Partner Program · Compliance Policy

Built to be referred — and built to stay clean.

Subefy pays partners for one thing only: introducing people to a credit-education software subscription. This page explains the rules that keep the program compliant, in plain English. Version partner-cert-v1-2026-07.

1 · RESPA independence

The Real Estate Settlement Procedures Act (RESPA) Section 8 prohibits kickbacks for referring settlement services — things like loan origination, title, escrow, and appraisal. Subefy is not a settlement service; it is credit-education software. To keep it unambiguous:

Partner compensation is a flat fee per activated software subscription ($4 activation + $4/mo Plus · $1/mo Builder, for each client's first 3 months). It never varies with, and is never conditioned on, any mortgage application, pre-approval, loan closing, or real-estate transaction.
No mortgage referrals are bought or sold here. Subefy does not pay for, and partners may not accept or give anything of value for, referrals of mortgage or settlement business — in either direction, including with Slopes Mortgage or any lender.
Partners may never condition, price, or steer a mortgage, listing, or any settlement service based on whether a client uses Subefy.
Clients always see a disclosure at intake that their referring partner may be compensated, that it never changes their price, and that it is unconnected to any mortgage or real-estate service.
MLOs and real-estate licensees certify their employer and state regulator permit third-party referral compensation before enrolling.

2 · CROA marketing rules

The Credit Repair Organizations Act and FTC rules govern how credit help may be marketed. Every partner certifies they will:

Use only Subefy-approved marketing language — available in the portal.
Never promise a specific score increase, deletion, or timeline. Results vary and no outcome is guaranteed.
Never suggest Subefy can remove accurate, timely information, or create a "new credit identity."
Disclose their paid referral relationship to every client they refer (FTC Endorsement Guides).

3 · What we record

Each partner's signed program-terms and RESPA certifications, with timestamp and policy version.
Each partner's W-9 (required before first payout) — 1099-NEC forms are issued every January for partners paid $2,000+ in the prior year (IRS threshold for payments made on or after Jan 1, 2026).
Every referral's source code, and the consumer disclosure shown at intake.
All payouts: flat, scheduled (15th of the month, $50 minimum), via ACH.

4 · Enforcement

Violations — outcome promises, undisclosed relationships, tying Subefy to mortgage or real-estate services — result in removal from the program and forfeiture of unpaid amounts. We review partner marketing periodically and honor every takedown request within one business day.