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Public.com — Compliance & Regulatory Posture Review

Status: research-only. This document does NOT constitute legal or tax advice. Before making any product, structure, or filing decisions based on this research, consult a securities attorney licensed in New York and Pennsylvania (or your state of business), with specific experience in broker-dealer, investment adviser, and fintech regulation. Last updated: 2026-06-05. Sources as of that date — verify freshness before acting. Companion to: docs/marketing/competitors/public-com.md (marketing/positioning lens).

TL;DR

Public Holdings, Inc. operates a two-license entity stack (a registered broker-dealer + a registered RIA subsidiary) that lets it offer both brokerage execution and advisory-style tools under one roof. Its social/community features are legally framed as user-generated content with explicit disclaimers that no "supervised person" is advising community posters — placing them outside the Adviser Act registration requirement. Raxx, as a non-custodial platform with no BD or RIA registration, has a narrower but still viable path: the key is maintaining the "historical data display, not personalized advice" frame at every user-facing surface, and being especially careful that sentiment-gated backtesting is presented as informational analytics, not as a strategy recommendation engine.

1. Entity Registration Tree

Confirmed entities (from Public.com disclosures and FINRA BrokerCheck)

Entity Type Registration CRD / Notes
Public Holdings, Inc. Parent / tech operator Not a regulated entity itself Owns the app + brand
Open to the Public Investing, Inc. Broker-dealer FINRA/SIPC member, SEC-registered CRD #127818; SEC #8-66049; main office: 530 Broadway, 4th Floor, New York, NY 10012; 4 regulatory disclosure events on record
Public Advisors LLC Registered Investment Adviser SEC-registered CRD #318234 (confirmed via IAPD search); provides advisory services (AI Agents, Alpha features)
Jiko Securities, Inc. Broker-dealer (Treasury-only) FINRA/SIPC member CRD #287507; holds T-bill "Jiko Accounts"; files Form X-17A-5 annually with SEC; NOT an affiliate of Public Holdings
Zero Hash LLC Crypto infrastructure NYSDFS licensed Provides cryptocurrency services; separate licensing regime from SEC/FINRA
Alto Trust Co Trust company New Mexico trust company Custodies Crypto IRA assets
Apex Clearing Corporation Clearing firm Third-party clearing Executes and clears all standard equity/options trades for Open to the Public Investing

What the structure accomplishes

Sources: - https://public.com/disclosures (entity list, live) - https://public.com/terms-of-service (entity characterizations, live) - https://brokercheck.finra.org/firm/summary/127818 (CRD 127818, FINRA BrokerCheck) - https://adviserinfo.sec.gov/firm/summary/318234 (Public Advisors LLC, IAPD) - https://help.public.com/en/articles/6997525-what-is-jiko (Jiko role explanation)

What Public does

The disclaimer architecture

From the Terms of Service (verbatim, live):

"User Content is not advice created or provided by Public.com and does not constitute a recommendation to buy, sell, or hold any security."

"Public does not monitor, supervise or endorse any User Content, and Users are not supervised persons of Public.com."

"THE CONTENT PRESENTED ON THE SERVICES ARE NOT INTENDED TO PROVIDE YOU...WITH INVESTMENT, LEGAL, TAX, INSURANCE OR ANY OTHER KIND OF PROFESSIONAL ADVICE."

Public is using a user-generated content (UGC) safe harbor + unsupervised-persons argument, not the publisher's exclusion. The key language is "Users are not supervised persons of Public.com." Under FINRA's supervision rules and the Adviser Act, advice from an "associated person" of a BD or RIA triggers regulatory obligations. By affirmatively stating that community posters are not supervised persons, Public distinguishes the social feed from regulated speech.

This is a well-established framing: eToro, StockTwits, and other social-investing platforms use the same architecture. It is not a novel theory.

The publisher's exclusion — why Public probably does NOT need it

The publisher's exclusion under Section 202(a)(11) of the Advisers Act protects "publishers of any bona fide newspaper, news magazine or business or financial publication of general and regular circulation" providing impersonal advice. Its three-part test: 1. Bona fide publication (disinterested, not promotional) 2. Impersonal advice (not adapted to individual subscribers) 3. General and regular circulation (not event-driven)

Public's social feed is interactive, user-driven, and implicitly personalized (you follow specific traders). It would be difficult to qualify as "general and regular circulation." Public does NOT appear to invoke the publisher's exclusion for community features — instead it relies on the UGC + unsupervised-persons framing. The publisher's exclusion is more relevant to their Morningstar/analyst content (see Section 3).

The SEC's 2022 information-providers inquiry (S7-18-22) — still active

The SEC's June 2022 Request for Comment (File No. S7-18-22) specifically flagged services using "alternative data such as market sentiment from social media to build indices or price predictors" as potentially requiring investment adviser registration. Critically, this rulemaking was NOT withdrawn in the SEC's June 2025 batch withdrawal (which dropped 14 other proposals). It remains pending as of the date of this document. This is a live regulatory risk for any platform displaying social sentiment as actionable signal.

The SEC's Investor Advisory Committee issued a November 2024 recommendation on "finfluencers" that recommended tightened supervision requirements for platforms that amplify individual user investment commentary.

Sources: - https://public.com/terms-of-service (verbatim disclaimer text, live) - https://public.com/privacy-policy (UGC data handling, live) - https://www.sec.gov/rules-regulations/2022/06/s7-18-22 (S7-18-22 rulemaking, active) - https://www.sec.gov/files/sec-iac-finfluencer-recommendation-11222024.pdf - https://natlawreview.com/article/navigating-publishers-exclusion-under-advisers-act - https://www.wsgr.com/en/insights/informationor-advice-sec-regulation-of-information-providers-may-expand-to-include-providers-of-innovative-investment-analytics.html

3. Research / Premium Content Tier Disclosures

Public Premium and Alpha features

Public's premium content tier delivers: - Morningstar institutional research (bull/bear cases, competitor analysis) - AI-powered "Alpha" assistant (ChatGPT-backed, for stock screening and alerts) - Audio programming from analysts - Extended-hours trading

How they handle third-party research disclosures

Public does not publicly describe its Morningstar arrangement in detail in consumer-facing disclosures. The architecture most likely used industry-wide is: Morningstar (a registered RIA) provides the research under its own registration; Public distributes it as a licensed channel partner. The compliance wrapper belongs to Morningstar, not to Public. This is a licensed distribution / white-labeling model, which is common and well-understood.

The AI Alpha feature (GPT-backed) is handled differently: it is positioned under the Public Advisors LLC (the RIA sub) umbrella, allowing the advice-adjacent outputs to be supervised under an existing Adviser Act registration. From the AI Agents page:

"Outputs from Agentic Brokerage are provided for informational and illustrative purposes only, and should not be considered investment recommendations or advice." "You are solely responsible for determining the suitability of any strategy."

So even though Public Advisors LLC is the RIA of record, Public still appends explicit not-advice disclaimers — they are using the RIA registration as a safety net, not as a license to present outputs as professional recommendations.

Sources: - https://public.com/ai-agents (live) - Review: https://www.nerdwallet.com/reviews/investing/brokers/public (Morningstar framing) - Moneywise review (Public Premium feature description)

4. Order Routing, Custody, and PFOF Claims

The "no PFOF on stocks" claim — what it actually means

From Public's own help article and FINRA disclosures (verified live):

Substantiation of the claim

Public substantiates via transparency: they publish quarterly order-routing reports (Rule 606 reports), offer customers a choice of order-routing venues for equities (standard routing vs. paid exchange routing), and provide a fee schedule document at https://public.com/disclosures/fee-schedule. The "no PFOF" claim is comparative by implication (Robinhood, Webull use PFOF) but Public does not name competitors in their disclaimer copy.

Custody

Custody is held at Apex Clearing Corporation, a third-party clearing firm. Public does NOT hold customer assets itself. The customer agreement documents this: "Apex Clearing Corporation provides clearing and execution services."

Standard model language in Public's disclosures: - Brokerage accounts: SIPC coverage to $500,000 ($250,000 cash sublimit), with additional coverage to $100 million via supplemental insurance. - Cash accounts: FDIC coverage to $5 million via 20 partner banks.

Key pattern for Raxx: "Raxx does not custody assets" model language should mirror this: explicitly name the custodial party (whichever broker the user connects), disclaim any custody role by Raxx, and reference SIPC coverage as residing with the user's broker. Public's version: "Clearing and custody provided by [clearing firm], not by Public."

Sources: - https://help.public.com/en/articles/4847508-public-s-approach-to-pfof (returned 404 — VERIFY DIRECTLY) - https://help.public.com/en/articles/8609726-what-are-options-order-flow-rebates (live) - https://public.com/trade-options/resources/order-flow-rebate (live) - https://www.nerdwallet.com/reviews/investing/brokers/public (SIPC/custody confirmation)

5. Options Compliance Posture

FINRA Rule 2360 implementation

Public's options onboarding flow (per live help content and marketing page):

  1. User initiates options trading application
  2. Platform collects: equities/options trading experience, investment goals, financial situation, risk tolerance
  3. Platform evaluates appropriateness and assigns an options approval level
  4. ODD (Characteristics and Risks of Standardized Options) is delivered prior to account approval — accessible at public.com/ODD
  5. Users without approval are placed in an onboarding/waitlist flow

Approved strategies include: long calls, long puts, covered calls, cash-secured puts (basic levels), plus straddles, strangles, collars, debit/credit spreads, butterflies, and condors (advanced levels). This is a standard FINRA Rule 2360 tiered-approval structure.

Risk disclosure language (verbatim from live pages)

From the options marketing page:

"Options trading entails significant risk and is not appropriate for all investors. Please review the Characteristics and Risks of Standardized Options before considering any options strategy."

"Options are considered riskier than many other investments because they are leveraged instruments, meaning that a small investment can lead to large gains or losses."

"The potential for the total loss of your investment is higher than stocks or bonds."

Relevance to Raxx

Raxx ships an IC (iron condor) builder and options-chain viewer. Raxx is NOT executing trades — it is a non-custodial platform. This significantly reduces (but does not eliminate) options-related compliance exposure. However: - If Raxx proposes specific options structures to users, the "personalized advice" question under the Adviser Act is triggered regardless of who executes. - If Raxx users connect brokers and execute proposed structures, Raxx should disclaim any advisory role explicitly. - An ODD-style risk disclosure is not legally required of a non-BD, non-RIA platform — but it is defensively wise as a signal of sophistication and good faith.

Sources: - https://help.public.com/en/articles/8852206-how-do-i-trade-options-on-public-com (live) - https://public.com/invest/options-trading (live) - https://www.finra.org/rules-guidance/rulebooks/finra-rules/2360 (FINRA Rule 2360, primary)

6. Backtest-Style Features and Hypothetical Performance Disclosures

What Public has

Public operates two backtest-adjacent surfaces:

AI Agents / Generated Assets (active): - Users describe an investment strategy in plain language; the AI builds an investable index and backtests it against the S&P 500. - Disclaimer (verbatim, live): "Returns displayed by the backtest are hypothetical in nature, do not reflect actual investment results, and are not guarantees of future results. Results may vary with each use and over time." - Benchmark disclosure: "Indices are unmanaged, it is not possible to invest directly in a benchmark index, and returns for benchmark indices do not account for fees."

Planned (as of 2026-06-05): - A "Fear/Greed Index" is listed as a future data source ("soon") on the AI Agents page — indicating Public is moving toward sentiment signals. They have not yet shipped a sentiment-gated backtest comparable to what Raxx is planning with Option D.

The SEC Marketing Rule (Rule 206(4)-1) on hypothetical performance

This rule governs investment advisers' use of hypothetical performance in marketing. Key constraints: 1. Policies and procedures must be in place to ensure hypothetical performance is shown only to appropriate audiences. 2. Sufficient information must accompany results to allow the audience to understand risks and limitations. 3. Hypothetical performance must NOT be shown on publicly accessible websites — April 2024 SEC enforcement actions against five advisers for this exact violation.

Critical caveat: The SEC Marketing Rule applies to registered investment advisers. Raxx is NOT a registered RIA. However: - If Raxx is later deemed to be providing investment advice (under S7-18-22 expansion of the adviser definition), the Marketing Rule would apply retroactively to your backtest displays. - Even as a non-RIA, displaying hypothetical performance that is misleading or deceptive could expose Raxx to SEC or FTC enforcement under anti-fraud provisions. - Best practice regardless of registration status: apply the same disclaimer language Public uses, restrict detailed backtest results behind a login gate (not public-facing), and avoid displaying results in ways that could be construed as performance advertising.

Sources: - https://public.com/ai-agents (backtest disclaimer, verbatim, live) - https://www.sec.gov/rules-regulations/staff-guidance/division-investment-management-frequently-asked-questions/marketing-compliance-frequently-asked-questions - https://wolf.financial/blog/hypothetical-performance-disclosure-compliance-marketing-guide - https://www.troutman.com/insights/the-secs-new-marketing-rule-practically-speaking-hypothetical-performance/

7. Comparative Claims and "No PFOF" Substantiation

How Public substantiates without naming names

Public's no-PFOF-on-stocks claim is supported by: 1. Published quarterly Rule 606 order-routing reports (mandatory for all BDs) 2. A customer-facing choice mechanism (opt into paid exchange routing) 3. The fee schedule document with rebate terms disclosed precisely

The claim is made in the affirmative ("Public does not accept PFOF for equities") rather than the comparative ("unlike Robinhood"). This is the safe framing for comparative claims under FINRA Rule 2210 (communications with the public): affirmative factual claims are easier to substantiate than competitor-comparative claims.

Pattern Raxx can adapt for the D-scope launch claim

The planned claim "Backtest your strategy. Understand how the market is positioning. Make your call." is promotional but not comparative. It does not name competitors and does not imply historical performance will repeat. This framing is relatively clean.

Riskier framing to avoid: "See how your iron condor performs in different market regimes" — this implies a forward-looking capability and could be read as implying predictive value. Safer: "See how similar setups played out historically under different sentiment conditions" — retrospective, user-data-anchored, no prediction.

Key principle from memory context: "Raxx never predicts; AI surfaces describe what DID happen on the user's own data with historical markers."

Sources: - https://public.com/disclosures/rebate-terms (options rebate terms, live) - https://www.finra.org/rules-guidance/notices/21-15 (FINRA Reg Notice on communications)

8. State-Level and International Posture

United States

Open to the Public Investing, Inc. (CRD 127818) is FINRA-registered and therefore has broker-dealer registration in all states that participate in FINRA's uniform broker-dealer registration system (effectively all 50 states + DC). State-specific carve-outs by product have not been publicly documented by Public for most features.

The NerdWallet 2026 review notes no explicit state-by-state restrictions on the standard product.

Options: FINRA Rule 2360 applies nationally; no state-level variation has been identified in publicly available disclosures.

Canada / Quebec

Public.com does not serve Canadian residents. Multiple third-party sources confirm this as of late 2025/early 2026: - https://brokerchooser.com/broker-reviews/publiccom-review/publiccom-canada - https://rankfi.com/ca/public/

Public made no attempt at a Quebec Bill-96-compliant French-language service. The approach was a clean geo-block of all Canadian users. Public's privacy policy references the Digital Advertising Alliance of Canada but contains no Quebec-specific privacy provisions — consistent with not serving Quebec users.

Implication for Raxx: Raxx's Quebec geo-block decision (locked 2026-05-09, per project memory) is the same posture as Public. This is the industry norm for US-only fintech products. The Raxx EU geo-block (locked 2026-05-19) similarly mirrors Public having no international service outside the US.

Sources: - https://brokerchooser.com/broker-reviews/publiccom-review/publiccom-canada - https://rankfi.com/ca/public/ (confirmed US-only as of 2026) - Public privacy policy (no Quebec provisions)

9. What Public Is NOT Doing That Raxx Will Do

The Raxx D-scope white space

Feature Public.com Raxx D-scope
Sentiment-gated backtesting Not shipped; "Fear/Greed Index" listed as "soon" Core v1 differentiator
Options-derived sentiment overlay Not available Planned (IV, skew, put/call ratio regime segmentation)
User pre-commitment sentiment labels Not available The LCC flow — user labels their own regime expectation before seeing historical outcomes
Multi-leg structure backtesting (IC, spreads) Not available; backtest is index/equity only IC builder output fed into backtest engine
Non-custodial / BYOB model Custodial (Apex) Non-custodial — user's broker executes

The first-mover regulatory implication

Raxx's LCC sentiment-label flow is genuinely novel: the user declares their market sentiment reading, THEN the platform shows historically how that regime has behaved, THEN the user makes a structure decision. This flow is: - More defensible than "here's what to do": the user asserts the hypothesis; the platform only confirms/challenges it with historical data. - More aligned with the "fully retrospective on user's own data" principle in project memory. - Still at risk under the S7-18-22 rulemaking inquiry: if the platform uses "alternative data such as market sentiment... to build pricing predictors," the SEC has indicated interest in whether that constitutes investment advice.

The key structural protection: Raxx never takes the first step of saying "the market IS in regime X." The user asserts it; Raxx responds with historical data. This is a meaningfully different fact pattern from an AI that classifies the regime and then tells you what to trade.

Regulatory risk unique to Raxx's first-mover position

No enforcement guidance exists yet for sentiment-gated backtesting as a consumer product. Public has not shipped this. Tastytrade, ThinkorSwim, and other advanced platforms have backtest features but none paired specifically with an options-sentiment regime classifier at a retail price point. This means: 1. No established safe-harbor language exists — Raxx will need to write it. 2. The 2022 SEC information-providers inquiry (still pending) is the most relevant live regulatory threat to this specific feature design. 3. A securities attorney's opinion letter on the LCC flow would be highly valuable as a first-mover defense artifact — not because Raxx is currently regulated, but because having a contemporaneous legal analysis protects against future "you knew this was risky" enforcement narratives.

Compliance Posture Comparison Table

Dimension Public.com Proposed Raxx D-scope Gap / Risk
BD registration Yes — Open to the Public Investing, CRD 127818 None — non-custodial Raxx cannot execute trades; must disclaim this explicitly at every execution touchpoint
RIA registration Yes — Public Advisors LLC, CRD 318234 None Advisory-adjacent features (strategy proposals, sentiment analysis) carry Adviser Act risk; no registration buffer
Custody Apex Clearing (third party) None — user's broker Raxx must disclaim explicitly; language pattern exists from Public
Sentiment feature framing Not yet shipped; Fear/Greed "soon" Core D-scope feature First-mover; no established safe harbor; S7-18-22 is the live risk
Backtest disclaimers Shipped; clear hypothetical disclaimer Required by design Adapt Public's verbatim language; keep behind login gate
Social/community feed UGC + unsupervised-persons disclaimer Not planned for v1 N/A for D-scope launch
Options risk disclosures ODD delivery at approval (FINRA 2360) IC builder is display-only Non-BD = ODD not legally required; defensive disclosure still recommended
PFOF / compensation disclosure Full disclosure; quarterly 606 reports No order routing (non-custodial) Raxx should disclose compensation model (subscription/free); no 606 obligation
Marketing Rule (hypo perf) Backtest disclaimed; not on public page Must be gated Gate backtest results behind login; never on public marketing pages
State registration All 50 states (BD license) Pennsylvania (LLC formation state) Raxx's SaaS/non-custodial status means state securities registration is not triggered by BD activity; VERIFY with attorney
Canada/Quebec Geo-blocked Already geo-blocked (locked 2026-05-09) Aligned — no action needed
EU/EEA US-only Already geo-blocked (locked 2026-05-19) Aligned — no action needed

Lessons for Raxx D-scope — Actionable

Use directly

  1. Backtest disclaimer language. Public's verbatim text is the industry standard: "Returns displayed by the backtest are hypothetical in nature, do not reflect actual investment results, and are not guarantees of future results. Results may vary with each use and over time." Use this verbatim or adapt closely. CRITICAL: display this disclaimer inline with every backtest result, not just in ToS.

  2. "Not a supervised person" framing for community / AI outputs. If Raxx ever ships community features, the legal frame is: users are not supervised persons of Raxx; content is UGC not advice; Raxx does not monitor or endorse it. For AI-generated outputs: "Outputs are provided for informational and illustrative purposes only and should not be considered investment recommendations or advice. You are solely responsible for determining the suitability of any strategy." This is Public Advisors LLC's own language from their AI Agents page — adapted for non-RIA use.

  3. Custody disclaimer model. "Raxx does not hold, custody, or clear your assets. All trades are executed through your connected broker. Securities are held by your broker's clearing firm. Raxx has no role in custody or trade execution." Vary as needed per broker connection but this is the structural frame.

  4. Options risk acknowledgment. Even though Raxx is not a BD and ODD delivery is not legally required, displaying options risk language at IC builder entry is defensively sound. Use the OCC ODD language: "Options trading entails significant risk and is not appropriate for all investors. Options investors can rapidly lose the value of their investment in a short period of time."

  5. "No PFOF" framing equivalent for Raxx. Raxx's equivalent is: "Raxx does not route or receive compensation from your order flow. Your broker determines execution." This is clean because it is true and differentiates from any custodial platform.

Approach carefully

  1. Sentiment classification as a product feature. Public has NOT shipped this; the SEC has flagged sentiment-as-service in the 2022 information-providers inquiry. The defensible framing for Raxx: the platform displays historical aggregate market conditions segmented by regime (IV, skew, news sentiment), and the USER maps their own thesis onto that data. Raxx never says "you are in regime X." The user asserts it. The distinction between "display of historical aggregate data" and "personalized advice based on proprietary sentiment models" is the difference between a data tool and an investment adviser. Maintain that line rigorously in every user-facing surface, every marketing copy revision, and every engineering spec.

  2. Backtest results behind login, never on public pages. The SEC's April 2024 enforcement actions against five advisers were specifically for showing hypothetical performance on publicly accessible websites. Even though those actions targeted RIAs (and Raxx is not an RIA), the same fact pattern on a non-RIA could attract anti-fraud enforcement. Keep all backtest result UIs behind authenticated sessions. Marketing pages can describe the feature; they should not show illustrative backtest results.

Avoid entirely

  1. "What this week's best-performing strategy is" type surfaces. If Raxx ever aggregates and surfaces community strategy outcomes ranked by return, that is functionally a "what others are buying" / performance-chasing feature. Public deliberately does NOT rank community feed by performance. Raxx should have the same design guardrail: never surface aggregate strategy performance rankings in a way that implies a recommendation.

  2. The publisher's exclusion is NOT available to Raxx in the same way as it might be for a pure newsletter product. Raxx provides interactive, user-specific analysis based on the user's own data and strategy inputs. That is not "general and regular circulation" of impersonal advice. Do not build a legal theory around the publisher's exclusion for the sentiment/backtest features. The UGC + no-supervised-persons frame (for community) and the "historical data display, not advice" frame (for backtest) are the stronger arguments.

  3. Do not use Robinhood's copy-trading architecture as a model. Robinhood's Social feature (launched March 2026) lets users "copy" other traders — this is significantly closer to personalized advice than what Raxx is building. FINRA fined Webull $1.6M in May 2025 for failures around social media influencer supervision. The compliance overhead of copy-trading is high and not relevant to Raxx's D-scope.

Questions for a Securities Attorney

These are research-generated questions, not advice. A securities attorney licensed in Pennsylvania and familiar with broker-dealer, investment adviser, and fintech regulation should be retained to answer these.

  1. Does Raxx's D-scope backtest feature — specifically, displaying historical options strategy outcomes segmented by market sentiment regime based on a user's own structure inputs — constitute "investment advisory activity" under Section 202(a)(11) of the Advisers Act? Does the pending S7-18-22 rulemaking create near-term registration risk?

  2. What language must appear, and in what placements (at account creation, at each backtest run, in ToS), to preserve the "informational data display, not personalized advice" characterization of the sentiment-gated backtest feature? Is an opinion letter documenting this analysis worth obtaining before v1 launch?

  3. Does Raxx's LCC flow — where the USER asserts a sentiment regime and the platform shows historical outcomes — change the analysis compared to a platform that classifies the regime autonomously? Is user-assertion a meaningful legal distinction in the Adviser Act context?

  4. At what point does Raxx's IC builder (proposing specific option structures matched to a user-defined P/L target) cross from "tool" to "recommendation" under FINRA Rule 2111 (suitability) or Reg BI? Does Raxx's non-custodial, non-BD status mean Reg BI does not apply?

  5. If Raxx later adds a sentiment signal feed (news sentiment + social sentiment alongside options-derived sentiment), does that create a higher registration risk than options-only IV/skew data?

  6. Is there a safe-harbor letter, exemption, or no-action request Raxx should consider filing with the SEC before shipping the D-scope sentiment-backtest feature, given that no direct precedent exists?

Questions for a CPA / Tax Advisor

  1. Raxx earns subscription revenue (SaaS). Is any portion of revenue potentially characterized as investment advisory fees, which would trigger different tax treatment or self-employment tax exposure? (Pennsylvania LLC context.)

  2. If Raxx in the future shares a portion of options PFOF-style rebates with users (mirroring the Public model), how is that rebate income characterized for users? For Raxx?

Sources (Full List)