The University of Michigan Wolverines benched sophomore quarterback Bryce Underwood against Penn State this past weekend. Underwood’s two first half interceptions, combined with his lackluster play in general, were enough for Head Coach Kyle Whittingham to pull the plug on his starting role both Saturday and for the upcoming game this weekend against Indiana. Underwood came into the game with a 59% completion rate, six touchdowns, and six interceptions in five games. Backup quarterback Tommy Carr, a freshman who led the team to victory against Penn State, will seemingly start the rest of the season for the Wolverines.
This is news because Bryce Underwood was one of the nation’s most highly recruited quarterbacks coming out of high school. According to Front Office Sports, his NIL package was reported as exceeding $10 million. Whittingham’s decision to bench Underwood raises questions about the financial risks of investing millions in unproven athletes, some of whom are still legally children when the commitments are made.
According to the Michigan Journal of Economics and Front Office Sports, Bryce Underwood was the number one recruit in the 2025 class and a generous NIL package of approximately $10.5 million over four years influenced him to flip his commitment from LSU to Michigan in November of 2024. Michigan boosters like billionaire Larry Ellison and Barstool Sports founder Dave Portnoy gambled millions on Underwood’s potential, rather than proven college production. Underwood was only 17 years old when these commitments were made, having never played a collegiate snap.
In September of 2025, Sports Illustrated reported that Underwood had an estimated annual NIL valuation of $3 million, with endorsements and opportunities from Barstool Sports to Beats by Dre, with unique Michigan-related merchandise as well. A player like Bryce Underwood, according to the Michigan Journal of Economics, has a value that extends far beyond the football field. The value is tied to his merchandise, publicity, and influence on future recruits. His struggles this season raise serious questions about whether NIL contributors are receiving the return that they anticipated. Although he may still provide commercial value, his on-field production has fallen far short of expectations.
In addition to NIL money from third parties and collectives, athletes have the ability to make money through revenue-sharing from their institution. Following the House v. NCAA settlement, participating universities began directly compensating athletes through revenue-sharing agreements. According to the NCAA, third-party NIL agreements separately compensate athletes for endorsements, appearances, and commercial use of their identities. Schools and outside NIL contributors may therefore have different contractual obligations. An athlete getting benched does not automatically terminate either type of agreement, but should there be an obligation to pay the athlete the same amount of money as promised if the athlete is failing to meet expectations?
This topic quickly turns into a conversation about whether or not college athlete contracts should be fully guaranteed. Bryce Underwood’s situation raises that exact question due to his massive multiyear commitment. The contracts that student-athletes sign are rarely, if ever, public, so the guarantees, conditions, and termination provisions in Underwood’s deal are not common knowledge. Traditional contract law generally requires parties to honor their agreements, even in the case of a disappointing investment. Contributors could potentially protect themselves from risk through the contract’s structure. Athletes also deserve financial security and protection from arbitrary termination. Each side of the agreement deserves protection, so these NCAA student-athlete agreements should allocate the risk fairly, rather than place it entirely on either the athlete or the contributor.
Every day it seems like we see the world of college sports look more and more similar to professional sports, so should there be performance clauses in college sports? Professional contracts sometimes contain incentives tied to statistics, playing time, or performance. Similar provisions in college athletics could theoretically help contributors limit financial exposure. One of the main issues, however, is that, according to the NCAA, third-party NIL compensation cannot simply serve as a payment for athletic performance. No “pay-for-play” – no payment without a valid business purpose and fair market value. Reducing NIL payments because a quarterback is performing poorly could create a major pay-for-play compliance issue. School revenue-sharing agreements present separate contractual and regulatory questions. College athletes increasingly receive professional-level compensation without operating under professional-style contractual rules.
On October 1st, I posted an article entitled LINK: Discipline in College Football: Why Not Just Fine the Player? I examined whether monetary penalties could be used to address misconduct, like fines in professional sports. Third-party NIL agreements may contain clauses addressing morality or termination provisions addressing inappropriate behavior, so what is stopping some sort of performance-based clause or provision? If college athletes are compensated like professionals, it only seems fair that some form of professional contractual accountability comes with it.
In October 2026, the SEC adopted standardized NIL and revenue-sharing contracts, following the Big Ten. These agreements provide greater clarity regarding compensation and obligations, but do not necessarily allow pay reductions for poor performance. Underwood’s situation highlights the need for stronger contractual protection.
Underwood’s struggles raise the important question of how reasonable it is to invest millions in an unproven teenager. His benching demonstrates how quickly an athlete’s value can change. While athletes deserve fair compensation, NIL contributors must consider financial risks as college athletics become increasingly professionalized.

