Creator codes: MMP, store and finance reconciliation

Reconcile creator promo codes using FTC material-connection disclosure guidance and AppsFlyer revenue/event identifiers — without inventing attribution magic.
Creator codes fail in three ledgers at once: disclosure, attribution, and payout. This checklist ties the first to FTC staff guidance and the second to MMP event hygiene.
Disclosure (FTC staff FAQ)
FTC's Endorsement Guides: What People Are Asking states that a clearly personalized unique discount code probably signals a brand relationship, but may not make the financial relationship obvious. Staff recommend erring on the side of a clearer disclosure when consumer understanding is uncertain. Material connections that would affect credibility should be disclosed clearly and conspicuously.
Measurement (MMP events)
AppsFlyer in-app events require structured events with identifiers for revenue reporting. Codes do not dedupe themselves against store proceeds or influencer invoices.
Reconciliation checklist
| Ledger | Gate |
|---|---|
| Creative / legal | Every paid code post carries clear material-connection disclosure |
| MMP | Code → campaign or partner parameter mapped before flight |
| Store / IAP | Redemptions exportable by code or offer ID |
| Finance | Invoice line items join to redemptions within agreed window |
| Exceptions | Refunds, chargebacks, multi-code carts labelled |
Facts versus limits
| Field | Evidence or limit |
|---|---|
| FTC view on personalized codes | Staff FAQ — clearer disclosure often needed |
| Automatic MMP↔finance reconciliation | **Not** provided by citing these pages |
| Non-US disclosure law | Out of scope here; add local counsel gates |
Do not treat code install volume as ROAS until the join keys exist.


