Only in reply to your first paragraph.
It is not supposed to be that easy. That picture hanging there would have to be evaluated by Deloitte to determine if $1M is the FMV to that company - which I would guess it is not.
Now - I do not believe for one second that this process will work and prevent outright pay for pay.
Deloitte is hired by the NCAA. They get their pay from the NCAA. As soon as they deny a NIL and the NCAA gets sued then Deloitte's gravy train is cut off because the NCAA while find another party to administer the "Clearinghouse".