# 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.

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## 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).

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## 2. A1 — Affiliate & material-connection disclosure

| Property | Affiliate activity | Disclosure present | Verdict |
|---|---|---|---|
| agedleadsales.com | Promotes lead providers + AgedLeadStore | Dedicated page + in-context labels + **founder-role disclosure** | **Strong / exemplary** |
| selfemployedlendinghub.com | Lender directory + product recs | Dedicated page (uses `rel="sponsored"`, RESPA § 8 carve-out) | **Adequate** — proximity gap |
| cryptolendinghub.com | Platform reviews/comparisons | Footer line + dedicated `/affiliate-disclosure` page | **Adequate** — proximity gap |
| proinvestorhub.com | Lender directory, ratings, comparison | One blanket line on `/lenders` only | **Needs work** |
| howtoworkleads.com | Funnels all CTAs to AgedLeadStore (commonly owned) | **None** | **Fail — P0** |
| billricestrategy.com | Sells own services; one "Outbounder" partner mention | **None** | **Minor** (low risk) |
| verifiedvector.com | Sells own services; showcases own sites | Self-ownership stated in copy | **Pass** (low risk) |
| demoleadgen.com | — | — | Unbuilt (no deployment) |

### 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.

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## 3. A3 — Privacy policy & CCPA/CPRA

| Property | Collects PII | Privacy policy | Verdict |
|---|---|---|---|
| agedleadsales.com | Email (newsletter) | Live at `/privacy`; CCPA rights stated; "we do not sell" | **Pass** — minor polish |
| cryptolendinghub.com | Email + analytics | Live at `/privacy-policy`; names processors | **Needs work** — no CCPA rights section, no Do-Not-Sell/Share link |
| billricestrategy.com | Email + multiple lead flows | **None** (`/privacy` 404) | **Fail — P0** |
| proinvestorhub.com | Email + lender lead routing | **None** (`/privacy` 404) | **Fail — P0** |
| selfemployedlendinghub.com | Email + gated lead magnet | **None** (`/privacy` 404) | **Fail — P0** |
| verifiedvector.com | Lead intake form (name/email/company) | **None**; no notice-at-collection on form | **Fail — P0** |
| howtoworkleads.com | Email + gated downloads | **Broken** — footer links to `/privacy-policy` and `/terms-of-service`, both 404 | **Fail — P0** |
| demoleadgen.com | — | — | Unbuilt |

### 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.

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## 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.

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## 5. Action register (carry into the program tracker)

| ID | Action | Priority |
|---|---|---|
| A1-1 | howtoworkleads.com — add material-connection / common-ownership disclosure + footer + dedicated page | P0 |
| A1-2 | proinvestorhub.com — site-wide footer disclosure, dedicated page, per-lender paid flagging | P1 |
| A1-3 | crypto + self-employed — add proximate article/listing-level disclosure banner | P2 |
| A1-4 | billricestrategy.com — disclose Outbounder partner mention if material | P3 |
| A3-1 | Publish privacy policy on billricestrategy, proinvestorhub, selfemployedlendinghub, verifiedvector | P0 |
| A3-2 | howtoworkleads.com — publish real privacy policy + Terms (fix dead footer links) | P0 |
| A3-3 | proinvestorhub.com — Do-Not-Sell/Share mechanism for lender lead routing | P0 |
| A3-4 | verifiedvector.com — notice-at-collection beneath lead form submit | P1 |
| A3-5 | cryptolendinghub.com — add CCPA rights section + Do-Not-Sell/Share + retention | P1 |
| A3-6 | agedleadsales.com — footer link cleanup + CPRA sharing language | P2 |

## Version History

| Version | Date | Change |
|---|---|---|
| v1.0 | 2026-06-25 | Initial audit of all owned properties — affiliate disclosure (A1) and privacy/CCPA (A3). |