Affiliate & Structural Compliance

SDC Affiliate & Structural Compliance

Split 2026-08-27 from MBR/Mktg/Affiliate-Mechanics.md — that note mixed revenue mechanics (moved to SDC/Offerings/Advisor-Firm-Pricing.md) with compliance guardrails (this file). This half matters more for SDC than it did for MBR: leverage is the regulated, controversial topic, not an adjacent retail-banking referral.

The structural rule that keeps the business unlicensed

SDC operates as a software facilitation and mathematical-analysis provider, never as a licensed advisor, broker, or dealer. This is the single most important compliance guardrail in the business — carried over verbatim from MBR’s framing because the underlying regulatory logic is the same, just higher-stakes for leverage.

To scale without direct financial licensing, SDC must avoid operations requiring human-to-human regulated advice. SDC provides software facilitation and mathematical analysis — the client-first $MART DEBT framework and LevPro’s calculations — not investment or lending advice.

Jurisdiction — unresolved, do not assume

MBR’s compliance guardrails (FCAC, PIPEDA, CRA) are Canadian retail-banking rules. SDC’s own ROADMAP.md states the target market is ~100% U.S. financial advisors, ~0% direct-to-investor. This means:

The MBR guardrails below are preserved as precedent and structure, not as SDC’s actual compliance regime.
U.S. equivalents (SEC, FINRA, state-level investment-adviser rules) have not been researched. Do not cite FCAC/PIPEDA/CRA as governing SDC’s U.S. advisor-facing activity — that would be exactly the kind of unverified claim the vault’s “never guess” rule exists to prevent.
This is named as open research in SDC/Risks/JOB_DESCRIPTION.md UPGRADES.

MBR guardrails (preserved as structure/precedent only)

FCAC-style consolidated disclosure standard: marketing copy must accurately reflect live rates/terms; no stale or misleading figures.
PIPEDA-style consent standard: explicit, unbundled consent before any user/client data is transmitted to a third party.
CRA-style charitable routing: if SDC ever routes a portion of fees to a charitable pledge (as Cancer50Pledge does), use a split-payment processor so the donor/client receives their own tax receipt directly — avoids corporate tax-auditing issues.

Additional SDC-specific constraint (from `SDC/Risks/JOB_DESCRIPTION.md`)

No forcing or coercive behavioural/marketing mechanism may be applied to any risk-magnifying leverage strategy — objective, client-first disclosure only. This is stricter than anything in MBR’s guardrails and takes precedence wherever the two would conflict.

SDC/Offerings/Advisor-Firm-Pricing.md — revenue mechanics (the other half of the original MBR note)
SDC/Risks/JOB_DESCRIPTION.md — the core risk-tiering constraint
MBR/Mktg/Affiliate-Mechanics.md — source material, full MBR/Canadian context