Plan Your Passing — Realtor Partnership Compliance Summary
For: Designated Managing Broker / Brokerage Compliance Officer · Re: Independent-contractor marketing collateral & sphere communications under the Plan Your Passing platform
1. What Plan Your Passing is
Plan Your Passing is a technology platform that provides educational content (scripts, checklists, scenario walkthroughs, 50-state legal summaries) and document-builder tools (will builder, advance directive builder, power of attorney builder) for families navigating estate planning and inheritance. The platform is operated by Plan Your Passing, owned by Roger Daniel Grubb, a California-licensed real estate broker with 15 years in active practice. Mailing address: 5740 Everwood Court, San Pablo, CA 94806.
2. What Plan Your Passing is NOT
- Not a law firm. No attorney-client relationship is created.
- Not a real estate brokerage. Does not list, show, or transact property.
- Not a financial advisor, CPA firm, or insurance carrier.
- Not a referral service for any specific transaction.
- Not a settlement-service provider under RESPA (no kickbacks, no fee-splitting on real estate transactions).
3. The Partner Realtor's Role
A Plan Your Passing realtor partner subscribes to a white-label license of the platform. The partner receives a co-branded subdomain (e.g. partnersname.planyourpassing.org) displaying their name, photo, license number, brokerage affiliation, and contact information layered over the Plan Your Passing content. The partner uses the subdomain and the provided sales-asset library (emails, postcards, social posts, workshop kit) as personal marketing collateral within the partner's own sphere of influence — the same category as any other broker-approved farm or sphere marketing.
4. Brokerage Identification & Required Disclosures
Every co-branded page on the partner subdomain displays:
- Partner's legal name as licensed
- Partner's license number and licensing state(s)
- Brokerage name (and brokerage license number where required)
- Brokerage office address (where required by state)
- Equal Housing Opportunity logo
- “Powered by Plan Your Passing” vendor disclosure (FTC §255)
- Educational-only / not-legal-advice disclaimer on every page
State-specific advertising disclosures (e.g., California BRE §10140.6 license number format, Texas TREC supervising broker statement, New York Article 12-A disclosure) are configurable per partner during onboarding.
5. NAR Code of Ethics Alignment
- Article 12 (Truth in Advertising): All educational content is sourced and dated. Income claims on vertical landing pages carry an FTC-compliant earnings disclaimer and link to the full disclosure. No deceptive or misleading statements about properties, services, or outcomes.
- Article 13 (No Unauthorized Practice of Law): Document-builder tools produce starting drafts only and instruct users to consult a licensed attorney in their jurisdiction before signing. No legal advice is given.
- Article 16 (Respect for Other Realtors' Relationships): The platform does not solicit clients of other realtors, does not target listed properties, and does not engage in pocket-listing-style referrals.
- Article 1 & 2 (Client Protection): The platform never collects transactional client data, never originates loans, never handles earnest money, and never represents itself as the partner's representative in a real estate transaction.
6. RESPA Compliance
The platform fee paid by the partner ($97–$297/month) is a flat SaaS subscription for technology and content access. It is not contingent on the partner closing any real estate transaction, is not a referral fee, and is not paid out of any real estate commission. RESPA §8 does not apply because no settlement service is being exchanged and no kickback or unearned fee is involved. The subscription is the same category as any other CRM, lead-source, or marketing-platform fee (Salesforce, BoomTown, Follow Up Boss, Zillow Premier Agent — all of which are flat-SaaS, RESPA-permissible expenses).
7. CAN-SPAM & TCPA Compliance
Every email template in the partner sales kit includes the CAN-SPAM-required physical mailing address (the partner's brokerage address), a clear unsubscribe mechanism, and a non-deceptive subject line. Partners are responsible for sending only to recipients with whom they have an existing business relationship or who have opted in. TCPA: partners do not use the platform to send unsolicited text messages or automated calls; SMS notifications (when enabled) require explicit recipient consent.
8. Data & Privacy
The partner's subdomain operates under the Plan Your Passing privacy policy and CCPA/CPRA-compliant California consumer notice. Client data submitted through the partner's portal (e.g., contact form leads) is forwarded to the partner and is not used for any other purpose. No data is sold or shared with third parties for behavioral advertising. Full data-processing terms available on request.
9. Termination & Data Return
The partner may cancel the subscription at any time with one email. Upon cancellation, the subdomain is decommissioned within 30 days. The partner retains permanent access to their downloaded sales-asset library (emails, scripts, workshop kit, postcards) under the 90-day refund + keep-all- assets guarantee. The platform retains no client lead data after termination.
10. Broker Sign-Off Block
I have reviewed this compliance summary and the partner's co-branded subdomain. The partner is approved to deploy the Plan Your Passing marketing collateral within their sphere-of-influence marketing program, subject to all applicable brokerage advertising and supervision policies.
Designated Managing Broker (signature)
Date
Brokerage name + license #
Partner realtor name + license #
Printing tip: This page is sized to a single 8.5×11 sheet.
Questions your broker has that aren't answered here? Email roger@planyourpassing.org with the subject line “Broker Compliance Question” and we'll respond within one business day. We also offer a free 20-minute call with your broker if helpful.