FLSA Compliance Statement
All roles are unpaid FLSA-compliant roles.
The purpose of this internship program is only for 2 reasons.
First, to foster an environment where students can LEARN about being a business broker in an effort to recruit and develop future business brokers to a very niche and very small industry where most business brokers are independent. To illustrate, Russell Bernstein is only 1 of 500 CBI's in the USA, the only one within 50 miles and only 1 of 2 within 100 miles of New Orleans, 1 of 40 total business brokers in the State of Louisiana, 1 of 3 among ALL agents in the Keller Williams brand GLOBALLY, and only 14 real estate commissions in 14 states in the USA require additional certification and or training to sell businesses.
Secondly, success in the career of business brokering is heavily dependent upon the quality of referrals from industry stakeholders like CPA's, financial advisors, lawyers, residential realtors, commercial realtors, building owners, private equity firms, investment banks, and lenders. These are all careers that MOST interns will pursuing after graduation. Therefore, this program helps to cultivate a long term relationship with interns who may be in a position later in their career to not only give a referral but to give one with substantive first-hand and intimate knowledge of the quality of the service and benefit of the program.
Overall, roles are only a minimum of 5 hours a week. This may increase, but usually only if desired by the intern.
There is a limit at 10 hours per week unless prescribed by the university requirements (for example, 120 hours in 15 weeks), CPT requirements aligned with university requirements or remaining available time (for example, 10 hours per week), or OPT requirements (+20 hours per week if the intern has no other job or other internship).
About 40% is intended to be focused on LEADERSHIP experience of work-related actions. This is where interns train other interns and collaborate getting experience with 5 unique levels of LEADERSHIP including but not limited to coordinating meetings with multiple people, training someone to learn to do something for the first time, getting feedback from supervisors, giving feedback to others.
Another 40% is intended to be focused on doing actual work, but a 1/4 to 1/3 of which also includes time spent coordinating, orienting, and supervising the onboarding process of new interns.
The final 20% is intended to be time spent getting training and getting feedback from the program administrator (Russell Bernstein), reviewing their progress in the internship, or discussing unique topics beyond the scope of the internship for personal or professional ENRICHMENT.
Overall, up to 20% of an intern's time is spent writing about their learning experiences. EACH action, in increments of 30-60 minutes, is recorded and requires a minimum of 200 characters reflecting upon the intern's learning experience for that action. That is not the only requirement, however. What is written is scrutinized heavily to ensure that the intern is not merely summarizing a list of subactions but that it is truly a deeper reflection of the action.
In terms of expectations and significant contribution toward profit, an intern is not expected to contribute meaningful work. In fact, more than 50% of everything that is submitted is revised, recreated, or deleted. The contributions of each task provide very little unique contribution toward sales of the company. For example, on the marketing team, one of the roles is to engage with others on social media, and the impact of that action on the growth of followers is usually less than 2% growth over a 120 day program with 1-5 marketing interns contributing to that growth. Alternatively, among all sales interns in the history of the program, there have been only TWO scheduled meetings as a result of an intern's efforts to schedule meetings with prospective clients, which is the primary purpose of the role.
If these roles generated more income, then they would be paid roles. However, they provide almost zero economic benefit and likely create a short-term loss.
The actions of the program are heavily set in supplementary learning materials as well. For example, the Sales Team interns listen to 100 minutes of sales-, motivational-, or negotiation-related books per week. Alternatively, the Management Team assigns unique articles, YouTube videos, or chapters of Audibles for interns who are experiencing unique challenges or conflict in the program and have weekly meetings with them to discuss and reflect on those topics.
Keller Williams Worldwide (“KW”) is the #1 real estate franchise in the USA, the world’s largest real estate franchise, and the #1 training organization (of any business type) in the world. Each office is an independently owned and operated franchise. Russell Bernstein is a registered agent with an office in Metairie, LA, doing business as "KW Commercial 889-9898" & "Keller Williams Realty 4550100".
Russell is an award-winning "business broker", serving as an Economic Development Ambassador for the New Orleans Business Alliance and being awarded the 2018 Rising Star Award from the Commercial Investment Division of the New Orleans Association of REATLROS in 2018. He is also a contributing writer for City Business New Orleans.
Russell helps people value, buy, and sell businesses that include the lease or sale of real estate. He is also a member of the International Business Broker's Association, and he has a MBA, a Certified Business Intermediary (CBI) designation, and a Certified International Property Specialist (CIPS) designation. He is one of 500 people in the USA with a CBI, the only one within 50 miles of New Orleans with a CBI, and 1 of 2 within 100 miles with a CBI. He is likely the only on in the world who is also a CBI. He is also the owner of the registered trademark
Ask Russell to Bring the Muscle to Your Hustle! ®
The following 7 items are use to measure whether an internship is FLSA compliant if it is unpaid via a for-profit company.
- The extent to which the intern and the employer clearly understand that there is no expectation of compensation. Any promise of compensation, express or implied, suggests that the intern is an employee—and vice versa.
THERE IS NO PROMISE OF COMPENSATION. IF AN INTERN GETS A REAL ESTATE LICENSE IT IS POSSIBLE TO NEGOTIATE A COMMISSION. HOWEVER, COMMISSION IS PERFORMANCE-BASED. COMMISSION IS EARNED ONLY WHEN A LICENSED AGENT SELLS AND A LICENSED AGENT MAKES ZERO NOTHING IS SOLD. PLEASE CALL TO DISCUSS GETTING YOUR REAL ESTATE LICENSE
- The extent to which the internship provides training that would be similar to that which would be given in an educational environment, including the clinical and other hands-on training provided by educational institutions.
THE PROGRAM IS HEAVILY WEIGHTED TOWARD LEARNING. 20% IS INTENDED TO BE FOCUSED ON TRAINING OTHER INTERNS, EXPOSING INTERNS TO LEADERSHIP OPPORTUNITIES ONE WOULD NOT BE EXPOSED TO WITHOUT ACHIEVING DIRECTOR LEVEL ROLES IN A REAL WORLD WORK ENVIRONMENT. 40% IS INTENDED TO BE FOCUSED ON REAL WORK, AND 40% IS INTENDED TO BE TIME SPENT WITH THE PROGRAM ADMINISTRATOR FOCUSING ON LEARNING. ADDITIONALLY, AT LEAST 20% OF THE TIME IS INTENDED TO BE SPENT WRITING ABOUT THE ACTIONS PERFORMED. EVERY ACTION IS RECORDED IN INCREMENTS OF 30-60 MINUTES, AND EACH ACTION MUST HAVE A LEAST 200 CHARACTERS DESCRIBING WHAT WAS LEARNED. THIS DATA IS ANALYZED STRICTLY AND THOSE ACTIONS MERELY SUMMARIZING SUB-ACTIONS WILL NOT BE APPROVED. THE CEO HAS BOTH TEACHING AND COACHING EXPERIENCE AS WELL AS CURRICULUM DEVELOPMENT AS WELL AS A MBA. IF YOU ESTABLISH A FORMAL INTERNSHIP FOR CREDIT, YOU WILL BE GIVEN A GRADE AS PRESCRIBED BY THE UNIQUE INSTRUCTIONS OF YOUR UNIVERSITY.
- The extent to which the internship is tied to the intern’s formal education program by integrated coursework or the receipt of academic credit.
THIS IS UP TO THE STUDENT TO ESTABLISH
- The extent to which the internship accommodates the intern’s academic commitments by corresponding to the academic calendar.
THIS IS LEFT UP TO THE STUDENT TO DEFINE, AND OUR PROGRAM CAN BE TIED TO IT OR ALLOW FOR THE FLEXIBILITY TO DO MORE OUTSIDE OF IT. WE CAN ALSO ACCOMMODATE LAST MINUTE AND EARLY STARTERS WHEREBY THOSE STARTING LATE (FOR EXAMPLE AT A UNIVERSITY REQUIRING 120 HOURS IN 15 WEEKS BUT STARTING IN WEEK 10, THE PROGRAM ALLOWS THE STUDENT TO KEEP TRACK OF ONGOING WEEKLY PERFORMANCE IN AN EFFORT TO ACHIEVE THAT GOAL AND WE HAVE ACCOMMODATED SITUATIONS LIKE THIS BEFORE.
- The extent to which the internship’s duration is limited to the period in which the internship provides the intern with beneficial learning.
THIS IS LEFT UP TO THE STUDENT TO DEFINE. THE PROGRAM IS 120 DAYS. HOWEVER, SOME INTERNS DECIDE TO STAY LONGER. THE PROGRAM IS ALSO ONLY A MINIMUM OF 5 HOURS PER WEEK UNLESS OTHERWISE PRESCRIBED BY THE UNIVERSITY OR OPT OR CPT STATUS REQUIREMENTS.
- The extent to which the intern’s work complements, rather than displaces, the work of paid employees while providing significant educational benefits to the intern.
MORE THAN 50% OF ANYTHING CONTRIBUTED BY THE INTERN IS REVISED, REMADE, OR DELETED. THE FOCUS OF THE INTERNSHIP IS ON 2 THINGS. FIRST, THE INDUSTRY OF BUSINESS BROKERING IS SO SMALL THAT IT IS NEARLY IMPOSSIBLE TO RECRUIT EXISTING BUSINESS BROKERS WHO LARGELY WORK INDEPENDENTLY. THEREFORE, THE PRIMARY FOCUS OF THE INTERNSHIP PROGRAM IS A RECRUITING MECHANISM TO EXPOSE THE INTERNS TO A POTENTIAL FUTURE CAREER IN BUSINESS BROKERING AND THUS THE POSSIBILITY THAT IT MIGHT BE A SUITABLE FIT FOR THEM AND SPECIFICALLY VIA THE DEVELOPMENT WITHIN THE RUSSELL BERNSTEIN'S PROGRAM. THE SECOND MAJOR REASON IS THE LONG TERM RELATIONSHIPS THAT RUSSELL BERNSTEIN WANTS TO DEVELOP WITH GRADUATES WHO MAY BE INTERESTED IN RETURNING TO THE CAREER IN THE FUTURE OR WHO MAY SIMPLY BE A GOOD REFERRAL PARTNER IN COMPLIMENTARY CAREER PATHS WHO WILL BE ABLE TO MAKE A REFERRAL WITH MORE INTIMATE KNOWLEDGE OF THE VALUE OF THE PROGRAM AND SERVICES
- The extent to which the intern and the employer understand that the internship is conducted without entitlement to a paid job at the conclusion of the internship.
THE INTERN IS NOT ENTITLED TO A JOB AT THE CONCLUSION OF THE INTERNSHIP. EVEN IF AN INTERN GETS A REAL ESTATE LICENSE, THEY MUST STILL INTERVIEW WITH RUSSELL BERNSTEIN'S BROKER OR WITH A BROKER IN THE INTERN'S CHOSEN STATE OF LICENSURE