The trust layer · technical companion · mirrors FWA-PREVENTION-PLAN v1.0 + LEGAL-METABOLISM v0.1 · in review 📋

Fraud, waste, and abuse — technical

The seams table, the money controls, the law map by trigger, the governance skeleton, the monitoring cadences, the phases, and the open decisions — tracking the working plan of July 11, 2026 section by section. The plain-words page is the story; this is the machinery. Cybersecurity (authentication mechanics, keys, transport, backups) is a separate plan; the boundary and handshake are §11 below, same as in the plan.

Status labels, used strictly throughout: ★ BUILT — exists in tested code or a published register today · ▲ DESIGNED — specified in the plan, phased, not yet running · ◇ PROPOSED — awaiting the founder's ruling or counsel · 📋 — legal statement cited from knowledge, pending primary-source verification; nothing on this page is legal advice.

§1 · Architecture as controls

The plan's first move is an audit claim: most of an enterprise FWA program exists here as design facts. Each row is checkable — diligence verifies it.

Enterprise FWA controlKISOP controlStatus
Access monitoring & DLPDeny-by-default consent gate; exact-match grants (a grant of class G admits only class G); one append-only log line per access; fail-closed if the log can't be written★ BUILT — pna-mcp, 268 tests incl. 90-test independent adversarial suite
Insider-snooping detectionThe owner reads their own complete access log; C0 (sealed) is absent in text and shape — even to emergency access★ BUILT
Central-breach exposureArchives are person-held at the person's chosen rung (binder → laptop → reference build → hardened). No central archive exists.★ BUILT (doctrine + running v1)
Segregation of duties on fundsMoney movement is a blocking human gate: funder pledges, named job owner releases; escrow at an independent fiscal host▲ DESIGNED — jobs board rules v1, pre-launch
Anti-embezzlement (platform float)Circle settlement is integer-cent, person-to-person, through_kisop:false. The platform never holds a dollar★ BUILT — 143-test exchange engine
Expense transparencyOpen registers: budgets, compliance, provenance are public surfaces▲ DESIGNED — Trust page live, registers fill at launch
Records retention & tamper-evidenceSupersede with version chains; nothing is ever deleted; provenance on every item; scheduled hash verification (pna verify)★ BUILT
Anti-dark-patternsTime-in-app counts as an anti-metric. No engagement economy exists here.★ BUILT (by absence, stated in the PRD)
Vendor lock-in abuseKISOP-compatible clause 5: the archive stays fully usable when any tool is uninstalled or unpaid▲ DESIGNED — conformance test of the open standard
Scam-contact surfaceSharing is pairing-gated, known-people-only; circle invites are blind; envelopes are utterance-only. A consented sentence travels. The calendar never leaves the archive★ BUILT — sharing rail + circles, 400-test suite
Background screeningT0–T4 ladder: no screening at application; FCRA-compliant checks at trust roles; individualized assessment; no credit checks ever▲ DESIGNED — Screening Policy v1.0, counsel-pending
Human-in-the-loopGold gates (named human, blocking) on consent, money, publishing, clinical; purple review (logged, append-only) on all agent output★ BUILT as doctrine; enforced at the gate where wired

The inversion: ordinary platforms centralize data and buy fraud detection to guard the pile. KISOP holds no pile. Monitoring runs member-side (§8), and the platform sees only seam metadata. That is the control.

§2 · Who we protect, from what

ParticipantDominant FWA exposurePrimary defense
Archive ownerIdentity theft (classic + medical), scams, coerced consent, record tamperingIdentity spine §3; gate + provenance; duress-aware design §6
Seniors / people in declineDelegate financial exploitation, undue influence over grantsTrusted second contact; decline-mode second eyes; mandated-reporter SOP
Minors & teensGuardian overreach; the majority-transfer seamGraduated consent; transfer ritual; COPPA/FERPA posture §9
Caregivers / People CircleScapegoating; scope-creep accusationsVerb+partition-scoped grants; the log protects the delegate too
Community HelpersImpersonation; false credential or scope claims; kickback-shaped compensationHelper register + credential labels §3.4; session evidence trail; compensation rules §4
Solution CentersFunds-touching fraud; accidental-franchise exposureT4 dual signoff; open budgets; franchise-or-not counsel item
Circle membersOrganizer/shopper theft, receipt inflation, no-showsFormation controls (built): blind invite, all-ack-or-cancel, verified savings, local-C1 vouch
Funders (backers, donors, sponsors, government)Non-delivery, diversion, double-funding, sybil pledgesEscrow + milestones + open registers; Other-Support controls §4
BuildersRigged selection; others' self-dealingPublic selection rationale; no-self-dealing rule
Clinicians / credentialed verifiersCredential spoofing; registry liabilityPrimary-source license verification (T2); verified-as-of stamps
Researchers / the commons (C4)Fabricated cohorts; re-identification scandalC4 grant terms; de-id standards; no-re-identification covenant §6
AI agentsPoisoned inputs; blame without logsAgents propose and people decide; review gates; derived+AI-generated provenance marks
The ecosystem (from us)Platform self-dealing; charter betrayal; family-COI opticsPublished promises = FTC-enforceable §4; COI firewall; open registers

§3 · The identity spine — the seams table

Design premise: identity assurance is proportional to what the identity unlocks, asserted at seams. An empty archive you fill with your own life is worth nothing to steal — so enrollment stays nearly frictionless, and proof concentrates where a claim touches someone else's data, money, or trust. Knowledge-based authentication is banned permanently, because a thief can already find the answers in breached data. Higher tiers use document + liveness proofing per NIST SP 800-63A concepts (rev 4 📋), or identity-by-relationship: pairing and vouching among people who already know each other.

SeamWhat a false identity getsControl todayHardeningPhase
Enrollment (T0)An empty archive; a waitlist slotEmail verification + the human sentenceNothing more, by design — more proof at this step would break the thesis—
Pairing (sharing rail)A channel to one person★ Known-people-only; pairing secrets; dup-secret defect fixedPairing-hygiene page ("pair in person or by a voice you recognize")0
People Circle grant (C3)Another person's partitions★ Blocking gate; scope in plain language; loggedFirst-grantee confirmation ritual; genetic-info warning on Family-History shares1
Emergency (ICE) invocationThe pre-consented slice; C0 excluded even here★ Pre-consent + identified invoker + after-noticeAfter-notice to a second circle member; 100% break-glass audit1
Executor mode (death)The archive, per the person's designation▲ DesignedDeath-certificate + instrument verification; RUFADAA mapping — the in-tool designation is the Act's "online tool," which takes precedence over the will 📋1–2
Minor → majority transferA whole childhood record▲ Graduated-consent designTransfer ritual verifying the teen-now-adult; the guardian cannot stand in2
Host certification (T3)A trusted seat beside vulnerable people▲ Screening ladder v1.0Public Host register + ID codes; LEIE/SAM exclusion screening once federal dollars flow1–2
Host session startA living room▲ Scoped session accessMember-side verify-your-Host code match before first session1
Circle join / organizer / shopperNeighbors' money (bounded)★ Blind invite; all-ack-or-cancel; local-C1 vouch; no-show completionSmall-and-local first runs (norms); organizer rotation default0
Funded-job builder selectionCommunity escrow▲ Job-owner gatePublished selection rationale; no-self-dealing rule0–1
Pledge / donationA laundering or chargeback vector▲ Fiscal-host railsDocumented reliance on host KYC/AML; structuring-pattern eyes on open registers1
Benefits assistance (P7)A beneficiary's programs▲ Human-beside-human flowHosts never handle credentials. Training and member education both teach the rule.1
Research consent (C4)A cohort seat▲ Class-scoped grantsFounder-authored consent strings; IRB posture before first study2
Registry contributionThe commons' trustworthiness▲ Publication gate + named ownerPrimary-source credential verification; verified-as-of stamps1
ACCESS attributionMedicare moneyNot yet liveRides American Care's enrollment integrity; KISOP-side COI firewall2

§3.3 · Medical identity theft — detection and recovery mechanics

Right-of-access supply lines (45 CFR 164.524 + information-blocking rules 📋) pull institutional records to the person, where a local agent diffs them against lived reality. The recovery runbook, with its legal instruments named:

1

Detect — local watchdog flags the foreign entry: an EOB line, portal record, or collection notice that doesn't match the archive's timeline.

2

Preserve — the archive is the evidence locker: provenance chain + append-only log make the person's own timeline credible.

3

Report — FTC IdentityTheft.gov affidavit; police report; provider and payer SIU letters (template pack, EN/ES).

4

Correct — HIPAA amendment requests (45 CFR 164.526) to each record holder; accounting-of-disclosures requests (164.528); credit-side FCRA §605B blocks, fraud alerts, freezes 📋.

5

Follow — stale-marking on each open correction until closed; the countdown pattern from Action Plans applies as-is.

§3.4 · Anti-impersonation mechanics

§4 · Fraud — the money seams

SeamThreatsControls
Community funds (jobs board)Sybil pledge-farming; stolen-card pledges → chargebacks; builder non-delivery; rigged selection; self-dealing; wash-fundingCustody at the fiscal host (their KYC, card-network, chargeback machinery — the reliance is documented; we build none of it ourselves); escrow + milestone release behind the job-owner gate; open register of every pledge and release; no-self-dealing rule (owner ≠ builder, ever — staff who build community jobs go through the same public selection as everyone else); published stall policy: time-boxed → re-bid or refund
Buying circlesOrganizer/shopper theft; receipt inflation; no-showsThe no-cut design (through_kisop:false) keeps money outside the platform, which may avoid money-transmitter licensing 📋 and prevents platform embezzlement. It also limits remediation: we cannot claw back money we never held. Controls at formation include known people, blind invites, all-ack-or-cancel, savings arithmetic verified against real prices, receipts with provenance, local-C1 vouching, and organizer rotation. Counsel must review warehouse-club membership terms before any pilot
Hosts & sessionsGhost sessions; comp that drifts into kickbacks; steeringSession notes deposited to the member's archive with consent = member-confirmed evidence; the content never leaves the archive; comp rules fixed before the first paid Host: flat fair-market session rates, and pay never varies with referrals, enrollment, or vendor choice; Benefits Finder results are compensation-blind (the Anti-Kickback posture and the trust posture are the same sentence); sponsors buy capabilities-for-everyone; steerage is never for sale
Government moneyFalse certifications; double-funding; unallowable costs; exclusion violations; beneficiary inducementsSBIR: truthful eligibility/effort certifications; Other-Support disclosure with a written scope line between Kickstarter-funded and SBIR-funded work (the classic small-award False Claims case, pre-empted); allowable-cost books from day one. ACCESS (Jan 2027, via the American Care lane): participation-agreement program-integrity terms verified against the RFA; monthly OIG LEIE + GSA SAM exclusion screening; CMS-style FWA training in that flow; CMP beneficiary-inducement analysis (nominal-value ~$15/$75 limits; promotes-access and financial-need exceptions) 📋
Donations & crowdfundingNon-delivery claims; laundering; unregistered solicitationKickstarter posture: use funds as represented or refund/account publicly (the FTC's first crowdfunding case set the rule 📋); state charitable-solicitation registration before any fiscal-sponsorship ask; written sponsorship agreement; reliance on fiscal-host KYC/AML documented; structuring-pattern eyes on the registers
The platform itselfSelf-dealing; charter betrayal; family conflictsPublished promises may create FTC Act §5 exposure if broken; dual signoff on community-adjacent spending (T4); open budget register; a standing conflict register covering the founder's brother/American Care (written exclusion from DUA negotiation and an arm's-length FMV services agreement), Kurt/platform work (two-gate reconciliation routed to the founder), and bounded lanes for family hires

§5 · Waste — community-funds definition

Waste classControlPlain note
Duplicate buildsSearch-what-exists before any funded job starts (feature table + registers)Live example, named: two consent-gate implementations exist today; reconciliation is a scheduled checkpoint decision
Stalled funded jobsPublished stall policy — time-boxed, then re-bid or refundEscrowed money sleeping is waste; policy makes it a published process
Storage & infrastructurePerson-held archives — near-zero platform storage by designEvery proposal to centralize data adds storage cost and breach risk
Verification economicsAI drafts (~1 hr), credentialed human verifies — the paid work is judgmentThe published ratio is the waste control and the government-sponsorship argument
Grant allowabilitySBIR cost accounting from day oneUnallowable spend converts to fraud at the next progress report
Over-verification frictionNo screening at T0–T1; no identity proofing at the doorWasted reviewer hours and a thesis violation at once
Hidden overheadPlatform/fiscal-host fee stated on every funded jobOverhead hidden is overhead abused

§6 · Abuse — of people, through the system

PatternDesign answerStatus
Delegate / elder financial exploitationScope minimization stated at grant time (appointments never require Finances); trusted-second-contact designation (the FINRA 2165 pattern 📋); decline-mode second eyes — consent changes notify a second circle member when supported decision-making is active; Host training + state mandated-reporter SOP (Florida's duty is universal — any person; California names care custodians incl. financial abuse 📋)▲ Phase 1
Coerced access / intimate-partner surveillanceTraceless grant re-review (revocation review leaves no trace visible to the grantee); revocation-notification designed not to escalate (batched/naturalized); safety-planning resources at the grant surface; Hosts trained to spot third-party-controlled archives; built with DV-advocacy input▲ Phase 1, before People-Circle grants are widespread
Insider snoopingNo member archives held → enterprise-scale snooping structurally impossible; the gate's owner special-case reaches the founder's own archive only. No operator backdoor into anyone else's exists; keep that sentence true forever; when HIPAA attaches, 42 U.S.C. 1320d-6 criminal tiers apply and sanction policy + training become mandatory 📋★ structural today; ▲ BA-grade internals Phase 2
Sponsor / enterprise abuseNo sponsor ever gets exclusivity (charter red line, written into the enterprise proposal as a clause); no sponsor ever sees member data; the KISOP-compatible mark license forbids exclusivity, data hostage-taking, and privacy violation — violation = termination + public register entry◇ mark-license design is a counsel item
Data abuse (secondary use, re-identification, discrimination)Exact-match consent (nothing leaks upward); C4 grants carry de-identification standards (expert-determination vs safe-harbor, 45 CFR 164.514 📋) + a no-re-identification covenant with published sanction; GINA-aware share warnings on Family-History partitions toward employment/insurance-adjacent recipients 📋★ exact-match built; ▲ C4 terms Phase 2
Agent abuseAgents propose. They never decide (blocking gates); all output logged + reviewed append-only; derived/AI-generated provenance marks; document-borne injection is on the standing attack list — the consequence rule here: no agent output becomes a record without a review gate, so a poisoned document cannot commit fraud alone★ doctrine + gate; injection hardening tracked on the attack list

§7 · Governance — OIG's seven elements, community-sized

Element (OIG GCPG 2023 📋)Here
1 · Written standardsCharter + the FWA plan + Community Guidelines + Screening Policy + Terms (incl. §15 safe harbor) — published in the open compliance register; the standards are themselves public
2 · Named ownerIntegrity sits with the founder now; moves to a named board seat when there is a board. All family conflicts route around the owner via the standing COI register — the integrity owner is never inside a conflicted transaction
3 · TrainingHost certification includes FWA + scam recognition + mandated reporting + the "never ask" doctrine. The bigger lever: member education — the scam-awareness kit makes members the sensor network
4 · Open linesThe support phone number also serves as the fraud line. Anonymous reports are accepted; non-retaliation is written; every report is logged and answered
5 · Monitoring & auditing§8 — designed to respect the architecture (member-side detection, seam-level review)
6 · Enforcement & disciplinePublished sanctions ladder ◇: members — education first, removal only for cause with due process (a record is one chapter of a person's story — at exit too); Hosts — retraining → suspension → decertification on the register; builders — selection ban; sponsors/tools — mark termination + register entry; staff — sanction policy per counsel (mandatory once HIPAA attaches)
7 · Response & preventionIncident playbooks as runbooks: identity-theft recovery (§3.3), elder-exploitation response (report/protect/preserve/APS), coerced-access response (safety-first, DV-informed), funds incident (freeze via fiscal host + public register note), breach duties (the HBNR clock, §9). Every incident ends with a one-page "what changed" register entry. Annual risk assessment re-walks §2 and §3

§8 · Monitoring that respects the architecture

The rule: detection runs where the data lives. The platform cannot mine member archives, because by design it cannot see them.

Member-side (the local watchdog — a community-fundable job)

Seam-level (all the platform may see)

CadenceWhat
100%Break-glass invocations reviewed (they should be rare)
MonthlyFast-mover legal watchlist; LEIE/SAM exclusion runs once federal money flows
QuarterlyRegisters walk + sample of Host sessions confirmed against member-side evidence; legal-framework refresh agents re-walk sources
AnnuallyFWA risk assessment; full legal re-verification (retainers); stale-mark audit (stale >1 yr → fund-or-retire); plan re-versioned; the old version is never overwritten

Every audit is written to the compliance register with a date and a named reviewer.

§9 · The law map, by trigger

Register status: every row below is 📋 — based on working knowledge and pending primary-source verification, including a quotation and fetch date for each framework, plus counsel review of the highest-impact rows. This describes the plan's legal analysis; it is not legal advice. The verification queue appears at the end of the page.

§9.1 · Duties that attach to Care Delivery Inc

TriggerLaw / ruleThe duty, one line
Offering consumer Personal Neutral Archive (PNA) tools at allFTC Act §5 (UDAP)Keep every published promise or it is a deceptive practice — the post-GoodRx enforcement era reaches health promises
SameFTC Health Breach Notification Rule (16 CFR 318, as amended 2024)As a likely "vendor of personal health records" for hosted rails: unauthorized acquisition or disclosure = breach → individuals ≤60 days, FTC within 10 business days if ≥500. The truly person-held archive may sit outside "vendor" — posture memo for counsel; operate as covered meanwhile
Serving California membersCMIA, Cal. Civ. Code §56.06(b)Consumer software managing medical information makes the business a "provider of health care" under CMIA — full duties + private right of action. Likely the most directly-attaching consumer-lane law
SameCCPA/CPRA sensitive-data rulesNotice, purpose limits, SPI rights
WA members / marketingWashington My Health My Data (RCW 19.373)Consent for collection/sharing beyond necessity; authorization for sale; private right of action
NY membersNY Health Information Privacy Act (2025)Broad processing-consent regime — verify current status 🔎
Members in other statesCO/CT/VA/TX/OR/MT + 2026-effective laws; NV SB 370Maintain the state matrix as a living framework 🔎
Any breach50-state breach-notification lawsParallel state clocks beside HBNR
Becoming a Business Associate (enterprise/ACCESS roles)HIPAA Privacy/Security/Breach + HITECH; criminal 42 U.S.C. 1320d-6BAA duties, minimum necessary, sanction policy, breach notification; criminal tiers for workforce snooping/selling
Members pulling their own recordsHIPAA right of access (164.524) + Cures info-blocking (45 CFR 171)Duties sit on providers/HIEs/HIT developers — this asymmetry is the PNA's legal foundation; we become an "actor" only if we operate exchange infrastructure
SUD-program records in flows we operate42 CFR Part 2Person-held is the person's right; intermediary/lawful-holder duties flagged before any Part 2-sourced integration
Screening Hosts/staffFCRA + fair-chance laws + state limitsGoverned by Screening Policy v1.0 (standalone)
Paying Hosts / Benefits Finder / referrals, once federal-program business existsAnti-Kickback Statute (42 U.S.C. 1320a-7b(b))No remuneration to induce federal-program referrals; comp design per §4; safe harbors papered (personal-services FMV; value-based care-coordination)
Free/discounted things to Medicare/Medicaid beneficiariesCMP beneficiary-inducement (42 U.S.C. 1320a-7a(a)(5))Nominal-value limits (~$15 / $75 aggregate) unless promotes-access or financial-need exceptions fit — counsel before ACCESS-lane perks
Physician arrangements (later)Stark (42 U.S.C. 1395nn)Peripheral now; screen any future clinician comp
Lab/SUD-facility arrangements (if ever)EKRA (18 U.S.C. 220)Broader than AKS, includes private pay — flag-only
SBIR application & awardFalse Claims Act (31 U.S.C. 3729) + NIH policy + 42 CFR 93 + FAR-based cost principlesTruthful certifications, Other Support, real effort, allowable costs, misconduct process
ACCESS participation (via American Care)CMS Innovation Center participation agreement + program-integrity rules + exclusion authorities (42 U.S.C. 1320a-7)Records access, reporting, beneficiary protections, marketing rules; monthly LEIE/SAM screening; RFA program-integrity section read is queued
Retaining any federal overpaymentACA 60-day rule (42 U.S.C. 1320a-7k(d))Identified overpayments returned in 60 days or reverse-false-claim exposure
Kickstarter campaignFTC Act §5 (crowdfunding precedent) + platform ToS + state UDAPUse funds as represented; deliver or refund/account publicly
Soliciting donations (fiscal-sponsorship route)State charitable-solicitation registration (~40 states) + IRS private-benefit rulesRegister before soliciting; written sponsorship agreement; no inurement — family relationships noted
Membership auto-renewalROSCA (15 U.S.C. 8403) + state auto-renewal lawsClear terms, express consent, easy cancel; the FTC click-to-cancel rule was vacated on appeal (2025) — ROSCA + states still bite 🔎
Reminder texts/callsTCPA (47 U.S.C. 227) + CAN-SPAMPrior express consent with records; healthcare-exemption fit verified before use
Under-13 usersCOPPA (16 CFR 312, 2025 amendments)Verifiable parental consent, retention limits; graduated-consent design maps well; school-authorization path verified 🔎
Hosts in schoolsFERPA + state student-privacy (e.g., SOPIPA)Education records stay in the school lane. Nothing commingles without consent.
Serving vulnerable adultsState APS mandatory reporting (FL universal; CA care-custodian incl. financial abuse) + Elder Justice Act contextMandated-reporter matrix + SOP before the first senior-serving Host — FL and CA first
Executor mode / deathRUFADAA (~47 states)The in-tool designation is the Act's "online tool," taking precedence over the will — align records so the designation is provable
Accepting POA/guardianshipState POA/guardianship law (UPOAA pattern)Valid-instrument verification SOP
Circles' money mechanicsState money-transmitter laws / BSAStay out of the flow of funds (built); boundary memo so no future feature crosses it 🔎
Solution Center expansionFTC Franchise Rule + state franchise lawsMark + significant assistance + fee may create an accidental franchise and FDD duties; counsel must distinguish a mark license from a franchise
Legal/jurisdiction registryState UPL rulesInformation-vs-advice line; credentialed authorship + verification
EU members (Spain first)GDPR (Art 9; Chapter V) + EU AI Act + Spain AEPDExplicit-consent basis; residency answered by in-country archive deployment; AI-Act classification review before EU launch 🔎

§9.2 · Laws protecting participants — operationalized as product

§9.3 · Frameworks adopted voluntarily

None of these frameworks is law for us. We adopt them anyway, because they harden the seams.

§10 · The legal metabolism — how the map stays alive

The law map above is a snapshot; the metabolism is the machine that keeps every snapshot current, across jurisdictions. Seven organs, all assembled from parts that already exist here:

OrganMechanics
1 · SensePer-framework watch specs (primary sources, cadence, change definition); scheduled refresh agents — quarterly baseline, monthly fast-movers; human sensors (credentialed members, Hosts) with a visible flag route; trackers and firm alerts are tips; only primary sources enter the register
2 · TriageMateriality gate against the §9.1 trigger table: which duties, seams, runbooks, consent strings, pages — plus the effective date. Severity: 🔴 operate-blocking (handled before the effective date, company fast lane) · 🟠 lane-gating (resolved before that feature/geography advances; outer bound one quarter ◇) · 🟢 routine (next quarterly cycle). Patch management, for law
3 · VerifyAgent drafts the diff — verbatim quote, fetch date, plain-English restatement; a credentialed owner verifies (the paid work is judgment); verified-as-of stamps; bar/license provenance on authors; UPL line held everywhere
4 · FundChange-triggered update jobs + annual verification retainers per jurisdiction page + sponsors (governments funding their own jurisdiction's page; diaspora; market-entry). Failure mode is in the open: an unfunded page goes visibly stale. It is never silently wrong
5 · DisseminateOne verified change → five surfaces: public register diff · plain-words "what changed where you live" EN/ES with term IDs (a Tampa member gets the Florida sentence) · re-versioned job aids and glossary strips, print included · Host training deltas — the human last mile · new legal terms into the terms registry
6 · ImplementThe published change cycle with a statutory deadline: runbook version bump → consent-string revision (always a blocking human gate) → mechanical enforcement changes as build jobs (🔴 rides the company fast lane; the crowdfund queue never carries it) → acceptance tests re-run → training → publication-gate go-live. Effective-dated versions sit beside each other — the never-overwrite rule matches how statutes actually work
7 · PropagateMark-license holders inherit material changes: the register diff is the notice; material-change re-attestation is the license clause ◇ (counsel designs it)

Two registers, one metabolism: the inward obligations register (our duties: company cost, always; a platform that crowdfunds its own compliance has abdicated it) and the outward Law & Jurisdiction Registry (the commons: community-funded, stale-marking as its trust metric). Jurisdiction is first-class: duties attach by member geography on the regions/counties spine, and company HQ has no bearing; cross-jurisdiction surfaces default to the most protective participant's rule ◇ (counsel per seam); data-location law is answered by in-country archive deployment, conduct law by the registry; "no page, no launch" ◇: a new geography opens with its verified jurisdiction page, funded by its market-entry sponsor.

§11 · Phases, and the cyber boundary

PhaseWindowThe work (owners: founder / counsel / verification session / build job / infra)
0 — before public launchnow → launch"Never ask" page EN/ES (launch-blocking candidate) · counsel index worked in priority order · HBNR + CMIA posture memo · Kickstarter disclosure block · charitable-solicitation check (slow, start early) · no-self-dealing + stall policy in jobs-board rules v1 · circle-landing safety language · RUFADAA alignment note · the §9 verification sweep → framework folders
1 — first paid trust roles, SBIR window, circles at scalefall 2026Seam hardening marked Phase 1 (§3.2): grant-confirmation ritual, Host register + codes, second-contact after-notices, pairing hygiene · trusted-second-contact + decline-mode second eyes · duress-aware UX review with DV-advocacy input · Host comp rules + compensation-blind Benefits Finder into agreements · SBIR integrity setup on award (cost books, effort, Other-Support memo) · mandated-reporter matrix + APS SOP (FL/CA first) · member-side watchdog v0 (rendering the existing log) · fiscal-host reliance memo · incident playbooks v1
2 — ACCESS live + enterprise pilot2027Medicare program-integrity package (RFA-verified register, monthly LEIE/SAM, CMS-style training, CMP/AKS sign-off on comp + perks) · COI firewall documented + auditable in the open register · BA-grade internals when HIPAA attaches (sanction policy, minimum-necessary, 1320d-6 training) — coordinated with the cyber plan's Security Rule work · mark-license FWA clauses live with first ecosystem tools · first annual risk assessment → plan v2.0 beside v1.0; v1.0 is never overwritten

The boundary and the handshake

Cyber owns: authentication mechanics and credential storage, key custody, transport, endpoint/server hardening, backup/restore, log-integrity machinery, network binding of the gate, injection-attack mechanics, availability. This plan owns: identity proofing and assurance policy, authorization policy, money integrity, human-trust abuse, program-fund compliance, sanctions, redress, victim recovery. The handshake: proofed identity (here) hands off to authenticated sessions (cyber) · break-glass policy (here) rides break-glass implementation (cyber) · logs are written by cyber's machinery and reviewed here on §8's cadences · adversarial findings flow both ways — the gate's owner-spoof and timing-compare findings were cyber-shaped; their FWA consequence (impersonation risk) landed in §3. Joint review at each annual assessment.

§12 · Open decisions — all ◇, all the founder's

Where this stands, and what to verify next

This page mirrors FWA-PREVENTION-PLAN v1.0 and LEGAL-METABOLISM v0.1 (both July 11, 2026) — working drafts for counsel. No certification exists. Status labels are per-row; Carmen's review of both documents and this page is pending, and the two ◇-heavy sections ship only on her rulings.

The verification queue (next session-class work): every 📋/🔎 row in §9 → primary source + verbatim quote + fetch date into per-framework folders; the ACCESS RFA program-integrity section read; HBNR/CMIA/MHMD applicability memos with counsel; 2026-effective state privacy laws; COPPA compliance dates; NY HIPA status; the Negative-Option-Rule aftermath; NIST 800-63-4 final status; EU AI Act health-AI classification timeline.

Argue with this plan. If you can name a seam we missed, a control that fails under pressure, or a law row that's wrong, that's exactly the review this page exists to invite: on the main site, Write to us → "feedback," or Write to us → "security" for good-faith testing under the Terms §15 safe harbor.