Card Mills are a Symptom, Not the Disease
Why “fair prices and autonomy” is a terminal strategy for Training Centers—SitRep #013.
Note: I do not believe in cutting compliance corners. Full stop. But if we pretend they are the whole problem, we miss the deeper issue: the business model almost every Training Center is running underneath.
If your Training Center’s pitch is “fair card prices” and “we’re hands-off—you run your own business,” you’re running a pull network, whether you mean to or not.
A pull network assumes demand gets created at the edges. Instructors and sites find their own students. The center’s job is to process whatever shows up: buy cards in bulk, transfer cards, collect rosters, submit to AHA.
In this model: instructors grow the center; not the other way around.
Your network’s value is purchasing power: more instructors → more volume → better pricing → more instructors.
That model works. As long as demand keeps growing.
If you’ve run your TC like this for years, you weren’t wrong. The market shifted. Now it’s time to adapt.
The death loop
Walk your current reality forward.
Your affiliates’ main lead source—Find-a-Class—is getting flooded by RQI/VAM and big players. Their classes thin out. Your card volume drops.
You have two moves.
Raise card prices to protect margin. This will squeeze instructors and they’ll start shopping for a cheaper TC.
Add more instructors to hold volume on paper. This will spread a shrinking pie thinner and strain your operations to keep up.
Your support gets overwhelmed. Response times slow. The instructors who were loyal start noticing.
Meanwhile, your affiliates make moves too.
They cut prices to maintain volume. Paired with your price raise it’s a double hit.
They pivot to instructor courses. Higher ticket price. Every graduate becomes a card-buying customer. Sounds smart… until you realize you’re flooding the market with more instructors who also don’t know how to drive demand.
You’re not solving the problem. You’re multiplying it.
And here’s the part nobody wants to say out loud: card mills aren’t a corruption of the pull network. They’re the destination.
Compete on price. Add instructors to grow volume. Strain operations. Watch compliance slip.
The TC you call a card mill isn’t running a different model—they just followed yours further than you have.
Nobody is structurally responsible for creating demand.
That’s not a rough patch. That’s a death loop baked into the model.
What comes after
One TC told me last week that she’s making a move:
“If you get on the wrong train, get off at the next station. The longer you stay, the more expensive the return trip.”
You’ve hit the ceiling of the purchasing-power game. The next advantage won’t come from cheaper cards.
It’ll come from push networks: infrastructure that treats instructors and sites as logistics nodes, not just reporting nodes. Systems where the center can push demand down into the network—promote classes across locations, convert students into group contracts, coordinate multi-site relationships with one backbone.
That’s the shift the industry hasn’t made yet. From “we help you buy cheap cards and file rosters” to “we help you get, keep, and grow business.”
Where to start
The 2025 guidelines transition is going to force you to touch your systems anyway. Classes, materials, card processes—everything’s getting rebuilt in the next two months whether you want it to or not.
That’s either a tax or an opportunity.
If you rebuild the same pull network with updated course names, you’ll be back in the same loop by 2026. If you rebuild toward push—toward infrastructure that can actually create and route demand—you come out of the transition ahead.
Over the next few SitReps, I’ll break down how existing software traps you in pull-network land:
Trap 2: DIY stacks (you become the glue)
Before you lock in your 2025 setup, ask yourself one question:
Am I rebuilding toward pull, or toward push?
Because in a pull network, when the easy demand dries up, purchasing power doesn’t save you.
It just takes you to the bottom faster.
If you want to see what push infrastructure looks like before you lock in your 2025 setup: Book a Demo — we’ll walk through how it works.
—Jon
Want a second set of eyes on your operation? 15 minutes. We review your setup. You walk away knowing what to fix first.


