Broker authority guidance for dispatch alliance

I run Global Command Dispatch and I’m planning a pilot driver rewards program (CommandMiles) plus a group of independent dispatch companies (FreedomRoad Alliance). Before I operate any of this with a second dispatch company, I need legal-style guidance on whether my proposed load/referral flow would require broker authority/bond and what I should put in writing or avoid saying to brokers. Scope of work - Review my proposed model for CommandMiles + FreedomRoad Alliance (including the proposed load flow) and assess whether it triggers a need for broker authority and a bond. - Answer: if I build it this way, do I need broker authority and a bond? - If broker authority is required, identify which specific proposed step(s) create brokerage. - Advise what should be in writing before I add a second dispatch company (agreements/terms needed for the Alliance, dispatch-to-dispatch referral, and CommandMiles per-load fee). - Advise what I should not say to brokers (language/representations to avoid) based on the proposed structure. - Flag what would make the proposed model illegal and any clear red lines to avoid. - Deliver a written memo and do a call with me before I operate any of this with a second dispatch company (contract drafting can be quoted later). Show less Additional information - Nothing below is currently in operation except my dispatch company; CommandMiles is only a planned pilot on my carriers. - FreedomRoad Alliance: group of independent dispatch companies; rule is you can’t join unless you run CommandMiles (no CommandMiles, no seat). - Alliance would not be a carrier and would not be on the rate confirmation. - Proposed load flow details: broker calls Dispatcher A; A has no truck; A introduces Dispatcher B (in the Alliance/CommandMiles); broker sends a new rate con to B’s carrier; A is not on the con; B takes B’s dispatch % from B’s carrier; B pays A a flat referral fee (not off linehaul); driver earns CommandMiles on B’s load; B pays a flat CommandMiles per-load fee (carrier does not pay it; not taken off linehaul). - Carriers would pay $0 to the group; brokers would not join. Read more Company details - Company name: Global Command Dispatch - Trucking dispatch / logistics - I run a dispatch company that dispatches owner-operators as their agent, and carriers pay us a percentage.