Affiliate Disclosure
Effective August 25, 2026 · Version 1.0
Plain-English summary (read this first). When you click a link on Vested Gifts that goes to Robinhood, we may earn a small referral fee from Robinhood if you open and fund a Robinhood account. We want you to know about this up front, because we think you deserve to know who pays us. The fee does not change your costs, your account terms, or how Robinhood treats you. We earn the same flat fee regardless of how much (or how little) you eventually deposit, trade, or hold at Robinhood — by design, so our interests stay aligned with yours rather than with pushing you toward riskier activity.
1. Why We Publish This Page
The U.S. Federal Trade Commission's Endorsement Guides (16 C.F.R. Part 255), as updated in 2023, require companies that endorse, recommend, or link to third-party products to clearly and conspicuously disclose any material connection with the third party — including financial compensation. (Federal Register 88 FR 48092, July 26, 2023)
Vested Gifts ("Vested," "we," "us") earns referral compensation from Robinhood Markets, Inc. and its affiliates ("Robinhood") in connection with brokerage-account referrals. This page explains that relationship in detail. A short version of this disclosure ("Vested earns a referral fee from Robinhood when you open and fund an account through our link") will also appear at or near the first mention of Robinhood on every page, email, and Book — not just in the footer — as required by the Endorsement Guides.
2. The Compensation We Receive
Vested participates in Robinhood's Impact affiliate program (administered through the Impact.com network). Apply or verify at affiliates.robinhood.com.
The program pays Vested:
- a flat fee per qualified lead (a user who opens, and is approved for, a Robinhood account through our link), and
- a flat fee per funded account (a user who deposits the minimum required to fund a new Robinhood account through our link)
with a 30-day attribution cookie. The fees are flat per-referral amounts — they do not vary with how much a user funds, how often they trade, or what they hold.
These terms may change at Robinhood's discretion. We will update this page when we become aware of material changes.
3. The Compensation We Do NOT Accept
By policy, Vested does not accept, and will not negotiate for, any of the following compensation structures from Robinhood or any other broker-dealer:
- Per-trade compensation (any fee tied to specific securities transactions a user makes)
- AUM revenue share (a percentage of assets the referred user holds at Robinhood)
- Tiered volume bonuses that scale with referred users' trading activity
- Payment for order flow participation
- Any other transaction-based compensation as that term is used under Section 15 of the Securities Exchange Act of 1934 (15 U.S.C. § 78o) and FINRA Rule 2040 (finra.org)
This boundary exists so that Vested's compensation is not contingent on the size, frequency, or risk of the trading you do at Robinhood after you sign up. We benefit only from the act of you opening and funding an account — we have no incentive to influence what you do next.
If at any time we change this policy, we will update this page and notify users by email at least 14 days before the change takes effect.
4. How the Tracking Works
When you click a Robinhood link on Vested:
- Robinhood (through Impact.com) sets a tracking cookie or identifier in your browser. This cookie tells Robinhood that your subsequent account opening, if any, was referred by Vested.
- The cookie lasts 30 days. If you open and fund an account within that window through Robinhood, Vested is credited.
- Robinhood reports back to Vested (in aggregate, without your name, email, or account details) that a referral was completed. We then receive a payout once aggregate referrals exceed the program's minimum payout threshold.
We do not receive your Robinhood account number, balance, trading activity, holdings, or any other personal financial information from Robinhood. The tracking flows in one direction: Robinhood tells us a referral closed; nothing else.
For more detail on the cookies Vested sets directly, see our Cookie Notice. For Robinhood's privacy practices, consult Robinhood's Privacy Policy.
5. What This Relationship Is Not
To be precise about what the affiliate relationship does and does not mean:
- Vested is not a broker-dealer, investment adviser, or financial institution. We are not registered with the SEC, FINRA, or any state securities regulator.
- Vested is not a partner, agent, employee, or representative of Robinhood. We do not have authority to bind Robinhood or to make representations on Robinhood's behalf.
- Vested does not open, custody, or have any access to your Robinhood account. The relationship that account opening creates is solely between you and Robinhood.
- Vested does not receive a commission on your trades, a percentage of your account balance, or any compensation that depends on what you do at Robinhood after opening.
- Robinhood is not the only broker available. You may use any custodial brokerage you choose. Vested links to Robinhood because the Robinhood gift link is a clean, ledgered way for parents to receive contributions; we do not represent that Robinhood is the best, cheapest, or safest option for your family. You should evaluate Robinhood independently before opening an account — see Robinhood's customer agreement and the SEC's Investor.gov resources.
See also our Brokerage Disclosure and Pledge Disclosure for related context.
6. Conflict of Interest — Plainly
Because Vested earns money when you open and fund a Robinhood account, we have a financial incentive to encourage you to do so. We want to be transparent about that incentive rather than pretend it does not exist. Some practical implications:
- We have an incentive to recommend Robinhood over alternatives. The Robinhood gift link is the only brokerage gift mechanism we currently support in our product flow. Other custodial brokerages exist (Fidelity Youth, Charles Schwab Custodial, E\*TRADE Custodial, Vanguard UTMA) and may be more suitable for your family. We do not (currently) earn a referral fee from those providers.
- We have an incentive to surface Robinhood prominently in product UI. We try to balance this by being explicit, in product copy, that you may use any custodial brokerage you wish, and by not gating Vested apparel purchases or Book use on having a Robinhood account.
- We have an incentive to encourage funding (not just signup). Because most of the per-referral payout is tied to funding rather than signup alone, we benefit when users deposit money at Robinhood. We address this conflict by not earning anything tied to the amount funded, how often the user trades, or what the user invests in — so our incentive maxes out at "the user funded the account at all," and we have no incentive to push higher deposits or riskier behavior.
If you would prefer to use Vested without contributing to our affiliate revenue, you can:
- Visit Robinhood directly at robinhood.com instead of clicking our link, or
- Use a different custodial brokerage entirely. Vested's apparel and Book features work regardless of which broker you choose.
7. Where the Short-Form Disclosure Appears
Per FTC §255.5, the material-connection disclosure must be "clear and conspicuous" and at or near the first mention of the endorsed product in the relevant content, in the same modality. To meet that standard, you will see a short disclosure such as:
Vested earns a referral fee from Robinhood when you open and fund an account through our link. Learn more.
at or near the first mention of Robinhood on:
- Our marketing pages (homepage, How It Works, FAQ)
- Each Book that includes a Robinhood link
- The Parent Claim flow (where you connect your Robinhood gift link to a Book)
- Every transactional and marketing email that mentions Robinhood
- Every SMS message that mentions Robinhood (in plain text, since SMS does not support hyperlinks reliably)
This page is the long-form version that the short-form disclosure links to.
8. Updates to This Disclosure
We may update this page from time to time. When we do, we will update the Last Updated date at the top of this page and, for material changes, post a notice on the homepage and notify registered users by email. Material changes that introduce a new compensation type (e.g., AUM revenue share — which we do not currently accept) will be accompanied by a re-acceptance flow.
Prior versions of this page will be archived at /legal/archive/affiliate-disclosure/v<version> for audit purposes.
9. Contact
Questions about this disclosure, or about Vested's relationship with Robinhood, may be sent to:
Vested Gifts Attn: Legal [REGISTERED AGENT NAME] [REGISTERED AGENT ADDRESS], [ZIP] Email: support@vestedgifts.com
10. Related Policies
- Terms of Service — see §6 (Affiliate Compensation)
- Privacy Policy — see §7.2 and §8 (Affiliate Cookies)
- Cookie Notice
- Brokerage Disclosure — see §3 and §3A
- Pledge Disclosure — see §3, §6, §7, §9
This Affiliate Disclosure is part of the Vested Gifts Policy Pack v1.1 and should be read together with the documents listed above. It is not legal advice; have it reviewed by qualified counsel before publishing.