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SettleADebt C_IE PASS-02 — Ireland traceability corrections

Six narrative cross-references corrected Underlying levy authority and other P01 holds remain open

Scope: Six identified citation/cross-reference groups only. P01 findings, calculations, scenarios and registers remain preserved except for the replacement text below.

Research baseline: 22 October 2026, America/Los_Angeles. Actual P02 source checks: 26 October 2026 (UTC, America/Los_Angeles and Ireland local date; exact retrieval times not recorded).

I reopened the relevant Irish statutory sections and Central Bank webpages. The August 2026 industry-funding guide failed on a fresh direct request and one official URL variant; its precise P01 reading is retained as attributable prior evidence, not freshly verified in P02. The six defects are source-ID assignments, not demonstrated errors in the underlying P01 conclusions. Law Reform+4

1. Complete replacement text — all six groups

Group 1 — C4 industry-funding formula paragraph

Replace the original formula paragraph and its concluding cross-reference with:

The Central Bank of Ireland's August 2026 Funding Strategy and Guide to the 2026 Industry Funding Regulations, section 4.3, Table 6 (printed page 14; zero-based PDF page 13), places authorised debt management firms in industry-funding Category C.

According to that Bank guide:

• The minimum Category C levy is €1,198.
• The stated variable calculation is (A − B) × C, where B = €205,000 and C = 0.21%.
• A is income from fees plus commissions reported for the year ended 31 December 2024, or the most recently received preceding return as specified in the guide.
• Fees and commissions are measured before deducting commissions payable to third parties.
• The 2026 billing exercise relates to recovery of 2025 supervisory costs; it is not a consumer fee or debt-settlement charge.
• Under the guide, newly authorised firms for which a return is not yet due receive the specified minimum assessment. Failure to file a required return may produce a €4,500 default assessment, replaceable following submission.
• Partial-year authorisations and firms holding multiple regulatory authorisations may require additional calculations.

These are the figures and conditions recorded from the Bank guide in P01. The guide itself could not be reopened in P02, and the operative charging instrument remains unread; therefore the paragraph does not independently certify the enacted levy law or any current invoice. [C_IE-P01-C036–C037, C040; C_IE-P01-S035, §2 and §4.3 Table 6, printed pp.5, 8, 14 / PDF indices 4, 7, 13.]

Correction: S034 becomes S035.

Why: S034 is the Bank's Consumer Protection Code Review, addressing consumer-code history and implementation. S035 is the Bank's industry-funding guide containing the reported Category C calculations. P02's failed re-fetch does not erase or elevate P01's documented reading.

Group 2 — C4 evidence-limit paragraph

Replace the original evidence-limit paragraph with:

Legal-evidence limitation: The Central Bank's official calculation guide was reported read in P01, but a fresh P02 retrieval failed. The operative text of S.I. 348/2026 has not been directly read in either the preserved P01 record or this correction pass. Accordingly, the two numerical illustrations reproduce the Bank guide formula as recorded in P01, rather than representing an independently reconciled interpretation of the complete charging instrument. Actual invoices, assessment bases, part-year adjustments, waivers, appeals, multiple-authorisation charges and any additional agency levies remain subject to the operative instrument and the relevant firm's facts. Neither illustration establishes a consumer charge, an insurance premium, a settlement percentage or a legal entitlement. [C_IE-P01-C040; C_IE-P01-S035, §2 and §4.3 Table 6, printed pp.5, 8, 14 / PDF indices 4, 7, 13; C_IE-P01-S040, operative instrument not read.]

Correction: S034, S040 becomes S035, S040.

Why: The consumer-code review cannot support a levy calculation. S040 remains a failed/not-read primary instrument, and cannot be presented as though its provisions were verified.

Group 3 — E statutory insolvency-option names

Replace the original opening paragraph of section E with:

Ireland's named statutory insolvency options include Debt Relief Notice (DRN), Debt Settlement Arrangement (DSA), Personal Insolvency Arrangement (PIA) and bankruptcy. They must not be relabelled using mechanisms from another jurisdiction. The Central Bank's reproduction of the Consumer Protection Regulations 2025, Regulation 286, expressly uses these four names when defining insolvency option for Chapter 12 on debt management firms. Regulation 287 confines that Chapter to debt-management services provided by a debt management firm. These definitions identify the relevant Irish mechanisms but do not establish their eligibility conditions, application steps, discharge results or costs, which remain deferred. [C_IE-P01-C032–C033, C049; C_IE-P01-S033, regs.286–287.]

Correction: S032 becomes S033.

Why: S032, Regulation 1(2), establishes the 24 March 2026 commencement of the 2025 Regulations. The specific list of statutory insolvency options is in S033, Regulation 286. Regulation 287 also supplies the proper Chapter 12 application boundary. Central Bank of Ireland+1

Group 4 — E statutory practitioner capacities

Replace the original statutory-capacity discussion with:

The Personal Insolvency Act 2012 identifies distinct statutory capacities:

• Under section 47(1), the Insolvency Service of Ireland may authorise a person or class of persons to perform the functions of an approved intermediary under the relevant Chapter. Section 47(5)–(6) provides for regulations governing that authorisation and its possible withdrawal.
• Under section 164(1), the Insolvency Service may authorise an individual to practise as a personal insolvency practitioner (PIP). Section 164(3) contains grounds for refusing authorisation; subsection (5) makes that authorisation personal. Crucially, section 164(6) states that PIP authorisation does not authorise other forms of financial advisory service regulated by the Central Bank.

The DMF definition's excepted-person provision in the Central Bank Act 1997, section 28(1)(f), includes the Insolvency Service of Ireland, a section 47 approved intermediary acting as such, and an authorised PIP carrying on practice as such. The statutory capacity therefore matters: neither a professional title nor a PIP authorisation automatically excepts a separate commercial debtor-advice business or another legal person's paid voluntary debt negotiations. Determination of the actual capacity would require the relevant authorisation and engagement documents. [C_IE-P01-C014, C033, C049; C_IE-P01-S005, s.28(1)(f); S036, s.47(1), (5)–(6); S037, s.164(1), (3), (5)–(6).]

Correction: S005, S035–S036 becomes S005, S036–S037.

Why: S035 is the levy guide, not an insolvency statute. S036 contains approved-intermediary authority; S037 contains PIP authorisation and its limits. The actual sections support the bounded capacity distinction. Law Reform+2

Group 5 — E credit-servicing framework

Replace the original credit-servicing paragraph with:

The credit-servicing regulatory framework is a separate activity and permission category from debtor-side debt-management services. The Central Bank explains that Irish credit-servicing regulation includes Part V of the Central Bank Act 1997 and the European Union (Credit Servicers and Credit Purchasers) Regulations 2023, implementing Directive (EU) 2021/2167 with effect from 30 December 2023. In describing the 2023 regime, the Bank distinguishes a relevant credit servicer, for which authorisation is required, from a credit purchaser on whom those particular regulations do not impose a direct authorisation obligation merely as purchaser. The Bank describes cross-border rights for appropriately authorised credit servicers under that framework. Such a service-specific route is not evidence of an equivalent passport for paid Irish debtor-side debt-management advice or negotiation. A real activity still requires classification under its applicable legislation. The complete 2023 implementing instrument was not independently analysed in P01 or P02. [C_IE-P01-C034, C044; C_IE-P01-S005, s.28(1), credit-servicing definition; C_IE-P01-S038, “Credit Servicing Firms” and “Credit Servicers” sections.]

Correction: S037 becomes S038, with S005 retained for the statutory distinction.

Precise qualification from the opened regulator text: The Bank's direct-purchaser statement is specifically about the 2023 regulations. It cannot be expanded into a claim that every credit purchaser is exempt from every Irish financial-services authorisation rule. Central Bank of Ireland+1

Group 6 — B2 adjacent-activity matrix closing cross-reference

Leave every matrix row and its substantive classifications intact. Replace only the closing cross-reference with:

[C_IE-P01-C003–C004, C011–C015, C034–C035, C043; C_IE-P01-S005, s.28(1), debt-management services, remuneration, excepted-person paragraphs (c), (d), (f) and credit-servicing definitions; S031, “Introduction to Debt Management Firms,” client-funds authorisation warning; S036, Personal Insolvency Act s.47(1); S037, Personal Insolvency Act s.164(1), (5)–(6); S038, “Credit Servicing Firms” and “Credit Servicers” sections.]

Corrections:

• S005 supports the activity and actor definitions, including the professional and statutory-capacity predicates.
• S031 supports the Bank's warning that DMF authorisation by itself does not confer authority to hold client funds. Its reference to historic payment legislation must not be treated as certification of present payment-law detail.
• S036 and S037 support the distinct insolvency-practitioner capacities.
• S038 supports the separate credit-servicing gateway.
• S035 is removed entirely from this actor matrix because levy calculations do not establish any of these actor distinctions.
• S030, the general register/unauthorised-firms page, is not needed for this specific activity-and-capacity cross-reference. Its separate P01 verification use remains intact.

Law Reform+4## 2. Correction crosswalk

Here and below, short identifiers such as S035 refer to the original P01 IDs. P02's own source and claim identifiers follow.

3. Arithmetic reconfirmation — no change to P01 examples

The original formula is used only as recorded in the P01 Bank guide. Assume one Category C authorisation, full-year relevant authorisation, the specified reporting base, no other levy category, pro-rating, waiver or adjustment.

Both calculations were recomputed in P02. This verifies arithmetic against stipulated inputs, not source-law currency, liability, invoice amount or a consumer price. [C_IE-P01-C036–C037, C040; C_IE-P01-S035, §4.3 Table 6, reported P01 read.]

4. P02 source register — C_IE-P02-S001 onward

Status meanings

• Fresh body read: This pass opened and examined the relevant official body on 26 October 2026.
• Precisely attributed P01 reuse: P01's recorded read is preserved; the present pass does not claim a new successful fetch.
• Failed/not read: The specified retrieval failed or the authority remains inaccessible. It is not evidence of the operative contents.
• Context only: Checked or preserved for boundary integrity, but not authority for a changed conclusion.

All listed dates are 26 October 2026 unless a document/version date is separately specified. No PDF page indices apply to HTML sources.

P02 direct-source access boundary: P02 freshly verified S001–S005 and S007–S011 above. S006 was attempted twice in distinct official URL forms and failed; no third attempt or workaround was made. S012–S015 are precisely identified inherited records or holds, not fresh checks.

5. Atomic P02 claim register — C_IE-P02-C001 onward

Each P02 claim concerns the accuracy of the specified correction, not independent recertification of all Irish law. P01 claim IDs remain the controlling labels for preserved substantive content.

6. Granular P02 coverage register

7. Researcher self-check

Disposition

The six specified narrative source-traceability defects are corrected, and their exact replacement text and registers are visible above. P01 remains the preserved substantive base. The levy guide's successful P01 read and failed P02 retrieval have been distinguished; neither the enacted levy instrument nor the broader Ireland report has been certified.

No country, component, A097 or A098 acceptance is claimed.

END C_IE PASS-02