Can't sign up for a Free Books Account

I'm trying to sell a book for free wthout an ISBN.
I just discovered that you cannot do this with a Paid Books Account. Evidently, with a Paid Books Account you must have an ISBN no matter what price you set, even if its free.
So, I set up a second Apple ID, confirmed a second credit card, and when I go to sign up for a Free Books Account, I get this error:
Is anyone else having this issue?

I feel your pain. I am working on a free e-book project to raise awareness for ALS and running into the same difficulty. We have some big name celebrities lending their Names to the book and are now being forced to explore alternate distribution networks. You are not alone!

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