Owned-Property Compliance Audit — Affiliate Disclosure & Privacy

Owner: Bill Rice (BRC LLC d/b/a Bill Rice Strategy Group) Version: v1.0 — 2026-06-25 Audit date: 2026-06-25 Scope: All BRSG-owned web properties. Two checks per property: (A1) affiliate / material-connection disclosure against the Affiliate & Sponsorship Disclosure Standard and FTC 16 CFR Part 255; (A3) privacy policy presence and CCPA/CPRA coverage. Method: live fetch of each homepage plus common legal paths (/privacy, /privacy-policy, /disclosure, /affiliate-disclosure, /terms). Article-level deep crawl was not performed; findings are at the site/template level.

1. Headline finding

The affiliate-disclosure posture is, on balance, healthier than expected — most content hubs already carry a disclosure, and one property (agedleadsales.com) is an exemplary FTC pattern. The material, systemic exposure is privacy. Five of seven live properties collect personal information through active forms while serving no working privacy policy. That is the priority remediation, ahead of the affiliate-disclosure refinements.

Two properties carry a true point-zero affiliate gap: howtoworkleads.com (no disclosure at all while funneling to a commonly-owned vendor) and, secondarily, proinvestorhub.com (a single blanket line, no dedicated page, no footer coverage).

2. A1 — Affiliate & material-connection disclosure

Remediation (A1)

P0 — howtoworkleads.com. Every CTA routes to AgedLeadStore (a commonly-owned BRSG property) with tracking parameters, and there is no disclosure of the common-ownership / material connection anywhere on the site. Add a clear, conspicuous material-connection disclosure proximate to the CTAs (e.g., "AgedLeadStore is a Bill Rice Strategy Group company") plus a standing footer line and a dedicated disclosure page. This mirrors the founder-role disclosure already used well on agedleadsales.com.

P1 — proinvestorhub.com. Promote the single /lenders blanket line into: (a) a site-wide footer disclosure, (b) a dedicated affiliate-disclosure page, and (c) per-lender flagging of which listings are paid. The current "each affiliate relationship is always disclosed" claim is not borne out by per-link labeling.

P2 — proximity polish (crypto, self-employed). Both have solid dedicated pages but rely on footer/separate-page placement on comparison content. Add an article/listing-level disclosure banner at the top of any page carrying affiliate links or a lender table, per Affiliate Standard § 3.1 (proximate).

P3 — billricestrategy.com. The "Outbounder" partner mention should carry a one-line disclosure if any material connection exists. Low urgency given the services-based model.

3. A3 — Privacy policy & CCPA/CPRA

Remediation (A3)

P0 — publish a privacy policy on every live property that collects PII. Affected now: billricestrategy.com, proinvestorhub.com, selfemployedlendinghub.com, verifiedvector.com (none exist) and howtoworkleads.com (links exist but 404). Each policy must carry the elements in the Privacy Policy & CCPA Standard: categories of personal information collected, categories of third parties it is shared with, a Do-Not-Sell/Share mechanism (or an explicit no-sale/no-share statement that addresses cross-context behavioral advertising), a privacy contact, and a CCPA/CPRA consumer-rights section. Link it site-wide in the footer.

• proinvestorhub.com carries added urgency: its "Find Your Lender" flow may transfer consumer data to lenders for value, which can constitute a "sale" or "share" under CPRA — making the missing Do-Not-Sell/Share mechanism a direct exposure, not a formality.
• verifiedvector.com also needs a notice-at-collection directly beneath the lead form's submit button (CPRA requires notice at or before the point of collection).
• howtoworkleads.com must also fix the dead Terms-of-Service link.

P1 — cryptolendinghub.com. Add a California/CCPA-CPRA consumer-rights section and a Do-Not-Sell/Share statement (its Google Analytics use can constitute "sharing" under CPRA even with no monetary sale). Add data-retention periods and a physical contact address.

P2 — agedleadsales.com. Verify the footer link points to /privacy (the /privacy-policy slug 404s and should not be referenced). Add the explicit cross-context-behavioral-advertising opt-out language to tighten CPRA alignment.

4. Cross-cutting observations

• Templated fix opportunity. The BRSG content hubs share a Next.js + Sanity stack. A single privacy-policy page component and a footer disclosure component, deployed across the fleet, closes most of the privacy gap and the affiliate-footer gap in one pass rather than site-by-site.
• TCPA exposure is currently low. No audited form collects a phone number, which keeps TCPA/consent risk minimal. If any lead form adds a phone field, express-written-consent language at the submit becomes mandatory (see the planned TCPA/Lead Consent Standard).
• demoleadgen.com is an undeployed Vercel domain. No action until it is built; re-audit at launch.

5. Action register (carry into the program tracker)

Version History