RJ GrowthOS — AI funnels, CRM, follow-up, compliance controls and conversion intelligence in one platform.
Compliance Guard
Verbatim disclaimers, consent language, and legal checklists — the armor for every launch. Everything here requires review by a licensed attorney in your state before use. Not legal advice.
Universal Marketing Compliance
TCPA Consent Language (all opt-in forms — separate UNCHECKED checkbox)
By checking this box, I consent to receive marketing calls and text messages from [Company Name] at the phone number provided, including messages sent via automated dialing systems. Consent is not a condition of purchase. Message and data rates may apply. Reply STOP to opt out. Reply HELP for assistance. View our Privacy Policy and Terms of Service.
IMPLEMENTATION RULES:
→ Never pre-check the box
→ Store consent timestamp, IP address, and form version
→ Use a consent verification platform (TrustedForm, ActiveProspect)
→ Honor opt-outs within 10 business days
→ No texts before 8 AM or after 9 PM recipient's local time
→ Violations: $500–$1,500 per text, no class action cap
CAN-SPAM Email Footer (every marketing email)
[Company Name] | [Physical Street Address] | [City, State, ZIP]
You're receiving this email because you opted in at [source].
To unsubscribe, click here: [unsubscribe link]
REQUIREMENTS PER EMAIL:
→ Accurate FROM name and email address
→ Honest subject line — no deception
→ Physical mailing address visible
→ Working unsubscribe honored within 10 business days
→ No harvested addresses
FTC Testimonial Disclaimer (below every testimonial/case study)
Results may vary. This client's results depended on their specific situation. Your results will vary based on your individual circumstances. [If compensated/affiliated: This testimonial was provided by a compensated client/partner.]
FTC ENDORSEMENT RULES (updated 2024):
→ Non-typical results MUST be disclosed as non-typical
→ Paid/incentivized reviews MUST disclose compensation
→ Employee/partner testimonials MUST disclose the relationship
→ AI-generated testimonials/faces: NEVER acceptable
→ Systematic suppression of negative reviews violates CRFA
→ FTC Review Rule (effective Oct 21, 2024): fake reviews = civil penalties per violation
FTC Affiliate Disclosures (3 formats)
PAGE (above the fold):
Disclosure: [Your Name/Company] earns a commission if you purchase through links on this page. This doesn't affect our analysis. We only recommend services we believe are legitimate and compliant.
SOCIAL POST:
#ad — I partnered with [Company] to share their [service]. As always, all opinions are my own. [Link to disclosure policy]
EMAIL:
Note: This email contains affiliate links. I may earn a commission if you sign up through my link.
Data Privacy Notice (GLBA businesses — tax & credit)
Your information is protected under the Gramm-Leach-Bliley Act and our Written Information Security Program (WISP). We do not sell your personal information. See our Privacy Policy for complete details.
GLBA SAFEGUARDS RULE REQUIREMENTS (documented, not just implemented):
→ Written Information Security Program (WISP)
→ Designated security coordinator
→ Annual risk assessment
→ Breach notification procedures
→ Encryption in transit and at rest
→ MFA on all systems with client data
→ Vendor agreements with security requirements
Results may vary. Individual results depend on the specific facts and circumstances of each taxpayer's situation. Prior results do not guarantee similar outcomes. Settlements, installment agreements, and other IRS resolution programs are subject to IRS approval and individual eligibility requirements.
OIC Disclaimer (any Offer in Compromise claim)
An Offer in Compromise (OIC) is an IRS program that allows eligible taxpayers to settle their tax debt for less than the full amount owed. OIC acceptance is determined solely by the IRS based on your ability to pay, income, expenses, and asset equity. Not all taxpayers qualify. The IRS accepted approximately [X]% of OIC applications in [year]. We do not guarantee OIC acceptance or any specific settlement amount without first evaluating your complete tax situation.
Representation Disclaimer
Tax resolution services are provided by [licensed credential holders: EA/CPA/JD]. IRS representation requires a signed Power of Attorney (Form 2848). Services are not a guarantee of any specific outcome before the IRS.
General Tax Service Disclaimer (site footer)
This content is for informational purposes only and does not constitute legal or tax advice. Tax laws change frequently. Consult a licensed tax professional regarding your specific situation. [Firm Name] is not affiliated with or endorsed by the IRS or any government agency.
TSR Pre-Enrollment Disclosures (debt relief — mandatory before signup)
Before enrolling any consumer, you MUST disclose:
[1] How long the program will take to show results
[2] How much the program will cost (TOTAL, not monthly only)
[3] Potential NEGATIVE consequences of using the service
(credit impact, liens continuing, potential collection activity
during negotiation period)
[4] Key terms of any dedicated/escrow account
TSR CARDINAL RULES (tax/debt relief):
→ NO fee collection before settling/resolving the debt
→ TSR covers INBOUND calls from your ads (post-Dec 2024 amendment)
→ Honor National DNC Registry + internal DNC list
→ Call window: 8 AM – 9 PM recipient local time
→ Retain ads 36 months (Circular 230), scripts/recordings/consents 24 months (TSR)
Credit Repair Disclosures (CROA · FCRA · FTC)
CROA Identity Footer (site + emails)
[Company Name] is a credit repair organization as defined by the Credit Repair Organizations Act (15 U.S.C. §1679). You have the right to dispute inaccurate information in your credit report by contacting the credit bureaus directly, at no cost, via annualcreditreport.com. Results may vary and are not guaranteed.
Post-Service Billing Statement (pricing pages)
Under the Credit Repair Organizations Act (CROA), we are legally required to complete services before billing for them. We do not charge upfront fees for credit repair services. You have the right to cancel within 3 business days of signing your service agreement, no questions asked. For our complete contract terms and your consumer rights disclosure, see [link].
Credit Results Disclaimer (every testimonial)
Results may vary. Individual outcomes depend on the specific items on your credit report, whether those items can be successfully disputed under the FCRA, and the credit bureaus' investigation findings.
CROA Written Contract — Required Elements (§1679d)
EVERY credit repair contract MUST contain:
a) Full description of services to be performed
b) Total amount of ALL payments (itemized, complete)
c) Specific date or time period for performance
d) Company name and business address
e) Consumer's three-day right to cancel
f) Notice of Cancellation form (attached)
SEQUENCE REQUIREMENT:
1. Consumer Rights Statement (§1679c) — SEPARATE document,
provided and acknowledged FIRST
2. Then the contract is presented for signature
3. Then the 3-day cancellation window runs (cannot be waived —
waiver clauses are VOID)
4. Services may not begin until the window expires
Note: The §1679c Consumer Rights Statement must use the verbatim
statutory text — pull it from 15 U.S.C. §1679c and have your
attorney confirm the current version.
Earnings and income representations made by [Company] are aspirational statements only. Individual results will vary based on many factors including work ethic, experience, compliance, and market conditions. [Company] makes no guarantee of income or business success.
Events & General Offer Disclaimers
Event Testimonial Disclaimer
Results shown are from real attendee reports and are not typical. Individual results depend on your audience, offer, effort, and execution. No specific outcome is guaranteed.
Urgency & Scarcity Rules (FTC deception standard)
REAL ONLY, ALWAYS:
✅ Real seat limits (venue capacity, cohort caps)
✅ Real deadlines that ACTUALLY expire (no rolling resets)
✅ Real sponsor spot counts (don't invent infinite tiers)
✅ Countdown timers tied to fixed dates
NEVER:
❌ Fake countdown timers that reset per visitor
❌ "Only 3 left!" when inventory is unlimited
❌ Fake "price goes up tonight" that never goes up
❌ Manufactured "sold out" claims
Fake urgency = deceptive practice under FTC Act §5. It's also
the fastest way to torch audience trust permanently.
Sponsor ROI Illustration Disclaimer
Illustrative math only — actual results depend on your offer, follow-up, and conversion rates. Past sponsor results are self-reported and are not a guarantee of your outcome.
Event Guarantee Language (clean risk reversal)
100% Money-Back Guarantee: attend Day 1 — if you don't believe it was worth every penny, email us before Day 2 begins for a full refund. No forms, no friction.
GUARANTEE RULES:
→ State the exact condition and exact deadline
→ Honor it without friction (refund friction = FTC complaints)
→ Never offer a guarantee you can't operationally deliver
Pre-Launch Checklists
Events Funnel
All testimonials real + permissioned + disclaimered
Countdown tied to a real, fixed deadline
Seat/spot counts reflect actual inventory
Guarantee terms exact and operationally deliverable
TCPA checkbox on any SMS opt-in (unchecked)
CAN-SPAM footer on every email
Refund policy published and linked
Tracking events wired (GA4 + Meta Pixel)
Tax Funnel
Attorney reviewed all copy + disclaimers
State CPA/EA advertising rules confirmed
No result guarantees anywhere in copy
No IRS affiliation implied (logos, language)
"Not affiliated with IRS" statement present
PTIN + EFIN current; credentials verifiable
WISP documented (GLBA)
§7216 consent forms for any data sharing
TSR analysis if phone/inbound-call sales
Marketing materials retained 36 months
Credit Repair Funnel
Attorney reviewed all copy + contracts
State CSO registration + bonds in every operating state
CROA contract has ALL §1679d elements
Consumer Rights Statement is a SEPARATE doc, provided FIRST
Notice of Cancellation form in every contract
Billing fires AFTER completed work only
No score guarantees anywhere
All testimonials consented + disclaimered
TSR analysis if any phone contact with prospects
WISP documented; marketing retained 24+ months
Hard Stops — Do Not Launch If:
🔴 Any copy guarantees specific results (scores, settlements, refunds)
🔴 Any billing collects before services are performed (tax resolution / credit repair)
🔴 Any implied government affiliation exists anywhere
🔴 Testimonials are fabricated, AI-generated, or lack consent
🔴 Required state registrations/bonds are missing
🔴 No attorney has reviewed the final assets
Real Estate — Fair Housing · RESPA · License Rules
[Agent Name] · [Brokerage Name] · License #[XXXXX] · [State]
Equal Housing Opportunity. 🏠⚖️
All information deemed reliable but not guaranteed. Market statistics sourced from [MLS name] as of [date] and subject to change. Past sales performance does not guarantee future results.
HARD RULES (Fair Housing Act, 42 U.S.C. §3601):
→ NEVER describe the desired buyer/renter ("perfect for young families" = violation; describe the PROPERTY, not people)
→ No steering language about neighborhoods ("safe area," "good schools" used as demographic code = risk)
→ Ad targeting: no exclusion by race, color, religion, sex, disability, familial status, national origin — and platform special-category rules apply (Meta/Google housing ad categories are mandatory)
→ Display brokerage name as required by your state license law
→ Team names and DBAs must comply with state advertising rules
RESPA + testimonial rules
RESPA (12 U.S.C. §2607) — REFERRAL RULES:
→ NO kickbacks or things of value for mortgage/title/escrow referrals
→ Affiliated business arrangements require written AfBA disclosure
→ "Preferred lender" arrangements need attorney review
TESTIMONIALS & STATS:
→ Client reviews must be genuine, with consent to publish
→ "#1 agent" claims need a verifiable basis + source cited ("#1 in [MLS] units sold, [year], [source]")
→ Days-on-market / %-over-list stats: cite MLS + date range
→ Guaranteed-sale programs ("We'll buy your home if...") = full written terms + attorney review + state-specific rules
Fitness — Health Claims · Results · Liability
Results disclaimer (every results mention, near the claim)
*Results vary. [Client name]'s results reflect [his/her] individual effort, consistency, nutrition, and starting point, and are not typical. You should not expect the same or similar results. Consult your physician before beginning this or any exercise or nutrition program, especially if you have any medical condition or take medication.
FTC RULES (Health Products & Services + Endorsement Guides, 16 C.F.R. Part 255):
→ Testimonials claiming specific results REQUIRE a clear "not typical" disclosure NEAR the claim (footer-only = insufficient)
→ Before/after photos: same lighting/pose/timeframe honesty; disclose timeframe
→ NO disease claims ("reverses diabetes," "cures back pain") — that's drug/medical-device territory (FDA)
→ Weight-loss red flags per FTC "Gut Check": >2 lbs/week without diet+exercise, "no diet needed," "permanent loss" = presumptively false
→ Influencer/affiliate posts need #ad disclosure
Liability waiver pointer + supplement rules
LIABILITY:
→ Written informed-consent + assumption-of-risk waiver signed BEFORE any programming (attorney-drafted, state-specific)
→ PAR-Q or equivalent health screening for new clients
→ Scope of practice: trainers may not prescribe diets/meal plans in some states (dietetics licensure laws) — check your state
SUPPLEMENTS (if you sell/recommend):
→ DSHEA disclaimer required: "These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease."
→ Affiliate income from supplement links must be disclosed
Coaching — FTC Earnings Claims · Refunds
Earnings disclaimer (mandatory near ANY income mention)
EARNINGS DISCLAIMER: We make no guarantee or representation that you will earn any money using the techniques, strategies, or programs offered. Any income or earnings statements are estimates or examples of what certain individuals have achieved and are not typical. Your results will differ and depend on many factors including but not limited to your background, experience, effort, market conditions, and business skills. All business entails risk, including the risk of losing your investment entirely.
FTC RULES (post-2021 enforcement era):
→ ANY earnings claim ("clients make $10K/mo," screenshots of Stripe dashboards, "6-figure launch") requires substantiation you possess BEFORE making the claim
→ "Not typical" disclosure must be CLEAR AND CONSPICUOUS near the claim — not buried in a footer link
→ Lifestyle imagery implying income (rented Lambos, cash fans) = implied earnings claim, same rules
→ Fake urgency/scarcity ("3 spots left" when untrue) = deceptive practice
→ Testimonials: written consent, unedited substance, disclose any compensation ("received free access")
Refund policy + auto-renewal rules
REFUND POLICY (post in checkout, enforce as written):
[Program Name] Refund Policy: [X]-day money-back guarantee. To request a refund, email [email] within [X] days of purchase [+ any completion conditions — action-based conditions must be reasonable and clearly disclosed BEFORE purchase].
AUTO-RENEWAL / NEGATIVE OPTION (FTC Click-to-Cancel rules + state ARL laws):
→ Clear disclosure of renewal terms BEFORE checkout
→ Express informed consent to the subscription
→ Cancellation must be AS EASY as signup (online cancel if online signup)
→ CA/NY/etc. require renewal reminder notices — check state list
→ Chargebacks from hidden renewals = processor account termination risk
REVIEWS — 16 C.F.R. Part 465 (effective Oct 2024, penalties up to $53K+ per violation):
→ NO fake or AI-generated reviews, ever
→ NO buying positive reviews (incentives contingent on sentiment = illegal)
→ NO review suppression (hiding negatives while showing positives on your site)
→ NO undisclosed insider reviews (employees/family must disclose relationship)
→ Review counts and ratings shown in ads must match reality at time of display
→ Influencer posts: #ad or "paid partnership" — visible, not buried in hashtags
PRICING:
→ "Was $X, now $Y" — the $X must be a genuine former price (state strike-through pricing laws)
→ Countdown timers must reflect real deadlines
→ "Free" + forced shipping markup = deceptive
Shipping, returns & product claims
SHIPPING — FTC Mail Order Rule (16 C.F.R. Part 435):
→ Ship within advertised timeframe (or 30 days if none stated)
→ Delay = notify + offer cancel/refund option
→ Refund within 7 days of a cancelled order (or 1 billing cycle for card)
RETURNS:
→ Post the policy conspicuously BEFORE purchase; state laws (e.g. CA, NY) set default rights if you don't
→ Honor as written — deviations = deceptive practice + chargeback fuel
PRODUCT CLAIMS:
→ "Made in USA" = "all or virtually all" made domestically (FTC enforces hard)
→ Health/beauty benefit claims need competent scientific substantiation
→ Eco claims ("biodegradable," "recyclable") must meet FTC Green Guides
SaaS — Privacy · Data · Subscription Law
Required legal pages + privacy laws
MINIMUM LEGAL STACK (before launch):
→ Privacy Policy — what you collect, why, who you share with, retention, user rights
→ Terms of Service — license, acceptable use, liability caps, arbitration, termination
→ Cookie notice/consent if using analytics/ads pixels (GDPR/ePrivacy for EU visitors)
→ DPA (Data Processing Agreement) available if customers are businesses
→ Subprocessor list if you're B2B
PRIVACY LAWS THAT PROBABLY APPLY:
→ GDPR (any EU users): lawful basis, DSR handling (30 days), breach notice (72 hrs)
→ CCPA/CPRA (CA revenue/data thresholds): "Do Not Sell/Share" link, deletion rights
→ State patchwork (VA, CO, CT, TX, ...): honor universal opt-outs (GPC signal)
→ COPPA: if under-13 users possible — parental consent regime, penalties per child
Trial, billing & uptime claims
TRIALS & BILLING (FTC negative-option rules):
→ Card-required trials: disclose exact charge date + amount BEFORE collecting card
→ Renewal reminders where state law requires (and as best practice)
→ Cancel flow ≤ signup friction ("Click-to-Cancel")
→ Proration/refund terms in ToS, honored as written
MARKETING CLAIMS:
→ "99.9% uptime" needs measurement basis + SLA definition
→ "Bank-level security" / "military-grade encryption" = substantiate or delete
→ SOC 2 / HIPAA / GDPR "compliant" badges: only if audited/true — false certification claims = FTC + private suits
→ Competitor comparisons must be accurate and current
Law Firm — Bar Advertising Rules (Model Rules 7.1–7.3)
Attorney advertising disclaimer block (adapt to your state)
ATTORNEY ADVERTISING. [Firm Name], [Address]. Responsible attorney: [Name], licensed in [State(s)].
Prior results do not guarantee a similar outcome. Every case is different and must be evaluated on its own facts. This website provides general information only and does not constitute legal advice. Viewing this site or contacting the firm does not create an attorney-client relationship. Do not send confidential information until an attorney-client relationship is established in writing.
[Contingency practices:] "No fee unless we win" refers to attorney's fees only; client may remain responsible for case costs and expenses. [Some states REQUIRE this clarification.]
STATE-SPECIFIC LANDMINES (verify yours):
→ NY: "ATTORNEY ADVERTISING" label on emails/site required
→ FL: pre-filing review of some TV/radio ads by the Bar
→ TX: filing requirements with Advertising Review Committee
→ Testimonials banned or restricted in several states
→ "Specialist"/"expert" claims only if state-certified in that specialty
Solicitation + intake compliance
SOLICITATION (Rule 7.3):
→ NO live/telephone/real-time electronic solicitation of non-lawyers with whom you have no prior relationship (limited exceptions)
→ Targeted mail to accident victims: many states impose 30-day blackout periods
→ Lead generation services: cannot be fee-splitting or improper recommendation — structure review required
INTAKE:
→ TCPA still applies to law firm texting — consent checkbox on all forms
→ Conflicts check before substantive discussions
→ Non-engagement letters for declined matters (malpractice protection)
→ Advertising in states where you're not licensed = UPL risk
Home Services — Licensing · Contracts · Door-to-Door
License display + estimate rules
EVERY AD / PAGE / TRUCK / CARD:
[Company Name] · [State] License #[XXXXX] · Licensed, Bonded & Insured
RULES:
→ Most states REQUIRE license number in all advertising (CA CSLB, FL DBPR, AZ ROC, etc.) — fines per ad without it
→ "Bonded & insured" only if currently true — carry certificates
→ Unlicensed contracting over state dollar thresholds = criminal in many states; advertising without license also violates
→ Written estimates: itemized, signed, with change-order process — several states mandate written contracts over $ thresholds ($500 CA)
→ Warranty claims ("lifetime warranty") = written warranty terms required (Magnuson-Moss)
Home solicitation + financing rules
3-DAY RIGHT TO CANCEL (FTC Cooling-Off Rule + state versions):
→ Sales made at the customer's home over $25: written notice of 3-business-day cancellation right, in duplicate
→ Applies to most in-home contract signings — build the form into your paperwork
FINANCING OFFERS:
→ "0% financing" / "$99/month" triggers Truth in Lending (Reg Z) disclosure requirements
→ Third-party financing (GreenSky etc.): use lender-approved language only
STORM CHASER LAWS:
→ Post-disaster states regulate roofing solicitation heavily (deductible-waiving offers are ILLEGAL in many states)
→ Insurance-claim assistance language: don't act as a public adjuster without a license
Med Spa — Medical Practice · HIPAA · Before/After
Medical disclaimer + supervision rules
TREATMENT DISCLAIMER (site-wide + per treatment page):
Individual results vary. All medical aesthetic treatments are performed by or under the supervision of licensed medical professionals. A consultation and medical evaluation are required before any treatment to determine candidacy. Information on this site is educational only and is not medical advice. [Treatment]-specific risks will be reviewed during your consultation.
STRUCTURE RULES (state medical board):
→ Corporate Practice of Medicine states: med spa must be physician-owned or MSO-structured — marketing cannot imply otherwise
→ Medical Director name/credentials displayed where state requires
→ Who may inject varies by state (RN/NP/PA/MD scopes) — never advertise services your staffing can't legally deliver
→ Prescription devices/drugs (Botox®, lasers): trademark correctly, no OTC-style claims
HIPAA marketing + before/after photo rules
HIPAA MARKETING:
→ Client photos/testimonials = PHI: written HIPAA authorization (not just a model release) BEFORE posting
→ Never confirm someone is a patient in review responses ("We're glad YOU loved YOUR Botox results" = violation) — respond generically
→ Email lists: appointment reminders OK; marketing new services may require authorization — segment carefully
→ Meta/Google pixels on booking pages = potential PHI disclosure (OCR bulletin) — audit your tracking
BEFORE/AFTER PHOTOS:
→ Real clients of YOUR practice, with signed authorization
→ Same lighting/angle/expression; no retouching of treatment areas
→ Timeframe + number of sessions disclosed
→ Stock photos presented as results = deceptive advertising
Insurance — Producer Licensing · Ad Rules
Agent identity + advertising rules
EVERY MARKETING ASSET:
[Agent Name], Licensed Insurance Producer · [State] License #[XXXXX]
[Agency Name] · [Address] · [Phone]
RULES (state DOI + NAIC model rules):
→ License number + true producer name in advertising (most states)
→ Carrier names/logos only per carrier co-op advertising guidelines
→ "Savings up to $X" claims: substantiation + "savings vary" disclosure
→ NO misrepresenting policy terms, benefits, or dividends (unfair trade practices acts)
→ Quote forms: disclose you're an agent (not the insurer) and that quotes are estimates subject to underwriting
→ Rebating (giving part of commission/gifts to induce purchase) is ILLEGAL in most states — gift caps vary ($25–$100)
Medicare + lead-gen specific rules
MEDICARE (if applicable — CMS Marketing Guidelines, 42 C.F.R. §422/423):
→ Mandatory disclaimer: "We do not offer every plan available in your area. Currently we represent [X] organizations which offer [Y] products in your area. Please contact Medicare.gov, 1-800-MEDICARE, or your local State Health Insurance Program to get information on all of your options."
→ ALL marketing materials require CMS filing/approval via carriers
→ 48-hour Scope of Appointment before sales meetings
→ Call recording required for marketing/sales/enrollment calls (retain 10 years)
LEAD GENERATION:
→ TCPA consent specific to insurance calls; one-to-one consent rules post-2025 FCC changes
→ Buying leads: verify the consent chain names YOUR agency
→ "Final expense" / "burial insurance" ads face heightened state scrutiny — no fake government affiliation ("2024 State Benefit Update" mailers = enforcement magnet)
CASE STUDY DISCLAIMER (near every result claim):
*Results shown are from a specific client engagement and depend on that client's market, offer, budget, and execution. They are not typical and are not a guarantee or prediction of your results.
RULES:
→ "We'll 3x your revenue" / "guaranteed #1 rankings" = deceptive (nobody controls Google) — FTC + platform policy violation
→ Client results in ads: written permission + accurate numbers you can substantiate (screenshots retained)
→ "As seen in Forbes" only for real editorial coverage — paid placements must say so
→ White-label work: don't claim another agency's portfolio as your own
→ AI-generated "client testimonials" = illegal under FTC Consumer Review Rule
Client contract must-haves + platform compliance
CONTRACT ESSENTIALS (attorney-drafted):
→ Scope of work + explicit exclusions (scope creep kills agencies)
→ Performance language: effort/deliverable-based, NOT outcome-guaranteed
→ Who owns ad accounts, creatives, and data at termination (client should own accounts)
→ Payment terms + late-payment work-stoppage clause
→ Limitation of liability + indemnification for client-supplied claims/content
→ Term, termination notice, and offboarding process
YOU'RE LIABLE FOR CLIENT ADS TOO:
→ FTC holds ad agencies responsible for deceptive claims they create or should have known were false
→ Regulated verticals (supplements, finance, legal, health) — apply THAT industry's rules to client work
→ Platform policies (Meta/Google restricted verticals): agency account bans propagate across clients — vet client claims before launching