Neon Law Nautilus — screening-shield design

Nautilus is the firm's $66/month consumer-report screening shield. A licensed attorney disputes the inaccurate tenant-screening and employment background-check reports that keep a person out of housing or a job, answering the consumer reporting agency under the consumer's federal Fair Credit Reporting Act rights — by letter, with an attorney signing every one. It runs on the inbound-email engine and the @approve attorney-approval gate that already serve the firm in production; the /services/nautilus product page, route, and nav ship.

This document is the canonical compliance contract for the offering. The Restate workflow PRs (intake, triage, consumer-report dispute, reinvestigation review, referral) each cite it rather than re-deriving the scope boundary. Every statutory claim below is grounded in an official U.S. government source so a future reader can re-verify it as the law moves.

The scope boundary (read this first)

Nautilus v1 is a dispute-correspondence shield only. It is what it does — and just as load-bearing, what it deliberately is not:

  1. A flat legal fee, never contingent. The fee is a flat $66/month for legal representation in disputing inaccurate consumer reports. It is never a percentage of anything, never contingent on a report changing, and never sold by outbound telephone solicitation. The number stays $66 whether the report has one error or ten.
  2. Not credit repair. Nautilus disputes information that is inaccurate; it does not sell to "improve," "repair," or "boost" a credit score or rating. That distinction is what holds the product clear of the credit-repair regime (below), and it is a hard rule for every marketing surface.
  3. No litigation. An FCRA damages suit, a collection or unlawful-detainer lawsuit, a summons — that is litigation, referred to litigation counsel, never answered as correspondence.
  4. We assert the client's own rights; we do not become a user of consumer reports. The consumer is entitled to their own reports for free (below); Nautilus starts there rather than pulling reports on the client, so it never takes on permissible-purpose obligations as a report user.

These four hold the product clear of the regime that would otherwise reach it, and keep it inside the firm's no-litigation, access-to-justice identity. Each carve-out is grounded below.

Why the Credit Repair Organizations Act (CROA) does not reach us

CROA reaches a "credit repair organization" — a person who, for money, provides services for the express or implied purpose of "improving any consumer's credit record, credit history, or credit rating," or advice about doing so (15 U.S.C. § 1679a(3)). It does not reach Nautilus, on two grounds:

The bright line is therefore in the copy and the intake, not only in this doc: "dispute what is inaccurate," never "improve your credit." A future tier that marketed score improvement would take on the CROA analysis deliberately; it is out of v1.

Open item for the attorney of record before launch. Several states run a Credit Services Organization Act analog (e.g. California Credit Services Act, Nev. Rev. Stat. Chapter 598, Wash. Rev. Code Chapter 19.134) that can reach dispute services and typically exempts attorneys rendering services in the practice of law. The exemption is conditional on genuine practice of law in an attorney-client relationship. The attorney of record confirms the per-state citation before the product launches in that state; it is not asserted here.

We assert the client's free-disclosure right rather than buying reports

The consumer is entitled to their own consumer file for free, which is where Nautilus starts:

Because the client obtains their own reports, Nautilus does not pull consumer reports on the client and does not take on the permissible-purpose duties of a report user (15 U.S.C. § 1681b). If a matter ever needs the firm to obtain a paid record, it is disclosed to the client first and passed through at actual cost with no markup.

Unauthorized practice of law

A licensed attorney reviews and signs every outbound dispute letter via the @approve gate — the staff-reply approval bridge already live in production. No letter auto-sends. The attorney is load-bearing, per mission.md: the fee buys an actual lawyer in the loop, not software pretending to be one. Every Nautilus Restate workflow PR reuses this @approve gate as its UPL control; none introduces an auto-send path.

The engagement letter governs

A written engagement letter signed before representation begins states the exact scope, the $66 monthly fee, any out-of-scope cost, and how either party may end the representation. The no-contingency rule lives in the engagement letter itself, not only in marketing. Nautilus guarantees no particular result and does not promise a report changes — it makes sure the consumer's accuracy rights are asserted and that the reporting agency deals with the consumer's lawyer. The letter is compliant across the firm's California, Nevada, and Washington admissions.

The core letter and its statutory hooks

The dispute letter carries role-scoped signature anchors so the attorney signs, and it goes out only through the @approve gate.

Official sources for the operative text:

Two adjacent provisions the workflows track as the product grows: a furnisher must reinvestigate a dispute forwarded by the agency (15 U.S.C. § 1681s-2(b)), and a consumer reporting agency that reports public-record information for employment carries heightened procedures (15 U.S.C. § 1681k). The CFPB's Regulation V (12 C.F.R. part 1022) is the FCRA implementing rule and the layer most likely to drift first, so workflow copy should track it as the regulation, with the statute as the anchor.

The on-chain record (Neon Law Node)

Every attorney-signed Nautilus letter can be anchored to the blockchain through Neon Law Node, reusing Node's Solana rail: one transaction binds the firm wallet, the client wallet, and a SHA-256 fingerprint of the signed letter. The letter itself stays private with the client; only the fingerprint goes on-chain, so the client can independently prove the exact letter existed and was signed, without exposing its contents. Anchoring is optional and opt-in.

Pricing — anchoring is included, not a second attestation fee. Node is a $44 per-attestation product because that fee buys a new attorney attestation of a fact. In Nautilus the attorney has already signed the letter under the @approve gate and the $66/month fee, so anchoring records a fingerprint of an already-signed document; there is no second attestation to bill. Only the Solana network fee (fractions of a cent) passes through at cost. Billing an indigent client $44 per letter on top of the flat fee would be regressive and off-mission; Node remains the $44 product for standalone attestations of new facts.

The referral seams

Nautilus refers out the moment a matter leaves dispute correspondence:

Intake & portal UX contract

The Client Council's findings are requirements for the surfaces the workflows build:

Build sequence

Nautilus engagements are projects matters opened by onboarding__ and closed by closing__letter. The workflows ride the existing workflows-service Restate worker — one worker, no per-workflow pod — and the existing inbound-email engine and @approve gate. Build order, each as one PR:

  1. 01 — Intake & consumer-report dispute (fcra_dispute, § 1681i; 30-day reinvestigation timer).
  2. 02 — Inbound triage — classify each inbound .eml (adverse-action notice, forwarded report, agency reinvestigation result) against active matters; the deadline-tracking spine.
  3. 03 — Reinvestigation review — the agency's § 1681i response (corrected/deleted vs verified-unchanged), surfaced to the client and queued for attorney review of the next step.
  4. 04 — Furnisher dispute (furnisher_dispute, § 1681s-2(b)) — the escalation when the agency verifies an item the furnisher's records do not support.
  5. 05 — Referral (lawsuit/summons or viable FCRA damages claim → litigation referral).

See docs/glossary.md for the Person / Entity / role vocabulary these workflows use, and the agent-workflows.md for the feature-first recipe each PR follows.