The FTC has reached a proposed consent agreement with Victory Media, Inc., resolving allegations that Victory violated Section 5 of the FTC Act. The allegations stem from Victory’s promotion of post-secondary schools to members of the armed forces.

Victory advertises to members of the armed forces in a variety of ways, including through its publications G.I. Jobs, the Guide to Military Friendly Schools, and Military Spouse; through its websites, including militaryfriendly.com, militaryspouse.com, and gijobs.com; and on social media platforms like Facebook, Twitter, and LinkedIn. On its website militaryfriendly.com, Victory says it has “researched thousands of employers and schools so you can make informed choices about your future,” and that it “measures an organization’s commitment, effort and success in creating sustainable and meaningful benefit for the military community.”

According to the FTC’s complaint, however, some of Victory’s advice and tools promoted schools that paid the company for promotions, with disclosing payments. The FTC alleged that beginning in 2015, Victory would not include a school as a possible match in its search unless the school paid to be a part of that search, and that Victory then failed to disclose that it had been paid for these promotions. The FTC said that some of the schools that were promoted on Victory’s website were not actually “military friendly” under the company’s criteria, but were being endorsed or included only because they had paid Victory.

The consent agreement is available for public comment until November 20. After that time, the FTC will review the agreement and comments received, and decide whether to enter the agreement’s proposed order resolving the matter.