Is this Multilevel Marketing (MLM)?

No, THAT Card is not Multilevel Marketing (MLM). MLM has been described as a way of distributing products or services in a way in which the distributors earn income not only from their own sales, but the sales made from their direct and indirect recruits. The distributors in an MLM earn commissions based on their own sales and those of the people they recruit. With THAT Card FriendSpend Rewards Program, we do not distribute any products or services (other than THAT Card), and you are not making any commissions that are derived on the sale of any goods or services that we sell. 

Another distinction is that in a multilevel marketing program, the commissions paid are for sales of products and services. With THAT Card FriendSpend Rewards Program, you are not compensated for your own purchases or for referring others to get a THAT Card and you have no influence over any purchases made by any Cardholders that you directly or indirectly referred. Although the amount of FriendSpend Rewards that you may be eligible to earn is based on the spending of the Cardholders which you have directly or indirectly referred, there is no requirement that those Cardholders purchase from any specific product or service providers. This is another indicator that THAT Card FriendSpend Rewards Program is not a multilevel marketing program.