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How this directory makes money, and the legal basis

Directories in fee-free or licence-gated scopes earn only from products that are NOT consideration for a placement, referral, booking or debt service: flat subscriptions not tied to leads, clearly labelled sponsored placement, at-cost verification, content, software, disclosed affiliates, labelled ads, aggregate data and free lead magnets. Each (tenant, category, state) resolves to one context; the context lists the products it may sell. Unknown contexts fail closed to the most restrictive set.

F7522 AI legal analysis (owner-accepted review posture of F7506/F7516; not attorney advice). Prices are PROPOSED: nothing is charged until fees.status == approved AND the tenant's launch.live_money is true.

Products

Pro profile (flat monthly subscription)

A flat fee that is not contingent on any referral, lead or transaction is advertising, not a referral/placement fee. Recurring billing follows ROSCA (15 U.S.C. 8403: clear terms, express informed consent, simple cancellation) and the California Automatic Renewal Law (Bus. & Prof. Code 17600-17606, incl. online cancellation, 17602(d)).

Citations: 15 U.S.C. 8403; Cal. Bus. & Prof. Code 17602

Sponsored placement (labelled)

Paid placement must be clearly and prominently distinguished from unpaid results (FTC Act s.5, 15 U.S.C. 45; FTC search-engine advertising letter of 2013-06-24; FTC '.com Disclosures' 2013). TRUST_TIERS.json seller_boosts already requires the 'Sponsored' label and forbids changing trust status.

Citations: 15 U.S.C. 45; FTC letter to search engines 2013-06-24; FTC .com Disclosures (2013)

Verification badge (provider-paid check at cost + admin fee where lawful)

FCRA: standalone disclosure and written authorisation before a consumer report for a hiring-type purpose (15 U.S.C. 1681b(b)(2)), handled on Checkr's hosted consent page; California ICRAA (Civ. Code 1786.16) disclosure. In a fee-free context the admin fee is 0: the check is passed through at the vendor's cost, so it is not consideration for a placement.

Citations: 15 U.S.C. 1681b(b)(2); Cal. Civ. Code 1786.16

Training courses and business templates

Selling information products is ordinary commerce. Claims of CE credit or board approval without approval would be deceptive (FTC Act s.5, 15 U.S.C. 45), so none are made.

Citations: 15 U.S.C. 45

Business tools (invoice generator, scheduling, simple CRM)

Software sold to a business is not a referral. The tools never receive or transmit funds, so no money-transmitter definition is met (31 CFR 1010.100(ff)(5)).

Citations: 31 CFR 1010.100(ff)(5)

Disclosed partner offers (payroll, insurance, software)

Material connections must be disclosed clearly and close to the claim (FTC Endorsement Guides, 16 CFR 255.5). Insurance partners are paid per click/lead, never contingent on a policy sale, and we never discuss coverage terms, because a commission contingent on a sale generally needs a producer licence (NAIC Producer Licensing Model Act, MDL-218, as adopted state by state; verify per state before any per-sale deal).

Citations: 16 CFR 255.5; NAIC MDL-218 (state adoptions)

Display ads on high-traffic SEO pages (labelled)

Ads must be identifiable as ads (FTC Act s.5; FTC Enforcement Policy Statement on Deceptively Formatted Advertisements, 2015). Contextual ads avoid CCPA/CPRA 'sharing' for cross-context behavioural advertising (Cal. Civ. Code 1798.140(ah), 1798.135) and COPPA personal-information collection (16 CFR 312.2, 312.5) on pages that touch minors' services.

Citations: 15 U.S.C. 45; FTC Deceptively Formatted Ads policy (2015); Cal. Civ. Code 1798.140(ah); 16 CFR 312.5

Market data reports (aggregate)

Aggregate, non-personal statistics. OpenStreetMap-derived data keeps the ODbL attribution (ODbL 1.0 s.4.3); a Produced Work may be sold. No PHI or personal data is included.

Citations: ODbL 1.0 s.4.3

Free checklists and guides (lead magnets)

Commercial email follows CAN-SPAM (15 U.S.C. 7704(a)(3)-(5): opt-out, postal address, honour within 10 business days).

Citations: 15 U.S.C. 7704(a)(5)

Where each product is offered

care_fee_free

Care in a fees.fee_free_states state (California).

Offered: verify_badge, courses_templates, saas_tools, affiliates, display_ads, data_reports, lead_magnets.

Not offered, because: Cal. Civ. Code 1812.501(a)(1)(C): anyone who 'for a fee or other valuable consideration, procures, offers, promises, provides, or attempts to procure ... domestics or babysitters for others' is an employment agency; (a)(1)(A)(ii) and (a)(1)(B) also catch fees from a jobseeker to be registered or to secure employment, and 1812.501 defines a paid 'job listing service'. A caregiver-paid Pro profile, a paid sponsored slot, or a family-paid search subscription is valuable consideration for being put in front of the other side, which would need the $3,000 bond (Civ. 1812.503) and the 1812.5095 duties. So none is sold; the badge is passed through at Checkr's cost with no admin fee, and ads exclude domestic staffing.

Citations: Cal. Civ. Code 1812.501(a)(1)(A)-(C); Cal. Civ. Code 1812.503; Cal. Civ. Code 1812.5095; Cal. Health & Safety Code 1796.17(b)(7)

care_domestic

Care in every other state (listing + waitlist).

Offered: verify_badge, courses_templates, saas_tools, affiliates, display_ads, data_reports, lead_magnets.

Not offered, because: Caregivers are domestic workers seeking engagements. Many states regulate anyone who takes a fee to procure domestic employment (e.g. N.Y. Gen. Bus. Law 171(2) employment agency; Ill. 225 ILCS 515 private employment agency; Ill. 77 IAC 245 home services placement agency). Until each state row is attested, no worker-paid or family-paid visibility product is sold; checks are at cost.

Citations: N.Y. Gen. Bus. Law 171; 225 ILCS 515; 77 Ill. Adm. Code 245

jobseeker_board

ShiftFill (independent gig board).

Offered: courses_templates, saas_tools, affiliates, display_ads, data_reports, lead_magnets.

Not offered, because: A fee from a worker for registration or access to engagements is the classic employment-agency / job-listing-service fee (e.g. Cal. Civ. Code 1812.501(a)(1)(A)-(B); N.Y. Gen. Bus. Law 171-172). No worker-paid product is sold; worker classification is still under counsel review.

Citations: Cal. Civ. Code 1812.501(a)(1)(A)-(B); N.Y. Gen. Bus. Law 171

debt_closed

BillAdvocate: every category (hospital_bill and claim_denial closed in all 51; recurring_bill / bill_error_audit closed in 18 states; whole market waitlist).

Offered: data_reports, lead_magnets.

Not offered, because: Several debt-adjusting statutes reach anyone 'holding oneself out as providing services to debtors in the management of their debts' (e.g. O.C.G.A. 18-5-1; KRS 380.010; R.C. 4710.01; SDCL 37-34-1), and debt-relief telemarketing bars advance fees (16 CFR 310.4(a)(5)). Selling visibility to advocates, debt-relief affiliate deals or ads next to closed scopes could make the platform a participant. Only free self-help templates (consumer sends them) and aggregate, PHI-free B2B data are offered. The tenant already says ads: never.

Citations: O.C.G.A. 18-5-1; KRS 380.010; Ohio R.C. 4710.01; SDCL 37-34-1; 16 CFR 310.4(a)(5)

upl_sensitive

Docs & Language: immigration_forms.

Offered: data_reports, lead_magnets.

Not offered, because: Non-attorney immigration help is tightly regulated (Cal. Bus. & Prof. Code 22440-22449 immigration consultants, incl. the 'notario' advertising ban in 22442.3; 8 CFR 292.1 who may represent) and lawyers may not pay for a recommendation (ABA Model Rule 7.2(b)). No paid visibility or ads are sold in this category.

Citations: Cal. Bus. & Prof. Code 22442.3; 8 CFR 292.1; ABA Model Rule 7.2(b)

licensed_directory

Every other listing_waitlist category (licensed trades, handyman, estate clean-out, household-goods transport, drone, catering, notary/RON, fingerprinting, translation, tax prep, sublets, sports officials).

Offered: pro_profile, featured, verify_badge, courses_templates, saas_tools, affiliates, display_ads, data_reports, lead_magnets.

Citations: 15 U.S.C. 45; 16 CFR 312.5

open_marketplace

open_nationwide categories (bookings allowed where rule rows pass).

Offered: pro_profile, featured, verify_badge, courses_templates, saas_tools, affiliates, display_ads, data_reports, lead_magnets.

Citations: 15 U.S.C. 45

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