Purpose: a reusable instrument for deciding whether a FedM8 build plan that touches veterans, money, and third-party professionals is safe to build. Written to be applied by someone who did not write the plan.
Design principle: a weighted score alone is gameable — a plan can average its way past a fatal flaw. So the instrument has two independent parts, and both must pass:
encode consequences that are not tradeable: criminal exposure, per-violation civil penalties, loss of a platform licence, or a claim to the veteran that cannot be substantiated.
Verdicts: GO (all gates pass, score ≥ 75) · CONDITIONAL GO (all gates pass, score 65–74 — build the unaffected phases, named fixes before the rest) · NO-GO (any gate fails, or score < 65).
Evidence rule. Every gate result and every dimension score must cite a specific line, section or artifact in the plan. A score with no citation is recorded as the minimum for that band. Assertions of intent do not count as evidence; a mechanism does. "We will be careful about X" scores as if X were absent.
| # | Gate | Passes when | Fails when |
|---|---|---|---|
| G1 | Unlawful-assistance monetization | No entity is paid-promoted in a jurisdiction where its fee practice is prohibited, and no revenue line is tied to referring veterans to unlawful fee-charging | Any paid placement, per-lead fee, or ranking boost accrues to an entity charging veterans for pre-decision claim assistance in a prohibiting state |
| G2 | Paid-placement disclosure | Each paid unit is labeled Sponsored/Ad, unavoidable, visually distinct, above or on the block; no "best/top/objective/independently ranked" framing anywhere; no first-party rating or ordering influenced by payment | Ambiguous labels ("Featured," "Partner," "Top Pick"), disclosure behind a hover or link, or any superlative/objectivity claim over a paid list |
| G3 | Third-party data licence | Google ratings/reviews/counts are live-served, never persisted; only place_id (indefinite) and lat/long (≤30 days) stored; Maps attribution present; content visually segregated; no composite blending | Any schema column, cache, warehouse table, or export holding a Google rating, review count or review text |
| G4 | Substantiated identity claims | Every badge shown to a veteran is backed by a source that actually returns that attribute | The site says "honorable discharge" while the integration behind it (ID.me, SheerID, VerifyPass, GovX) returns only affiliation |
| G5 | Review integrity | Sentiment-blind published moderation criteria applied identically to paying and non-paying firms; no incentivized reviews; insider reviews blocked; every action audit-logged | Any path by which subscription status affects whether, where, or how a review appears |
| G6 | Compensation structure | No payment to the platform contingent on retention, engagement, settlement or recovery; referral-service registration held or jurisdiction excluded where required | Per-lead or per-outcome economics live in a state with runner/capper or referral-registration exposure without counsel sign-off |
| G7 | Legal-basis prerequisites | Public ToS and privacy policy live before any identity integration; breach process documented; PII minimization stated (no SSN, no discharge documents at rest) | Identity or payment work scheduled ahead of the legal pages, or any design storing SSNs or DD-214 images |
| G8 | Directive compliance | Claim→boot→work→verify→usage→status→release; one billable per claim; gated-lane PR/chat-approve respected; documents via /api/1099/document | Post-hoc billing, duplicate sessions, auto-merge to production, or new files under public/framework/ |
A gate may be recorded PASS, FAIL, or N/A (phase not in scope). N/A is only available where the plan explicitly defers the phase behind a stated gate.
Does the plan survive a state AG civil investigative demand? Scored on: correctness of the accreditation/fee model (38 CFR 14.629, 14.636; 38 U.S.C. 5904); handling of the unaccredited-consultant question; per-state variation; awareness that the law is unsettled in both directions; whether risk is engineered out or merely disclosed.
Would a disabled veteran be better off? Scored on: free-VSO path shown before paid options; plain-language accreditation explanation; fee-rule transparency; no dark patterns; the directory answers "who should I choose" rather than "who paid us."
Can the revenue model be described to a veteran without embarrassment? Scored on: separation of payment from ranking quality signals; disclosure quality; absence of outcome-contingent economics; whether the pricing model is defensible in the most restrictive state, not the average one.
Scored on: PII minimization; correct choice among verification vendors given what each actually returns; schema honesty (no columns that cannot lawfully hold data); RLS design with read/write scope agreement; blast-radius awareness on the estate's most sensitive project.
Scored against 16 CFR Part 465 clause by clause: fake reviews, incentives, insider reviews, suppression, company-controlled-site representations; plus moderation transparency, appeal path, and audit trail.
Scored on: fit to the actual estate (Railway fedm8, Supabase oeohvlajtexuxjfrtcdb, GitHub Pages front end, gated lane); phase sizing; dependency ordering; whether external approvals sit on the critical path; whether prerequisites are surfaced or discovered late.
Claim loop, one billable per claim, usage + health band, gated-lane deploy path, documents via the API, verification evidence format.
Two-sided liquidity: is the veteran side useful before firms subscribe? Seeding strategy and its cost; willingness-to-pay evidence; churn risk if leads are thin; whether the plan states what it does not know about pricing.
| Dim | Weight | Score | Evidence cited |
|---|---|---|---|
| D1 Legal & regulatory | 20 | ||
| D2 Veteran outcome | 15 | ||
| D3 Monetization integrity | 15 | ||
| D4 Data & identity | 12 | ||
| D5 Trust & safety | 12 | ||
| D6 Delivery feasibility | 10 | ||
| D7 Directive & ops | 6 | ||
| D8 Commercial viability | 10 | ||
| Total | 100 |
Stated so the framework itself can be challenged:
Louisiana rulings signal that these state laws will fall could justifiably score D1 higher. The framework does not resolve that; it forces the position to be stated.
timing. A plan that is legally spotless and commercially pointless can score 80.
shipped product matches. G2, G3 and G5 all need re-testing against the live site before launch — the FTC and Google evaluate what renders, not what was specified.
not two. If the first three applications of this framework all land at 62–74, the bar is wrong, not the plans.