Rhode Island = “Deregulated Zone” — NO state NIL statute (H 5082 failed in Senate 2021). “Regulatory Arbitrage through Inaction” = strategic advantage. Providence College: “Friar Family Collective” + “Calabria Revenue Share Challenge” + Devin Carter/CVS Health. URI: Dissolved “Rhody Excellence” INTO Foundation (Tom Ryan, CVS CEO) = tax deductibility strategy. Brown: Ivy League OPT-OUT + Choh v. Brown antitrust lawsuit. “Jock Tax” ~5.99% = recruiting disadvantage vs. FL/TX/TN. RIIL high school = Permitted but NO school IP (“brand-less” restriction). Here’s the complete guide.
Rhode Island’s NIL Evolution
Rhode Island = “Ocean State’s New Economy” — smallest state offers concentrated microcosm of three competing philosophies: hyper-commercialized professional model (PC), institutionalized hybrid model (URI), and recalcitrant traditionalist model (Brown).
NO State NIL Statute — H 5082 Failed:
- House Bill 5082 (Rep. Joseph Solomon Jr., D-Warwick): “Compensation for Students Participating in Intercollegiate Athletics Act”
- June 15, 2021: Passed RI House 69-1-5
- STALLED in Senate — never emerged from committee
- Reintroduced 2022, 2024, 2025 (paired with S 0036) — “held for further study”
- 2021: Failure viewed as liability (no “safe harbor”)
- 2025: Failure = strategic ADVANTAGE (“Deregulated Zone”)
“Regulatory Arbitrage through Inaction”:
- No state law = governed solely by NCAA Interim Policy + House settlement
- Avoided “Obsolescence Trap” (FL, AL had to repeal/amend restrictive laws)
- No “booster” restrictions limiting interaction with athletic department
- No state law barring institutional facilitation
- Enabled URI to dissolve collective into Foundation (would have been prohibited under H 5082)
Providence College — “High-Major Capitalist”:
- Private Catholic institution, Big East Conference
- Men’s basketball = primary marketing engine + revenue driver
- “Friar Family Collective”: Led by Michael Ferranti (Coast to Coast Promotional Products)
- For-profit entity, $1M+ annually to men’s basketball roster (2023-24)
- “Calabria Revenue Share Challenge”: Dollar-for-dollar match up to $250K for Men’s Basketball Revenue Share
- Moving toward employment-adjacent model (school = primary payor)
PC Case Studies — Bryce Hopkins + Devin Carter:
- Bryce Hopkins: Kentucky transfer, deals with Dunkin’, Southcoast Health, Snack Fanatics (custom chip brand)
- Hopkins: Signed with Priority Sports, then transferred to St. John’s (Rick Pitino, Mike Repole)
- “Arms race” dynamic: Even $1M collective outbid by deeper pockets
- Devin Carter: South Carolina transfer, partnered with CVS Health (Fortune 50, RI-based)
- CVS deal = beyond “local pizza” NIL — national corporate message
- Leveraging RI corporate HQs (CVS Woonsocket, Hasbro Pawtucket)
PC Infrastructure — “Friar Edge”:
- “AdvantEdge Marketplace” (Opendorse): Shoutouts, appearances, autographs
- “Friar Edge” program: Financial literacy + branding education
- One of FIRST school-specific marketplaces
URI — “Institutional Innovator”:
- State’s land-grant public institution
- DISSOLVED “Rhody Excellence” collective (late 2024)
- Operations ABSORBED by URI Foundation & Alumni Engagement
- Tom Ryan (former CVS CEO, major benefactor): Championed move
- “Foundation Model”: Potential TAX DEDUCTIBILITY (501(c)(3) umbrella)
- IRS GLAM 2023-004: Third-party collectives NOT tax-deductible
- URI argument: Foundation contributions support educational mission
- Advantage: 30-40% effective subsidy for high-bracket donors
URI — FCS Opt-In + Corporate Partnerships:
- CAA (football/FCS) + Atlantic 10 (basketball)
- OPTED IN to House revenue-sharing settlement (defensive move vs. CAA peers)
- Likely $1-3M spending (not $20.5M cap)
- Adidas + BSN Sports partnership renewed through 2030
- Newport Craft Brewing: “Rhody Ruckus Lager” + “Rhody Ram IPA”
- Unique: Coast to Coast Promotional Products manages NIL portal (same as PC)
Brown University — “Amateurist Fortress”:
- Ivy League: Collectively OPTED OUT of House revenue-sharing settlement
- No athletic scholarships (students first, admitted on academic merit)
- Opt-out saves short-term money but loses “release of claims” protection
- Vulnerable to antitrust lawsuits from athletes denied compensation
Choh v. Brown University — Antitrust Litigation:
- Tamenang Choh (former Brown basketball star 2017-2022, 3x All-Ivy) + Grace Kirk = lead plaintiffs
- Class-action lawsuit against Ivy League
- Allegation: Illegal price-fixing conspiracy (Sherman Act Section 1)
- Ivies “agreed” not to offer scholarships = fixed price of athletic labor at ZERO
- Brown endowment: $6B+; Ivy League combined: $170B+
- Ivy defense: Third-party NIL available; Plaintiffs: NOT substitute for institutional pay
Brown — “Bruno Exchange” + Bruno United:
- “Bruno Exchange” (Opendorse): Marketed as networking tool (not “pay-for-play”)
- Connects athletes with powerful alumni network for endorsement + mentorship
- Bruno United FC (youth soccer): Brown athletes paid to run clinics
- “Pure” NIL: Payment for services rendered (fits Ivy ethical framework)
“Jock Tax” ~5.99% — Recruiting Disadvantage:
- Rhode Island enforces “Jock Tax” (non-resident income tax)
- RI residents: NIL income subject to ~5.99% state income tax
- Net-income disadvantage vs. FL, TX, TN (0% state income tax)
- In dollar-by-dollar negotiations, 6% “haircut” = material factor
Why Rhode Island Matters:
Rhode Island = “Deregulated Zone” (H 5082 failed). “Regulatory Arbitrage through Inaction” = strategic advantage. PC: “Friar Family Collective” + CVS Health (Devin Carter). URI: Dissolved collective INTO Foundation (tax deductibility). Brown: Ivy League OPT-OUT + Choh v. Brown antitrust. ~5.99% “Jock Tax.” RIIL high school = Permitted (no school IP).
Rhode Island College NIL Rules
No state statute = governed by NCAA Interim Policy + House settlement + institutional policy. Three divergent models: PC (professionalization), URI (integration), Brown (resistance).
What Rhode Island Offers:
- “Deregulated Zone” (no restrictive state law)
- Institutional facilitation permitted
- Foundation integration possible (URI model)
- Note: ~5.99% state income tax
PC Infrastructure:
- “Friar Family Collective” (for-profit, $1M+ to basketball)
- “Calabria Revenue Share Challenge” (dollar-for-dollar match)
- “AdvantEdge Marketplace” + “Friar Edge” program
URI Infrastructure:
- URI Foundation & Alumni Engagement (absorbed “Rhody Excellence”)
- “Foundation Model” = potential tax deductibility
- CAA (FCS) opted IN to House settlement
Brown Infrastructure:
- “Bruno Exchange” (Opendorse, networking focus)
- Ivy League OPT-OUT from House settlement
- No athletic scholarships (antitrust risk: Choh lawsuit)
Rhode Island High School NIL Rules
RIIL (Rhode Island Interscholastic League) permits NIL but enforces strict “brand-less” restriction: NO school IP.
Key Facts:
- Governing Body: Rhode Island Interscholastic League (RIIL)
- Status: Permitted (with restrictions)
- Rule: Article 19
RIIL Article 19 — Permissibility:
NIL permitted for student-athletes. Rhode Island = “green” category (alongside MA, CT, NY, CA). No pay-for-play (compensation cannot be contingent on athletic performance). No inducements (NIL deals cannot be used to recruit transfers).
“Brand-Less” Restriction — NO School IP:
STRICT prohibition on using: School name, logo, mascot, facilities, or uniform. Athletes must appear in plain clothes (no jersey in ads). Economic impact: Significantly DEPRESSES market value of HS NIL deals. Creates “influencer economy” distinct from collegiate level. Market restricted to elite prospects with national recruiting fame OR massive social media followings independent of sport.
College vs. High School: Key Differences
| Feature | College (No State Statute) | High School (RIIL) |
|---|---|---|
| NIL Status | Legal (NCAA interim policy) | Permitted (restricted) |
| State Statute | NONE (H 5082 failed) | RIIL Article 19 |
| School IP Usage | Allowed (varies by institution) | PROHIBITED ("brand-less") |
| State Income Tax | ~5.99% | ~5.99% |
| Foundation Model | YES (URI) | N/A |
| Revenue Sharing | PC/URI: YES; Brown: NO | N/A |
| Pay-for-Play | House settlement terms | PROHIBITED |
| Inducements | House settlement terms | PROHIBITED |
The Key Distinction: Rhode Island = “Deregulated Zone” (H 5082 failed). PC: “Friar Family Collective” + revenue sharing. URI: Foundation integration (tax deductibility). Brown: Ivy League OPT-OUT (Choh antitrust risk). ~5.99% “Jock Tax.” RIIL permits HS NIL but NO school IP (“brand-less”).
What Rhode Island Athletes Can Do
College Athletes (PC/URI/Brown):
- Earn NIL compensation (NCAA interim policy)
- PC: Work with “Friar Family Collective,” “Calabria Revenue Share Challenge,” CVS Health-level deals
- URI: Work through URI Foundation (tax-deductible donations possible)
- Brown: “Bruno Exchange” networking + clinic-based NIL
- Sign endorsement deals with RI corporate HQs (CVS, Hasbro, Dunkin’)
- Monetize social media accounts
- Earn from camps, clinics, appearances
- Receive fan support through platforms like RallyFuel.
High School Athletes:
- Sign commercial endorsements (NO school affiliation)
- Social media monetization (NO school uniforms/logos);
- Autographs and appearances (in plain clothes)
- Note: “Brand-less” restriction significantly depresses market value.
What Rhode Island Athletes Cannot Do
College Athletes:
- Cannot endorse: gambling, tobacco, adult entertainment, controlled substances (NCAA rules)
- International students (F-1 visa): Cannot engage in active NIL on U.S. soil
- Brown athletes: No direct institutional revenue sharing (Ivy League opt-out).
High School Athletes:
- Cannot use school name, logo, mascot, facilities, or uniform in ANY commercial activity
- Cannot appear in ads wearing jersey
- Cannot accept pay-for-play (compensation contingent on performance)
- Cannot accept NIL as transfer inducement.
Both:
- Must pay RI state income tax (~5.99%) + federal
- Must maintain academic eligibility.
Compliance Requirements
For College Athletes:
PC:
- Work with “Friar Family Collective” (for-profit)Use “AdvantEdge Marketplace” (Opendorse)
- “Friar Edge” financial literacy program
URI:
- Work through URI Foundation & Alumni Engagement
- Understand “Foundation Model” implications
- Coast to Coast Promotional Products manages portal
Brown:
- “Bruno Exchange” (networking + mentorship)
- Understand Ivy League opt-out from revenue sharing
- “Pure” NIL (services rendered, e.g., clinics).
For High School Athletes:
- NEVER use school name, logo, mascot, facilities, or uniform
- Must appear in plain clothes
- No pay-for-play (not contingent on performance)
- No inducements (cannot be used to recruit transfers)
- Competition between public schools (North Kingstown, Barrington) and private powerhouses (Bishop Hendricken, La Salle Academy).
For Parents:
For college:
- No state statute = “Deregulated Zone” (NCAA + House settlement govern)
- PC = professionalization (revenue sharing, “Calabria Challenge”)
- URI = Foundation integration (potential tax deductibility)
- Brown = Ivy League opt-out (no revenue sharing, antitrust risk)
- ~5.99% state income tax (disadvantage vs. FL/TX/TN)
For high school:
- RIIL Article 19 permits NIL; STRICT “brand-less” restriction (no school IP)
- No pay-for-play, no inducements
“Market inefficiency”:
- Athletes can monetize personhood but NOT performance context.
How Fans Support Rhode Island Athletes
Rhode Island has passionate Friar, Ram, and Bear fans — and now they can directly support athletes through NIL.
College Athletes:
Platforms like RallyFuel enable Rhode Island fans to support athletes at:
- Providence College – Big East
- University of Rhode Island – CAA (Football) / Atlantic 10 (Basketball)
- Brown University – Ivy League
- All sports—Basketball, Football, and more
Rhode Island NIL Infrastructure:
PC “Friar Family Collective”: For-profit. Michael Ferranti (Coast to Coast Promotional Products). $1M+ to men’s basketball (2023-24). “Calabria Revenue Share Challenge” (dollar-for-dollar to $250K). “AdvantEdge Marketplace” + “Friar Edge” program. URI Foundation & Alumni Engagement: Absorbed “Rhody Excellence.” Tom Ryan (former CVS CEO). “Foundation Model” = potential tax deductibility. Coast to Coast manages portal. Brown “Bruno Exchange”: Opendorse networking. Alumni mentorship. “Pure” NIL (clinics, Bruno United FC). Sponsors: CVS Health (Devin Carter, Fortune 50). Dunkin’ (pan-RI). Del’s Lemonade, Iggy’s Doughboys (local cult brands).
How It Works:
1. Create an account on RallyFuel.com or the mobile app
2. Select your Rhode Island school affiliation
3. Browse verified athletes currently on your program’s roster
4. Fuel athletes you want to support
5. Track your support through your fan dashboard
How It Works: When you purchase Fan Fuel, you’re purchasing Conditional NIL Engagement Rights (CNERs). If conditions are met, RallyFuel or its affiliate offers an NIL Agreement to the athlete. If conditions aren’t met — for example, if an athlete transfers — you receive an automatic refund.
Conditional Protection: RallyFuel’s conditional model protects Fan Fuel with automatic refunds if athletes transfer or conditions aren’t met. Rhode Island fans can support players without financial risk.
Important: Fan support through RallyFuel is voluntary and conditional. Fuel purchases are not charitable donations. RallyFuel is not a guarantor that any athlete will accept an NIL Agreement. Purchasing Fan Fuel does not guarantee athletic performance, playing time, or any specific outcome.
High School Athletes:
Rhode Island high school athletes may pursue NIL opportunities under RIIL Article 19 provided they do not use school name, logo, mascot, facilities, or uniform in any commercial activity.
Learn More About the NIL Landscape
Name, Image, and Likeness plays an increasing role in college sports, and understanding how it works often requires more than individual articles or news updates.
RallyFuel is a platform focused on NIL-related topics across college athletics. It brings together information about athletes, NIL activity, and the broader structure behind modern college sports, helping readers explore the topic in more depth.
Frequently Asked Questions
Can Rhode Island high school athletes do NIL?
Yes, with strict limits. RIIL Article 19 permits NIL. “Brand-less” restriction: CANNOT use school name, logo, mascot, facilities, or uniform. Must appear in plain clothes. No pay-for-play (not contingent on performance). No inducements (cannot recruit transfers). Rhode Island = “green” category (alongside MA, CT, NY, CA). Economic impact: Significantly depresses market value — creates “influencer economy” distinct from collegiate level.
Why is Rhode Island a “Deregulated Zone”?
H 5082 passed RI House 69-1-5 (June 2021) but STALLED in Senate. Reintroduced 2022/2024/2025 — always “held for further study.” 2021: Failure viewed as liability (no “safe harbor”). 2025: Failure = strategic ADVANTAGE. No state law = governed solely by NCAA Interim Policy + House settlement. Avoided “Obsolescence Trap” (FL, AL had to repeal restrictive laws). Enabled URI to dissolve collective INTO Foundation (would have been prohibited under H 5082). No “booster” restrictions. No institutional facilitation bars.
What is URI’s “Foundation Model”?
URI DISSOLVED “Rhody Excellence” collective (late 2024). Operations ABSORBED by URI Foundation & Alumni Engagement (501(c)(3)). Tom Ryan (former CVS CEO) championed move. IRS GLAM 2023-004: Third-party collectives NOT tax-deductible. URI argument: Foundation contributions support educational mission. If revenue sharing = valid university expense, deductibility stronger. Advantage: 30-40% effective subsidy for high-bracket donors. Coast to Coast Promotional Products manages portal (same as PC).
What is Choh v. Brown University?
Class-action antitrust lawsuit against Ivy League. Tamenang Choh (former Brown basketball star 2017-2022, 3x All-Ivy) + Grace Kirk = lead plaintiffs. Allegation: Illegal price-fixing conspiracy (Sherman Act Section 1). Ivies “agreed” not to offer scholarships = fixed price of athletic labor at ZERO. Endowments: Brown $6B+; Ivy League combined $170B+. Ivy defense: Third-party NIL available. Plaintiffs: NOT substitute for institutional scholarships/revenue sharing. Brown opted OUT of House settlement = loses “release of claims” protection.
What is Rhode Island’s “Jock Tax” impact?
Rhode Island enforces non-resident income tax on athletes. RI residents: NIL income subject to ~5.99% state income tax. Net-income DISADVANTAGE vs. FL, TX, TN (0% state income tax). In dollar-by-dollar negotiations, 6% “haircut” = material recruiting disadvantage. As revenue sharing (“salaries”) begins, state tax authorities may become more aggressive.
What happens if an athlete I supported transfers?
If an athlete transfers or selects a different school during the conditional period, you receive an automatic refund to your original payment method. No manual request is required.
Rhode Island: The Ocean State’s New Economy
Rhode Island = “Deregulated Zone” — NO state NIL statute (H 5082 passed House 69-1-5 in June 2021, stalled in Senate; reintroduced 2022/2024/2025, always “held for further study”). “Regulatory Arbitrage through Inaction” = strategic advantage (avoided “Obsolescence Trap”). Providence College: “Friar Family Collective” (for-profit, Michael Ferranti, $1M+ to basketball); “Calabria Revenue Share Challenge” (dollar-for-dollar to $250K); Devin Carter → CVS Health (Fortune 50); “AdvantEdge Marketplace” + “Friar Edge” program. URI: DISSOLVED “Rhody Excellence” collective INTO URI Foundation & Alumni Engagement (late 2024); Tom Ryan (former CVS CEO); “Foundation Model” = potential tax deductibility; FCS (CAA) OPTED IN to House settlement. Brown: Ivy League OPT-OUT from House settlement; Choh v. Brown University antitrust lawsuit (Sherman Act Section 1, price-fixing); “Bruno Exchange” (networking) + Bruno United FC (clinics). “Jock Tax” ~5.99% = recruiting disadvantage vs. FL/TX/TN. RIIL high school: Article 19 permits NIL but “brand-less” restriction (NO school name, logo, mascot, facilities, uniform); no pay-for-play; no inducements. Corporate sponsors: CVS Health, Dunkin’, Del’s Lemonade, Iggy’s Doughboys.
For college athletes ready to maximize their NIL potential, RallyFuel provides fan-powered support with conditional protection. Explore verified Rhode Island athletes and start fueling today.


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