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 — you never refer borrowers to Co-Operate. Your Contractor Fee compensates bona fide, documented services actually performed. The statute explicitly permits compensation for services that are not merely nominal.
DriveX Audit Trail
Every service deliverable flows through 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 70% — more than the entire 7-tier downline combined. This architecture passes every FTC test for legitimate business opportunity.
How the framework protects you.
Service-for-Pay Documentation
Every Contractor 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.
Five agreements.
One framework.
Co-Operate's compliance infrastructure is codified across five attorney-drafted agreements. Every Contractor receives and signs all five before onboarding.
Contractor Service Agreement (CSA)
Master agreement defining independent contractor relationship, services, and compensation structure.
Governance & Requirements Document (GRD)
Detailed operational rules, service requirements, forfeiture mechanics, and compliance obligations.
RAP Program
Retention Re-Assignment Program — economics and rules for re-assigned Qualified Individuals.
CSP Program
Growth Co-Sponsorship — volume-weighted Direct Compensation split for retention collaboration on a placed QI.
Platform Services Agreement (PSA)
DriveX platform terms — data handling, IP, availability, and audit access for all Contractors.
The compliance essentials.
Contractors recruit and retain talent. They never refer, solicit, or interact with borrowers.
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.
70% flows to Direct Compensation — structurally greater than the entire 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.