Compliance
by design.
Multi-tier recruiting models in mortgage face scrutiny under two federal frameworks: RESPA Section 8, which prohibits unearned fees and other prohibited compensation in real estate settlement services, and the FTC Act, which targets business opportunity structures where participant fees — not external revenue — drive compensation. Co-Operate was architected from day one to satisfy both. Every service is documented, every payout is tied to verified work product, and zero dollars come from contractor enrollment.
"Every dollar of compensation must be justified by a documented service in DriveX. That is a RESPA defense AND the FTC defense — operationalized. This is the most critical component of our platform."
Three regulatory defenses.
Co-Operate's compliance framework is built on three pillars — each reinforcing the others. Together, they create a defensible structure for every transaction, every payout, every contractor.
RESPA § 8(c)(2)
You recruit and retain talent for Co-Operate — no borrowers are ever referred to Co-Operate, and your Co-Operator Fee compensates only recruiting and retention services, never any borrower-related activity. The statute explicitly permits compensation for services that are not merely nominal.
DriveX Audit Trail
Every service deliverable is recorded in DriveX, G26x's proprietary AI Platform. DriveX generates the task, you execute, DriveX logs the completion with timestamped evidence. No documentation, no pay.
FTC Alignment
Revenue originates from external funded loans, not participant fees. Zero cost to join. Direct production earns $800 — more than three times the entire 7-tier Network Growth Allocation combined. This architecture is designed to satisfy every FTC test for legitimate business opportunity.
Co-Operate contracts directly with its lender clients and pays Contractors for services performed. Contractors are never paid by a lender, by a borrower, or out of a closing, do not refer consumers or settlement service business, and are not compensated for doing so.
How the framework protects you.
Service-for-Pay Documentation
Every Co-Operator Fee payout maps to a specific, documented service. Monthly retention services, quarterly N1–N4 Network Growth services — all logged with timestamps, deliverables, and evidence.
Forfeiture as Enforcement
Miss a service cycle and your allocation is permanently forfeited. This isn't punitive — it's evidence that the platform only pays for services actually rendered.
Independent Contractor Structure
You own your LLC. You carry your own E&O. You are not an employee, not an agent, not a licensed originator. The Contractor Service Agreement makes this explicit and enforceable.
Revenue from External Production
All compensation originates from external funded transactions — not from fees charged to participants. There is zero cost to join. This is the fundamental distinction between a legitimate business opportunity and a prohibited structure.
Compliance Pre-Approval
All marketing materials, communications, and recruiting collateral must be pre-approved through Co-Operate's compliance review process. This protects both the Contractor and the platform.
Two documents.
Two enrollment programs.
Every Contractor is bound through two signed items: the Contractor Service Agreement and an onboarding governance certification. RAP and CSP are enrollment-based programs that apply only to Contractors who participate in them — not separately signed agreements.
Contractor Service Agreement (CSA)
Master agreement defining the independent contractor relationship, services, and compensation structure. Incorporates the Master Governance Document by reference.
Onboarding Governance Certification
Certifies the Contractor's agreement to operate under the Master Governance Document's operational rules, service requirements, forfeiture mechanics, and compliance obligations.
RAP Program — enrollment-based
Retention Assignment Program — economics and rules for retaining Qualified Individuals already working at a lender client.
CSP Program — enrollment-based
Growth Co-Sponsorship — volume-weighted Direct Compensation split for retention collaboration on a placed QI.
The compliance essentials.
Co-Operate's recruiting and retention services involve no borrower referrals, solicitation, or contact. (Buy-Side Influencer Co-Operators may separately serve homebuyers in their own real estate practice; that activity is independent of, and not compensated through, their Co-Operate services.)
Contractors are not licensed originators. Active NMLS conflicts must be disclosed and resolved.
No franchise fee. No subscription. No buy-in. Startup costs (LLC, E&O) are standard business expenses.
The $800 Co-Operator Fee is payable as Direct Compensation — structurally greater than the entire $250 7-tier Network Growth Allocation combined.
No offline compensation. Every service is AI-generated, contractor-executed, and platform-logged.
Co-Operate LLC is domiciled in Ohio. All agreements are governed by Ohio law.