Instruct the reviewer before the review appears, and keep what was said: 16 CFR § 465.5(c)(1)(ii) makes failing to instruct an element of the violation, not a lapse in hygiene.
A review appears, and 16 CFR Part 465, at 89 FR 68034, took effect on 21 October 2024.
02
A post is drafted by an employee, and § 255.5 counts the payslip as a material connection.
Reason
03
A review is written by an officer, and § 465.5(a) wants that relationship disclosed.
04
A review hub you control publishes, and § 465.6 asks whether it reads as independent.
05
An instruction goes unissued, and § 465.5(c)(1)(ii) makes that omission the violation.
Decide
06
An undisclosed review surfaces, and § 465.5(c)(1)(iii) turns on what you then remedied.
07
A takedown is proposed, and § 465.7 reads a groundless threat to a critic as the wrong.
Out
08
A post is archived, and no US rule makes an ordinary business keep it for a period.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent drafts and routes community replies, records the instruction given and the remediation taken, and flags. A named person publishes, discloses and decides a takedown.
Example workflow
One post, evidence to publication
AgentHuman
1Post evidence receivedOwned-account posts, review feeds, community threads or moderation queues
2Post context assembledThe post, the account it sits on, the connection behind it and the day it appeared
3Disclosure evidence draftedThe post, its connection, the instruction issued and completeness
4Controls appliedConnection checks, disclosure checks, sentiment-neutrality checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is published at any of them — the agent is assembling, and the legal lane opens at the completeness gate.
5DecisionSplits at the completeness gate
Evidence sufficient
Goes to the social owner to approve.
Anything thin
Adds a legal counsel read first.
Legal review
The post is held with its connection, its instruction and the account it sits on.
Publish · Append evidence · Send to legal review
Published — by a named owner▼
6Post and community records updatedOnly where write access and records policy allow it
7Outcome evaluatedDisclosure coverage, instruction records, reviewer corrections and what the read found
Corrections
Each legal correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Publishing a post to an owned channel.
Deciding that a disclosure is not owed.
Deciding a takedown under § 465.7.
Setting the incentive terms under § 465.4.
Automation boundaryAgent acts unaided
✓Hold each post beside the connection that sits behind the person.
✓Record the instruction to disclose and the date sent.
✓Draft the community reply and route it to the owner who.
✓Flag the undisclosed insider review before the display set moves.
Nothing is published or disclosed except by a named person, inside the agreed boundaries.
Judging whether a relationship is already clear.
Telling the Commission anything at all.
Setting the moderation policy posts are held to.
Changes to live posts, replies or review displays.
Example output
One post, annotated
Our influencer outreach and negotiation agent owns paid creator sourcing, vetting and negotiation, while paid inventory suitability belongs to our brand safety and suitability agent; this page claims neither, and works the channels you own and the people you employ.
Record entry · single postIllustrative example
Post
Recorded as
Connection
Evidence of record
Confidence
Held for
Staff review, § 465.5(b)
Insider connection found, disclosure instructed
Employee
Instruction issued, 3 August 2026
Held unpublished
The social owner, by name
As receivedTaken from the account record and the workforce feed — it reaches as far as those sources do.
What the record holdsAccount recordInstruction issuedRemediation taken
Why no takedown hereWhether a critical review may come down is a § 465.7 call, not a model output.
ActionPublishAppend evidenceSend to legal review
What the score decidesBelow the configured threshold a post picks up a legal read before the owner sees it.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every postFrom the account that carries it
03Evidence
Where the evidence is used
Those advertising pages sit agency-side and answer to a client who booked the media; this one answers to the brand functions that employ the reviewer.
01Approved path
An employee is an insider
Section 465.5 reaches officers, managers, employees, agents and immediate relatives, and § 465.1 reads officer as owners, executives and managing members, and relative as spouse, parent, child or sibling.
02Human review
What was checked, and not found
The word agent is used across § 465.5 and carries no standalone definition in § 465.1, the literal text of § 465.5 and § 465.1 wants a clean pull from the eCFR before anything is quoted at length, no survey of state fake-review or insider-disclosure statutes was undertaken, and no court-docket search was performed.
04Build an evidence trail
The post, the connection behind it and the person who disclosed it stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Owned social accountsPublishing and scheduling tools Posts, replies and comment threads
Review estateOwn-site reviews · review platforms Review and testimonial records
Workforce and advocacyWorkforce feed · advocacy tooling Employee and relative connections
Agent
Social and community management
Reads the posts Tests the connections Holds for the owner
Community and case systemsForum platform · ticketing Moderation and instruction records
Integration availability depends on the client's existing systems and API access.
Agent controls
Six filters between the model and the owner
Six filters laid end to end, the last the least generous. Whatever passes is named in the map below.
L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeNarrow the agent to evidence assembly when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and disclosure rules; § 465.3 stands reserved after the Notice of Informal Hearing of 16 January 2024, so nothing here answers review hijacking.Track
L4TraceabilityRecord each post, the connection behind it and the instruction issued; the Endorsement Guides at 16 CFR Part 255, revised at 88 FR 48102 on 26 July 2023, carry no force of their own.Record
L3Owner releaseHold the post for a named owner; TruHeight, charged 13 April 2026 and closed by final order on 15 July 2026, ran on staff-written reviews and bot social profiles.Gate
L2Moderation guardrailsTest each removal against a documented policy; an agent that quietly suppresses negative sentiment is building the § 465.7 case against its owner.Restrict
L1Confidence thresholdsRoute a thin post to a legal read first; § 465.2 and § 465.8 turn on what you knew or should have known, and the December 2025 warning letters went to advertisers.Require review
Model coreEvidence assembled — the post, its connection, the instruction and completeness
L1 – L2Test whether a post may go out
L3Puts the publication in a person's hands
L4 – L5Keep the post and the connection behind it
L6Falls back to draft-only when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the disclosure record that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the record an investigator reads
Depth of coverage ▼
E1Final-output evaluationDid the record hold what the post actually carried?
E2Step-level evaluationDid the agent read the right account, the right thread and the live connection?
E3Tool evaluationDid it read and write the correct post record and the correct instruction?
E4Confidence calibrationDo low-confidence posts actually attract more legal corrections?
E5Slice evaluationHow does performance change across specific channel types?
E6Business outcomeHow many posts needed a correction before the owner published?
Floor — the record the brand answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each set at the stage where it first shows.
Agent lifecycleDirection of processing →
01 · Retrieval1 mode
LE-03
Stale thread read
The thread read is not the one now on display.
Stage gathersThe posts, the accounts, the people and threads
02 · Reasoning2 modes
LE-04
Disclosure asserted, not shown
A post is called clear with no connection check.
LE-06
Reserved section worked as live
Review hijacking is worked as a Part 465 duty.
Stage proposesThe posts, their connections and completeness
03 · Tool / write2 modes
LE-02
Thin post passed forward
A post moves on without the legal read.
LE-05
Bound to the wrong person
A connection is filed against the wrong account.
Stage writesOnly where write access and approval policy allow it
04 · Output1 mode
LE-01
Published, instruction unrecorded
The record shows a post but not what was instructed.
Stage returnsThe record an owner clears and a reviewer reads
05 · Change / Version1 mode
LE-07
Silent moderation drift
A policy change biases removals, not the record.
Stage tracksModel, prompt, disclosure rules and post fields
Sev-1 · an insider review left undisclosedSev-2 · a critical review cut on sentimentSev-3 · source degrades, post held in draft
A channel-level disclosure-coverage figure can read clean while employee and insider posts carry most of the rework. Nestack reports the correction rate by channel, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Employee and insider posts
10.5%
3.6×
Review
Own-site review estate
7.5%
2.6×
Review
Community forum threads
4.6%
1.6×
Watch
Brand account replies
2.1%
0.7×
Normal
Bar: correction-rate lift vs. brand-reply baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an undisclosed staff review costs
The loop shuts when the undisclosed staff review is a regression case. That suite is what the next post cleared is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on employee and insider posts.
02Diagnose
The five-star review written by someone whose payslip the company signs is read back until one cause remains.
03Improve
Any change goes out numbered, with the posts that caused it attached.
04Verify
One post case still failing is enough to hold the release back.
05Learn
One case joins the suite, one line joins the disclosure record.
Learn → DetectThe return edge. The next post is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, disclosure assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Insider-disclosure discovery and boundary work.
02Owned-channel and review-estate sources.
03Post-to-connection and disclosure-coverage mapping.
04Post and review ingestion.
05Post, connection and record binding.
06Completeness scoring and review routing.
07Owner publication workflow.
08Community-platform integration.
09Connection and instruction cases.
10Guardrails and moderation controls.
11Post-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne channel, one yearProductionProduction publication workflowAdvancedMultiple brands / markets
Introduced at Pilot
Disclosure assembly to your channels✓✓✓
Named owner publication✓✓✓
Owned-channel baseline✓✓✓
Introduced at Production
Reporting by channel—✓✓
Publication workflow in your systems—✓✓
Approved write-back—✓✓
Community-platform integration—✓✓
Introduced at Advanced
Multi-brand estates——✓
Cross-market evidence packs——✓
Large community estates——✓
Multi-account disclosure controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, post volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your owned accounts and review estate→Channel inventory mapping and post captureWeek 1
02Representative posts, reviews and community threads→Record binding, disclosure logic and the coverage baselineWeek 2
03Your officers, managers, employees and their relatives→Channel mapping, connection binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Channel, review and workforce-source assessment, then integration setupWeek 2
05Posts you would not want produced→Disclosure cases and the failure-mode runWeek 4
06What no moderation log may prove→Completeness scoring, review routing, guardrails and release controlsWeek 3
07A named owner to publish the post→Publication workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
What each bar spans is working time and not the drawn page, so a pair has to share the fifth week.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Social workflow discovery, channel mapping and the automation boundaryW2Source integration and the disclosure-coverage baselineW3Disclosure assembly, connection logic and moderation controlsW4Evaluation suite, insider cases and failure-mode testingW5Community integration, pilot posts and targeted correctionsW6One community year run under the social lead, then Agent Care handover
Reading the bandEach bar covers only the weeks its own work is named for. The fifth holds a pair because the work does.
At the end of W6Once the disclosure record validates, Agent Care assumes the agent.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Marketing AI agent
Build a social agent around the review your own payroll wrote and nobody instructed to disclose.
One post, and the person standing behind it, is enough to begin. Show us your instruction record and the remediation that followed. Nothing under Part 465 or Part 255 is signed, filed or certified; both are conduct rules read after the fact.
