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.
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.
Can you actually make money with Surge365?
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.
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
- 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.
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.
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.
| Product | Price | Pays |
|---|---|---|
| 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 |
Who runs it, and what they ran before
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.
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.
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.
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.
The veteran's checklist
Eight questions that decide whether this is a business or a transfer mechanism. Same eight, every review.
| Question | Answer |
|---|---|
| Is it still operating? |
OK
Yes, unambiguously. Enrollment is open at both tiers, the plan in force is stamped "V 2, ©2026," a 2025 income disclosure is published, a new COO and President were promoted in December 2025 and a national tour opened in Los Angeles on 10 January 2026.
|
| Any regulator ever acted against it? |
OK
No. No FTC action, no state Attorney General action, no consent order, no assurance of voluntary compliance, no warning letter and no pyramid finding in eleven years. Two self-regulatory cases exist and both closed in the company’s favor with no referral.
|
| What does it really cost? |
CONCERN
$1,698.40 in year one and $1,199.40 thereafter for the Travel Technology Package, which is the only route that qualifies you to earn overrides. The $19.95-a-month tier costs $259.35 in year one and does not qualify you. A 2023 complainant records paying $579 at enrollment, so expect tax on top.
|
| What is the commissionable product? |
RED
The business package itself. Every front-end commission triggers on the $499 + $99.95-a-month package, the qualification rules say the buyer’s own package counts, no rank counts customers, and the consumer portal is free - so there is no retail price on the commissionable product.
|
| How much do people earn? |
RED
The company’s own 2025 disclosure: 67.66% earned nothing; the average across everybody was $636.37; the average among those who earned anything was $1,967.93, which clears the $1,698.40 package cost by $269.53 before tax and before expenses the disclosure excludes. No median is published.
|
| Is the travel actually cheaper? |
CONCERN
Unknown, and unknowable before you pay - the portal is a password-protected discount site with no public rates, and the 150% Price Difference Guarantee has no published mechanics and does not appear in the Terms and Conditions. The free alternatives cost $0 and the fullest paid stack about $413 a year.
|
| Is it registered as a seller of travel? |
WATCH
Could not be established. All four registering states - California, Florida, Washington and Hawaii - refused automated retrieval, so registration status is unverified and must not be reported as absent. What is verified is that no registration number appears in any company document retrieved.
|
| Can you get your money back? |
OK
Within five business days of the initial payment, in full, including on monthly subscriptions - a genuinely clean term. After that, nothing: the terms state products are "non-refundable thereafter." Longer windows apply in Montana, Canada and Romania, and six US states plus Puerto Rico may cancel at any time.
|
What has to be true for you to get paid
| To cover | You 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.
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.
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 you | What you'd use instead | Your cost |
|---|---|---|
| Flight and hotel search across all suppliers | Google Flights, Kayak, Skyscanner, Momondo | $0 |
| Member-only hotel pricing | Booking.com Genius - 10% from two stays, 15% plus breakfast or upgrade from five | $0 |
| Member-only hotel and flight pricing | Expedia One Key and Hotels.com member prices | $0 |
| Opaque / wholesale hotel rates | Priceline Express Deals, Hotwire Hot Rate - the actual wholesale channel | $0 |
| Brand member rates plus elite benefits | Marriott Bonvoy, Hilton Honors, IHG One Rewards | $0 |
| Points-boosted booking portal | Chase Travel or American Express Travel, for a card already held | $0 |
| Curated package and cruise pricing with a rebate | Costco Travel - Gold Star membership | ~$65/yr |
| Proactive cheap-fare alerts | Going Premium (Limited tier is free; Elite is $199) | $49/yr |
| Travel Advisor Package - $149 + $49.95/mo, CLIA-associated training | Fora 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 tours | AAA or CAA club membership | ~$60–$100/yr |
| Long-haul premium-cabin discounting | Named consolidators quoting net fares on business and first | $0 to quote |
| Personal concierge line | Card-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.
Three operators, five horizons
Probability of cumulative net profit
Hover any point for median, top decile and bottom quartile.
Part-time associate
buys the package because the $19.95 tier "doesn’t qualify you", makes a handful of sales to friends and family
| Horizon | P(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
| Horizon | P(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
| Horizon | P(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.
Where you are actually allowed to promote this
Platform policy reads, not verifications. Check every one before you spend a dollar - enforcement changes faster than the written policy does.
Red flags and green flags
Red flags
151There is no retail price on the commissionable product
2The qualification rules state that the representative’s own package counts
3"3 & FREE" pays $1,199.40 a year in waived fees purely for recruiting
4Not one rank in the ladder counts customers
5Two-thirds of associates earned nothing, against a $1,698.40 year-one cost
6No median, no rank table, no participant counts
7The compensation plan document is itself the source of the claims the self-regulator keeps flagging
8The leadership record runs back to an enterprise sued as an illegal pyramid, and the site discloses none of it
9The page headed "Founders" lists distributors, not owners
10The travel inventory supplier is named nowhere
11The "150% Price Difference Guarantee" has no published mechanics
12The core value claim is unfalsifiable before purchase
13No seller-of-travel registration number is displayed anywhere
14A five-business-day refund window against a failure mode that takes longer to discover
15A "Powerline" layer announced in August 2025 that appears in no published plan document
Green flags
101No government enforcement action against Surge365, ever
2Two self-regulatory cases, both closed in the company’s favor with no referral
3A functioning compliance operation that actually acts
4It publishes the percentage who earned nothing
5The published figures are arithmetically consistent and the denominator is honest
6A clean five-business-day refund that extends to the subscription
7Very low complaint volume and an A+ private rating
8A real travel product with a real spine
9Fast, published payment cycles with no holds
10A genuinely low door exists, and physical infrastructure was built
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.
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.
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.
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.
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.
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.
Nine dimensions, weighted
Dimension profile
Further from center is better. Hover any point.
Hard caps that bind here
The lowest binding cap wins, regardless of the weighted arithmetic.
What we read
Every source below links to the document itself. Tier 1 is a primary record - the company’s own plan, policy or disclosure, a court filing, a regulator’s decision or an SEC filing. Tier 2 is a self-regulatory or secondary regulator record, tier 3 reporting or academic work, tier 4 an open-market price comparison. Where a document can be moved or withdrawn, an archived copy is linked beside it. If a link is dead when you try it, that is a correction we want.
- 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
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
- 2025 Surge365 Income Disclosure Statement - company-served web version
- 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
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.
- 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
- 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
- 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
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.
- 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
- 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
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
- 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
- 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
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.
- Surge365 "Founder's Founders" page - the Founders Circle field distributors and their self-written biographies
- Surge365 corporate Home page - officer roster (Christopher Cokley, Chairman & CEO; Delvy Santiago; Clint Tomer) and the "launch in March 2015" statement
- DSSRC Case #58-2022 - Monitoring Inquiry, Surge365 (BBB National Programs)
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
- DSSRC Case #173-2024 - Administrative Closure, Surge365 (closed 11 September 2024, published 20 September 2024; 15 of 21 posts removed; "good faith efforts")
- "Brown Sues To Topple Online Pyramid Scheme" - California Attorney General press release on the YourTravelBiz.com action, 5 August 2008
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
- People of the State of California v. YourTravelBiz.com, Inc. et al. - civil complaint, Los Angeles County Superior Court (PDF)
- "Brown Ends YTB's Online Travel Pyramid Scheme" - California Attorney General press release on the $1 million settlement, 14 May 2009
- 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
- Better Business Bureau profile - Surge 365, Glen Carbon, Illinois (A+, not accredited, LLC, business start 2 March 2015)
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
- Better Business Bureau complaints file - Surge 365, including the $579 enrollment complaint and the company's five-business-day cancellation response
- "Surge365 Announces Executive Promotions, Breakthrough Powerline Compensation, and 2026 National Kickoff Tour" - company press release, 23/24 December 2025
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
- Surge365 press-release archive on EIN Presswire - including the August 2024 "New Ownership and Relocation" release
- Fora Travel - "Become a travel agent" joining page, published advisor commission model
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.
- Going - Premium membership page (economy flight-deal subscription tiers)
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.
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
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Surge365 - frequently asked
QIs Surge365 still operating in 2026?
QHas Surge365 ever been found to be a pyramid scheme?
QHow much does Surge365 cost and how much do people earn?
QWhat is the connection between Surge365 and YTB International?
QIs the travel through Surge365 actually cheaper than booking it yourself?
Author, editor and publisher
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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