The “new-ish” framework governing Name, Image, and Likeness (NIL) compensation for student-athletes continues to mature after the NCAA-House settlement. Recent guidance from the College Sports Commission introduces new requirements for disclosure and compliance, centered on a critical concept: “valid business purpose.” For student athletes and potential sponsors, understanding this refined-but-still-tricky definition will be essential for structuring permissible and effective NIL agreements.

On June 7, 2025, a new era of oversight began, mandating that NCAA Division I student-athletes report third-party NIL deals valued at $600 or more through a new portal, NIL Go. This system, developed with Deloitte, is designed to vet agreements against key criteria, ensuring they are commercially sound and not merely a pretext for pay-for-play. The problem is that NIL Go has been functioning far from perfectly.

The oversight will continue and the new guidance may accelerate some NIL deal review. The Commission’s evaluation rests on three pillars: the payor’s association with the school, a reasonable range of compensation, and, most notably, the existence of a “valid business purpose.”

The Core of Compliance: Valid Business Purpose (VBP)

The CSC guidance specifies that a deal must have a legitimate commercial rationale. The core of the VBP requirement is that the entity paying the student-athlete must be “seeking the use of the student-athlete’s NIL for a valid business purpose, meaning to sell a good or service to the public for profit” (¶ 14).

This standard directly targets arrangements where the primary goal is to channel funds to athletes rather than to promote a public-facing commercial enterprise.

The guidance states, “An entity with a business purpose of providing payments or benefits to student-athletes or institutions, rather than providing goods or services to the general public for profit, does not satisfy the valid business purpose requirement” (¶ 15).

Deconstructing a Tricky Example

The College Sports Commission provided a specific, and potentially challenging, example to illustrate this point.

The guidance clarifies that certain activities undertaken by NIL collectives—entities often formed with the express purpose of supporting a particular school’s athletes—do not meet the VBP standard on their own.

Consider the hypothetical situation presented:

“For example, a NIL collective that has a business purpose to pay student-athletes associated with a particular school or schools does not satisfy Rule 22.1.3 when it reaches a deal with a student-athlete to make an appearance on behalf of the collective at an event even if that event is open to the general public and the collective charges an admission fee (e.g., a golf tournament).

In this example, the NIL collective’s purpose is to raise money at the event to pay that student-athlete and potentially fund deals with other student-athletes at that school, which are not goods or services available to the general public for profit.” (¶ 16)

This logic extends to merchandise sales. If the “whole purpose in selling merchandise is to raise money to pay that student-athlete and potentially other student-athletes at a particular school or schools,” it is not considered a valid business purpose (¶ 17).

The distinction is subtle but significant. The primary purpose of the transaction determines its validity. If the collective’s activity—be it a golf tournament or a t-shirt sale—is fundamentally a fundraising mechanism to pay players, it fails the VBP test. The “good or service” (the event ticket or the merchandise) is incidental to the non-compliant purpose of athlete payment.

A Path Forward for Collectives and Brands

This CSC guidance does not foreclose opportunities for collectives or the businesses that support them. Instead, it directs them toward an allegedly more compliant operational model.

The Commission notes that these same deals would be permissible if the entity paying the student-athlete and receiving the public’s money were a genuine business with a purpose beyond paying athletes, such as “a golf course, an apparel company” (¶ 18).

This points to a viable path: NIL collectives—if they still exist—can potentially function as marketing agencies. They can broker deals between student-athletes and legitimate businesses that seek to use an athlete’s NIL to promote their actual goods and services.

The guidance explicitly allows for this, mandating that there is “documentation establishing that the sources of those specific funds were the entities with a valid business purpose that received the benefit of the student’s NIL” (¶ 19).

For schools, athletes, and the brands they represent, this clarification underscores the importance of proper structuring and documentation—good for all the lawyers and agents. When engaging a student-athlete, especially through an intermediary like a collective, the commercial logic needs to be clear. (Disclaimer: This is provided for informational purposes only and does not constitute legal or financial advice.)

It sounds like the agreement should demonstrate that the athlete’s NIL is being used to drive sales or promote a bona fide business, not simply as a pass-through for compensation.

While these new rules introduce compliance burdens for unsophisticated student-athletes, they may also offer a clearer, if narrower, path for legitimate commercial partnerships in the collegiate sports arena.

If certain programs are gaming the system (e.g., football-focused schools) to exceed the $20.5 million revenue sharing cap, then perhaps this enforcement catches or deters using unclean NIL funds for pay-to-play salaries.

NASHVILLE, Tenn. — Tennessee State is delaying the inaugural season of its men’s hockey program by a year as the school addresses financial issues associated with launching the program.

The Tigers will now start playing in the 2026-27 season rather than in 2025-26.

Tennessee State announced in June 2023 that it was planning to become the first historically Black college and university to sponsor Division I men’s hockey. Duanté Abercrombie was hired as the program’s first head coach in April 2024.

The decision to delay the start of competition was made by the school in collaboration with the NHL, Nashville Predators and College Hockey Inc., and that it reflected their “shared commitment to building a sustainable and competitive program.”

“We agree that an additional year will provide the program with the time and resources it needs to launch at full strength and with long-term financial success in mind,” Tennessee State interim president Dwayne Tucker said in a statement. “The extra preparation period will focus on recruiting, facility planning, staff development, and fundraising efforts. It also aligns with a broader vision to grow the sport of hockey in diverse communities.”

The release announcing the move noted that the school had received a $250,000 grant from the NHL/National Hockey League Players Association and continued support from the Predators.

“Deferring the inaugural season of TSU Tigers hockey to 2026-27 is the right step to build a foundation worthy of the university,” said Kevin Westgarth, the NHL’s vice president of hockey development and strategic collaboration. “TSU has faced challenges before and always met them and come back stronger, and we expect hockey to be the latest chapter of that story.”

NEW HAVEN, Conn. – The Yale field hockey team will welcome seven first years to the roster as part of the Class of 2029. The Bulldogs announced the class Thursday.

The incoming class comes from four countries: England, Germany, Scotland and the United States. It includes two goalkeepers, one back/forward, one back/midfielder, one forward/midfielder, one midfielder and one midfielder/forward.

The members of the Class of 2029 come from successful programs, with all having won at least one championship at the national, regional, state, league or tournament level. They have also demonstrated leadership skills, as four have served as captains of teams.

The incomings have found multiple ways to contribute to their communities, volunteering at a church, at Easter Seals, at a microenterprise initiative empowering refugee women in Houston, at the Special Olympics World Games and at triathlons. They have spent time coaching younger players and tutoring students in subjects such as math and science. Their accomplishments also include winning a social enterprise challenge and being the first author on a peer-reviewed publication assessing gender-based disparities in NCAA athlete injury research.

The Class of 2029 will join a core group of returnees for Melissa Gonzalez, who enters her fourth year as Yale’s Caroline Ruth Thompson ’02 Head Coach of Field Hockey. Yale returns four players who made 14 or more starts in 2024, when the Bulldogs came within one win of making the Ivy League Tournament. Assistant coaches Belle Bressler and Kerry Kiddoo return as well.

Here is a look at the incoming Bulldogs:

 

Carys Donahoe

#8

Midfielder

5-4

Annapolis, Md.

Archbishop Spalding High School

USA Field Hockey: Selected to Nexus Championships in 2022, 2023 and 2024… Third Place at AAU Junior Olympics 2022.

Archbishop Spalding High School: Field hockey team captain senior year… First team All-IAAM (A Conference)… Max Field Hockey Top 100 Class of 2025… Team won one IAAM A Conference Championship; three-time runners-up during her career… Also played lacrosse.

Freedom: Placed second at National Club Championships in 2023.

Notes: Played for Maryland United Club Lacrosse for multiple years… Volunteer field hockey coach at high school’s summer camp… Volunteer Eucharistic Minister for school church (from the Archdiocese of Baltimore)… Father, Jerry Donahoe, wrestled at United States Naval Academy (Class of ’94)… Sister, Laney Donahoe, plays lacrosse at United States Coast Guard Academy (Class of ’28).

Why Yale? “I chose Yale because it is a school that will provide me with a uniquely diverse college experience that will challenge me academically and athletically — which was something I couldn’t pass up on.”

 

Carys Isherwood

#6

Back/Midfielder

5-3

London, England

Alleyn’s School

England Hockey: U18 England squad 2023-2025… U18 8 nations bronze medallists 2024… U18 captain for Ireland series… U16 squad 2022-2023… U16 captain for Scotland series.

Alleyn’s School: Field hockey 1XI 2021-2025; captain 2024-2025… football (soccer) 1XI 2022-2024… David Fournel Trophy for outstanding sports achievement 2024… Physical education academic award 2024… ISHC National cup winner 2024… England hockey national trophy winner 2024… Best sports team award 2024… Upper school hockey award 2023… Middle school hockey award 2022… Eliot Pugh sports outreach award 2022.

Hampstead and Westminster HC: Ladies 1’s Premier League 2024-2025… Premier League winners 2025… European trophy winner 2025… Most improved player of the season 2024-2025… Ladies 2’s National League player 2023-2024.

London Wayfarers: Ladies 1’s national league 2022-2023… London Premier League winners 2022… London Division 1 league winners 2021.

Notes: Coach at Tulse Hill and Dulwich HC… Volunteer coach in THD Phoenix Programme… Volunteer coach at Alleyn’s Academy Outreach Programme… Math and science tutor… Volunteer at local primary schools teaching math and science… Volunteer at COVID vaccination centers 2021… Member of combined cadet force 2021-2023… Won social enterprise challenge 2024.

Why Yale?: “Yale’s impressive combination of athletics, academics and community creates an amazing environment for me to learn and challenge myself both on and off the field.”

 

Lore Laniyan

#3

Back/Forward

5-3

Houston, Texas

St. John’s School

St. John’s School: Scored 10 goals senior season and won Senior Award… Team was two-time Southwest Preparatory Conference 4A championship winners… NFHCA Scholar of Distinction in 2023 and 2024… Also played lacrosse and soccer as a freshman.

U19 Texas Pride: Second place U19 Regional Club Championship 2025… Ranked No. 2 in the country by USA Field Hockey 2024.

 

Notes: Coached field hockey at Texas Pride Field Hockey and did lessons with younger girls… Led a mentorship program for black middle school girls at her high school… Volunteered at Houston Museum of Natural Science… Enjoys designing and 3D printing jewelry… Hobbies also include film photography, baking, pilates and nail art… Favorite soccer team is Arsenal… Brother, Layo, is currently attending Yale School of Medicine.

Why Yale? “I believed that Yale would provide me with the opportunities to discover what I want to do in life while also having a community that will support me and continue to shape me into a better person. The caliber of academics, athletics and community at Yale is incredible and incomparable to most schools in the United States and since I am always striving for excellence, I knew it was a place I’d love to be.”  

 

Emma Mueller

#15

Midfielder/Forward

5-8

Barrington, R.I.

Barrington High School

USA Field Hockey: Selected for USA Field Hockey Nexus program in 2021, 2022, 2023, 2024 and 2025.

Barrington High School: Rhode Island Player of the Year Nominee 2022, 2023, 2024… Ray Biber All-State Award 2023, 2024, 2025… First team Providence Journal all-state 2022, 2023, 2024… Second team Providence Journal all-state 2021… RI Field Hockey Coaches Association All-Division 2021, 2022, 2023, 2024… RIIL All-Tournament Team 2023… WJAR Friday Night Rivals Scholar Athlete of the Week September 2024… RIIL Scholar Athlete of the Year Nominee 2025… Led high school in goals junior and senior years… Team was four-time state semi-finalists… First team All-American in fencing 2021-2025.

Club Team: U19 National Club Championship ninth place 2024… U16 National Club Championship eighth place 2023… U16 National Indoor Tournament pool winner 2022… U16 Regional Club Championships first place 2023… U19 Regional Club Championships first place 2024.

Notes: Volunteered at Special Olympics World Games in Berlin, Germany in June 2023… First author on peer-reviewed publication assessing gender-based disparities in NCAA athlete injury research… Volunteer coach for local youth field hockey… Volunteer tutor… Hobbies include kitesurfing and skiing… Older sister Victoria graduated from Columbia in 2023… Older sister Vivienne plays field hockey at Cornell… Father Marian plays USA Masters field hockey and was captain at 2022 WMH Masters World Cup in Cape Town, South Africa.

Why Yale? “Yale stood out to me because I saw a place where I could challenge myself academically and athletically while being surrounded by people who are both highly ambitious and supportive. I am very excited about the opportunity to grow in a diverse and curious academic environment and to contribute to the competitive and motivated field hockey team!”

 

Ella Ou

#19

Forward/Midfielder

5-3

Houston, Texas

The Kinkaid School

USA Field Hockey: Nexus National Championship 2021, 2022, 2023, 2024 and 2025… Nexus National Championship Silver Medal 2021, 2023.

Texas Pride Field Hockey: First place at U19 Regional Club Championship 2024… Silver medal at National Club Championship 2024… Second place U19 Regional Club Championship 2025…

The Kinkaid School: Varsity Field Hockey 2021-2024; captain 2024… MAX Field Hockey Top 150 Players Class of 2025… NFHCA Scholar of Distinction 2022, 2023, 2024, 2025… Leading scorer 2024 season (20 goals, 10 assists)… All-South Zone 2025… Team was Southern Preparatory Conference first place 2021, Southwest Preparatory Conference runners-up 2022, 2023, 2024.

Notes: Volunteered for The Community Cloth Houston for Refugees… Volunteered for Easter Seals… Coached Pride Field Hockey Camps and private lessons for girls of all ages… Multiple Ivy Leaguers in her family… Father, Richard Ou, was on varsity swimming and diving team at Harvard for your years, served as captain (graduated in 1994)… Uncle Jerry Ou, played varsity water polo at Harvard (graduated in 1998)… Mother, Sophia Ou, attended Penn (graduated in 1996)… Sister, Natalie Ou, attends Penn (class of 2026).

Why Yale? “I chose Yale because it’s a place where I know I’ll be pushed to grow both academically and athletically. When I visited, I was struck by how welcoming and driven the community was. The field hockey program is competitive and full of teammates and staff who really care about each other. I could see myself not only becoming a better player, but also growing as a person.”

 

Amelie Schwarzkopf

#42

Goalkeeper

5-6

Berlin, Germany

Dreilinden Gymnasium

National Team: 2022 U16 games against France and England… 2024 U18 games against England and Poland.

Berlin State Team: Competed 2017-2022.

Club Team (Berliner Hockey Club) (Women’s/Seniors): Made her first appearance for 1.Damen (women’s senior team) during 2024-25 indoor season in 1.Bundesliga (highest league)…  Indoor German Vize Champion 2025 (1.Hallenbundesliga)… Outdoor season 2024-25: reached the quarterfinals.

Club Team (Berliner Hockey Club) (Youth): Four-time Berlin State Champion (2018, 2022, 2024 Outdoor; 2019 indoor)…  2023-24 indoor: fifth place at German U18 Championship… 2024 outdoor: third place at German U18 Championship… Selected at both German championships as goalie of the tournament (all-star team)… 2025 third place at U18 EHCO trophy (youth format of the EHL).

Dreilinden Gymnasium: Graduated top five of her class 2024 (fourth-best point score for the Abitur)… Junior and senior years: spokeswomen/representative for graduating class (part of a team of spokespersons)… Organized graduation ceremony.

Notes: Has played field hockey since she was three years old and goalie since she was 12… Volunteer hockey coach at her club, organizes camps… Volunteer at 2019 German triathlon championship… Volunteer at triathlon competitions of her triathlon club… Volunteer at 2018 Indoor Field Hockey World Championship Tournament in Berlin as ball girl… Participated in Berlin cross country championship and finished seventh… Also did triathlon competitively until the age of 13, and has occasionally done triathlons since… Likes to mountain bike and swim… Enjoys playing board games with friends and cooking.

Why Yale? “I chose Yale because it offers  me a unique opportunity to develop in many different ways. Everyone at Yale has been extremely helpful, making me feel welcome and supported from day one.”

 

Maddie Shepherd

#90

Goalkeeper

5-5

Edinburgh, Scotland

Trinity Academy

U18/U16 Scotland National Teams: Selected to play in 2024 Four Nations tournament; Played in all four games against Germany, Belgium and England; Named coaches player of the tournament… Selected to play in 2024 England series… Selected to play in 2024 Ulster series (series win)… Selected to Brave Emerging Scotland Academy training squad 2022-2023… Selected for Brave Emerging Brave Cup 2023 squad… Selected to Brave Aspiring Scotland Academy training squad 2023-2024… Selected to Brave Aspiring Scotland Academy training squad 2024-2025… Selected to play in 2025 6 nations tournament against USA, England, Czech, Poland, Spain; named player of match for USA vs. Scotland… Selected to play in 2025 Ulster series (series win)… Team was Brave Cup winners 2023 and 2024… 2023 U16 Scottish Cup club finalists (second place)… National district winners 2022… 13 caps gained. 

Gaelic Football: U18 captain.

Trinity Academy: 2025 SPOTY winner… Field hockey first 11 vice captain.

Notes: Brown belt in karate… World-champion kick-boxer.

Why Yale? “Choosing to study at Yale and become a member of the YFH wasn’t a difficult decision. The combination of academic excellence, field hockey opportunities and its inclusive, supportive, environment, was a no brainer. I can’t wait to get on campus and begin my journey as a Bulldog.”

Name, image and likeness collectives — a staple in the college landscape since 2021 – must do more than simply pay college athletes under new guidance from the College Sports Commission.

The commission, created by the four biggest revenue-generating conferences to enforce terms of the House settlement, said collectives or any entity wishing to pay players must meet a “valid business purpose” standard. The commission sent a letter to athletics directors at NCAA Division I schools Thursday with an update on the number of deals approved and the additional guidance.

“An entity with a business purpose of providing payments or benefits to student-athletes or institutions, rather than providing goods or services to the general public for profit, does not satisfy the valid business purpose requirement,” the commission wrote in its letter and posted on its website.

More than 1,500 deals have been cleared, including seven-figure agreements. More than 12,000 athletes have registered and been approved to use the NIL Go system, which functions as a clearinghouse for NIL deals worth more than $600. In recent days, the commission has begun telling athletes that their deals were not cleared.

“Since many of these deals cannot be cleared for similar reasons, we are providing additional guidance,” the commission wrote.

The commission included examples of deals that won’t be approved, including paying an athlete to promote the sale of merchandise in order to raise money to pay the athletes or others at the school. Or paying an athlete to make an appearance at an event, such as a golf tournament, since the purpose of the collective is to pay athletes associated with a particular school.

The commission said that NIL collectives “may act as marketing agencies that match student-athletes with businesses that have a valid business purpose and seek to use the student’s NIL to promote their business.”

Bryan Seeley, a former MLB executive, is the chief executive officer of the commission, and former Washington Nationals executive John Bramlette is its head of operations and deputy general counsel.

Leaders in college athletics hoped the new structure would limit the money flowing into college sports and provide some guardrails.

“The idea that you’re going to be a social media influencer or you’re going to be able to create economic value for a business and, therefore, monetize your name, image and likeness, that’s what the intent was,” UNC athletics director Bubba Cunningham said in May. 

“But the collectives were really collecting money so that we could pay players to play on our team, and we’ve done that now for three or four years.”

The House settlement – under which the NCAA and its member schools will pay nearly $3B to former athletes – allows for schools to directly pay athletes up to $20.5 million this year. 

And with a new NIL Go clearinghouse, deals will face scrutiny.

“To ensure that it is a fair-market value test, that there is a range of compensation that is actually legitimate, that you can’t get paid $5,000 to sign an autograph,” Cunningham said.

Brand deals such as those signed by former Duke star Cooper Flagg to endorse Gatorade or New Balance must also go through the clearinghouse. But those clearly meet the “valid business purpose” standard.

Deals in NIL Go are either cleared, not cleared or flagged for additional review, according to the commission. NIL Go is reportedly holding up deals, frustrating some around college athletics.

The One Pack NIL Collective at NC State sells memberships to fans and supporters. The membership packages start at $10 per month and range up to $500 per month. Each membership level comes with certain benefits, including, for top donors, lunch or dinner with One Pack athletes. The collective pays athletes with the money it generates from membership sales.

“We’re in the business of providing fan experiences and those moments people want to pay for to drive revenue so the collective has the resources it needs to attract and retain the players that are going to have the most impact at NC State,” Chris Vurnakes, the collective’s executive director, told WRAL last year.

The collective saw a huge jump in memberships around the hiring of new men’s basketball coach Will Wade. The additional money helped Wade stock the Wolfpack roster. Wade said NC State men’s basketball has yet to submit a deal through NIL Go.

Schools, including NC State, front loaded contracts to execute before July 1 when the House settlement terms took effect. Those deals didn’t have to be approved by the clearinghouse nor did they count against the $20.5 million revenue sharing cap.

“We will continually work to serve NC State and our student-athletes like we have for the past three years,” Vurnakes told WRAL on Thursday.

North Carolina, which hasn’t offered memberships to its fans through a collective, consolidated its NIL offerings under the Carolina NIL brand last year.

By: Nick Guerriero, Asst. AD / Communications

NASHVILLE — Tennessee State University announced today that the launch of its historic men’s hockey program will shift to the 2026-27 season. The decision, made in collaboration with the National Hockey League (NHL), the Nashville Predators, and College Hockey Inc., underscores a shared commitment to building a sustainable and competitive program from day one.

The announcement coincides with a $250,000 grant from the NHL/ National Hockey League Players Association (NHLPA) Industry Growth Fund and continued support from the Nashville Predators. TSU remains poised to become the first historically Black college or university (HBCU) to sponsor NCAA Division I men’s ice hockey.

“Working closely with the NHL and the Predators, we agree that an additional year will provide the program with the time and resources it needs to launch at full strength and with long-term financial success in mind,” said TSU Interim President Dwayne Tucker.

The extra preparation period will focus on recruiting, facility planning, staff development, and fundraising efforts. It also aligns with a broader vision to grow the sport of hockey in diverse communities.

“We continue to look forward to helping to make the Division I hockey dream a reality at Tennessee State,” said Bill Wickett, Chief Marketing Officer of the Nashville Predators. “We applaud University leadership, led by interim President Tucker,  for its desire to ensure that when the Tigers step on the ice for the first time, they are doing it for a long time, and we pledge to walk hand-in-hand with that leadership in making it happen.”

The NHL and the NHLPA Industry Growth Fund have been catalysts for the historic launch of TSU hockey. From funding the initial feasibility study to providing seed funding that is attracting even greater investment, the IGF exemplifies how bold, innovative initiatives can grow the game and expand hockey’s reach into new communities.

“Deferring the inaugural season of TSU Tigers hockey to 2026-27 is the right step to build a foundation worthy of the university,” said Kevin Westgarth, NHL VP Hockey Development & Strategic Collaboration. “TSU has faced challenges before and always met them and come back stronger, and we expect hockey to be the latest chapter of that story. We have faith in President Tucker’s vision and look forward to adding new names to the TSU Athletics history alongside legends like Olympic Gold medalist Wilma Rudolph and NBA Champion Dick Barnett. Hopefully, we’ll see an ex-Tiger raise the Stanley Cup one day, not too far in the future.”

College Hockey Inc. has provided key support throughout the process, beginning with its initial feasibility study in 2021. Its continued guidance will help ensure TSU’s successful transition into NCAA Division I hockey.

“College Hockey Inc. remains fully supportive of Tennessee State’s commitment to adding men’s ice hockey to its athletics program,” said Sean Hogan, Executive Director of College Hockey Inc. “We’re excited to work closely with TSU as it prepares to launch and to see the impact this historic initiative will have on both the university and the growth of college hockey.”

TSU’s inaugural season is now set for Fall 2026. In the meantime, preparations will continue through the upcoming academic year, including community engagement, donor initiatives, and program development.

For more information or to support TSU hockey, visit www.tsutigers.com/hockey.