residual - $1 × 3 generations ($3.00)Marketing Director regional residual ($2.00)National Team Builder per-person residual ($2.00)
ProductPricePays
Travel Technology Package (TTP)
The commissionable product and the earning position in one. $1,698.40 in year one, $1,199.40 thereafter. Includes the Executive Travel Membership (4-Person), the Vortex platform, weekly specials, a personal concierge, the 150% Price Difference Guarantee, the first-anniversary reward trip and the Travel Advisor Package. Buying it is what makes you Qualified To Override - and the plan states that your own package counts.
$499 initial
$99.95/month
$50 / $100 / $120–$140 by rank, plus $10 × 6 generations, plus $500 / $1,000 / $10,000 bonus triggers and a 25% match
Jr. Executive Program (SBA position)
$259.35 in year one. A genuinely low door - but it does not make you Qualified To Override unless you hold your own active package or have an active personally-sponsored package holder, so it is not an earning position. Its function in the plan is to be countable toward the five Junior Executives that Team Builder requires.
$19.95 initial
$19.95/month
No direct front-end commission is documented on the $19.95 initial fee
Vortex customer portal
The only genuinely consumer-facing artifact, and it carries no price and no company-funded commission. The Travel Builder Bonus pays uplines 6% at National Team Builder and 4% at Director of team travel commissions, described as "up to 10%" combined - a bonus available only at the two highest tiers.
$0
free
None from the company - the member "earn[s] 100% of what they save" plus Reward Credits
Travel Advisor Package
$748.40 in year one if bought standalone. Host-agency-style advisor access with travel-specialist training described by a trade publication as CLIA-associated, though no CLIA member number is published anywhere. Fora Travel charges $299 flat for the year with a published 70% split.
$149 initial (bundled inside the TTP)
$49.95/month
Bundled; no separate commission schedule is published
S365 Reward Trip (first anniversary)
Up to seven nights at worldwide resorts after twelve consecutive months of active membership, with 30 months to use it. The company does honor it; the disclaimer that "some resorts may require an additional fee upon check-in" is not quantified anywhere.
$100 registration
year two benefit
None - a retention device
"3 & FREE" monthly fee waiver
Granted for three active personally-sponsored package holders. No customer component of any kind. It is the single clearest recruitment incentive in the document, and it systematically hollows out the recurring revenue base by rewarding exactly the behavior the plan is built on.
−$99.95/month
while maintained
Effectively $1,199.40 a year in waived fees
Historical consumer tiers (discontinued)
The company’s own 2019 FAQ still online references Vortex, Vortex Membership and Vortex Platinum subscribers at these prices. A genuine consumer product with a consumer price did once exist; it has since been collapsed into the free portal on one side and the business package on the other.
$199 / $299 / $499
$59.95/month
$15–$30 per membership sale by tier, 2019-era record
Events and the National Kickoff Tour
The 2026 tour opened in Los Angeles on 10 January 2026. Ticket prices, travel and any tools, leads or funnel costs sold to participants are not published anywhere and are excluded from every cost figure in this report - which flatters the arithmetic rather than the reverse.
Not published
as scheduled
Not published
Background check

Who runs it, and what they ran before

DC
Dr. Christopher J. Cokley
Chairman and Chief Executive Officer

The corporate biography states that he "has held positions from Vice President of Marketing to Executive Sales Director to CEO, with some of the leading companies in the home based business arena" - and names none of them. No regulatory action, fraud judgment or criminal proceeding against him could be located in any source reviewed, which counts in his favor. The transparency gap does not: a chief executive whose stated career is entirely in direct selling should be able to name the firms, and the omission is recorded here as a disclosure fact rather than an allegation. Earlier third-party reviews place him as President rather than CEO, so the elevation appears to be recent.

CT
Clint Tomer
Chief Operating Officer, promoted December 2025

His own public LinkedIn headline records him as a former "Director of Sales & Marketing at YTB" - YTB International, the Illinois travel MLM that the California Attorney General sued in August 2008 alleging an illegal pyramid scheme. That is the documented personnel bridge between the two enterprises, and it comes from his own profile rather than from a critic. Stage-labeling matters: he was not a defendant in that action, there is no finding of any kind against him personally, and holding a sales role at a company that was later sued is not wrongdoing. What is a legitimate criticism is that the Surge365 corporate biography - which credits him with "20+ years of professional experience focused on operational scaling and infrastructure development" - does not mention YTB at all.

DS
Delvy Santiago
President, promoted December 2025

Described by the company as having traveled "from team leader to corporate positions" - a field distributor promoted into a corporate role. No prior ventures are disclosed and none could be located. No regulatory or criminal matter involving him was found.

Gn
Governance note - the predecessor, stage-labeled
What the founder record does and does not establish

YTB International was founded in Alton, Illinois in 2001 by J. Lloyd "Coach" Tomer, J. Scott Tomer and J. Kim Sorensen. On 5 August 2008 the California Attorney General filed a civil complaint against the corporate entities and four principals alleging an illegal pyramid scheme, unfair business practices and false advertising, pleading that only 38% of members earned travel commissions in 2007 and that the median commission among those who earned anything was $39.00 - that is a filed complaint, and allegations are not findings. On 14 May 2009 it settled for $1 million in penalties, costs and restitution together with injunctive terms, with no admission of liability recorded - a settled civil matter, not a litigated finding of fact and not a criminal one. In May 2011 Illinois settled for $150,000 in restitution with no admission or denial of guilt; the accompanying finding that 80% of revenue came from new agent recruitment was a private ratings body’s, not a government’s. Rhode Island investigated in 2007 and the disposition could not be established. YTB International filed Chapter 11 on 1 March 2013 - an insolvency filing, which is not a finding of wrongdoing. Its travel arm had been rebranded First Alliance Travel in 2012; assets were acquired by Jamraval, Inc. in October 2013 and operated as YTB Global Travel, which ceased enrolling new representatives on 2 March 2015 - the same date the Better Business Bureau records as Surge365’s business start. Reports naming J. Scott Tomer as Surge365’s CEO and J. Lloyd Tomer as its Chief Visionary Officer rest on secondary review sites; the current corporate site names only Cokley, Santiago and Clint Tomer, and those identifications are treated here as unverified rather than asserted. None of the predecessor file is a finding against Surge365, which is a separate legal person that has never been sued by a regulator.

Registered address

Glen Carbon and Wood River, Illinois, USA
This is a going concern, and the report says so before it says anything else. Enrollment is open at both published tiers; a compensation plan document stamped "V 2, ©2026" is in force; an income disclosure covering the full 2025 calendar year is published; a press release dated 24 December 2025 announced Clint Tomer as Chief Operating Officer and Delvy Santiago as President with Dr. Christopher J. Cokley continuing as Chief Executive Officer; a "Surge365 Powerline Compensation" layer was introduced in August 2025; and a 2026 National Kickoff Tour opened in Los Angeles on 10 January 2026. A 7,500-square-foot corporate campus in Wood River, Illinois was announced in August 2024. Nothing has been renamed, merged or wound down. Surge365, LLC is a private company with no public filing obligation, so no audited accounts exist; the only revenue figure in circulation - roughly $5 million a year for each of 2020 through 2025 - is a trade publication’s estimate and not a company figure. The Illinois Secretary of State entity record could not be retrieved from this session, so the file number, registered agent and current standing are unverified.

Compensation plan

What has to be true for you to get paid

To coverYou need
Recover the year-one package cost at the base rate 34 personal package sales
$1,698.40 ÷ $50 per sale at Junior Executive - about $57,745 of other people’s year-one commitments
Reach Team Builder, the plan’s designed early win 5 Junior Executives and 5 package sales
yields roughly $2,115 against $1,698.40 - net about +$417, from five people each committing $1,698.40
Reach Regional Team Builder, top-few-percent territory 3 Team Builders developed from your group
roughly $5,380 against $1,698.40 - net about +$3,682, on a downline whose collective year-one outlay is $70,000–$200,000
Justify the package as a travel club with no recruiting $1,698.40 of genuine savings in year one
at a generous 8% saving that implies about $21,000 of annual travel spend, against free tools costing $0

Read this twice

Every figure above uses only commission amounts published in the company’s own plan, assumes the Travel Technology Package route because it is the only one that qualifies a participant to earn overrides, and excludes tax, travel costs, event attendance and advertising - all of which flatter the participant. Set them against the company’s own 2025 income disclosure: 67.66% of Surge Business Associates earned no income at all; the average across everybody was $636.37, which is $1,062.03 short of the $1,698.40 package cost; and the average among those who earned anything was $1,967.93, which clears that cost by $269.53 before tax and before a single expense the disclosure expressly does not deduct. The modal outcome in the first scenario is therefore not a slow build toward 34 sales - it is minus $1,698.40. The second scenario deserves the most attention, because it is the plan working: a participant who recruits five people, makes five package sales, takes the $500 promotion bonus and one $1,000 seven-sale bonus, and carries roughly 22 subscriptions in their group by year end, finishes the year at approximately break-even having introduced 22 people to a $1,199.40-a-year subscription. Above that, the structural arithmetic is worth stating once: a Level 1 Marketing Director requires 250 active members across three legs, funded by roughly $299,850 of annual subscription inflow, and if two-thirds of associates earn nothing then those 250 actives sit on a base of roughly 770 enrolled people - so for every Level 1 Director, around 520 people are earning zero. One caveat cuts the company’s way and belongs here: "3 & FREE" genuinely does remove the $1,199.40 recurring cost for anyone holding three active personally-sponsored package holders, so a participant who reaches that point is carrying only the original $499 plus their own time.

Run your own numbers

Drag the sliders. Nothing here is stored or sent.

-
Cumulative net, after costs
Total Travel Technology Package sales -
Commission that month -
Total commissions earned -
Total you paid in -
Net -

Fifty dollars is the base-rank commission on a $499 Travel Technology Package sale; it rises to $100 and then to $120–$140 with rank, so this slider models the entry rate a new participant actually earns rather than the best case. The $10 payments across six generations are excluded because they are keyed to headcount rather than to anything sold, as are the $500, $1,000 and $10,000 bonus triggers and the 25% match. The cost line is the $99.95 monthly subscription that keeps the position commissionable - $1,698.40 in year one - and note that the "3 & FREE" mechanic waives $1,199.40 a year for recruiting three people, which is a recruitment incentive dressed as a discount. The consumer-facing portal is free, so there is no retail price on the commissionable product at all. For calibration, the company’s own 2025 disclosure reports 67.66% of representatives earning nothing, and an average for active representatives of $1,967.93 against that $1,698.40 of cost - a margin of $269.53 before any expense. Your own subscription cost of $99.95/mo is included.

Your money

What it costs to replace this yourself

What the same capability costs on the open market at 2026 published prices. The comparison is unusually clean in this category because the core proposition - member-only hotel pricing behind a closed user group - has become the travel industry’s standard free customer-acquisition tool. Prices are taken from vendors’ own published pages where those were retrievable and labeled where they were not.

What they sell youWhat you'd use insteadYour cost
Flight and hotel search across all suppliersGoogle Flights, Kayak, Skyscanner, Momondo$0
Member-only hotel pricingBooking.com Genius - 10% from two stays, 15% plus breakfast or upgrade from five$0
Member-only hotel and flight pricingExpedia One Key and Hotels.com member prices$0
Opaque / wholesale hotel ratesPriceline Express Deals, Hotwire Hot Rate - the actual wholesale channel$0
Brand member rates plus elite benefitsMarriott Bonvoy, Hilton Honors, IHG One Rewards$0
Points-boosted booking portalChase Travel or American Express Travel, for a card already held$0
Curated package and cruise pricing with a rebateCostco Travel - Gold Star membership~$65/yr
Proactive cheap-fare alertsGoing Premium (Limited tier is free; Elite is $199)$49/yr
Travel Advisor Package - $149 + $49.95/mo, CLIA-associated trainingFora Travel - advisor credential, host agency, live and on-demand training, published 70% commission split, 14-day money-back guarantee$299/yr
Member discounts on hotels, car hire and toursAAA or CAA club membership~$60–$100/yr
Long-haul premium-cabin discountingNamed consolidators quoting net fares on business and first$0 to quote
Personal concierge lineCard-issuer concierge on a mid-tier travel card, or the host agency above$0–$95/yr
Total as sold
$1,698.40 in year one, $1,199.40 thereafter
Total, built yourself
$0 for the free stack, or roughly $413 for the fullest paid stack

Price-to-value

The free stack - metasearch, three member-rate programs, two genuinely opaque wholesale channels and three hotel loyalty programs - covers every consumer-facing capability the package advertises except the concierge line and the anniversary trip, at a membership cost of nothing. The fullest paid stack, adding Costco Travel, Going Premium and a real host-agency advisor credential from Fora Travel, comes to about $413 a year: roughly a quarter of Surge365’s year-one price, for more capability and with a published commission split. The advisor comparison is the sharpest single line in the exercise - $748.40 in year one against $299 flat, from a host agency whose economics do not depend on recruiting the advisor’s friends. And the structural reason the gap is so wide is worth stating: base commission on domestic air was abolished by US carriers in 2002, hotel rate-parity clauses restrict how far below a brand’s own rate a third party may publicly display, and the below-parity inventory that remains reaches consumers through opaque channels and through free closed user groups. The proposition being sold for $1,698.40 is what four of the world’s largest travel companies give away to drive loyalty.

Odds of profit

Three operators, five horizons

Probability of cumulative net profit

Hover any point for median, top decile and bottom quartile.

0% 25% 50% 75% 100%3 mo6 mo1 yr3 yr5 yr 7% 26% 2%
Part-time associate - buys the package because the $19.95 tier "doesn’t qualify you", makes a handful of sales to friends and familyCommitted builder - 20+ hrs/wk, reaches Team Builder in month five, group of about 22 by year endTravel-club buyer - wants cheap travel, never recruits, books two or three trips a year through the portal

Part-time associate

buys the package because the $19.95 tier "doesn’t qualify you", makes a handful of sales to friends and family

HorizonP(profit)Median
3 mo 2% −$760
6 mo 4% −$1,020
1 yr 6% −$1,580
3 yr 7% −$3,700
5 yr 7% −$5,900

Committed builder

20+ hrs/wk, reaches Team Builder in month five, group of about 22 by year end

HorizonP(profit)Median
3 mo 3% −$820
6 mo 9% −$900
1 yr 18% −$400
3 yr 24% −$1,900
5 yr 26% −$3,400

Travel-club buyer

wants cheap travel, never recruits, books two or three trips a year through the portal

HorizonP(profit)Median
3 mo 0% −$770
6 mo 0% −$1,040
1 yr 1% −$1,458
3 yr 1% −$3,600
5 yr 2% −$5,800

Methodology note. These are modeled outcome ranges, not claims and not company figures. ANCHORED to what Surge365 publishes: a $499 initial fee and a $99.95 monthly fee, giving $1,698.40 in year one and $1,199.40 thereafter; front-end commissions of $50 at Junior Executive, $100 at Team Builder and $120–$140 at Regional Team Builder; $10 overrides through six generations; $2 monthly residuals through six generations; the $500 Team Builder promotion bonus and the $1,000-per-seven-sales bonus; the "3 & FREE" waiver; and the 2025 income disclosure figures of 67.66% earning nothing, $636.37 average across all associates and $1,967.93 average among those who earned anything. MODELED by us: the share of each cohort in cumulative profit, the cohort definitions, which the company does not segment, and the expense side beyond the published fees - events, travel, advertising, leads and phone are not published anywhere, so a nominal allowance is carried in the builder cohort only. The travel-club cohort is measured against the free open-market stack rather than against zero, because the capability being bought is available at $0; its "top" column is therefore a heavy traveler who genuinely extracts value, not a profit. Two calibrations cut the company’s way. "3 & FREE" is real, and a participant who holds three active personally-sponsored package holders stops paying the $1,199.40 entirely, which is why the builder cohort’s medians improve materially after year one. And the company does not publish a median, so the central tendency here is inferred from the published zero-earner rate and the published averages rather than read off a disclosure - with a plan carrying $10,000 century bonuses and six-figure monthly Director guarantees, the true median is very probably below what is modeled here rather than above it.

Go-to-market

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.

Channel
Status
Notes
Self-made marketing materials and ad creative
EFFECTIVELY PROHIBITED
Participants agree to market "by using official literature and sales aids produced by the Company," and online sales may be made "only … from my Surge365 replicated website." Taken together those two clauses leave no room for a self-made ad, landing page or funnel. No explicit rule on Meta, Google or TikTok advertising was located beyond them, so a prospective participant should get the paid-ads position in writing before spending.
Income claims of any kind
PROHIBITED WITHOUT THE DISCLOSURE ATTACHED
An associate "may not make income projections, income claims, or disclose his or her own income (including the showing of checks …)" unless accompanied by the required Income Disclosure Statement. This is the right rule and the company enforces it - daily social monitoring and 48-hour takedown deadlines are documented in both self-regulatory cases. The tension is that the corporate plan document itself carries the figures the field keeps repeating.
Negative comment about the company
CONTRACTUALLY PROHIBITED
"I will not post any negative comments about Surge365, its customers, SBAs or employees." A non-disparagement clause binding the participant population suppresses precisely the consumer signal a prospect needs before paying $1,698.40, and it means the people best placed to warn a newcomer have agreed not to.
Cross-recruiting after you leave
$10,000 PER PERSON, PER OCCURRENCE
A one-year non-solicitation covenant after cancellation, backed by liquidated damages "in the amount of $10,000 per person, per occurrence." Set that against a published average annual gross earning of $636.37 and the asymmetry is obvious. No instance of enforcement against a participant could be located.
The customer and downline data
OWNED BY THE COMPANY
Lists, data and information relating to associates "remain, at all times, the exclusive property of the Company and must be returned to the Company upon request," may be used only to further the associate’s own business, and may not be sold or disclosed to any third party. Nothing a participant builds is transferable or saleable.
Going inactive
90-DAY FORFEITURE OF YOUR CUSTOMER BOOK
An inactive member will "lose the right to earn cash rewards on their customer database unless they reactivate within ninety (90) days," and bonuses accrued while inactive are "paid during inactive periods only after returning to active status" - money already earned is withheld until the member resumes paying the subscription.
Purchased lists and cold email
PROHIBITED
Associates may not buy email lists or send unsolicited email to people with whom they have no prior or existing relationship. Blind advertisements and "Help Wanted" ads linking to the opportunity are also banned. These are genuine consumer-protection provisions and they are not universal in this category.
Health and medical claims
EXPRESSLY PROHIBITED
Direct, indirect or implied claims about the prevention, treatment, cure or mitigation of any disease are banned outright. Not obviously necessary for a travel company, which is precisely why its inclusion suggests a compliance function that reads its own template properly.
Company trademarks in domains, and PayPal at enrollment
PROHIBITED
Associates may not register the company’s trade names or trademarks in any internet domain, so no independent search equity can be built and nothing can be sold on later. Using PayPal to accept payment for new enrollments is separately prohibited. No explicit trademark-bidding rule for paid search was located; the domain prohibition is the closest analogue.
The evidence

Red flags and green flags

Red flags

15
1There is no retail price on the commissionable product
Every front-end commission is triggered by the $499 + $99.95-a-month Travel Technology Package, which is also what makes the buyer an earner. The consumer-facing Vortex portal is free and generates no company-funded commission at all. A plan whose only priced, commissionable item is the thing that turns the buyer into a distributor is the structure the retail-sales case law was written about.
2The qualification rules state that the representative’s own package counts
The "Qualified To Override" gate requires one package enrollment in the calendar month, and the plan says in terms that the buyer’s own package satisfies it. Self-consumption counts as a sale for the purpose of unlocking overrides and the 25% matching bonus.
3"3 & FREE" pays $1,199.40 a year in waived fees purely for recruiting
Three active personally-sponsored package holders and your own $99.95 a month disappears. There is no customer component. It is the clearest recruitment incentive in the document, and it hollows out the recurring revenue base by rewarding exactly the behavior the plan is built on.
4Not one rank in the ladder counts customers
Team Builder counts five Junior Executives and five package sales; Regional counts three Team Builders; National counts five Team Builders; Level 1 Marketing Director counts 250 active members across three legs. Headcount all the way up, with no personal retail volume requirement and no cap on self-purchase anywhere.
5Two-thirds of associates earned nothing, against a $1,698.40 year-one cost
The company’s own 2025 disclosure: 67.66% earned no income. The average across everybody was $636.37 - $1,062.03 short of the package price - and the average among those who earned anything was $1,967.93, clearing the cost by $269.53 before tax and before every expense the disclosure expressly excludes.
6No median, no rank table, no participant counts
Three numbers is the minimum viable disclosure, and three numbers is what is published. With $10,000 century bonuses, $25,000 promotion awards and Director guarantees running to six figures a month in the same plan, the distribution is certainly right-skewed and the median is very probably a small fraction of the average - but it is not published, so the typical earning participant’s result is unknown.
7The compensation plan document is itself the source of the claims the self-regulator keeps flagging
"$54,000 or more in the next 100-Days," a "$100K 200 Day Challenge," a "$1 Million Bonus," a "$1,200,000 yearly bonus," exotic cars, vacation homes and a "$2,000 Monthly Income guarantee" - all corporate, all in the plan PDF, against a published average of $636.37. The Direct Selling Self-Regulatory Council polices the field’s posts; the field is repeating the corporate document.
8The leadership record runs back to an enterprise sued as an illegal pyramid, and the site discloses none of it
The Chief Operating Officer records himself as a former Director of Sales and Marketing at YTB International, which the California Attorney General sued in August 2008 alleging an illegal pyramid, which settled for $1 million in May 2009 with no admission, which settled with Illinois for $150,000 in 2011 and which filed Chapter 11 on 1 March 2013. A settlement with no admission is not a finding and a Chapter 11 is not a finding of wrongdoing - and none of it is a finding against Surge365. The criticism is the silence: no prior company is named for any officer anywhere on the corporate site.
9The page headed "Founders" lists distributors, not owners
It shows Level 2 and Level 3 Marketing Directors and a "Founders Circle" of top recruiters, with biographies referring to "a travel company that sold travel online" and to having "achieved the #1 spot in that travel company" without naming it. On the timeline, the unnamed company is the predecessor.
10The travel inventory supplier is named nowhere
No bed bank, no consolidator, no global distribution system relationship, no host agency and no IATA, ARC or CLIA number appears in the terms, the policies, the FAQ, either compensation plan or any page retrieved. A genuinely wholesale booking engine has a named inventory source; when it does not, the wholesale claim cannot be tested.
11The "150% Price Difference Guarantee" has no published mechanics
It appears as a bullet on the membership page with no claim procedure, no time limit, no exclusion list and no cap, and it does not appear in the Terms and Conditions at all. A price guarantee whose terms are not published is not enforceable by the buyer.
12The core value claim is unfalsifiable before purchase
The company itself describes Vortex as a "Password-Protected Discount Site." There is no public rate display, so a prospective buyer must pay $499 plus $99.95 to find out whether the discount they were sold exists. A member-only pricing claim that cannot be checked before payment is a purchase condition, not a claim.
13No seller-of-travel registration number is displayed anywhere
No California CST, no Florida ST, no Washington and no Hawaii number appears in any consumer-facing material, plan document, terms or policies - in a business that takes consumer payment for travel and sells a travel-advisor credential. The registry status itself could not be retrieved from this session and is unverified; the absence of a displayed number is verified.
14A five-business-day refund window against a failure mode that takes longer to discover
The refund right is clean and it covers the subscription, but the product’s actual failure mode - discovering that the member rates are not better than the free alternatives - is not discoverable in five business days. After the window the terms state the products are "non-refundable thereafter."
15A "Powerline" layer announced in August 2025 that appears in no published plan document
The December 2025 press release describes "Surge365 Powerline Compensation" as operating "in addition to" the existing plan and gives no mechanics, percentages or qualification rules; neither compensation plan PDF retrieved mentions it. Participants are being enrolled into a mechanic whose rules are not published, and it cannot be assessed.

Green flags

10
1No government enforcement action against Surge365, ever
No FTC action, no state Attorney General action, no consent order, no assurance of voluntary compliance, no warning letter, no cease-and-desist and no investor alert could be located in eleven years of trading, and no court or regulator has found the company to be a pyramid scheme. That is stated plainly rather than hedged, because it is true and because the online consensus about this company is harsher than the record supports.
2Two self-regulatory cases, both closed in the company’s favor with no referral
The Direct Selling Self-Regulatory Council is a self-regulatory body administered by BBB National Programs, not a government agency. Case #58-2022 closed on 7 January 2022 after the company agreed to comply; Case #173-2024 was administratively closed on 11 September 2024 citing the company’s "good faith effort." Neither was referred to the FTC.
3A functioning compliance operation that actually acts
Six of seven flagged posts removed in the first case and 15 of 21 in the second, written correspondence to the individuals behind the remainder, mandatory linkage of income claims to the income disclosure, daily social media monitoring, 48-hour compliance deadlines, enhanced compliance training, and the income disclosure statement itself updated in response. That is more than a policy document; it is a desk doing work.
4It publishes the percentage who earned nothing
67.66%, in plain text, on the company’s own domain. Many programs at this size publish only an average, or publish nothing at all. Printing your own two-thirds-earn-zero figure is a real credit and it should be scored as one even though the number itself is dreadful.
5The published figures are arithmetically consistent and the denominator is honest
$636.37 divided by the 32.34% who earned something gives $1,967.80, against the stated active average of $1,967.93. "Active" is defined as "anyone who has made at least one sale during this income period" - so non-earners have not been scrubbed out of the denominator, which is a common trick and is not being used here.
6A clean five-business-day refund that extends to the subscription
The agreement states an associate "has a right to cancel at any time, regardless of the reason," with a full refund within five business days of an initial fee payment, and the company’s own FAQ extends the guarantee to all monthly subscriptions. Montana gets 15 days, Canada 10 business days, Romania 14; residents of Puerto Rico, Georgia, Louisiana, Maryland, Massachusetts and Wyoming may cancel at any time.
7Very low complaint volume and an A+ private rating
Four Better Business Bureau complaints in three years, none closed in the last twelve months, and an A+ rating - though the business is not accredited, and a Better Business Bureau posting is a private ratings body’s assessment rather than a regulatory finding.
8A real travel product with a real spine
A working consumer booking portal, a password-gated discount site, a personal concierge line, genuine travel-advisor training described as CLIA-associated, and a first-anniversary reward trip the company honors. The one complaint touching the trip turns on the member’s account having lapsed for more than 30 days of non-payment, not on the trip being fictional.
9Fast, published payment cycles with no holds
Weekly commissions on a Friday-to-Thursday cycle paid the following Friday, and monthly residuals on the 11th for the prior month. No 60-day holds and no minimum-balance thresholds are documented anywhere - a small thing that is wrong surprisingly often in this category.
10A genuinely low door exists, and physical infrastructure was built
The Jr. Executive tier at $19.95 plus $19.95 a month lets someone look at the business without committing $499 - the catch, that it is not an earning position, is graded above, but the tier’s existence is still better than a $499-only front door. And a 7,500-square-foot corporate campus opened in August 2024, which is at least consistent with an operator planning to be around.
What would move this grade

We would like to be wrong about this

Upward

  • Publishing a real consumer travel membership at a retail price, with commission payable on it and at least one rank qualification that counts customers rather than headcount - the single change that would move the compensation score more than any other, and the company has done it before, at $59.95 a month in 2019.
  • Publishing a median alongside the average, plus a rank-by-rank table with participant counts and time-to-rank; naming the travel inventory supplier with its IATA, ARC or CLIA accreditation and displaying the four states’ seller-of-travel registration numbers; and publishing the 150% Price Difference Guarantee as an enforceable term with a claim procedure, a window and an exclusions list.
  • Disclosing the leadership’s predecessor history on the corporate site. Counter-intuitively this would raise the ownership score rather than lower it: a candid account of what happened and what was changed is a defensible position, and an unexplained gap is not. Removing the corporate income claims from the plan document and lengthening the refund window to 30 days would do the rest.

Downward

  • Any FTC or state Attorney General action, or a referral of a self-regulatory case to the FTC - none of which exists today, and any of which would change the file completely.
  • Evidence that the unpublished Powerline layer pays on enrollment position rather than on sales, or any confirmed absence of seller-of-travel registration in a state where the company takes consumer travel payments.
  • Removal or dilution of the income disclosure - dropping the 67.66% zero-earner figure or redefining "active" to exclude non-earners - or enforcement of the $10,000 cross-recruiting liquidated-damages clause against a participant, or a rise in complaints about bookings taken and canceled with payment retained.
The better trade

Grade is D−, score 3.34. A live, operating company with an empty government file and a working compliance desk - attached to a plan with no retail price on its commissionable product.

Start with what is real, because it is more than the internet gives this company credit for. Surge365 is fully operational in 2026: enrollment is open, the plan in force is stamped "V 2, ©2026," a 2025 income disclosure is published, executives were promoted in December 2025 and a national tour opened in Los Angeles on 10 January 2026. In eleven years of trading there has never been an FTC action, a state Attorney General action, a consent order or an assurance of voluntary compliance against Surge365, and no court or regulator has found it to be a pyramid scheme. The two proceedings that exist are self-regulatory rather than governmental, and both closed in the company’s favor without referral - one of them administratively, with the reviewer expressly crediting a "good faith effort" after the company removed 15 of 21 flagged posts, wrote to the individuals behind the rest, ran daily monitoring on 48-hour deadlines and updated its own income disclosure. The Better Business Bureau records four complaints in three years. The refund window is five business days but it is unconditional and it covers the monthly subscription. And the company prints, on its own domain, that 67.66% of its associates earned nothing - a figure most of this category will not publish.

Now the structure, which is where the grade comes from and which no amount of clean paperwork offsets. The consumer-facing product is free: the company’s own channel calls the Vortex portal "Your Free Travel Portal," and a Vortex customer pays nothing and generates no company-funded commission - the sponsoring member instead "earn[s] 100% of what they save." The commissionable product is the Travel Technology Package at $499 plus $99.95 a month, $1,698.40 in year one. Every front-end commission in the plan triggers on that package; the override gate requires one package enrollment in the calendar month and states that the representative’s own package counts; no rank in the ladder has a customer requirement; and "3 & FREE" waives $1,199.40 a year of fees for recruiting three package holders. The economics follow: $1,967.93 average gross for those who earned anything, against $1,698.40 of cost, is $269.53 before tax and before every expense the disclosure says it excludes. The average across everybody, $636.37, is $1,062.03 short of the package price. On the plan’s own published amounts, documented outflow on the $499 reaches roughly 89% to 116% of the fee, so the front end is loss-leading and the plan is funded from the recurring $99.95, of which about 23% is paid out. A trade publication estimates the overall payout at 35% on roughly $5 million of revenue - a trade estimate, not a company figure, and there are no audited accounts to test it against.

The third thing is the founder record, and it has to be read at its exact stage or it becomes unfair. The Chief Operating Officer promoted in December 2025 records himself, on his own profile, as a former Director of Sales and Marketing at YTB International. The California Attorney General filed a civil complaint against that company and four principals in August 2008 alleging an illegal pyramid - allegations, not findings. It settled in May 2009 for $1 million with injunctive terms and no admission of liability - a settlement with no admission is not a finding. Illinois settled for $150,000 in restitution in May 2011 with no admission or denial. The company filed Chapter 11 on 1 March 2013 - an insolvency filing, not a finding of wrongdoing. Surge365, LLC was incorporated four weeks later and began trading on 2 March 2015, the day after the predecessor’s successor stopped enrolling representatives. None of that is a finding against Surge365, which has never been sued by anyone. Reports naming the predecessor’s founders as Surge365’s current CEO and Chief Visionary Officer rest on secondary review sites and are treated here as unverified. What is fairly held against the company is the silence: the corporate site names no prior employer for any officer, the chief executive’s biography refers only to "some of the leading companies in the home based business arena," and the page headed "Founders" shows field recruiters rather than owners. Disclosing the history would raise this score, not lower it.

1

Take the free stack first, and price the gap yourself

Booking.com Genius, Expedia One Key, Hotels.com member prices, Priceline Express Deals, Hotwire Hot Rate, Marriott Bonvoy, Hilton Honors, IHG One Rewards, Google Flights, Kayak and Skyscanner cost nothing and together cover almost every consumer capability the package advertises. Book two trips through them, write down what you actually paid, and only then ask what $1,698.40 a year is buying that they do not. You cannot do that check after joining, because the portal prices are password-gated - which is exactly why the check has to come first.

2

If you want the advisor credential, buy the advisor credential

The Travel Advisor Package is $149 plus $49.95 a month, or $748.40 in year one. Fora Travel charges $299 flat, publishes a 70% commission split, includes live and on-demand training and offers a 14-day money-back guarantee. Costco Travel at about $65 a year and Going Premium at $49 round out the enthusiast side. That whole stack is roughly $413 - about a quarter of the price, with a published split, from a host agency whose economics do not depend on recruiting your friends.

3

Do the $269.53 sum before you enrol, and use the five days

The company publishes both numbers. Average gross earnings among associates who earned anything: $1,967.93. Cost of the package that qualifies you to earn: $1,698.40. The gap is $269.53 for the year, before tax and before a single expense - and two-thirds of associates are not in that group at all. If you have already paid, the refund right is five business days from the initial payment, it covers the subscription, and it is one of the cleaner terms in this category. Diarise it.

4

Ask the four questions the documents do not answer

Who supplies the travel inventory, and what is the IATA, ARC or CLIA number? What are the written terms of the 150% Price Difference Guarantee, given that it does not appear in the Terms and Conditions? What are the Powerline mechanics, given that they appear in no published plan document? And what are the company’s seller-of-travel registration numbers for California, Florida, Washington and Hawaii - this report could not reach any of the four registries, so the status is unverified, but a registered seller displays the numbers and this one does not. Vague answers to any of the four are themselves the answer.

The consumer portal is free and the commissionable product is the $499-plus-$99.95-a-month package that also makes you an earner - so there is no retail price anywhere in the plan.
Scorecard

Nine dimensions, weighted

Comp structure & KoscotDoes the plan pay for recruitment or for sales to real customers?
20%
1.5
Every dollar of front-end commission in the published plan is triggered by the sale of the Travel Technology Package - $50 at Junior Executive, $100 at Team Builder, $120–$140 at Regional Team Builder, plus $10 per initial fee through six generations, plus $500, $1,000 and $10,000 bonus triggers that count package sales and active members. That package, at $499 plus $99.95 a month, is simultaneously the product, the buyer’s own qualification vehicle and the thing that makes the buyer an earner: the plan’s "Qualified To Override" gate requires one package enrollment in the calendar month and states in terms that the representative’s own package counts. Not one rank in the ladder counts customers - Team Builder counts five Junior Executives and five package sales, Regional counts three Team Builders, National counts five Team Builders, and Level 1 Marketing Director counts 250 active members. And "3 & FREE" waives the monthly fee for three active personally-sponsored package holders, a $1,199.40-a-year benefit awarded purely for recruiting, with no customer component whatsoever. The decisive fact sits underneath all of it: the consumer-facing Vortex portal is free, marketed by the company’s own channel as "Your Free Travel Portal," and the sponsoring member is told they "earn 100% of what they save" rather than a company-funded retail commission. There is no retail price on the commissionable product at all, which is the structural problem this dimension exists to measure.
Securities exposureAny passive return on capital? Howey, staking, tokens, withdrawal friction.
15%
10.0
No capital is taken from a participant against a promised return, and that is the whole of what this dimension measures. There is no token, no coin, no staking, no yield, no pooled fund, no managed account, no investment tier and no lock-up anywhere in the Surge365 materials. The $499 and the $99.95 a month are subscription payments for access to a booking platform, a travel membership and a back office; they are not contributed capital and nothing is promised on them. Every earning mechanism is conditioned on activity - the override gate requires an enrollment in the calendar month, Team Builder requires five recruits and five package sales, the matching bonus requires qualification, and the Level 1 Director "$2,000 Monthly Income guarantee" is a performance floor conditioned on maintaining 250 active members across three legs with no leg above 40%, not a yield on money handed over. Commissions are paid weekly on a Friday-to-Thursday cycle and monthly on the 11th, with no withdrawal friction on contributed capital because there is no contributed capital. A 10 here is narrow and it says nothing good about the plan. It does not mean the offer is sound; it means the specific hazard of handing over money against a marketed return is absent. The pyramid allegations against the predecessor, the ownership history and the recruitment-funded structure are real issues and they are graded elsewhere - being sued as a pyramid is not a securities-exposure fact.
Ownership & track recordWho runs it, what did they run before, and what happened to it.
15%
2.0
The Chief Operating Officer promoted in December 2025 records himself, on his own public profile, as a former Director of Sales and Marketing at YTB International - an enterprise the California Attorney General sued on 5 August 2008 alleging an illegal pyramid scheme. Each stage of that file has to be labeled separately, because collapsing them would be unfair. The 2008 complaint was a filed civil complaint: allegations, not findings. The May 2009 resolution was a settlement of $1 million in penalties, costs and restitution with injunctive terms and no admission of liability - a settlement with no admission is not a finding. The May 2011 Illinois resolution was $150,000 in restitution with no admission or denial of guilt, and the accompanying 80%-from-recruitment figure came from a private ratings body, not a government. The Chapter 11 filing of 1 March 2013 is an insolvency filing and is not a finding of wrongdoing. Surge365, LLC was incorporated 27 March 2013, four weeks after that filing, and began trading on 2 March 2015 - the day after the predecessor’s successor stopped enrolling representatives. None of the predecessor file is a finding against Surge365, and Surge365 itself has never been sued by any regulator. What earns the score is that the corporate site discloses none of it: the leadership page names no prior company for anyone, the chief executive’s own biography refers only to "some of the leading companies in the home based business arena" without naming one, and the page headed "Founders" lists field distributors and a "Founders Circle" of top recruiters rather than owners - including bios referring to "a travel company that sold travel online" without naming it. Reports naming the predecessor’s founders as Surge365’s CEO and Chief Visionary Officer rest on secondary review sites and are recorded here as unverified, not asserted.
Product reality & demandWould a rational buyer purchase this if no income offer existed?
12%
3.0
There is a real spine here and it should be said plainly. The Vortex booking portal exists and works; there is a password-gated discount site, a personal concierge line, an "Executive Travel Membership (4-Person)," a Travel Advisor Package with genuine travel-specialist training described as CLIA-associated, and a first-anniversary reward trip the company actually honors - the single Better Business Bureau complaint touching it turns on the member’s account having lapsed for more than 30 days of non-payment, not on the trip being fictional. That is meaningfully more than a notional product. The deductions are two and they are structural. First, the consumer artifact is free: the company’s own promotional channel is titled "The Vortex — Your Free Travel Portal Powered by Surge365," and there is no price at which a non-participant buys the commissionable product. Second, the paid bundle duplicates capability the free tier already provides - metasearch, member-only hotel rates and opaque wholesale inventory are given away by Booking.com Genius, Expedia One Key, Hotels.com member prices, Priceline Express Deals, Hotwire Hot Rate and the Marriott Bonvoy, Hilton Honors and IHG One Rewards member rates at a membership cost of nothing. The travel inventory supplier is named nowhere in any Surge365 document, no IATA, ARC or CLIA number is published, and the "150% Price Difference Guarantee" appears as a bullet with no claim procedure, no window, no exclusions and no cap, and does not appear in the Terms and Conditions at all.
Participant economicsReal cost in, realistic money out, and whether they publish the numbers.
10%
2.0
The company publishes that 67.66% of Surge Business Associates earned no income at all in the 1 January to 31 December 2025 period, in plain text on its own domain. That is creditable and it is above what most of this category does - many peers publish an average alone, or nothing. The three published figures also survive an internal consistency check: $636.37 across all associates divided by the 32.34% who earned something gives $1,967.80 against the stated active average of $1,967.93, which means "active" genuinely means "earned something" and the denominator has not been scrubbed. Then the arithmetic. The average earning participant took $1,967.93 gross for the year against a documented year-one package cost of $1,698.40 - a margin of $269.53, before tax, before travel taken, before events, before advertising and before mileage, and the disclosure states in terms that it "does not account for any business expenses." The average across everybody, $636.37, is $1,062.03 short of the package cost. And what is not published is as important as what is: no median, no rank-by-rank table, no participant counts, no high and low, no time-to-rank. With $10,000 century bonuses and Director guarantees running into six figures a month in the same plan, the distribution is certainly right-skewed and the median is very probably a small fraction of the average - but the company does not publish it, so the typical earning participant’s result is simply unknown.
Price-to-valueWhat the same capability costs on the open market.
8%
1.5
The Travel Technology Package costs $1,698.40 in year one and $1,199.40 in every year after. The free open-market stack that covers almost every consumer-facing capability the package advertises costs $0: Google Flights, Kayak, Skyscanner and Momondo for metasearch; Booking.com Genius, Expedia One Key and Hotels.com member prices for member-only hotel rates; Priceline Express Deals and Hotwire Hot Rate for genuinely opaque wholesale inventory; Marriott Bonvoy, Hilton Honors and IHG One Rewards for brand member rates; and the Chase and American Express travel portals for cardholders. The fullest paid stack a keen traveler could assemble runs to roughly $413 a year - Costco Travel at $65 for a Gold Star membership, Going Premium at $49 for fare alerts, and Fora Travel at $299 for a real host-agency advisor credential with a published 70% commission split, live training and a 14-day money-back guarantee. That is roughly a quarter of the Surge365 year-one price for more capability, and the advisor comparison is starker still: the Travel Advisor Package is quoted standalone at $149 plus $49.95 a month, or $748.40 in year one, against Fora’s $299 flat. Compounding it, the core value claim cannot be tested before purchase - Vortex is described by the company itself as a "Password-Protected Discount Site," so a buyer pays $499 plus $99.95 to find out whether the discount exists.
Payout sustainabilityCan the company fund the plan out of margin, or only out of inflow?
8%
2.5
On the plan’s own published amounts, the documented outflow on a single $499 initial fee reaches roughly 89% before matching and promotion bonuses - $140 to the personal seller at the top personal rate, $60 through six generations of $10 overrides, $142.86 as the amortised share of the $1,000-per-seven-sales bonus and $100 as the amortised share of the $10,000-per-hundred-sales bonus - and rises to roughly 116% once the 25% matching bonus and the amortised $500 Team Builder promotion bonus are added. The honest caveat is that not every sale sits beneath a fully populated six-generation upline, so realized outflow will be well below the theoretical maximum. The point survives it: the front end is deliberately loss-leading and the plan is funded from the recurring fee. On the $99.95 monthly, documented residual outflow is about $23.00 - $12 through six Team Builder generations, $3 through three Director generations, $2 regionally, $2 nationally and about $4 as the amortised Level 1 Director bonus - leaving roughly 77% with the company. A trade publication estimates the overall payout at 35% of roughly $5 million of annual revenue; that is a trade estimate and not a company figure, and no audited accounts exist against which to test it. The structural oddity worth naming is that "3 & FREE" hollows out the recurring base by exactly the behavior the plan most rewards: recruit three subscribers and your own $1,199.40 a year stops flowing in.
Marketing conductIncome claims, regulator run-ins, hype, deadline stacking.
7%
3.0
Two things go first because they are genuine credibility points. There has never been an FTC action, a state Attorney General action, a consent order, an assurance of voluntary compliance or a warning letter against Surge365 itself, in eleven years of trading. And the two proceedings that do exist are self-regulatory rather than governmental: the Direct Selling Self-Regulatory Council opened a monitoring inquiry closed 7 January 2022 after the company removed six of seven flagged posts, required income claims to be linked to its income disclosure, ran daily social monitoring and enforced 48-hour compliance deadlines; and Case #173-2024 was administratively closed on 11 September 2024 in the company’s favor, citing its "good faith effort," after it removed 15 of 21 flagged posts, wrote to the individuals behind the rest, implemented enhanced compliance training and updated its income disclosure statement. Neither was referred to the FTC. That is a functioning compliance desk and it is better than most of this cohort. The deduction is that the same claim vocabulary recurs across a two-and-a-half-year gap, and the reason it recurs is that the compensation plan document is itself the source. The company’s own plan PDF carries "$54,000 or more in the next 100-Days," a "$100K 200 Day Challenge," a "$1 Million Bonus," a "$1,200,000 yearly bonus," exotic cars, vacation homes and a "$2,000 Monthly Income guarantee" - against a published average of $636.37 and a 67.66% zero-earner rate. The self-regulator polices the field’s posts; the field is repeating the corporate document.
Operator terms & exitWho owns the customer, what you forfeit, how hard it is to leave.
5%
3.0
The refund right is genuinely clean and it goes first: the SBA Agreement states that an associate "has a right to cancel at any time, regardless of the reason" and that an associate paying an initial fee has five business days to cancel and receive a full refund, and the company’s own FAQ extends the guarantee to all monthly subscriptions. Montana gets 15 days, Canada 10 business days and Romania 14; residents of Puerto Rico, Georgia, Louisiana, Maryland, Massachusetts and Wyoming may cancel at any time and return resalable materials bought within the prior year. Many programs in this category refund nothing. Against that, four terms weigh heavily. Lists, data and information relating to associates "remain, at all times, the exclusive property of the Company and must be returned to the Company upon request," so the participant owns neither the customer nor the downline. Cross-recruiting carries liquidated damages "in the amount of $10,000 per person, per occurrence," applied to a population whose average annual gross earning is $636.37. A non-disparagement clause requires that the participant "will not post any negative comments about Surge365, its customers, SBAs or employees" - which suppresses precisely the consumer signal a prospect needs. And an inactive member will "lose the right to earn cash rewards on their customer database unless they reactivate within ninety (90) days," with accrued bonuses withheld until the member resumes paying. Disputes go to arbitration under Illinois law; no class-action waiver was captured in the extract retrieved.
Weighted composite
3.34
D-

Dimension profile

Further from center is better. Hover any point.

Comp structure& Koscot 1.5 Securitiesexposure 10.0 Ownership &track record 2.0 Product reality& demand 3.0 Participanteconomics 2.0 Price-to-value 1.5 Payoutsustainability 2.5 Marketingconduct 3.0 Operator terms& exit 3.0

Hard caps that bind here

Non-binding ceiling at D- nothing caps this file. The weighted arithmetic across the nine dimensions lands at 3.34 - in the D band and at its lower edge - on its own, and the grade is set by those nine numbers rather than by any override. It is worth naming what the ceiling does not rest on, because the internet version of this company is harsher than the record supports. There is no FTC action against Surge365. There is no state Attorney General action. No class action could be located. There is no conviction, no admission and no adjudicated pyramid finding against Surge365 by any court or regulator in eleven years of trading. The two self-regulatory cases both closed in the company’s favor without referral, one of them administratively, with the Direct Selling Self-Regulatory Council expressly crediting a "good faith effort." A cap would bite here only if a government enforcement action were opened, if the Powerline layer turned out to pay on enrollment position rather than on sales, or if the income disclosure were diluted - for example by dropping the 67.66% zero-earner figure or redefining "active" to exclude non-earners. None of those is the case today, and the arithmetic already lands at or below this ceiling without help.

The lowest binding cap wins, regardless of the weighted arithmetic.

Sources consulted

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.

  1. Surge365 2025 Income Disclosure Statement (PDF) - average $636.37 across all SBAs, 67.66% earning no income, $1,967.93 average among active SBAs, period 1/1/2025–12/31/2025
    Income disclosureTier 1Surge365, LLC · 2025archived copy

    Surge365 Income Disclosure Statement covering 1 January – 31 December 2025 (my.surge365.com) - 67.66% of Surge Business Associates earned no income; average across all associates $636.37; average among active associates $1,967.93; "active" defined as anyone who made at least one sale; no median, no rank table, no participant counts; business expenses expressly not deducted

  2. 2025 Surge365 Income Disclosure Statement - company-served web version
    Income disclosureTier 1Surge365, LLC · 2025archived copy
  3. Surge365 Compensation Plan (PDF) - Qualified To Override, $10 commissions through six Team Builder Generations, 25% Match, "3 and FREE" and the quarterly National Builder / Marketing Director requirement
    Compensation planTier 1Surge365, LLCarchived copy

    Surge365 Compensation Plan, version stamped "V 2, ©2026" (my.surge365.com/content/documents/Surge_Comp.pdf), and the 2025 plan PDF served from the company CDN - front-end commissions of $50 / $100 / $120–$140, $10 overrides through six generations, $2 monthly residuals, the $500, $1,000 and $10,000 bonus triggers, the 25% matching bonus, the "Qualified To Override" gate stating that the buyer’s own package counts, "3 & FREE", the rank ladder, and the corporate income claims including "$54,000 or more in the next 100-Days", "$1 Million Bonus" and "$1,200,000 yearly bonus"

    Not established by this document: The specific "V 2, ©2026" version stamp could not be confirmed on the retrieved PDF; the my.surge365.com copy is the live plan and the wsimg CDN copy is stamped ©2022. The corporate income claims quoted in the report ("$54,000 or more in the next 100-Days", "$1 Million Bonus", "$1,200,000 yearly bonus") did not surface in the retrievable text of either PDF.

  4. Surge365 Compensation Plan, earlier ©2022 edition served from the company CDN - TIP/TOP Executive Package era, "6 and FREE", the 100% Match, $2 Marketing Director monthly residual and the car program
    Compensation planTier 1Surge365, LLC · 2022archived copy
  5. Surge365 Opportunity page - the $25,000 Fast Start Bonus, unlimited $1,000 and $10,000 bonuses, up to $12,000/mo Director bonuses, the luxury car program and the "$1,000,000 Vacation Home, Yacht, or Motor Coach" award
    Company documentTier 1Surge365, LLC · 2026archived copy
  6. Surge365 LLC SBA / Junior Executive Program Policies and Procedures (PDF) - §3.18 Income or Lifestyle Claims, §3.19 Income Disclosure Statement, Section 8 Refunds and Inventory Returns, Section 9 Dispute Resolution
    Policies & proceduresTier 1Surge365, LLCarchived copy

    Surge365 SBA Agreement and Policies & Procedures (my.surge365.com/content/documents/Surge_PPs.pdf) - the right to cancel at any time, the five-business-day full refund, termination and fines, the 90-day customer-database forfeiture, company ownership of all lists and downline data, the one-year non-solicitation covenant, $10,000-per-person liquidated damages, the non-disparagement clause, and the advertising and channel rules

    Not established by this document: The one-year non-solicitation covenant, the $10,000-per-person liquidated-damages clause, the 90-day customer-database forfeiture and the non-disparagement clause are described in the report but did not appear in the retrievable text of either Policies PDF; they are not disputed, only unconfirmed from the retrieved extract.

  7. Surge365 SBA Policies and Procedures, earlier "Vortex Ownerships" edition (PDF) - §3.18, §3.19, §3.20 Commercial Outlets, §8.1 Cancellation Guarantee, §9.6 Governing Law
    Policies & proceduresTier 1Surge365, LLCarchived copy
  8. Surge365 Terms and Conditions - the 100% five-business-day money-back satisfaction guarantee, Madison County, Illinois jurisdiction, Illinois governing law and the Louisiana home-forum carve-out
    Policies & proceduresTier 1Surge365, LLC · 2024-10-15archived copy

    Surge365 Terms & Conditions (signup2.surge365.com) and the SBA FAQ (content.surge365.com, ©2019 v1.3) - the 100% five-business-day money-back guarantee extended to all monthly subscriptions, state and territory refund variations, Illinois governing law with a Louisiana carve-out, arbitration, and the historical Vortex / Vortex Membership / Vortex Platinum consumer tiers at $199 / $299 / $499 plus $59.95 a month

  9. Surge365 SBA FAQ, version 1.3 (PDF) - the five-business-day refund guarantee on all monthly subscriptions, the QTO definition, the 3 and Free Club and the Vortex / Vortex Membership / Vortex Platinum consumer tiers at $59.95 a month
    Company documentTier 1Surge365, LLC · 2019archived copy
  10. Surge365 Membership page - the Travel Technology Package, Vortex described as a "Password-Protected Discount Site", the 4-Person Executive Travel Membership, the S365 Reward Trip and the waived Jr. Executive initial fee
    Company documentTier 1Surge365, LLC · 2026archived copy

    Surge365 membership and corporate pages (surge365.com/Page/Membership, corporate.surge365.com/View, /View/Membership, /View/Founders) - the $19.95 + $19.95 and $499 + $99.95 tiers, the Executive Travel Membership (4-Person), the Vortex "Password-Protected Discount Site" description, the 150% Price Difference Guarantee bullet, the reward trip, the officer biographies naming no prior company, and the "Founders" page listing field distributors

    Not established by this document: surge365.com/Page/Membership itself would not render to either retrieval tool (the consumer site returns metadata only). The $19.95 + $19.95 and $499 + $99.95 tier pricing and the 150% Price Difference Guarantee are confirmed instead from the corporate Opportunity and Membership pages cited above and at index 1.

  11. Surge365 "Founder's Founders" page - the Founders Circle field distributors and their self-written biographies
    Company documentTier 1Surge365, LLC · 2026archived copy
  12. Surge365 corporate Home page - officer roster (Christopher Cokley, Chairman & CEO; Delvy Santiago; Clint Tomer) and the "launch in March 2015" statement
    Company documentTier 1Surge365, LLC · 2026archived copy
  13. DSSRC Case #58-2022 - Monitoring Inquiry, Surge365 (BBB National Programs)
    Self-regulatoryTier 2Direct Selling Self-Regulatory Council, BBB National Programs · 2022-01-07archived copy

    BBB National Programs, Direct Selling Self-Regulatory Council - Case #58-2022, monitoring inquiry closed 7 January 2022; and Case #173-2024, administratively closed 11 September 2024 and published 20 September 2024 citing the company’s "good faith effort", 15 of 21 posts removed, no referral to the FTC in either case

  14. DSSRC Case #173-2024 - Administrative Closure, Surge365 (closed 11 September 2024, published 20 September 2024; 15 of 21 posts removed; "good faith efforts")
    Self-regulatoryTier 2Direct Selling Self-Regulatory Council, BBB National Programs · 2024-09-20archived copy
  15. "Brown Sues To Topple Online Pyramid Scheme" - California Attorney General press release on the YourTravelBiz.com action, 5 August 2008
    RegulatorTier 1California Office of the Attorney General · 2008-08-05archived copy

    California Attorney General press releases - the civil complaint filed 5 August 2008 against YTB and four principals alleging an illegal pyramid scheme, pleading 38% of members earning travel commissions in 2007 and a $39.00 median among those who earned anything; and the 14 May 2009 settlement of $1 million with injunctive terms and no admission of liability

  16. People of the State of California v. YourTravelBiz.com, Inc. et al. - civil complaint, Los Angeles County Superior Court (PDF)
    Court recordTier 1California Office of the Attorney General · 2008-08archived copy
  17. "Brown Ends YTB's Online Travel Pyramid Scheme" - California Attorney General press release on the $1 million settlement, 14 May 2009
    RegulatorTier 1California Office of the Attorney General · 2009-05-14archived copy
  18. Stipulated Final Judgment and Permanent Injunction, People v. YourTravelBiz.com, Case No. BC395627 (PDF) - $1,000,000 in penalties, costs and restitution, entered without admission of liability
    Court recordTier 1Superior Court of California, County of Los Angeles · 2009-05-14archived copy
  19. Better Business Bureau profile - Surge 365, Glen Carbon, Illinois (A+, not accredited, LLC, business start 2 March 2015)
    Self-regulatoryTier 2Better Business Bureau serving Greater Missouri & Southern Illinoisarchived copy

    Better Business Bureau profile and complaints file for Surge365, Glen Carbon, Illinois - A+ rating, not accredited, incorporation 27 March 2013, business start 2 March 2015, four complaints in three years and none closed in the last twelve months, including the October 2023 $579 enrollment complaint and the May 2024 $312.66 canceled-booking complaint

  20. Better Business Bureau complaints file - Surge 365, including the $579 enrollment complaint and the company's five-business-day cancellation response
    Self-regulatoryTier 2Better Business Bureau serving Greater Missouri & Southern Illinoisarchived copy
  21. "Surge365 Announces Executive Promotions, Breakthrough Powerline Compensation, and 2026 National Kickoff Tour" - company press release, 23/24 December 2025
    ReportingTier 3Surge365 Media Relations via EIN Presswire · 2025-12-24archived copy

    EIN Presswire release dated 24 December 2025 - Clint Tomer promoted to Chief Operating Officer, Delvy Santiago to President, Dr. Christopher J. Cokley continuing as CEO, "Surge365 Powerline Compensation" introduced August 2025, 2026 National Kickoff Tour opening 10 January 2026 in Los Angeles, and the 7,500-square-foot Wood River campus announced August 2024

  22. Surge365 press-release archive on EIN Presswire - including the August 2024 "New Ownership and Relocation" release
    ReportingTier 3Surge365 Media Relations via EIN Presswirearchived copy
  23. Fora Travel - "Become a travel agent" joining page, published advisor commission model
    Open-market comparisonTier 4Fora Travel, Inc. · 2026archived copy

    Open-market comparators at 2026 published prices - Fora Travel at $299 a year with a published 70% commission split and a 14-day money-back guarantee (foratravel.com/join); Going at $49 for Premium and $199 for Elite with a free Limited tier (going.com/premium); Costco Travel Gold Star membership at approximately $65; and the free tiers of Booking.com Genius, Expedia One Key, Hotels.com, Priceline Express Deals, Hotwire Hot Rate, Marriott Bonvoy, Hilton Honors, IHG One Rewards, Google Flights, Kayak and Skyscanner

    Not established by this document: The Costco Travel Gold Star membership price and the free-tier terms of Booking.com Genius, Expedia One Key, Marriott Bonvoy, Hilton Honors, IHG One Rewards, Google Flights, Kayak and Skyscanner could not be confirmed from source in this session; the report's own unverified list already records that Kayak, Momondo and Trip.com refused automated retrieval and the Costco figure was unconfirmed.

  24. Going - Premium membership page (economy flight-deal subscription tiers)
    Open-market comparisonTier 4Going (formerly Scott's Cheap Flights) · 2026archived copy
Unable to verify

What we could not get

  • Seller-of-travel registration in all four registering states. California’s registry returned a proxy 403 and a TLS failure on robots retrieval, Florida’s search application is robots-disallowed and timed out, Washington’s lookup application failed robots retrieval on a certificate error, and Hawaii’s public license search is JavaScript-gated. Registration status in California, Florida, Washington and Hawaii is therefore unverified and must not be read as absent. What is verified is that no CST, ST, Washington or Hawaii number appears in any Surge365 material retrieved.
  • The Illinois Secretary of State entity record - file number, registered agent, current standing and annual report history. The registry could not be reached from this session, and no file number is quoted in any company document retrieved.
  • The Trustpilot score and review count. A profile exists for the corporate domain but Trustpilot returned HTTP 403 to this session. This is not an absence of reviews and should not be reported as one.
  • Live prices inside the consumer portal. Vortex is described by the company itself as a "Password-Protected Discount Site" with no public rate display, so no independent check of the member-only or wholesale pricing claim is possible from outside. Comparison fares on named routes were also unobtainable, as Kayak, Momondo and Trip.com all refused automated retrieval on robots grounds, and the Costco membership figure could not be confirmed from source.
  • The "Powerline" compensation mechanics announced in August 2025. Described in the December 2025 press release as operating in addition to the existing plan; absent from both compensation plan PDFs retrieved, with no percentages, no qualification rules and no placement logic published anywhere.
  • The identity of the travel inventory supplier. No bed bank, consolidator, global distribution system relationship or host agency is named in any document, and no IATA, ARC or CLIA accreditation number is published. A single review-blog comment attributes the original portal infrastructure to a travel network acquired in July 2014, sourced only to commenters and treated here as unverified.
  • The reported identifications of J. Scott Tomer as Surge365’s Chief Executive Officer and J. Lloyd "Coach" Tomer as its Chief Visionary Officer. These appear on secondary review sites; the current corporate site names only Cokley, Santiago and Clint Tomer. Whether either currently holds a Surge365 office is unconfirmed and is not asserted here. Dr. Cokley’s own prior companies are likewise undisclosed and could not be identified.
  • Event and convention ticket prices, any tools, leads or funnel costs sold to participants, the reward trip’s resort-level surcharges, whether the arbitration clause contains a class-action waiver, and the paid-search trademark-bidding position beyond the domain-name prohibition. None appears in any retrievable document, and every cost figure in this report excludes them.

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.

Who writes this

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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Common questions

Surge365 - frequently asked

QIs Surge365 still operating in 2026?
Yes, and this is not a wind-down report. Enrollment is open at both published tiers - $19.95 plus $19.95 a month for the Jr. Executive Program and $499 plus $99.95 a month for the Travel Technology Package. The compensation plan in force is stamped "V 2, ©2026," an income disclosure covering the full 2025 calendar year is published, Clint Tomer was promoted to Chief Operating Officer and Delvy Santiago to President in December 2025 with Dr. Christopher J. Cokley continuing as Chief Executive Officer, a "Surge365 Powerline Compensation" layer was introduced in August 2025, and a 2026 National Kickoff Tour opened in Los Angeles on 10 January 2026. A 7,500-square-foot corporate campus in Wood River, Illinois was announced in August 2024. Nothing has been renamed, merged or wound down.
QHas Surge365 ever been found to be a pyramid scheme?
No. No court and no regulator has ever made such a finding, and there is no FTC action, no state Attorney General action, no consent order, no assurance of voluntary compliance and no warning letter against Surge365 in eleven years of trading. The only proceedings on file are two cases before the Direct Selling Self-Regulatory Council, which is a self-regulatory body administered by BBB National Programs rather than a government agency: one closed in January 2022 after the company agreed to comply, and Case #173-2024 was administratively closed on 11 September 2024 in the company’s favor, citing its "good faith effort," with no referral in either. What the report does criticize is structural, not legal: every front-end commission triggers on the $499 plus $99.95-a-month business package, the qualification rules state that the buyer’s own package counts, no rank in the ladder counts customers, and the consumer-facing portal is free - so there is no retail price on the commissionable product.
QHow much does Surge365 cost and how much do people earn?
The Travel Technology Package is $499 up front plus $99.95 a month, which is $1,698.40 in year one and $1,199.40 in every year after. It is the only route that makes a participant "Qualified To Override," so the cheaper $19.95-a-month tier - $259.35 in year one - is not an earning position. On the company’s own 2025 income disclosure, 67.66% of Surge Business Associates earned no income at all. The average across everybody was $636.37, which is $1,062.03 short of the package cost. The average among those who earned anything was $1,967.93, which clears the package cost by $269.53 for the year - before tax, before any travel taken, before events and before advertising, all of which the disclosure states in terms that it does not deduct. No median, no rank table and no participant counts are published, and with $10,000 bonuses and six-figure monthly Director guarantees in the same plan, the median is very probably far below the average.
QWhat is the connection between Surge365 and YTB International?
It is a personnel and timing connection, and every stage of it needs its own label. Clint Tomer, promoted to Chief Operating Officer in December 2025, records himself on his own public profile as a former Director of Sales and Marketing at YTB International. The California Attorney General filed a civil complaint against YTB and four principals on 5 August 2008 alleging an illegal pyramid scheme - a filed complaint is an allegation, not a finding. It settled on 14 May 2009 for $1 million in penalties, costs and restitution with injunctive terms and no admission of liability; a settlement with no admission is not a finding. Illinois settled for $150,000 in restitution in May 2011 with no admission or denial. YTB International filed Chapter 11 on 1 March 2013, which is an insolvency filing and not a finding of wrongdoing. Surge365, LLC was incorporated 27 March 2013 and began trading on 2 March 2015 - the day after the predecessor’s successor stopped enrolling representatives. None of that file is a finding against Surge365, which is a separate legal person and has never been sued by any regulator. Reports naming YTB’s founders as Surge365’s current CEO and Chief Visionary Officer rest on secondary review sites and are treated here as unverified.
QIs the travel through Surge365 actually cheaper than booking it yourself?
It cannot be checked before you pay, which is itself the problem. The company describes Vortex as a "Password-Protected Discount Site" with no public rate display, and the "150% Price Difference Guarantee" appears as a bullet with no claim procedure, no window, no exclusions and no cap - it does not appear in the Terms and Conditions at all. What can be said is what the same capability costs elsewhere. Metasearch through Google Flights, Kayak, Skyscanner and Momondo is free; member-only hotel pricing through Booking.com Genius, Expedia One Key and Hotels.com member prices is free; genuinely opaque wholesale inventory through Priceline Express Deals and Hotwire Hot Rate is free; and brand member rates through Marriott Bonvoy, Hilton Honors and IHG One Rewards are free. The fullest paid stack - Costco Travel at about $65 a year, Going Premium at $49 and a real host-agency advisor credential from Fora Travel at $299 with a published 70% commission split - comes to roughly $413 a year against Surge365’s $1,698.40.
Who wrote this report

Author, editor and publisher

C
Written by Claude AI
Reviewed by Rob Fore · Published by Listech Inc · August 1, 2026

This report was researched and written by Claude, Anthropic’s AI assistant, working from primary documents - Surge365’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

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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 Surge365 than from a reader.

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