A review of the policies established in the Fair Labor Standards Act indicates that the work students do during Phase III of the Rainmakers Internship Preparation Program has very little chance of benefiting the participating employer. In fact, the primary beneficiary of the internship Sponsor (the company managing the intern) is the participating student, not the employer. The ‘internship,’ which is a virtual experience, provides training similar to what would be given in an educational environment, is limited to the period in which the internship provides the intern with beneficial learning, accommodates the intern’s academic commitments by corresponding to the academic calendar, does not displace the work of paid employees, and provides the employer with little, if any, direct benefit. In fact, it is likely that the work product produced by participating high school juniors or seniors and college freshmen will not be of any use to participating employers. Therefore under those guidelines, students participating in Phase III of the Rainmakers Club program of work need not be compensated for their activities.

Students who successfully complete all three phases of the Rainmakers Clubs program are eligible to apply for available paid internships at the Internship Depot or one of its partners. Students whose skills match the requirements of specific available positions will be hired and paid as consultants under contracts of extremely limited duration.

There will be and is no promise or indication of extended employment in either Phase I, II or III of the Rainmakers Internship Preparation Program.