# ClearGrant Trust Profile — Counsel Review Packet

Status: prepared for review; no lawyer has reviewed or approved this product.

## Product boundary to review

ClearGrant currently organizes owner-entered evidence labels, dates, public source references, and short notes. Its QI checklist evaluates only five status labels. It does not read source documents, validate a person or entity, determine grant or credit eligibility, issue a credit decision, rank applicants, promise funding, or replace an accountant, bank, government program, or lawyer. Financial amounts stay in browser storage and are not included in the encrypted account profile.

The server-side profile endpoint is gated. If later enabled, it stores only the signed-in account's allowlisted evidence metadata, encrypted with an application-held AES-256-GCM key before writing to Netlify Blobs. There is no automatic expiration; users can request/delete their cloud copy. Loss of the encryption key makes stored profiles unreadable, while replacing the key without migration would strand existing data. QI session identity, key backup/rotation, deletion behavior, service-provider terms, and retention language need counsel/privacy review before customer use.

## Questions for qualified counsel

1. Do the product name, “trust profile,” site copy, workflow, or sales materials create an express or implied claim of investigation, certification, creditworthiness, grant eligibility, or funding recommendation?
2. Could any intended data, customer, workflow, or future scoring feature bring the service within consumer-reporting, financial-services, privacy, unfair/deceptive-practice, or other regulated activity? Identify the facts and laws that control; do not infer an answer from this packet.
3. Are the source-reference labels, reviewer notes, corrections, stale-source handling, and any future “verified” language adequately defined and disclosed?
4. What privacy notice, consent, retention period, deletion process, access/correction path, breach response, and processor/vendor terms are required for the proposed metadata and account storage?
5. What Pennsylvania and federal state-law obligations apply to the business's actual entity status and operation, and which statements about the company should be shown publicly?
6. Are terms, pilot consent, support process, disclaimers, and accessibility obligations adequate for museums, small businesses, grant applicants, or other intended users?

## Primary-source references for review

- Pennsylvania Department of State Business Entity Search: <https://file.dos.pa.gov/search/business>
- Pennsylvania DOS record-search scope and limitations: <https://www.pa.gov/agencies/dos/programs/business/information-services/record-searches>
- SAM.gov entity information: <https://sam.gov/entity-information>
- SAM.gov Assistance Listings: <https://sam.gov/find-assistance-listings>
- Grants.gov opportunity search: <https://www.grants.gov/search-grants>
- Pennsylvania DOS business guide (including its reminder to consult legal/tax advisers for specific questions): <https://www.pa.gov/content/dam/copapwp-pagov/en/dos/programs/business/guides/Business-Guide.pdf>

These are starting points only. They do not establish the company's current status, the accuracy of an evidence record, or an applicant's eligibility.

## Finding a qualified human reviewer (not yet engaged)

- The Pennsylvania Bar Association Lawyer Referral Service offers a referral to a participating attorney; its current public page says the initial 30-minute consultation costs no more than $30. Ask specifically for Pennsylvania business/privacy/technology counsel who can review the product boundary, website claims, data handling, terms, and intended customers: <https://www.pabar.org/PBA/Public-Resources/Find-a-Lawyer.aspx>. A referral and short consultation are not a completed review; ask for a written scope and fee before engaging.
- Penn Carey Law's Detkin IP & Technology Legal Clinic describes free legal work for individuals and for-profit ventures in technology/business/arts. Intake, eligibility, timing, and whether its scope covers ClearGrant must be confirmed directly; it is an option to ask, not an assumed appointment: <https://www.law.upenn.edu/live/news/18141-using-law-to-support-innovation>.

Do not publish an attorney name, legal approval, or reviewed status until counsel has actually accepted the engagement, completed the agreed work, and delivered documented findings.

## Review record — intentionally blank

- Reviewer name, bar jurisdiction, and firm: ____________________
- Materials/version reviewed: ____________________
- Review date: ____________________
- Scope and limitations: ____________________
- Written findings attached: yes / no
- Owner acceptance and implementation record: ____________________

Do not fill in a reviewer name, date, or approval until a qualified lawyer has actually completed and documented the review.
