accountability based on the amount of its annual revenue through filings with the IRS. Commonwealth NIL is a private entity that has basically has little to no accountability requirements with respect to the public, and to a certain extent, its investors. The funding for these entities can be comprised of donations, sales of merchandise and other sources. The disbursement of the funds to or for athletes is determined by internal operating policies of the respective organizations. I suggest visiting their websites and/or contacting the organizations directly to get answers to specific questions in this area. With regard to high school athletes, Virginia just recently passed laws allowing payment of NIL funds to high school athletes. I believe other states have as well. As for payments directly to athletes, I believe this is allowed but the college is required to be notified (I believe by the athlete) of the payment and how much and the purpose. It may be the same for high schools as well, but I’m not familiar with the mechanics of those laws.