What still needs counsel and the owner before launch
This program does not recruit a single reseller, take a single client payment, or publish any of these documents until counsel signs off. Open items:
- FTC Business Opportunity Rule assessment (16 C.F.R. Part 437) — does a $0-buy-in reseller program with no promise to supply customers fall outside the Rule, or trigger disclosure obligations?
- State franchise / business-opportunity / seller-assisted-marketing-plan review — a state-by-state check of whether the reseller program needs registration or disclosure, including states with no minimum-investment threshold.
- Final entity details — the drafts now name the entity as SiteRelay, a sole proprietorship operated by Chris Ellington, with Virginia governing law (filled as drafts). Counsel to confirm entity type, any DBA/registration, and the governing-law state.
- Final prices — every ⟨PRICE_…⟩ token (core package, periodic-care plan, deposit, reseller commission structure, self-serve tier) needs a real, owner-confirmed number; some legal thresholds depend on the figure.
- Brand-name confirmation — SiteRelay is provisional and must be cleared and confirmed by the owner before anything is finalized.
- Privacy-regime applicability — confirm which regimes apply (CCPA/CPRA and other state laws; GDPR/UK GDPR if any non-US applicant) and add the required disclosures.
- Third-party vendor list — name the form host, notification/email tools, and analytics providers in the Privacy Policy.
- Dispute-resolution mechanics, refund windows, and reseller time periods — arbitration/venue choice, deposit and refund windows, proration method, and the notice/cure/confidentiality periods.