A membership travel benefit exists to say one thing: members pay less than the public. Since May 2025 there has been a federal rule saying that the number allowed to dominate the screen is the total price, not the saving. If your product leads with a percentage off and reveals the resort fee three steps later, the prominence order is backwards.
That is the constraint worth designing around first, because it decides your pricing interface, and the interface is the product. Everything else in a partner integration is downstream of it.
The rule that now names lodging
The FTC Rule on Unfair or Deceptive Fees, 16 CFR Part 464, published at 90 FR 2166 on January 10, 2025, applies to two categories. Live-event tickets, and short-term lodging, which it defines as "temporary sleeping accommodations at a hotel, motel, inn, short-term rental, vacation rental, or other place of lodging."
Section 464.2(a) makes it an unfair and deceptive practice to "offer, display, or advertise any price of a covered good or service without clearly and conspicuously disclosing the total price."
Section 464.2(b) is the one that reaches into your layout. A business "must disclose the total price more prominently than any other pricing information." Where you also show the final amount of payment, that figure has to be at least as prominent as the total price.
Read those together and a familiar card design stops working. A large struck-through public rate, a large member rate, a large percentage saved, and a small line about taxes and fees is four pieces of pricing information competing with the number the rule says must win.
What total price includes, and what it does not
The definition in 464.1 is worth reading closely because the whole design turns on one word. Total price is "the maximum total of all fees or charges a consumer must pay for any good(s) or service(s) and any mandatory ancillary good or service, except that government charges, shipping charges, and fees or charges for any optional ancillary good or service may be excluded."
Mandatory is the word. A resort fee nobody can decline is inside the total price. A government tax is outside it. An add-on the member chooses is outside it.
Anything you exclude still has to be disclosed before the member consents to pay, and 464.2(c) says what that disclosure contains: the nature, purpose and amount of the charge, what it is for, and the final amount of payment.
There is a second requirement most product teams find harder than the arithmetic. Under the definition of clear and conspicuous at 464.1, in an interactive medium "the disclosure must be unavoidable." A tooltip the member has to hover, or an accordion they have to open, is avoidable by construction.
The air side is stricter, and much older
If your program touches flights, a second regime applies and it has been in force for years. Under 14 CFR 399.84, on price advertising and opt-out provisions, a stated air fare must be "the entire price to be paid by the customer."
The prominence rule goes further than the FTC's. Component charges such as government taxes may be shown separately or behind a link, but they "may not be displayed prominently, may not be presented in the same or larger size as the total price." Not merely less prominent. Not the same size.
Section 399.84(c) adds something a membership product runs into constantly. An optional service cannot be added automatically if the member takes no action. They have to affirmatively opt in. A pre-ticked insurance box, a pre-selected carbon add-on, or a bundled upgrade that only comes off if someone notices are all the same defect.
One scope note, because it is easy to over-apply. The DOT rule reaches a hotel stay only as a tour component that has to be bought with air transportation. A standalone hotel booking is Part 464 territory.
Where the value comes from, and who pays for it
Worth being precise about the model underneath, because the rules above are asking you to be honest about it in public.
A membership travel benefit has at most three sources of member value, and they behave differently.
A rate the public cannot see. Closed-user-group rates exist because a supplier will discount when the discount stays off open channels. That is a genuine differential rather than a marketing construct, and it is also the one most exposed to a total-price problem, because a lower room rate alongside an unchanged mandatory fee narrows the real gap.
A rewards layer. Value returned after the transaction rather than deducted from it. Cleaner under Part 464 for the obvious reason that it is not pricing information on the booking screen at all, though whatever you say about its worth is still a claim you have to stand behind.
Fee treatment. Absorbing or waiving something the member would otherwise pay. The most immediately legible to a member, and the easiest to describe wrongly, since a waived fee that reappears at the property is worse than never having claimed it.
On the platform's side, revenue in these programs comes from the booking rather than from the member: a commission or a margin on what the supplier pays out. That is unremarkable and worth stating plainly somewhere a member can find it. A program that presents itself as a pure benefit while earning on every transaction has a disclosure gap rather than a business-model problem, and the fix costs a sentence.
Where this bites a membership program specifically
The hero number. Savings-led design is the whole marketing premise, and 464.2(b) says the total price outranks it. You can still show the saving. It cannot be the most prominent piece of pricing information on the card.
Refundability. Section 464.3 makes it a violation to misrepresent "the nature, purpose, amount, or refundability of any fee or charge." Member rates are often the non-refundable ones, and that trade is exactly what gets soft-pedaled in a benefits portal. Describing it plainly is now a compliance question rather than a tone question.
The state floor. Section 464.4 says the rule does not supersede a state law that gives consumers greater protection. A national program inherits the strictest jurisdiction it operates in, so build to the ceiling rather than the federal floor.
What to build: a total-price-first integration checklist
An integration checklist that survives a screenshot.
One price object, not two. Your API should return a total price with mandatory ancillaries already inside it, and carry the excluded items as a separate itemized list. Programs that compute the total in the front end get inconsistent results across surfaces, and every surface is an advertisement.
Prominence as a rendered property, not a guideline. Whatever component renders price should enforce the ordering rather than trusting each partner's stylesheet. This is the single thing most likely to drift after launch.
Disclosure that cannot be skipped. Excluded charges shown inline before the consent step, not behind a hover. The word in the rule is unavoidable.
Refund terms on the same surface as the rate. If the member rate is non-refundable, that belongs next to the price, not in terms accepted at checkout.
Nothing pre-ticked. Cheaper to build this way from the start than to unpick later, and mandatory on the air side regardless.
Why a private rate can be lower than the public one in the first place, and how an employer treats it, are separate questions covered in how to offer private hotel rates as an employee benefit. The tax and payroll side is in our guide to employee travel benefits. If you want to see the booking and rewards mechanics a member experiences, how Dyme works lays them out, and Dyme for Business is where partnership conversations start.
FAQ: building a compliant membership travel benefit
Does the FTC fees rule apply to hotel bookings inside a membership program?＋
Yes. 16 CFR Part 464 covers short-term lodging by name, defined as temporary sleeping accommodations at a hotel, motel, inn, short-term rental, vacation rental or other place of lodging. Nothing in the rule turns on whether the booking is behind a membership. It applies to any offer, display or advertisement of a price, so a rate shown inside a benefits portal is covered the same way a public search result is.
Can we still lead with the member saving?＋
You can show it, but it cannot outrank the total price. Section 464.2(b) requires a business to disclose the total price more prominently than any other pricing information, and a percentage saved or a struck-through public rate is pricing information. In practice this is a layout decision rather than a messaging one. The saving can go next to the total price rather than above it in a larger weight.
Which fees go inside the total price and which stay outside?＋
Anything mandatory goes inside, including a resort fee the guest cannot decline. Government charges, shipping charges and optional add-ons may be excluded. Excluding a charge does not mean hiding it. Section 464.2(c) requires that before the consumer consents to pay you disclose the nature, purpose and amount of each excluded charge, what it is for, and the final amount of payment.
Are the air rules different from the hotel rules?＋
Yes, and the air rules are stricter and considerably older. Under 14 CFR 399.84 an advertised fare must be the entire price, and component charges may not be displayed prominently or presented in the same or larger size as the total price. Section 399.84(c) also bans automatically adding an optional service unless the customer affirmatively opts in, so nothing may be pre-ticked. The DOT rule reaches a hotel stay only when it is a tour component sold with air transportation.
Does complying with the federal rule mean we are covered everywhere?＋
No. Section 464.4 states the rule does not supersede a state law, regulation or interpretation that gives consumers greater protection than the federal one. For a program operating nationally that makes the federal rule a floor. The practical approach is to build to the strictest jurisdiction you sell into rather than maintaining per-state price displays.
