College Sports Commission Issues Warning to Schools, Ramps Up Investigations Into Potential Violations of House Terms
January 13, 2026
On Friday, January 9, the College Sports Commission (CSC) issued a letter warning schools and their partners that the CSC has “serious concerns” about certain deals that were reportedly being offered to student-athletes and the “consequences of those deals for the parties involved.” The CSC further announced that its investigations into certain unreported third-party NIL deals were progressing and that some schools should expect to hear from the CSC the week of January 12. This stern warning came as part of a more comprehensive reminder from the CSC that schools and their student-athletes must ensure compliance with the new NIL and revenue-share rules arising from the House settlement, and must report all third-party NIL deals worth $600 or more to the CSC (via the new NIL Go platform) for approval.
The CSC was created to ensure compliance with the new post-House settlement rules, including those pertaining to direct revenue sharing with student-athletes, third-party NIL agreements, and roster limits. The CSC now oversees NIL Go, the online platform through which schools and student-athletes report NIL deals, as well as the College Athlete Payment System (CAPS), which tracks roster limits and serves as the official revenue-share reporting tool for schools participating in the House settlement. The CSC is also empowered to investigate potential rule violations, provide notice and an opportunity to be heard with respect to alleged violations, and administer penalties for violations that occur, including implementing a new arbitration process that would permit challenges to any penalties for NIL deals that are determined to be inconsistent with the House settlement terms.
It remains to be seen exactly what penalties the CSC will impose for violations. The NCAA, however, did amend its bylaws in November to establish guidelines for the CSC to follow when determining the severity and type of penalties to be imposed on schools and student-athletes who violate the rules. According to those amended bylaws, the CSC should consider imposing harsher penalties on schools where the misconduct at issue was deliberate, serious, pervasive, frequent, or concealed, among other factors. Lesser penalties are appropriate where schools promptly and voluntarily report a violation, cooperate with any investigation, remediate the issue, and accept responsibility. Penalties for student-athletes can include being declared ineligible to compete, while schools and their personnel may face suspensions, fines, withholding of distributions, bans from post-season tournaments, and restrictions on recruitment, transfers, scholarships, rosters, and revenue sharing. The CSC is also empowered to assess any other penalty it finds reasonable under the circumstances.
The CSC’s warning is a reminder for schools to continue to take measures to ensure compliance with the House settlement terms. That includes staying apprised of evolving NCAA rules and new CSC guidance, including with respect to third-party NIL deals, and working with student-athletes to report all third-party NIL deals that meet or exceed the $600 threshold to the CSC for approval. O’Melveny is uniquely equipped to assist with preemptive and responsive policy development, strategy, compliance, and litigation in this area given its expertise in the post-House rules and experience with high-profile sports and university investigations and litigation.
Please do not hesitate to reach out for support or to discuss these issues, including if the CSC contacts your school or its affiliated entities or individuals regarding a potential investigation or violation.
This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. Steven J. Olson, an O'Melveny partner licensed to practice law in California; Timothy B. Heafner, an O'Melveny partner licensed to practice law in California; Matthew R. Cowan, an O’Melveny partner licensed to practice law in California; Ben Aronson, an O’Melveny partner licensed to practice law in New York; and Max Rothman, an O'Melveny counsel licensed to practice law in California, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.
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