`docs/03-roadmap-and-budget.md`

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# Roadmap & Budget — National Unclaimed Property Platform

_Cycle 3 artifact. All figures are illustrative estimates based on the regulatory matrix,
architecture, and comparable government-data-services deployments. Verify against current
state data-use agreement costs and actual infrastructure procurement before commitment._

---

## Phases

### Phase 0 — Regulatory & Legal Foundation (Months 1–3)
**Goal:** signed data-use agreements with 5–10 pilot states; legal clearance on the
finder-fee model; a compliance officer embedded in the workflow.

Key gates:
- Letter of intent with ≥3 states (TX, CA, FL as primary targets — largest programs)
- Outside counsel opinion on Cal. Bus. & Prof. Code §6155 (finder restrictions)
- Business entity formed; errors & omissions insurance in place
- All "Standing Steve-gates" (state contracts, fund custody, entitlement adjudication)
  reviewed and confirmed out-of-scope for the platform

### Phase 1 — Pilot (Months 3–9)
**Goal:** live with ≤3 states, SAMPLE→real data, first 100 rightful-owner matches confirmed
by state adjudication, first paid government participation contract signed.

Milestone checklist:
- [ ] Replace synthetic SAMPLE jurisdiction with ≥1 real state feed (NAUPA II)
- [ ] AES-256-GCM at-rest encryption wired (Sec 2.5 marker → implementation)
- [ ] Rate-limiter stub → real sliding-window rate limiter (brute-force guard)
- [ ] Matcher weights calibrated against ≥500 state-adjudicated positive pairs
- [ ] Fairness audit across name distributions (English/Spanish/Vietnamese/Chinese/Arabic)
- [ ] Public search UI live (masked results only, no raw PII displayed)
- [ ] Claim workflow end-to-end with pilot state: DRAFT→SUBMITTED_TO_STATE→adjudicated
- [ ] First confirmed payment from a state to a rightful owner (platform-assisted)

### Phase 2 — Scale (Months 9–24)
**Goal:** all 53 jurisdictions active; 10k+ claims submitted; operational breakeven.

Key work:
- NAUPA III XML parser production-hardened (Cycle 3 stub → production)
- Per-jurisdiction policy config driving mask depth and finder-fee cap enforcement
- Holder portal (companies self-filing to us rather than directly to state) — optional
- Staff adjudication-support UI for states to track their DUE queue
- Double Metaphone phonetic upgrade for international name recall
- Billing + finder-fee collection automation

### Phase 3 — Enterprise / API (Months 24–36)
**Goal:** B2B API for law firms, CPA networks, estate attorneys, and financial advisors
who have signed finder agreements with property owners.

Key work:
- Tiered API plan (bulk-lookup, per-query, SaaS)
- Webhook on claim status change → integrator's endpoint
- ISO 27001 audit prep (required by enterprise clients)
- State partner program (revenue share to states that co-market the service)

---

## Budget Model

### Capital (Pre-Revenue) — Conservative / Aggressive

| Category | Conservative | Aggressive |
|---|---|---|
| Legal (DUAs × 53, counsel, compliance) | $800k | $1.2M |
| Engineering (4 FTE × 18 mo) | $1.8M | $2.4M |
| Infra (cloud, KMS, audit logs) | $200k | $400k |
| Data licensing (state fees, background check APIs) | $400k | $800k |
| G&A / insurance / E&O | $400k | $600k |
| Marketing / rightful-owner outreach | $600k | $1.2M |
| Contingency (15%) | $600k | $1.0M |
| **Total** | **$4.8M** | **$7.6M** |

### Revenue Model (Year 3 Steady State) — GOVERNMENT-FIRST (B2G)

> **Reconciled 2026-08 to match `docs/00-thesis-and-guardrails.md` and the source brief.**
> An earlier draft of this table modeled **consumer finder fees** as the primary revenue
> stream. That is explicitly EXCLUDED at launch: taking a % of a claimant's recovery makes
> the platform a regulated *finder* (finder-law exposure in every state, FTC scam-adjacency,
> and direct conflict with the state agencies that are the real customer). Consumer search
> and claim initiation stay **free**. Revenue comes from **government**. If a finder/estate
> line is ever added, it is a separate, later, compliance-gated decision — never the base model.

| Revenue stream | Buyer | Basis | ARR (illustrative) |
|---|---|---|---:|
| Annual platform participation | State / NAUPA | population/volume tier | 35 jur × ~$250k = $8.75M |
| Feed onboarding & migration | State | one-time implementation | (amortized separately) |
| White-label state search portal | State | annual software + support | included above / upsell |
| Claim-workflow module | State | annual or per-claim | upsell on participation |
| Identity & document verification | State | pass-through + margin | upsell |
| Authorized partner API (gov/regulated institution) | Gov / regulated FI | contracted usage tiers | modest, contract-gated |
| **Total recurring (base)** | | | **~$8.75M+ ARR** |

At 35 participating jurisdictions the government-subscription base alone clears the earlier
$4.2M target ~2×, without any contingent consumer fee. Break-even is driven by how fast
jurisdictions sign, not by claimant volume.

---

## Hard Limits (Non-Negotiable)

These are architectural, not commercial — violating them risks license revocation or
state-partner termination:

1. **No custody of funds.** The platform never holds, transmits, or escrows unclaimed
   property cash. States pay rightful owners directly. The platform's role ends at
   verified-claim submission.
2. **State is the adjudicator.** The platform provides EVIDENCE; the state decides
   entitlement. No "pre-approved" or "guaranteed" language in user-facing copy.
3. **No unauthorized data acquisition.** Ingestion accepts authorized state feeds only.
   Web scraping of state portals is a terms-of-service violation and potentially
   a Computer Fraud and Abuse Act exposure.
4. **Masked results only on anonymous search.** Rightful owners see their own data after
   identity verification; unauthenticated search shows C••• O••• (constant-width mask).
5. **No contingent finder fees at launch.** The base model is government-paid (B2G); the
   platform does NOT take a percentage of a claimant's recovery. Statutory finder-fee caps
   are catalogued in `docs/jurisdictions.json` (e.g. CA 10%, IL 10%, TX 10%, FL ≤30%) ONLY
   so that IF a compliance-gated finder/estate line is ever added later, the billing engine
   can enforce the lowest applicable cap per claim. Until then, this limit means: don't
   build a finder product by default.