{"meta":{"key":"s_ak--pass-01","task":"S_AK","title":"SAK Alaska provider market access and consumer fees","parent_title":"Alaska debt and debt relief law","edition":"pass-01","path":"/research/s_ak--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":7,"claims":33,"sources":19,"review_status":"revise","review_complete":true,"sha256":"faccbecb444e1f72495756d1d0d10b6daa90a1bcc9d755a5dd7d5baeccef8164","headings":["Executive determination","1. How Alaska currently defines and classifies the relevant conduct","1.1 No verified Alaska debt-relief-specific taxonomy","1.2 Conduct matrix","1.3 Principal reduction versus concession/distribution services","1.4 Custodial versus noncustodial models","1.5 Consumer versus business purpose","1.6 Alaska-resident and remote-provider nexus","2. Whether each business model is prohibited, licensed, registered, authorized, or exempt","2.1 Market-access matrix","2.2 Telephonic seller registration is an access condition, not a debt license","2.3 Money-transmission authorization","2.4 Attorney status","2.5 Nonprofit status","2.6 Financial institutions and other institutional exclusions","2.7 Collection-agency crossover and self-creditor boundary","3. Current fee structures, dollar limits, percentages, and refunds","3.1 Consumer-facing debt-relief fees","3.2 Verified provider-side governmental fees","3.3 Money-transmission transaction fees","3.4 Virtual-currency kiosk cap is not a debt-relief cap","3.5 Refund and credit conditions","4. When fees may actually be requested or received","4.1 Alaska telephonic contract trigger","4.2 Federal TSR performance trigger","4.3 Dedicated accounts","4.4 State and federal conditions must be stacked","5. Actual regulator procedure, application, and lookup routes","5.1 Business-license procedure","5.2 Telephonic registration is operational","5.3 Money-transmission procedure and lookup limitation","5.4 The legacy “Company Uniform Application” is not a debt-relief application","5.5 Advertising authorization or status inaccurately creates UTPA risk","6. Fee and boundary examples","7. Component coverage and next investigations","D.1 Plain-text worked examples","Example 1 — TSR proportional fee after one individual debt is resolved","Example 2 — TSR savings-percentage method","Example 3 — Lower-balance debt shows why the fee base matters","Example 4 — Prior earned fees, partial program performance, and cancellation","Example 5 — Alaska telephonic pre-service cancellation","Example 6 — Licensed custodial DMP transmission calculation","Example 7 — Unlicensed custodial model: classification hold, not a fee calculation","Example 8 — Independent dedicated account boundary","Example 9 — The virtual-currency kiosk cap does not create a debt-relief cap","D.2 Full PASS-01 coverage and gap table","Material actually read","Material not established or not fully read","Overall confidence"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_AK/pass-01","facets":{"geography":["us","us-ak"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Alaska provider-access/fees component, all other state categories required","pending_corrections":0},"markdown":"# S_AK PASS-01 — Alaska provider market access and consumer fees\n\n**Current-law check and source access:** October 24, 2026, America/Los_Angeles.\n**Scope:** Alaska provider access, legal classification, fee structures, fee timing, and public application/lookup procedures. This is **not** an Alaska state overview or state acceptance. Agreement terms, client-fund architecture, bonding, remedies, enforcement, limitations, litigation, sector-specific rules, secured debt, local/tribal law, and full case-law coverage remain open for later passes.\n\n## Executive determination\n\nAfter reviewing Alaska’s published statutes, 2026 enacted legislation, operative regulations and adoption orders, official regulator materials, forms, public rosters, and targeted official-site searches, I did **not locate or verify a dedicated Alaska “debt adjuster,” “debt settlement,” “debt management,” or “credit-counseling” licensing and consumer-fee regime** comparable to the specialized statutes used by many other states. That is a bounded research finding, not a claim that no uncatalogued authority could exist.\n\nAlaska instead regulates the relevant conduct through a stack of generally applicable laws:\n\n1. A provider conducting Alaska business activity ordinarily needs an **Alaska business license**.\n2. A provider selling services through Alaska’s unusually broad definition of **“telephonic means”** ordinarily must register each solicitation campaign with the Alaska Department of Law at least 30 days before launch, unless a specific, conditional exemption applies.\n3. A provider that **receives consumer money for transmission to creditors or collectors** likely enters Alaska’s money-transmission regime and may not operate without an Alaska license, authorized-delegate relationship, qualifying out-of-state approval, or statutory exclusion.\n4. A provider acting for creditors to collect claims can enter Alaska’s collection-agency regime. A conventional debtor-side negotiator is not plainly within the creditor-side statutory text, but Alaska-specific decisional authority resolving every hybrid DMP arrangement was not located.\n5. Alaska does **not supply a verified numerical debt-relief service-fee ceiling** for setup fees, monthly fees, settlement percentages, savings percentages, per-debt charges, or aggregate fees. That does not make fees unrestricted: contracts, Alaska’s telephonic-sales and unfair-practices laws, money-transmission duties, and the federal Telemarketing Sales Rule may independently constrain them.\n6. For a federally covered debt-relief sale, the TSR’s performance rule remains separate: a provider may not request or receive its fee merely because Alaska lacks a numerical cap or because an Alaska telephonic contract has been signed.\n7. The current-law baseline includes **SB 249, Chapter 50 SLA 2026**, effective October 1, 2026. The broad money-transmission replacement enacted by **SB 86, Chapter 48 SLA 2026**, generally does not become operative until July 1, 2027. [LegiScan+3](https://legiscan.com/AK/bill/SB249/2025)\n\n# A. Substantive findings\n\n## 1. How Alaska currently defines and classifies the relevant conduct\n\n### 1.1 No verified Alaska debt-relief-specific taxonomy\n\nNo current Alaska statute or regulation was located that independently defines:\n\n- “debt adjustment”;\n- “debt settlement”;\n- “debt negotiation”;\n- “debt-management plan”;\n- “credit counseling”; or\n- a debt-relief provider’s permissible consumer fee.\n\nAlaska’s official consumer-law index lists the state’s Telephonic Solicitations Act, UTPA, and other consumer statutes, but no debt-adjuster chapter. DCCED’s complete professional-license menu includes collection agencies but no debt-settlement or credit-counseling profession. A legacy Alaska “Company Uniform Application” does list debt negotiation, debt settlement/debt adjuster, and debt management/credit counseling—but that same form expressly says its activity list includes businesses for which the applicant is **not seeking licensing authority**. It therefore cannot be treated as a debt-settlement license application. **Claims C001, C002, C025.** [Alaska Department of Law+3](https://law.alaska.gov/department/civil/consumer/laws.html)\n\nAlaska classification must consequently follow the provider’s **actual functions**, not its marketing label.\n\n### 1.2 Conduct matrix\n\n| Actual model | Alaska classification for this pass | Principal legal consequence |\n| --- | --- | --- |\n| **Financial education or budgeting only**—no representation that the provider will alter debt terms and no handling of consumer funds | No debt-specific license located. Not “money transmission” merely because advice is given. | Business-license, telephonic-sales, contract, advertising, and UTPA analysis still applies. |\n| **Principal-reduction settlement or negotiation, noncustodial**—provider negotiates but never receives or controls funds for creditor payment | On the face of AS 06.55, negotiation alone is not “receiving money or monetary value for transmission.” This is a statutory-text inference, not a published Alaska agency opinion. | No dedicated debt-settlement license located; business license and telephonic registration can still be required. Federal TSR may control fee timing. |\n| **DMP or credit counseling that obtains concessions but never takes consumer funds** | Same noncustodial analysis. Obtaining lower interest, waived fees, or changed payment terms does not by itself equal money transmission. | General Alaska business/telephonic/UTPA rules; federal TSR if represented to alter unsecured debt terms through telemarketing. |\n| **DMP that receives one consolidated consumer payment and distributes it to creditors** | Receiving money for transmission “to the state, from the state, or within the state” fits the ordinary text of current AS 06.55.990(15). | Money-transmission authorization is likely required unless an exclusion applies. |\n| **Debt-settlement company that receives settlement funds and pays creditors or collectors** | Same likely money-transmission classification. | A telephonic registration or ordinary business license does not cure an AS 06.55 licensing defect. |\n| **Consumer-owned dedicated account administered by an independent account company** | Fact-dependent. If the debt-relief provider never receives or controls the funds, its own AS 06.55 status may differ from the account administrator’s status. No Alaska opinion resolving this exact debt-relief architecture was located. | Hold Alaska classification until account ownership, withdrawal rights, payment instructions, control, affiliation, and actual fund flow are documented. |\n| **Creditor negotiating or settling its own debt in its own name** | Generally outside the core collection-agency definition, which concerns claims owed to another. | A creditor using another name to create the impression that a third party is collecting can be treated as conducting collection-agency business. |\n| **Provider retained by a creditor to collect or receive claims** | Collection-agency activity under AS 08.24.090 and .380, subject to statutory exclusions and the regulator’s creditor-location guidance. | Collection-agency licensing analysis, separate from debtor-side debt-relief analysis. |\n\nCurrent AS 06.55 defines money transmission to include receiving money or monetary value for transmission to, from, or within Alaska. A person may not engage in or hold itself out as providing money transmission unless licensed or an authorized delegate; AS 06.55.103 also supplies a qualifying approval route for certain entities licensed in another state. [LegiScan+2](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\n### 1.3 Principal reduction versus concession/distribution services\n\nFor Alaska purposes, the material distinctions are not simply “settlement” versus “DMP”:\n\n- A principal-reduction company that never handles money may avoid the money-transmission classification.\n- A DMP that never reduces principal but receives a consolidated monthly payment and distributes it can fall squarely within the money-transmission language.\n- Pure credit counseling can remain outside both functions if the provider neither promises altered creditor terms nor handles money.\n- A hybrid provider may be subject to different regimes for different parts of the same program.\n\nFor federal TSR purposes, by contrast, a “debt relief service” broadly includes a program represented to renegotiate, settle, reduce, or otherwise alter payment terms or other terms of unsecured debt—including balance, interest, or fees. Thus both settlement and concession-oriented DMP services can be covered when the telemarketing nexus exists. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\n### 1.4 Custodial versus noncustodial models\n\n**Noncustodial:** Merely advising a consumer or communicating offers between the consumer and creditor does not, without more, satisfy the words “receiving money or monetary value for transmission.” That conclusion is a reasoned reading of the text, not an Alaska safe harbor.\n\n**Custodial:** A provider that takes $500 from an Alaska consumer and is obligated to send some or all of it to creditors is receiving money for transmission. Unless licensed, approved, acting as a properly appointed authorized delegate, or within an exclusion, AS 06.55.101 prohibits the activity. [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/)\n\n**Control without literal receipt:** Alaska’s present definition does not supply a debt-relief-specific rule for constructive receipt, payment instruction authority, or consumer-owned dedicated accounts. Account documents and the administrator’s role must be investigated before making a market-access determination.\n\n### 1.5 Consumer versus business purpose\n\nAlaska’s telephonic-sales chapter defines a “buyer” simply as a **person** solicited by telephonic means. It does not contain a household-purpose qualifier in that definition. Its “telephonic means” definition includes electronic communication between computing devices and certain written communications encouraging the recipient to contact the seller. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/)\n\nSimilarly, AS 06.55’s transmission definition is based on receiving and transmitting value to, from, or within Alaska, not on whether the underlying debt is consumer or commercial.\n\nThe federal TSR is different. Its business-to-business call exemption generally excludes calls made to induce purchases by a business, subject to the exceptions stated in 16 C.F.R. § 310.6(b)(7). That federal exemption does not rewrite Alaska’s definitions. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\n### 1.6 Alaska-resident and remote-provider nexus\n\nAlaska’s business-licensing agency states that physical presence is not required; the obligation is based on business activity, and the agency expects a license when any portion of the business activity occurs within Alaska. Because that is administrative guidance rather than a debt-relief-specific jurisdictional holding, edge cases should be analyzed from the actual sales, service, and payment facts. [Alaska Department of Commerce+1](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs)\n\nFor money transmission, SB 249’s currently effective definition expressly covers transmission:\n\n- to Alaska;\n- from Alaska; or\n- within Alaska. [LegiScan](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\nFor telephonic selling, remote providers can be covered because “telephonic means” is not confined to a conventional outbound voice call. Written prompts, electronic communications, and substantially identical campaigns to two or more persons can trigger the chapter. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/)\n\n## 2. Whether each business model is prohibited, licensed, registered, authorized, or exempt\n\n### 2.1 Market-access matrix\n\n| Model or function | Alaska status | Required route or condition |\n| --- | --- | --- |\n| Pure fee-based counseling, no debt alteration and no money custody | Not subject to a dedicated debt license located in this pass | Alaska business license; telephonic registration if the sales campaign fits AS 45.63; UTPA compliance |\n| Noncustodial debt settlement/negotiation | Not prohibited as a named business and no dedicated debt license located | Business license; telephonic registration or actual exemption; federal TSR if applicable |\n| Noncustodial DMP/concession service | Same | Same |\n| Custodial DMP or settlement service receiving money for creditor payment | Prohibited without applicable AS 06.55 authority | Alaska money-transmission license, authorized-delegate status, AS 06.55.103 approval, or a verified statutory exclusion |\n| Independent dedicated-account administrator receiving or transmitting funds | Potential money transmitter; exact result depends on architecture | Separate classification and authorization verification |\n| Creditor-side collection | Licensed under AS 08.24 unless excluded or outside Alaska nexus described by regulator | Collection-agency license/operator/branch requirements as applicable |\n| Self-creditor collecting in its own name | Generally not the core “claims owed another” activity | Cannot create a false third-party appearance; UTPA remains |\n| Telephonic solicitation campaign | Prohibited unless registered at least 30 days before launch or actually exempt | Separate filing for each campaign; complete only upon Department acknowledgment |\n| Alaska business activity | Ordinary business license required unless a statutory exemption applies | Business-license filing does not replace regulatory licensing |\n\n### 2.2 Telephonic seller registration is an access condition, not a debt license\n\nAS 45.63.010 prohibits selling or attempting to sell services through a qualifying campaign unless the telephone seller is registered with the Department of Law at least 30 days before the campaign. A separate notice is required for each campaign, and registration is not complete until the seller receives the Department’s acknowledgment. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/)\n\nThe official application requires:\n\n- a separate filing per campaign;\n- a $200 nonrefundable fee;\n- service descriptions and costs;\n- a sample written contract;\n- updates within 10 days for material changes; and\n- salesperson updates every 90 days. [Alaska Department of Law+3](https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf)\n\nThat registration permits operation of the **telephonic sales channel** subject to the Act. It is not a substantive determination that the applicant may lawfully provide debt settlement, hold consumer funds, charge any particular fee, or avoid federal law.\n\n### 2.3 Money-transmission authorization\n\nFor a custodial model, the current pathways are:\n\n1. an Alaska money-transmission license;\n2. operation as an authorized delegate of an Alaska-licensed transmitter;\n3. qualifying approval under AS 06.55.103 for a person licensed in another state; or\n4. an actual statutory exclusion.\n\nThe Division of Banking and Securities states that all licensing activity is conducted through NMLS. Applications require the statutory information, screening materials, security evidence, background authorization, and applicable fees. [Alaska Department of Commerce+2](https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses)\n\n### 2.4 Attorney status\n\nNo blanket attorney exemption was located in either:\n\n- AS 45.63’s telephonic-solicitation exemptions; or\n- AS 06.55.802’s current money-transmission exclusions.\n\nAttorneys are expressly excluded from Alaska’s collection-agency chapter when acting in the regular course of their legal business, but that does not itself exempt an attorney-controlled business from money-transmission or telephonic-selling rules. [Justia Law+3](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/)\n\nThe federal TSR likewise has no general attorney exemption for attorneys engaging in covered interstate telemarketing. The FTC staff guide notes that particular attorneys may fall outside the rule because of their actual sales method, such as a qualifying face-to-face process, not merely because they use a law-firm or retainer label. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business)\n\n### 2.5 Nonprofit status\n\nA nonprofit label does not create a general Alaska exemption.\n\n- Alaska’s business-license guidance includes nonprofit entities when they engage or offer to engage in activity for financial benefit in exchange for services or goods.\n- The telephonic chapter’s charitable exemption applies only to a charitable organization or paid solicitor registered under AS 45.68 and acting within the capacity covered by that registration.\n- Even the listed AS 45.63 exemptions exclude only specified provisions: AS 45.63.010, .015, .020, and .030(c)–(d). They do not, by their text, erase the buyer’s refund rights in .030(a)–(b).\n- AS 06.55.802 contains no generic nonprofit exclusion. [Alaska Department of Commerce+3](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs)\n\nFor federal TSR purposes, bona fide nonprofits generally fall outside the rule because the rule applies to for-profit sellers, while a company falsely claiming nonprofit status remains covered. That is federal treatment and cannot be imported as an Alaska money-transmission or telephonic-registration exemption. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business)\n\n### 2.6 Financial institutions and other institutional exclusions\n\nAS 45.63.080 provides a conditional telephonic-sales exemption for a supervised financial institution and its parent, subsidiary, or affiliate. It also covers certain RCA-regulated businesses and insurers. The exemption is only from the particular sections identified in subsection (a), not necessarily every requirement in the chapter. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/)\n\nAS 06.55.802 excludes enumerated government entities, USPS transmission, qualifying banks and bank-related entities, government-benefit transfers, regulated securities/commodities clearance activity, certain payment-system operators, and securities broker-dealers to the extent stated. No general debt-relief, lawyer, or nonprofit exclusion appears in the present list. [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-802/)\n\n### 2.7 Collection-agency crossover and self-creditor boundary\n\nAS 08.24.090 prohibits an unlicensed person, for compensation, from collecting claims for others, soliciting the right to collect or receive another’s claim, or seeking payment on another’s behalf. The definition focuses on claims owed or asserted to be owed to another. [Justia Law+1](https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/)\n\nThe regulator states:\n\n- an out-of-state agency does not need an Alaska license merely because it is collecting from Alaska debtors when its creditor clients are outside Alaska;\n- licensing is required when the out-of-state agency collects or solicits claims for Alaska-based creditor clients; and\n- the division does not issue exemption letters. [Alaska Department of Commerce](https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/CollectionAgencies)\n\nA standard consumer-retained debt negotiator is not plainly collecting for the creditor. A hybrid provider that is paid by, contracted with, or delegated authority by creditors requires a separate functional analysis. No Alaska appellate decision or published agency interpretation resolving every such hybrid was located.\n\n## 3. Current fee structures, dollar limits, percentages, and refunds\n\n### 3.1 Consumer-facing debt-relief fees\n\nNo Alaska-specific numerical limit was located or verified for:\n\n- enrollment or setup fees;\n- monthly maintenance fees;\n- counseling fees;\n- per-debt fees;\n- settlement fees;\n- a percentage of enrolled debt;\n- a percentage of savings;\n- an aggregate program fee; or\n- an indexed or CPI-adjusted debt-relief fee.\n\nThat is **not** a conclusion that any amount is automatically lawful. It means Alaska did not supply a verified debt-relief-specific numerical schedule in the authorities found. Fee enforceability and timing remain subject to the applicable sales contract, Alaska refund and UTPA rules, federal TSR requirements, and any money-transmission or other law implicated by the actual model. **Claim C015.**\n\nNo Alaska bulletin or dated table establishing a debt-relief CPI adjustment was located. Accordingly, no “current adjusted amount” was calculated or inferred.\n\n### 3.2 Verified provider-side governmental fees\n\n| Fee | Current verified amount | Conditions and refund treatment |\n| --- | --- | --- |\n| Alaska telephonic seller registration | **$200 per campaign** | Nonrefundable; separate registration for each campaign |\n| Alaska business license | **$50 per year** | Nonrefundable after issuance; special sole-proprietor discounts exist but are not relevant to the ordinary entity model |\n| Money-transmission application or AS 06.55.103 approval application | **$2,000 + $200 per additional location** | Nonrefundable |\n| Money-transmission annual renewal | **$1,000** | Provider-side regulatory fee |\n| Initial license/first-year operation fee | **$1,000 initial location + $200 each additional physical location + $1,000 each additional Internet-based location** | Refundable if application is denied; nonrefundable if withdrawn or abandoned |\n| NMLS processing or other registry fees | Variable | Additional to Alaska fees |\n| Virtual-currency kiosk transaction fee | **Maximum 10% of transaction value** | Applies only to virtual-currency kiosk transactions—not debt settlement, DMP, counseling, or ordinary creditor payments |\n\nThe telephonic fee is confirmed by both 9 AAC 14.060 and the current official application. [Alaska Department of Law+1](https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf)\n\nThe current money-transmission fee amounts are stated in 3 AAC 13.840. The regulation’s history identifies the fee amendment as effective November 22, 2017; the official adoption order contains the same amounts. [Legal Information Institute+1](https://www.law.cornell.edu/regulations/alaska/3-AAC-13.840)\n\nThese are **governmental/provider access fees**, not consumer debt-relief charges and not evidence that Alaska has approved the provider’s consumer pricing.\n\n### 3.3 Money-transmission transaction fees\n\nAS 06.55.820 requires the licensee, generally within ten business days after receiving the value, to transmit the monetary equivalent **after deduction of fees** or make it available to the designated recipient. AS 06.55.830 requires a receipt stating the amount presented and total fees charged. [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/)\n\nThose provisions establish transaction-performance and disclosure duties. They do **not**:\n\n- authorize a debt-settlement percentage;\n- approve a debt-management service charge;\n- create an advance-fee exception; or\n- transform a telephonic registration into a debt-relief license.\n\n### 3.4 Virtual-currency kiosk cap is not a debt-relief cap\n\nSB 249 created a 10% fee ceiling for a “virtual currency kiosk transaction.” Its definition and surrounding provisions concern transactions conducted through a virtual-currency kiosk. The same act amended the general location language in the money-transmission definition and took effect October 1, 2026. [LegiScan+3](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\nA $4,000 credit-card debt settlement is not converted into a virtual-currency kiosk transaction merely because the same chapter contains a 10% limit.\n\n### 3.5 Refund and credit conditions\n\n**Telephonic services:** A buyer is entitled to a refund or credit when, within seven days after paying and before services are provided, the buyer makes a written request. Separate protection applies when services are defective, not as represented, or not received as promised. A timely request can be made in person or properly mailed and postmarked within the period. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/)\n\nSB 252, effective September 30, 2026, amended AS 45.63.030 only to add the new AS 45.36 UCC cross-reference. It retained the seven-day service-refund wording. [LegiScan+2](https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf)\n\n**Money transmission:** A money-transmission licensee must generally refund money equal to the money or equivalent value received for the transmission within ten days after a written request, unless the value has already been transmitted or made available, crime concerns exist, or another law prohibits the refund. The statute should not be treated as an automatic refund rule for every separate debt-relief service fee. [Justia Law](https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-840/)\n\nSB 249 separately excluded virtual-currency kiosk refunds under the new kiosk provisions from AS 06.55.840. That kiosk amendment does not alter ordinary debt-relief service-fee rules. [LegiScan](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\n## 4. When fees may actually be requested or received\n\n### 4.1 Alaska telephonic contract trigger\n\nA telephone seller may not:\n\n- solicit payment;\n- charge a credit card;\n- negotiate a check or other payment instrument; or\n- accept cash\n\nuntil it has received a signed written contract from the buyer. The contract must disclose the buyer’s AS 45.63.030 rights and required regulatory information. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/)\n\nThis is a **minimum Alaska sales-channel condition**, not affirmative authorization to collect a debt-relief fee immediately after signature.\n\n### 4.2 Federal TSR performance trigger\n\nFor a covered debt-relief service, 16 C.F.R. § 310.4(a)(5) prohibits requesting or receiving the provider’s fee until all three conditions are satisfied:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid settlement agreement, DMP, or other contractual agreement;\n2. the customer has made at least one payment under that agreement to the creditor or collector; and\n3. when debts are handled individually, the fee attributed to that debt follows one of the permitted allocation methods. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\nThe allocation alternatives are:\n\n- **Proportional enrolled-debt method:** the fee for the resolved debt bears the same proportion to the total contracted fee as that debt bore to total enrolled debt; or\n- **Savings method:** the provider charges a percentage of actual savings, using the same percentage from one individual debt to another. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\nThe TSR sets timing and allocation requirements; it does not itself prescribe a maximum 15%, 20%, 25%, or other fee.\n\n### 4.3 Dedicated accounts\n\nThe TSR permits requiring a customer to place funds in an account for creditor payments and lawful provider fees only if, among other things:\n\n- the account is at an insured financial institution;\n- the customer owns the funds and receives any interest;\n- the account administrator is not owned, controlled by, or affiliated with the debt-relief provider;\n- no referral compensation passes between the administrator and provider; and\n- the customer can withdraw at any time without penalty and receive all funds other than properly earned provider fees within seven business days. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\nThis federal permission to fund an independent account is not an Alaska money-transmission ruling. Alaska status still turns on who receives, controls, administers, and transmits the money.\n\n### 4.4 State and federal conditions must be stacked\n\nA covered telephonic transaction can therefore require all of the following:\n\n- Alaska campaign registration;\n- a signed Alaska-compliant contract before payment is solicited or accepted;\n- satisfaction of the federal performance trigger before the provider receives its service fee;\n- money-transmission authorization if the provider or related entity receives funds for creditor transmission; and\n- compliance with Alaska refund and deceptive-practices rules.\n\nPassing one condition does not satisfy the others.\n\n## 5. Actual regulator procedure, application, and lookup routes\n\n| Function | Regulator and procedure | Public verification route | What the result proves—and does not prove |\n| --- | --- | --- | --- |\n| Alaska business license | DCCED, Division of Corporations, Business and Professional Licensing | Official business-license search and online/new application links | Proves business-license status only; does not authorize debt settlement, telemarketing, or money transmission |\n| Telephonic sales | Alaska Department of Law, Consumer Protection Unit | Official application and registered-telemarketer PDF | Proves campaign registration; does not approve fees or fund handling |\n| Money transmission | DCCED, Division of Banking and Securities; filings through NMLS | NMLS licensing/checklist link and Alaska MSB roster | Proves money-services licensing/approval status if current; not a debt-settlement endorsement |\n| Collection agency | DCCED Professional Licensing | Alaska Professional License Search | Relevant only if actual conduct falls within AS 08.24 |\n| UTPA enforcement | Alaska Department of Law | Consumer Protection Unit and complaints/enforcement materials | Enforcement jurisdiction, not provider authorization |\n\n### 5.1 Business-license procedure\n\nThe official page provides:\n\n- online new and renewal applications;\n- business-license records and status search;\n- forms and fees; and\n- immediate posting of online new or renewed licenses to the search database. [Alaska Department of Commerce](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing)\n\nAn Alaska business license is a baseline permission to conduct business. AS 43.70.020(d) expressly requires a business subject to another regulatory regime to satisfy that regime as well. [Justia Law](https://law.justia.com/codes/alaska/title-43/chapter-70/section-43-70-020/)\n\n### 5.2 Telephonic registration is operational\n\nThe Department of Law’s current list is dated October 15, 2026 and includes, among others:\n\n- Beyond Finance—described as offering debt management, debt settlement, and marketing services;\n- Century Support Services—debt settlement;\n- ClearOne Advantage—debt settlement, debt negotiation, and financial education; and\n- DebtBlue—debt-relief services. [Alaska Department of Law+1](https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf)\n\nThis proves that the Department is currently administering AS 45.63 registrations for campaigns described as debt-relief campaigns. It does **not** prove:\n\n- authorization under AS 06.55;\n- an Alaska debt-settlement license;\n- approval of consumer fees;\n- compliance with the federal TSR;\n- compliance with contract or client-funds duties; or\n- current authorization of any provider not separately checked.\n\n### 5.3 Money-transmission procedure and lookup limitation\n\nThe Division of Banking and Securities states that all licensing activity is conducted through NMLS and links to the licensing checklist, statutes, regulations, and filing systems. [Alaska Department of Commerce](https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses)\n\nThe Alaska-hosted MSB roster available during this research has a filename indicating March 19, 2026. It contains filing status and license numbers, but it is older than the October 24, 2026 current-law check. It is useful as a public roster, but it should not be treated as conclusive current status when a current NMLS verification is available. [Alaska Department of Commerce](https://www.commerce.alaska.gov/web/Portals/3/pub/MSB%20Roster%2020260319.pdf?ver=I4DJq-khBB6DzfDe3jjgPw%3D%3D)\n\nNo provider-specific NMLS determination was made in this pass.\n\n### 5.4 The legacy “Company Uniform Application” is not a debt-relief application\n\nThe legacy form’s debt-related activity checklist is potentially misleading. Immediately before the checklist, the form instructs applicants to identify activities including those **“for which your company is not specifically seeking licensing authority.”** The following list includes debt negotiation, debt settlement/debt adjuster, and debt management/credit counseling. [Alaska Department of Commerce+1](https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827)\n\nIt is therefore a general business-activity disclosure taxonomy, not evidence that Alaska historically or currently grants a debt-settlement license.\n\n### 5.5 Advertising authorization or status inaccurately creates UTPA risk\n\nAlaska prohibits unfair or deceptive trade practices, including creating confusion about approval, affiliation, certification, sponsorship, or status. A provider should not advertise a business license, telephonic registration, nonprofit relationship, attorney relationship, or NMLS filing as an Alaska endorsement of its debt-relief program. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/)\n\nAlaska’s 2023 FirstChoice action illustrates the enforcement posture: the complaint alleged that debt-relief solicitations were designed to resemble government financial-assistance notices. It is an allegation and enforcement example, not a controlling judicial classification of debt settlement. [Alaska Department of Law](https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html)\n\n## 6. Fee and boundary examples\n\nDetailed examples appear in **D.1** below. The key outcomes are:\n\n- a hypothetical percentage can be used to demonstrate the federal proportional or savings calculation, but it is not an Alaska-approved percentage;\n- no fee may be allocated to an unresolved individual debt under the TSR’s individual-debt rule;\n- a telephonic buyer can have a seven-day pre-service refund right;\n- a licensed money transmitter’s disclosed transaction fee does not become a debt-management fee authorization; and\n- a provider that receives creditor funds without required AS 06.55 authority has no verified lawful custodial fee scenario to calculate.\n\n## 7. Component coverage and next investigations\n\nThis pass resolves the basic market-access and fee architecture but does not close Alaska.\n\nMaterial holds remain concerning:\n\n- Alaska agency interpretation of DMP and dedicated-account fund flow under AS 06.55;\n- complete provider-specific NMLS and authorized-delegate verification;\n- creditor-side collection crossover for hybrid debt-relief arrangements;\n- Alaska appellate or published administrative decisions directly classifying debt settlement;\n- client-fund account, trust, segregation, remittance, and reconciliation duties beyond the limited AS 06.55 provisions needed here;\n- security/bond and financial-condition requirements;\n- contract form and disclosure requirements beyond the telephonic-sales threshold;\n- remedies, penalties, private actions, and limitation periods;\n- secured debts and sector-specific products;\n- local, municipal, Alaska Native, and tribal issues; and\n- enforcement-history and full case-law review.\n\nThe full component table is in **D.2**.\n\n# B. Source table\n\n**Access date for every source below:** October 24, 2026, unless a different source date is stated. “Mirror” means the operative text was read there because the official Alaska Legislature endpoint returned a public-web 403 response. The failed official routes are preserved in S_AK-P1-S019.\n\n| Source ID | Title / issuer and direct literal URL | Exact passages, version, and legal status | Limitations |\n| --- | --- | --- | --- |\n| **S_AK-P1-S001** | Alaska Consumer Laws—Department of Law: https://law.alaska.gov/department/civil/consumer/laws.html  • Professional Licensing—DCCED: https://www.commerce.alaska.gov/web/cbpl/professionallicensing | Consumer-law index, list at page lines 51–73; licensed-professions list beginning at lines 53–99. Current agency pages. [Alaska Department of Law+1](https://law.alaska.gov/department/civil/consumer/laws.html) | Negative corroboration only. An index omission is not conclusive proof that no provision exists elsewhere. |\n| **S_AK-P1-S002** | AS 45.50.471: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/ • AS 45.50.481: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-481/ | § .471(a), (b)(3)–(4), lines 58–67; § .481(a)–(c), lines 59–66. 2025 codification mirror. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/) | No debt-relief-specific holding inferred from general UTPA text. |\n| **S_AK-P1-S003** | AS 45.63.010: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/ • .020: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/ • .030: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/ • .080: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/ • .100: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/ | Registration: § .010(a)–(c); written contract: § .020; refunds: § .030(a)–(c); exemptions: § .080(a)(1)–(19); definitions: § .100(1), (4)–(6). 2025 codification reconciled with S014. [Justia Law+5](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/) | Mirror. SB 252’s 2026 amendment must be read with § .030. |\n| **S_AK-P1-S004** | 9 AAC 14.010: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010 • .020: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.020 • .060: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060 | Application contents; 10-day and 90-day updates; $200 registration fee. Cornell quarterly regulatory text. [Legal Information Institute+2](https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010) | Cornell is not the official Alaska publisher, but the current official DOL form confirms the operative requirements and fee. |\n| **S_AK-P1-S005** | DOL telemarketer page: https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html • Official form: https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf | Agency instructions; form p.1 lines 9–20 and p.2 lines 51–60. Form revised October 2019 and currently posted. [Alaska Department of Law+2](https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html) | Procedure evidence, not substantive debt-relief authorization. |\n| **S_AK-P1-S006** | Registered Telemarketers—Alaska DOL: https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf | PDF dated October 15, 2026; Beyond Finance p.1; Century, ClearOne, DebtBlue p.2. [Alaska Department of Law+1](https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf) | Proves telephonic registration description only; does not establish any other license or compliance. |\n| **S_AK-P1-S007** | Alaska Company Uniform Application Form: https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827 | Rev. 9/2016; p.2 lines 41–43 says activities include ones for which no licensing authority is sought; lines 84–97 list debt activities. [Alaska Department of Commerce+1](https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827) | Historical/legacy form; not a current debt-settlement application and not legal permission. |\n| **S_AK-P1-S008** | Business Licensing: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing • FAQs: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs • Search: https://www.commerce.alaska.gov/cbp/businesslicense/search/License • AS 43.70.020: https://law.justia.com/codes/alaska/title-43/chapter-70/section-43-70-020/ | Remote activity guidance; $50/year; nonrefundability after issuance; separate regulatory compliance under § .020(d). [Alaska Department of Commerce+3](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing) | Business license is not a professional or financial-services authorization. Statute text is a mirror. |\n| **S_AK-P1-S009** | AS 06.55.101: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/ • .103: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-103/ • .802: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-802/ • .820: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/ • .830: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-830/ • .840: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-840/ | License/delegate prohibition; other-state approval; complete exclusions; ten-business-day transmission; receipt; refund. 2025 codification reconciled with SB 249 and SB 86. [Justia Law+5](https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/) | Mirror. Current definition in SB 249 supersedes the unreconciled 2025 definition text. |\n| **S_AK-P1-S010** | 3 AAC 13.010: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010 • .020: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.020 • .840: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.840 • 2017 adoption order: https://www.commerce.alaska.gov/web/portals/3/pub/JU2017200431.pdf • 2023 order: https://www.commerce.alaska.gov/web/Portals/3/pub/2022200373%203%20AAC%2013%20Virtual%20Currency%20Regs%20Final%20-%20Signed%20by%20Lt.%20Gov%20Eff%201-1-2023.pdf?ver=2022-12-01-104939-013 | Application and approval requirements; fee schedule; 2017 order pp.10–12; 2023 order p.1 effective January 1, 2023. [Legal Information Institute+4](https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010) | Regulations read through Cornell plus official adoption orders. |\n| **S_AK-P1-S011** | DBS Money Service Businesses: https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses • Alaska roster: https://www.commerce.alaska.gov/web/Portals/3/pub/MSB%20Roster%2020260319.pdf?ver=I4DJq-khBB6DzfDe3jjgPw%3D%3D | Official page lines 16–31; all licensing through NMLS. Roster filename/date March 19, 2026. [Alaska Department of Commerce+1](https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses) | Roster is older than current access date; current provider status must be separately verified. |\n| **S_AK-P1-S012** | SB 249 enrolled text mirror: https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB249 | Enrolled §§ 2–3 and 6; money-transmission definition p.10 lines 258–267; kiosk cap p.8 lines 192–194; effective October 1, 2026. Chapter 50 SLA 2026. [LegiScan+3](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com) | Official bill-detail/text route returned 403 in the public tool; enrolled text was read from the mirror, with chapter/effective status corroborated by official search results and status record. |\n| **S_AK-P1-S013** | SB 86 enrolled text mirror: https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB86 | Transition § 78, p.59; regulation transition § 79; effective-date § 82, p.60: operative §§ 1–65 and 75–78 effective July 1, 2027. Chapter 48 SLA 2026. [LegiScan+2](https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf) | Future law for this pass; not substituted for current AS 06.55. Official route returned 403. |\n| **S_AK-P1-S014** | SB 252 enrolled text mirror: https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB252 | §§ 185–186, pp.86–87; adds AS 45.36 cross-reference without changing seven-day service language. Effective September 30, 2026; Chapter 49 SLA 2026. [LegiScan+2](https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf) | Official bill route returned 403; enrolled text read from mirror. |\n| **S_AK-P1-S015** | AS 08.24.090: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/ • .380: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/ • Regulator: https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/CollectionAgencies • Verification: https://www.commerce.alaska.gov/web/cbpl/LicenseVerification | Creditor-side licensing and exemptions; definition; regulator’s out-of-state guidance; professional license search. [Justia Law+3](https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/) | Debt-relief/DMP crossover remains fact-specific; statute text read from mirror. |\n| **S_AK-P1-S016** | 16 C.F.R. Part 310—eCFR: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310 | § 310.2(o), debt-relief definition; § 310.4(a)(5), fee trigger and allocation; § 310.6(b)(7), business calls. eCFR shown current through October 22, 2026. [eCFR+3](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | Federal baseline only; does not establish Alaska authorization. |\n| **S_AK-P1-S017** | FTC Debt Relief Services & TSR Guide: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business | Coverage, bona fide nonprofit treatment, attorney discussion, inbound/outbound examples. [Federal Trade Commission+1](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) | FTC staff guide expressly states it is nonbinding; eCFR text controls. |\n| **S_AK-P1-S018** | Alaska v. FirstChoice press release: https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html | August 31, 2023; allegations concerning debt-relief advertisements designed to resemble government assistance. [Alaska Department of Law](https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html) | Enforcement allegation and agency statement, not a merits judgment or licensing interpretation. |\n| **S_AK-P1-S019** | Alaska Statutes endpoint: https://www.akleg.gov/basis/statutes.asp • Official bill text attempts: https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0249Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0086Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0252Z | Official site identifies “Alaska Statutes 2025”; direct statute and bill-text routes returned 403 in the public browsing tool. Targeted official-site searches for “debt adjuster,” “debt adjustment,” “debt settlement,” “debt management,” and “credit counseling” produced no dedicated current chapter. [Alaska State Legislature](https://www.akleg.gov/basis/statutes.asp) | This is the preserved failed-route/search log. Negative search results are not conclusive legal proof. |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_AK-P1-C001** | No dedicated Alaska debt-adjuster/debt-settlement/DMP licensing and consumer-fee regime was located or verified. | S001, S007, S019. [Alaska Department of Law+3](https://law.alaska.gov/department/civil/consumer/laws.html) | **Moderate-high, bounded negative finding.** Not an absolute proof of nonexistence. |\n| **S_AK-P1-C002** | Alaska classification must follow actual conduct rather than the provider’s “settlement,” “counseling,” “law firm,” or “nonprofit” label. | S007 form expressly separates activity disclosure from licensing authority; S002 prohibits false approval/status. [Alaska Department of Commerce+1](https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827) | **High** as a compliance principle; exact classification remains fact-specific. |\n| **S_AK-P1-C003** | Noncustodial negotiation that never receives consumer funds is not, on the face of current AS 06.55’s definition, money transmission. | S009 § .101; S012 § 3. [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/) | **Moderate.** Statutory-text inference; no Alaska debt-relief interpretive opinion found. |\n| **S_AK-P1-C004** | Receiving consumer funds for remittance to creditors or collectors likely constitutes money transmission. | S012 § 3; S009 § .101. [LegiScan+1](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com) | **High on ordinary text; moderate-high overall** because no DMP-specific Alaska opinion was located. |\n| **S_AK-P1-C005** | Pure education with no represented debt alteration and no fund receipt is not itself the conduct defined as money transmission or federal debt relief. | S009; S016 § 310.2(o). [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/) | **High**, assuming the stated facts are true and marketing does not imply creditor-term alteration. |\n| **S_AK-P1-C006** | A qualifying campaign using substantially the same offer and terms to two or more people requires Alaska telephonic registration unless exempt. | S003 § .010(a), § .100(4). [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/) | **High.** |\n| **S_AK-P1-C007** | Alaska “telephonic means” includes electronic communication and certain written prompts encouraging contact. | S003 § .100(6). [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/) | **High.** Application to a particular web funnel requires factual analysis. |\n| **S_AK-P1-C008** | Registration must precede the campaign by at least 30 days, requires a separate notice per campaign, and is complete only upon Department acknowledgment. | S003 § .010(a)–(c); S005 form p.1. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/) | **High.** |\n| **S_AK-P1-C009** | The current telephonic registration fee is $200 per campaign and nonrefundable; material changes and salesperson lists have update duties. | S004 §§ .020, .060; S005 form. [Alaska Department of Law+2](https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf) | **High.** |\n| **S_AK-P1-C010** | AS 45.63’s exemptions are conditional and do not eliminate every chapter duty. | S003 § .080(a), which names only .010, .015, .020, and .030(c)–(d). [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/) | **High.** |\n| **S_AK-P1-C011** | A telephone seller must receive a signed written contract before soliciting or accepting payment or charging payment instruments. | S003 § .020. [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/) | **High.** This is not advance-fee authorization under federal law. |\n| **S_AK-P1-C012** | A buyer may request a refund or credit within seven days after paying for services if services have not yet been provided; misrepresented or undelivered services have separate protection. | S003 § .030(a)–(b); S014 confirms 2026 wording. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/) | **High.** |\n| **S_AK-P1-C013** | Alaska business licensing is activity-based, not physical-presence-based; ordinary fee is $50/year. | S008. [Alaska Department of Commerce+2](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs) | **High as agency guidance/statutory baseline.** Edge nexus facts remain case-specific. |\n| **S_AK-P1-C014** | Alaska collection licensing principally addresses collecting claims for creditors, not a conventional debtor-retained negotiator. | S015 §§ .090, .380. [Justia Law+1](https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/) | **Moderate-high.** Hybrid creditor relationships remain unresolved. |\n| **S_AK-P1-C015** | No Alaska numerical debt-relief setup, monthly, settlement, per-debt, savings, percentage, aggregate, or indexed cap was located. | S001, S007, S019. | **Moderate-high bounded negative finding.** No conclusion of “unlimited fees.” |\n| **S_AK-P1-C016** | A money transmitter generally must transmit net value within ten business days, disclose the amount and total fee, and honor qualifying written refund requests. | S009 §§ .820, .830, .840. [Justia Law+2](https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/) | **High.** Does not authorize debt-relief service fees. |\n| **S_AK-P1-C017** | Custodial access paths include Alaska licensure, authorized-delegate status, or qualifying approval under AS 06.55.103; an actual exclusion may also remove coverage. | S009 §§ .101, .103, .802; S010. [Justia Law+3](https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/) | **High.** |\n| **S_AK-P1-C018** | Official public routes exist for business-license, telephonic-registration, money-services, and professional-license verification. | S005, S008, S011, S015. [Alaska Department of Commerce+3](https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing) | **High.** Some external/NMLS status searches may require separate interaction. |\n| **S_AK-P1-C019** | Appearance on the registered-telemarketer list proves telephonic registration only. | S003 scope; S006 list. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/) | **High.** No broader authorization inferred. |\n| **S_AK-P1-C020** | Misrepresenting government, regulator, attorney, nonprofit, or license approval can violate Alaska’s UTPA. | S002 § .471(b)(3)–(4); S018 enforcement example. [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/) | **High for statutory rule; enforcement example is nonprecedential.** |\n| **S_AK-P1-C021** | For a TSR-covered debt-relief service, no provider fee may be requested or received until one debt is altered under a valid agreement and the customer makes the first payment under that agreement. | S016 § 310.4(a)(5)(i)(A)–(B). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | **High.** Federal coverage facts must exist. |\n| **S_AK-P1-C022** | When debts are resolved individually, one permitted TSR allocation is the enrolled-debt proportional method. | S016 § 310.4(a)(5)(i)(C)(1). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | **High.** |\n| **S_AK-P1-C023** | The alternative TSR allocation is a consistent percentage of actual savings across debts. | S016 § 310.4(a)(5)(i)(C)(2). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | **High.** It is an alternative calculation method, not an Alaska cap. |\n| **S_AK-P1-C024** | A TSR-compliant dedicated account must be insured, consumer-owned, independently administered, free from referral compensation, and withdrawable without penalty. | S016 § 310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | **High federally; Alaska MT classification remains fact-dependent.** |\n| **S_AK-P1-C025** | SB 249 is current as of this pass, amended transmission nexus, and created a 10% cap only for virtual-currency kiosk transactions. | S012 §§ 3, 6 and kiosk § .172. [LegiScan+3](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com) | **High.** Effective October 1, 2026. |\n| **S_AK-P1-C026** | SB 86’s broad replacement money-transmission provisions are future-effective on July 1, 2027, not the October 2026 governing regime. | S013 §§ 78–82. [LegiScan+1](https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf) | **High.** |\n| **S_AK-P1-C027** | SB 252 did not alter the substantive seven-day service cancellation rule; it added the AS 45.36 UCC reference. | S014 §§ 185–186. [LegiScan](https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf) | **High.** Effective September 30, 2026. |\n| **S_AK-P1-C028** | A nonprofit designation is not a generic Alaska business, telephonic, or money-transmission exemption. | S003 § .080(a)(9); S008; S009 § .802. [Justia Law+2](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/) | **High.** Federal bona fide nonprofit treatment is separate. |\n| **S_AK-P1-C029** | Attorney status creates no blanket Alaska telephonic or money-transmission exemption; attorneys do have a regular-course collection-agency exclusion. | S003 § .080; S009 § .802; S015 § .090(b)(1); S017. [Justia Law+4](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/) | **High on text; professional-practice facts can matter.** |\n| **S_AK-P1-C030** | Supervised financial institutions have a conditional AS 45.63 exemption; banks and related institutions have a separate conditional AS 06.55 exclusion. | S003 § .080(a)(16); S009 § .802(4). [Justia Law+1](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/) | **High.** Scope must match statutory conditions. |\n| **S_AK-P1-C031** | A creditor collecting its own claim in its own name is outside the core “claims owed another” definition, but using a different name to imply third-party collection can bring it within the chapter. | S015 § .380(2)(A). [Justia Law](https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/) | **High.** |\n| **S_AK-P1-C032** | No named provider’s full Alaska authorization was determined in this pass. | S006 telemarketing list; S011 older MSB roster. [Alaska Department of Law+1](https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf) | **Express hold.** A current multi-registry review is required per provider. |\n| **S_AK-P1-C033** | The verified $200, $50, and AS 06.55 filing/license amounts are provider-side governmental fees, not consumer debt-relief fee ceilings. | S004, S008, S010. [Legal Information Institute+2](https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060) | **High.** |\n\n# D. Worked examples and coverage/gap table\n\n## D.1 Plain-text worked examples\n\n### Example 1 — TSR proportional fee after one individual debt is resolved\n\nPlain text\n```\nAssumptions:\n- Federal TSR applies.\n- Alaska telephonic and other access requirements have also been satisfied.\n- Debts enrolled at contract date:\n    Debt A = $8,000\n    Debt B = $7,000\n    Debt C = $5,000\n- Total enrolled debt = $20,000\n- Hypothetical contracted total fee = 25% of enrolled debt.\n- The 25% is an example only. It is not an Alaska-approved rate or Alaska cap.\n- Debt C is settled, a valid agreement is executed, and the consumer makes the\n  first payment required by that agreement.\n\nBase:\n$20,000 total enrolled debt\n\nTotal hypothetical fee:\n$20,000 × 25% = $5,000\n\nResolved-debt proportion:\n$5,000 ÷ $20,000 = 0.25\n\nFee attributable to Debt C:\n0.25 × $5,000 = $1,250.00\n\nResult:\n- Fee currently attributable to Debt C = $1,250.00\n- Fee not yet attributable to Debts A and B = $3,750.00\n- Units: U.S. dollars\n- Rounding: nearest cent\n```\n\nLegal condition: The calculation is not triggered merely by obtaining the consumer’s signature. The debt alteration and first creditor payment must both have occurred. **Claims C021–C022.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\n### Example 2 — TSR savings-percentage method\n\nPlain text\n```\nAssumptions:\n- TSR applies.\n- The provider uses the same 25% savings percentage for every individual debt.\n- Enrolled balance of the resolved debt = $5,000\n- Amount actually paid to satisfy it = $3,000\n- Valid agreement and first consumer payment have occurred.\n\nActual savings:\n$5,000 - $3,000 = $2,000\n\nFee:\n$2,000 × 25% = $500.00\n\nResult:\nFee attributable to that debt = $500.00\nUnits: U.S. dollars\nRounding: nearest cent\n```\n\nThe 25% figure is hypothetical. Alaska supplies no verified 25% ceiling or approval. The example treats the savings and proportional methods as alternatives, not cumulative fees. **Claims C015, C021, C023.**\n\n### Example 3 — Lower-balance debt shows why the fee base matters\n\nPlain text\n```\nInputs:\n- Enrolled balance = $800\n- Settlement payment = $600\n- Savings = $800 - $600 = $200\n- Hypothetical percentage = 25%\n\nAlternative A — enrolled-debt fee:\n$800 × 25% = $200.00\n\nAlternative B — savings fee:\n$200 × 25% = $50.00\n\nDifference:\n$200 - $50 = $150.00\n\nResult:\nThe same written percentage produces materially different fees depending on\nthe contractual base. Alaska did not verify or approve either base.\n```\n\nFor a federally covered individually resolved debt, the provider must use the applicable TSR allocation method and satisfy the performance trigger. **Claims C021–C023.**\n\n### Example 4 — Prior earned fees, partial program performance, and cancellation\n\nPlain text\n```\nInputs:\n- Debts at enrollment:\n    Debt A = $10,000\n    Debt B = $5,000\n    Debt C = $5,000\n- Total = $20,000\n- Hypothetical total fee = 20% = $4,000\n- Proportional method is used.\n- Debt A and Debt B have each satisfied all TSR triggers.\n- Debt C remains unresolved.\n- Consumer then cancels.\n\nDebt A proportion:\n$10,000 ÷ $20,000 = 50%\nFee for Debt A:\n50% × $4,000 = $2,000\n\nDebt B proportion:\n$5,000 ÷ $20,000 = 25%\nFee for Debt B:\n25% × $4,000 = $1,000\n\nDebt C proportion:\n$5,000 ÷ $20,000 = 25%\nPotential allocation = $1,000\nCurrent earned amount = $0 because Debt C has not satisfied the trigger.\n\nTotal previously triggered fee:\n$2,000 + $1,000 = $3,000\n\nAdditional fee due solely because the consumer cancels:\n$0\n\nResult:\n- Previously triggered fees = $3,000\n- Untriggered Debt C fee = $0\n- No cancellation fee is supplied by this example.\n```\n\nA compliant dedicated account would separately have to return consumer-owned funds other than properly earned fees within seven business days after withdrawal. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\n### Example 5 — Alaska telephonic pre-service cancellation\n\nPlain text\n```\nInputs:\n- Consumer pays $300 on Day 0 after signing the required written contract.\n- Consumer makes a written refund request on Day 5.\n- No service has yet been provided.\n\nElapsed period:\n5 days\n\nStatutory window:\nWithin 7 days after paying and before services are provided.\n\nRefund or credit:\n$300.00\n\nResult:\nThe consumer is entitled to a $300 refund or credit under AS 45.63.030(a)(3),\nassuming the transaction is covered and no other factual issue defeats the claim.\n```\n\nIf the service was already provided before the request, the unconditional pre-service branch does not apply on those facts. Claims that services were defective, misrepresented, or not provided as promised remain separately analyzed under subsection (a)(1). **Claim C012.** [Justia Law](https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/)\n\n### Example 6 — Licensed custodial DMP transmission calculation\n\nPlain text\n```\nAssumptions:\n- Provider is properly authorized under AS 06.55.\n- $400 is received for transmission.\n- A separately disclosed $30 transaction fee is lawful under the applicable\n  contract and all other law.\n- No contrary consumer instruction or crime concern exists.\n\nAmount received:\n$400.00\n\nDisclosed transaction fee:\n$30.00\n\nNet monetary equivalent for transmission:\n$400 - $30 = $370.00\n\nTiming:\nTransmit $370 or make it available to the consumer-designated recipients\nwithin 10 business days.\n\nReceipt:\nMust clearly show $400 presented and $30 total fees.\n```\n\nThis example demonstrates AS 06.55’s transaction rule. It does not establish that a $30 debt-management **service** fee is approved, capped, or earnable in advance. **Claim C016.** [Justia Law+1](https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/)\n\n### Example 7 — Unlicensed custodial model: classification hold, not a fee calculation\n\nPlain text\n```\nFacts:\n- Provider receives $1,000 from an Alaska consumer.\n- Provider promises to remit the money to three creditors.\n- Provider has no Alaska money-transmission license.\n- Provider is not an authorized delegate.\n- No AS 06.55.103 approval or statutory exclusion is established.\n\nClassification:\nReceiving the $1,000 for creditor transmission fits the ordinary current\nmoney-transmission language.\n\nLegal access result:\nThe provider may not proceed with the custodial activity on these facts.\n\nLawful service-fee calculation:\nHeld. No licensed custodial scenario has been established, so no fee is\ninvented or calculated.\n```\n\n**Claims C004 and C017.** [LegiScan+1](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\n### Example 8 — Independent dedicated account boundary\n\nPlain text\n```\nFacts requiring verification:\n- Consumer deposits $900 into an insured account in the consumer's own name.\n- Consumer receives any interest.\n- Independent administrator is not owned, controlled by, or affiliated with\n  the debt-relief provider.\n- No referral compensation passes between them.\n- Consumer may withdraw at any time.\n- Provider cannot unilaterally take or redirect creditor funds.\n- Provider receives only fees that have satisfied the TSR trigger.\n\nFederal result:\nThe structure may satisfy the TSR dedicated-account conditions.\n\nAlaska result:\nHeld pending:\n1. who legally receives the funds;\n2. who can issue payment instructions;\n3. whether the administrator transmits value to or from Alaska;\n4. whether the provider has direct or constructive control;\n5. whether either entity is licensed, approved, delegated, or excluded.\n```\n\nNo Alaska debt-relief-specific safe harbor was found for this architecture. **Claim C024.**\n\n### Example 9 — The virtual-currency kiosk cap does not create a debt-relief cap\n\nPlain text\n```\nTransaction:\nOrdinary credit-card debt settlement program\nEnrolled debt:\n$4,000\nVirtual-currency kiosk used:\nNo\n\nSB 249 kiosk fee calculation:\nNot applicable\n\nIncorrect calculation:\n$4,000 × 10% = $400 as an \"Alaska debt settlement cap\"\n\nCorrect result:\nNo Alaska debt-relief cap is derived from the kiosk statute.\n```\n\n**Claim C025.** [LegiScan](https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com)\n\n## D.2 Full PASS-01 coverage and gap table\n\n| Component | Status | Claims | What was answered | Exact missing evidence / next investigation |\n| --- | --- | --- | --- | --- |\n| Dedicated debt-adjuster/debt-settlement regime | **Answered, bounded** | C001, C015 | No dedicated Alaska regime or fee table located or verified | Repeat against later official codification and any post-10/24/26 enactments; inspect uncodified historical acts if needed |\n| Marketing labels versus actual functions | **Answered** | C002, C025 | Labels and legacy activity checkboxes do not create permission | Provider-specific contracts, disclosures, and operational flow |\n| Pure counseling | **Answered with conditions** | C005 | No MT classification when no debt alteration representation or fund handling | Review actual advertising and counseling agreement |\n| Noncustodial principal-reduction settlement | **Answered with interpretive limitation** | C003 | No receipt/transmission on stated facts | Alaska DBS published or nonpublic interpretation; controlling case |\n| Noncustodial concession/DMP model | **Answered with interpretive limitation** | C003, C005 | Same functional rule | Actual creditor communications and promises |\n| Custodial DMP/distribution | **Partial but operationally material** | C004, C017 | Likely AS 06.55 money transmission | Alaska DBS debt-management interpretation and exact fund-flow documents |\n| Custodial settlement payments | **Partial but operationally material** | C004, C017 | Likely AS 06.55 money transmission | Provider/administrator account and remittance documents |\n| Consumer-owned dedicated account | **Unresolved/fact-specific** | C024 | Federal requirements established; no Alaska safe harbor located | Ownership, administrator, control, payment authority, affiliate and licensing evidence |\n| Consumer/business-purpose distinction | **Answered for this pass** | C006, C007; federal context C021 | State statutes use person/activity/nexus rather than household-purpose language; TSR B2B rule separate | Business-purpose UTPA and contract issues if commercially material |\n| Resident/remote-provider nexus | **Answered with edge hold** | C007, C013, C025 | No physical-presence requirement; broad telephonic and transmission nexus | Constitutional and fact-intensive nexus analysis for unusual models |\n| Alaska business license | **Answered** | C013, C018 | Requirement, fee, application and search routes | Named-provider lookup not performed |\n| Telephonic campaign registration | **Answered** | C006–C012, C018–C019 | Trigger, timing, fee, contract, refund, exemptions, application, list | Campaign-specific exemption and script review |\n| Money-transmission authorization pathways | **Answered procedurally** | C017–C018 | License, delegate, other-state approval, exclusions, NMLS route | Named-provider current NMLS status and authorized-delegate appointments |\n| Collection-agency crossover | **Partial** | C014, C029, C031 | Creditor-side text and regulator guidance | Hybrid DMP contracts, creditor compensation, agency authority, appellate interpretation |\n| Attorney exclusion | **Answered for access scope** | C029 | No blanket telephonic/MT exemption; collection exclusion exists | Practice-of-law, ownership, fee-sharing, and ethics analysis reserved |\n| Nonprofit exclusion | **Answered for access scope** | C028 | No generic Alaska exemption | Organizational bona fides, AS 45.68 scope, tax status, and compensation structure |\n| Financial-institution exclusions | **Answered for access scope** | C030 | Conditional telephonic and MT exclusions | Institution and affiliate status, exact activity within exclusion |\n| Self-creditor | **Answered for boundary** | C031 | Own-name collection generally outside core definition; faux third-party risk | UTPA/FDCPA and sector rules later |\n| Alaska debt-relief numerical fee caps | **Answered, bounded negative** | C015 | No setup/monthly/per-debt/savings/percentage/aggregate cap found | Any agency unpublished interpretation or future enactment |\n| Indexing/adjusted debt-relief amounts | **Answered, bounded negative** | C015 | No indexed debt-relief schedule found; no CPI calculation invented | Later bulletin or enactment search |\n| Provider filing and license fees | **Answered** | C009, C013, C033 | Telephonic, business, and MT amounts | Collection-agency fee schedule excluded because no collection model established |\n| Fee request/receipt timing | **Answered** | C011, C021–C024 | Alaska signed-contract threshold and federal performance trigger separated | Provider-specific federal coverage and actual performance records |\n| Telephonic cancellation/refund | **Answered** | C012, C027 | Seven-day pre-service right and 2026 amendment reconciliation | Full contract/remedies pass |\n| Money-transmission receipt/refund | **Answered to access/fee extent** | C016, C025 | Net transmission, receipt, written refund rule and kiosk exception | Full client-funds/remedies pass |\n| Current telemarketer lookup | **Answered** | C018–C019 | Official list dated 10/15/26 read | Named-provider registration certificate and campaign expiration if needed |\n| Current MSB lookup | **Partial** | C018, C032 | Official route and older Alaska roster identified | Current NMLS Consumer Access verification per provider |\n| Current business/professional lookup | **Answered procedurally** | C018 | Official search routes identified | Named-provider status not requested or determined |\n| 2026 statutory updates | **Answered** | C025–C027 | SB 249 current; SB 252 current; SB 86 future | Monitor implementing regulations and pre-7/1/27 transition work |\n| Controlling Alaska decisions on debt-settlement classification | **Unresolved** | C003, C004, C014 | Targeted searches found no directly controlling decision | Broader Alaska appellate, administrative, trial-docket, and paid-database review |\n| Agreement form and complete disclosures | **Excluded/later pass** | — | Only AS 45.63 threshold discussed as needed for timing | Full contract/agreement pass |\n| Client-money segregation, trust, reconciliation, and administrator duties | **Excluded/later pass** | — | Only AS 06.55 transmission/receipt/refund rules needed here | Full funds pass |\n| Bonds, security, net worth, permissible investments | **Excluded/later pass** | — | Application security requirement noted only | Full market-access financial-condition pass |\n| Remedies, civil penalties, criminal exposure, private actions | **Excluded/later pass** | — | UTPA relevance noted; no complete remedies analysis | Remedies/enforcement pass |\n| Full collection, litigation, and limitations coverage | **Excluded/later pass** | — | Collection boundary only | Dedicated collection/litigation/limitations passes |\n| Secured debts, mortgage relief, tax debts, student loans, and sector products | **Excluded/later pass** | — | No substantive sector conclusion | Product-specific passes |\n| Local, municipal, tribal, and Alaska Native law | **Excluded/later pass** | — | No conclusion | Local/tribal jurisdictional investigation |\n| Named-provider authorization | **Expressly not determined** | C032 | No marketing statement treated as authorization | Current searches in every applicable registry and underlying certificates |\n\n# E. Researcher self-check\n\n## Material actually read\n\nI read the relevant operative passages of:\n\n- AS 45.63 registration, written-contract, cancellation, exemption, and definition provisions;\n- 9 AAC 14 registration, update, and fee regulations;\n- the official Alaska telephonic seller application;\n- the October 15, 2026 registered-telemarketer PDF;\n- AS 43.70 business-license provisions and current DCCED instructions;\n- AS 06.55 license, approval, exclusion, transmission, receipt, and refund provisions;\n- 3 AAC 13 application, approval, and fee provisions;\n- the official 2017 money-services fee adoption order;\n- the official 2023 virtual-currency regulation filing;\n- SB 249’s enrolled definition, kiosk-fee, refund, and effective-date provisions;\n- SB 86’s transition and effective-date provisions;\n- SB 252’s AS 45.63 amendments and effective status;\n- AS 08.24 collection-agency licensing and definition provisions;\n- Alaska’s collection-agency regulator guidance and verification page;\n- Alaska’s UTPA text and consumer-protection materials;\n- the federal TSR definition, fee trigger, allocation, dedicated-account, and business-call provisions;\n- the FTC debt-relief guide’s attorney and nonprofit treatment; and\n- the legacy Alaska Company Uniform Application language showing that its activity list is not a licensing request.\n\nPDFs material to the conclusions—including the applications, rosters, enrolled bills, and regulation adoption orders—were opened and their relevant pages visually inspected, not treated as title-only search results.\n\n## Material not established or not fully read\n\n- The Alaska Legislature’s official statute and bill-text endpoints repeatedly returned 403 responses in the available public browsing route. I preserved those failures rather than claiming direct access. Current statutory text was therefore assembled from the 2025 codification mirrors, official agency materials, enrolled-bill mirrors, and official chapter/effective-status corroboration.\n- I did not treat a search snippet, association chart, company website, or legacy form as legal authorization.\n- I did not obtain nonpublic Alaska agency opinions.\n- I did not complete a comprehensive paid-database, PACER, or every-trial-court docket search.\n- I did not inspect any provider’s private contracts, consumer files, bank agreements, dedicated-account agreements, creditor agreements, or actual transaction records.\n- I did not verify any named provider’s complete current Alaska status across business licensing, telephonic registration, NMLS, authorized-delegate records, collection licensing, and entity status.\n- The Alaska MSB roster available on the official site was dated March 19, 2026, so it was not used as conclusive current status.\n- I did not file an application, contact a regulator, solve a CAPTCHA, change an account or permission, access private borrower data, or represent that any provider was authorized.\n- I did not make local-file, publication, website-change, or publication-readiness claims.\n- This is researcher self-checking, **not independent legal review**.\n- Actual model and mode provenance is whatever the ChatGPT interface records; it is not inferred from the assignment wording.\n\n## Overall confidence\n\n- **High:** telephonic registration, contract timing, cancellation text, governmental fees, current 2026 effective dates, money-transmission licensing prohibition, public application procedures, and federal TSR timing.\n- **Moderate-high:** bounded conclusion that Alaska has no located dedicated debt-relief license or numerical fee schedule.\n- **Moderate:** applying AS 06.55 to particular custodial DMP arrangements and applying AS 08.24 to hybrid debtor/creditor relationships.\n- **Held:** dedicated-account arrangements without complete ownership, control, administrator, affiliate, instruction, and licensing facts.\n\nNo Alaska state completion, SettleADebt state acceptance, or A066 acceptance is implied.\n\n**END S_AK PASS-01.**\n\n","tables":[{"headers":["Actual model","Alaska classification for this pass","Principal legal consequence"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Actual model","Alaska classification for this pass","Principal legal consequence"],["Financial education or budgeting only—no representation that the provider will alter debt terms and no handling of consumer funds","No debt-specific license located. Not “money transmission” merely because advice is given.","Business-license, telephonic-sales, contract, advertising, and UTPA analysis still applies."],["Principal-reduction settlement or negotiation, noncustodial—provider negotiates but never receives or controls funds for creditor payment","On the face of AS 06.55, negotiation alone is not “receiving money or monetary value for transmission.” This is a statutory-text inference, not a published Alaska agency opinion.","No dedicated debt-settlement license located; business license and telephonic registration can still be required. Federal TSR may control fee timing."],["DMP or credit counseling that obtains concessions but never takes consumer funds","Same noncustodial analysis. Obtaining lower interest, waived fees, or changed payment terms does not by itself equal money transmission.","General Alaska business/telephonic/UTPA rules; federal TSR if represented to alter unsecured debt terms through telemarketing."],["DMP that receives one consolidated consumer payment and distributes it to creditors","Receiving money for transmission “to the state, from the state, or within the state” fits the ordinary text of current AS 06.55.990(15).","Money-transmission authorization is likely required unless an exclusion applies."],["Debt-settlement company that receives settlement funds and pays creditors or collectors","Same likely money-transmission classification.","A telephonic registration or ordinary business license does not cure an AS 06.55 licensing defect."],["Consumer-owned dedicated account administered by an independent account company","Fact-dependent. If the debt-relief provider never receives or controls the funds, its own AS 06.55 status may differ from the account administrator’s status. No Alaska opinion resolving this exact debt-relief architecture was located.","Hold Alaska classification until account ownership, withdrawal rights, payment instructions, control, affiliation, and actual fund flow are documented."],["Creditor negotiating or settling its own debt in its own name","Generally outside the core collection-agency definition, which concerns claims owed to another.","A creditor using another name to create the impression that a third party is collecting can be treated as conducting collection-agency business."],["Provider retained by a creditor to collect or receive claims","Collection-agency activity under AS 08.24.090 and .380, subject to statutory exclusions and the regulator’s creditor-location guidance.","Collection-agency licensing analysis, separate from debtor-side debt-relief analysis."]]},{"headers":["Model or function","Alaska status","Required route or condition"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or function","Alaska status","Required route or condition"],["Pure fee-based counseling, no debt alteration and no money custody","Not subject to a dedicated debt license located in this pass","Alaska business license; telephonic registration if the sales campaign fits AS 45.63; UTPA compliance"],["Noncustodial debt settlement/negotiation","Not prohibited as a named business and no dedicated debt license located","Business license; telephonic registration or actual exemption; federal TSR if applicable"],["Noncustodial DMP/concession service","Same","Same"],["Custodial DMP or settlement service receiving money for creditor payment","Prohibited without applicable AS 06.55 authority","Alaska money-transmission license, authorized-delegate status, AS 06.55.103 approval, or a verified statutory exclusion"],["Independent dedicated-account administrator receiving or transmitting funds","Potential money transmitter; exact result depends on architecture","Separate classification and authorization verification"],["Creditor-side collection","Licensed under AS 08.24 unless excluded or outside Alaska nexus described by regulator","Collection-agency license/operator/branch requirements as applicable"],["Self-creditor collecting in its own name","Generally not the core “claims owed another” activity","Cannot create a false third-party appearance; UTPA remains"],["Telephonic solicitation campaign","Prohibited unless registered at least 30 days before launch or actually exempt","Separate filing for each campaign; complete only upon Department acknowledgment"],["Alaska business activity","Ordinary business license required unless a statutory exemption applies","Business-license filing does not replace regulatory licensing"]]},{"headers":["Fee","Current verified amount","Conditions and refund treatment"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Fee","Current verified amount","Conditions and refund treatment"],["Alaska telephonic seller registration","$200 per campaign","Nonrefundable; separate registration for each campaign"],["Alaska business license","$50 per year","Nonrefundable after issuance; special sole-proprietor discounts exist but are not relevant to the ordinary entity model"],["Money-transmission application or AS 06.55.103 approval application","$2,000 + $200 per additional location","Nonrefundable"],["Money-transmission annual renewal","$1,000","Provider-side regulatory fee"],["Initial license/first-year operation fee","$1,000 initial location + $200 each additional physical location + $1,000 each additional Internet-based location","Refundable if application is denied; nonrefundable if withdrawn or abandoned"],["NMLS processing or other registry fees","Variable","Additional to Alaska fees"],["Virtual-currency kiosk transaction fee","Maximum 10% of transaction value","Applies only to virtual-currency kiosk transactions—not debt settlement, DMP, counseling, or ordinary creditor payments"]]},{"headers":["Function","Regulator and procedure","Public verification route","What the result proves—and does not prove"],"index":3,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Function","Regulator and procedure","Public verification route","What the result proves—and does not prove"],["Alaska business license","DCCED, Division of Corporations, Business and Professional Licensing","Official business-license search and online/new application links","Proves business-license status only; does not authorize debt settlement, telemarketing, or money transmission"],["Telephonic sales","Alaska Department of Law, Consumer Protection Unit","Official application and registered-telemarketer PDF","Proves campaign registration; does not approve fees or fund handling"],["Money transmission","DCCED, Division of Banking and Securities; filings through NMLS","NMLS licensing/checklist link and Alaska MSB roster","Proves money-services licensing/approval status if current; not a debt-settlement endorsement"],["Collection agency","DCCED Professional Licensing","Alaska Professional License Search","Relevant only if actual conduct falls within AS 08.24"],["UTPA enforcement","Alaska Department of Law","Consumer Protection Unit and complaints/enforcement materials","Enforcement jurisdiction, not provider authorization"]]},{"headers":["Source ID","Title / issuer and direct literal URL","Exact passages, version, and legal status","Limitations"],"index":4,"links":[{"href":"https://law.alaska.gov/department/civil/consumer/laws.html","text":"Alaska Department of Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+5"},{"href":"https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010","text":"Legal Information Institute\n+2"},{"href":"https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html","text":"Alaska Department of Law\n+2"},{"href":"https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","text":"Alaska Department of Law\n+1"},{"href":"https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","text":"Alaska Department of Commerce\n+1"},{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing","text":"Alaska Department of Commerce\n+3"},{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+5"},{"href":"https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010","text":"Legal Information Institute\n+4"},{"href":"https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses","text":"Alaska Department of Commerce\n+1"},{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+3"},{"href":"https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf","text":"LegiScan\n+2"},{"href":"https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf","text":"LegiScan\n+2"},{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/","text":"Justia Law\n+3"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+3"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+1"},{"href":"https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html","text":"Alaska Department of Law"},{"href":"https://www.akleg.gov/basis/statutes.asp","text":"Alaska State Legislature"}],"row_links":[[],[{"href":"https://law.alaska.gov/department/civil/consumer/laws.html","text":"Alaska Department of Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+5"}],[{"href":"https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010","text":"Legal Information Institute\n+2"}],[{"href":"https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html","text":"Alaska Department of Law\n+2"}],[{"href":"https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","text":"Alaska Department of Law\n+1"}],[{"href":"https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","text":"Alaska Department of Commerce\n+1"}],[{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing","text":"Alaska Department of Commerce\n+3"}],[{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+5"}],[{"href":"https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010","text":"Legal Information Institute\n+4"}],[{"href":"https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses","text":"Alaska Department of Commerce\n+1"}],[{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+3"}],[{"href":"https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf","text":"LegiScan\n+2"}],[{"href":"https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf","text":"LegiScan\n+2"}],[{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/","text":"Justia Law\n+3"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+3"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+1"}],[{"href":"https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html","text":"Alaska Department of Law"}],[{"href":"https://www.akleg.gov/basis/statutes.asp","text":"Alaska State Legislature"}]],"rows":[["Source ID","Title / issuer and direct literal URL","Exact passages, version, and legal status","Limitations"],["S_AK-P1-S001","Alaska Consumer Laws—Department of Law: https://law.alaska.gov/department/civil/consumer/laws.html • Professional Licensing—DCCED: https://www.commerce.alaska.gov/web/cbpl/professionallicensing","Consumer-law index, list at page lines 51–73; licensed-professions list beginning at lines 53–99. Current agency pages. \nAlaska Department of Law\n+1","Negative corroboration only. An index omission is not conclusive proof that no provision exists elsewhere."],["S_AK-P1-S002","AS 45.50.471: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/ • AS 45.50.481: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-481/","§ .471(a), (b)(3)–(4), lines 58–67; § .481(a)–(c), lines 59–66. 2025 codification mirror. \nJustia Law\n+1","No debt-relief-specific holding inferred from general UTPA text."],["S_AK-P1-S003","AS 45.63.010: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/ • .020: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/ • .030: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/ • .080: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/ • .100: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/","Registration: § .010(a)–(c); written contract: § .020; refunds: § .030(a)–(c); exemptions: § .080(a)(1)–(19); definitions: § .100(1), (4)–(6). 2025 codification reconciled with S014. \nJustia Law\n+5","Mirror. SB 252’s 2026 amendment must be read with § .030."],["S_AK-P1-S004","9 AAC 14.010: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010 • .020: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.020 • .060: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060","Application contents; 10-day and 90-day updates; $200 registration fee. Cornell quarterly regulatory text. \nLegal Information Institute\n+2","Cornell is not the official Alaska publisher, but the current official DOL form confirms the operative requirements and fee."],["S_AK-P1-S005","DOL telemarketer page: https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html • Official form: https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf","Agency instructions; form p.1 lines 9–20 and p.2 lines 51–60. Form revised October 2019 and currently posted. \nAlaska Department of Law\n+2","Procedure evidence, not substantive debt-relief authorization."],["S_AK-P1-S006","Registered Telemarketers—Alaska DOL: https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","PDF dated October 15, 2026; Beyond Finance p.1; Century, ClearOne, DebtBlue p.2. \nAlaska Department of Law\n+1","Proves telephonic registration description only; does not establish any other license or compliance."],["S_AK-P1-S007","Alaska Company Uniform Application Form: https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","Rev. 9/2016; p.2 lines 41–43 says activities include ones for which no licensing authority is sought; lines 84–97 list debt activities. \nAlaska Department of Commerce\n+1","Historical/legacy form; not a current debt-settlement application and not legal permission."],["S_AK-P1-S008","Business Licensing: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing • FAQs: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs • Search: https://www.commerce.alaska.gov/cbp/businesslicense/search/License • AS 43.70.020: https://law.justia.com/codes/alaska/title-43/chapter-70/section-43-70-020/","Remote activity guidance; $50/year; nonrefundability after issuance; separate regulatory compliance under § .020(d). \nAlaska Department of Commerce\n+3","Business license is not a professional or financial-services authorization. Statute text is a mirror."],["S_AK-P1-S009","AS 06.55.101: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/ • .103: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-103/ • .802: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-802/ • .820: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/ • .830: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-830/ • .840: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-840/","License/delegate prohibition; other-state approval; complete exclusions; ten-business-day transmission; receipt; refund. 2025 codification reconciled with SB 249 and SB 86. \nJustia Law\n+5","Mirror. Current definition in SB 249 supersedes the unreconciled 2025 definition text."],["S_AK-P1-S010","3 AAC 13.010: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010 • .020: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.020 • .840: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.840 • 2017 adoption order: https://www.commerce.alaska.gov/web/portals/3/pub/JU2017200431.pdf • 2023 order: https://www.commerce.alaska.gov/web/Portals/3/pub/2022200373%203%20AAC%2013%20Virtual%20Currency%20Regs%20Final%20-%20Signed%20by%20Lt.%20Gov%20Eff%201-1-2023.pdf?ver=2022-12-01-104939-013","Application and approval requirements; fee schedule; 2017 order pp.10–12; 2023 order p.1 effective January 1, 2023. \nLegal Information Institute\n+4","Regulations read through Cornell plus official adoption orders."],["S_AK-P1-S011","DBS Money Service Businesses: https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses • Alaska roster: https://www.commerce.alaska.gov/web/Portals/3/pub/MSB%20Roster%2020260319.pdf?ver=I4DJq-khBB6DzfDe3jjgPw%3D%3D","Official page lines 16–31; all licensing through NMLS. Roster filename/date March 19, 2026. \nAlaska Department of Commerce\n+1","Roster is older than current access date; current provider status must be separately verified."],["S_AK-P1-S012","SB 249 enrolled text mirror: https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB249","Enrolled §§ 2–3 and 6; money-transmission definition p.10 lines 258–267; kiosk cap p.8 lines 192–194; effective October 1, 2026. Chapter 50 SLA 2026. \nLegiScan\n+3","Official bill-detail/text route returned 403 in the public tool; enrolled text was read from the mirror, with chapter/effective status corroborated by official search results and status record."],["S_AK-P1-S013","SB 86 enrolled text mirror: https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB86","Transition § 78, p.59; regulation transition § 79; effective-date § 82, p.60: operative §§ 1–65 and 75–78 effective July 1, 2027. Chapter 48 SLA 2026. \nLegiScan\n+2","Future law for this pass; not substituted for current AS 06.55. Official route returned 403."],["S_AK-P1-S014","SB 252 enrolled text mirror: https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB252","§§ 185–186, pp.86–87; adds AS 45.36 cross-reference without changing seven-day service language. Effective September 30, 2026; Chapter 49 SLA 2026. \nLegiScan\n+2","Official bill route returned 403; enrolled text read from mirror."],["S_AK-P1-S015","AS 08.24.090: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/ • .380: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/ • Regulator: https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/CollectionAgencies • Verification: https://www.commerce.alaska.gov/web/cbpl/LicenseVerification","Creditor-side licensing and exemptions; definition; regulator’s out-of-state guidance; professional license search. \nJustia Law\n+3","Debt-relief/DMP crossover remains fact-specific; statute text read from mirror."],["S_AK-P1-S016","16 C.F.R. Part 310—eCFR: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","§ 310.2(o), debt-relief definition; § 310.4(a)(5), fee trigger and allocation; § 310.6(b)(7), business calls. eCFR shown current through October 22, 2026. \neCFR\n+3","Federal baseline only; does not establish Alaska authorization."],["S_AK-P1-S017","FTC Debt Relief Services & TSR Guide: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Coverage, bona fide nonprofit treatment, attorney discussion, inbound/outbound examples. \nFederal Trade Commission\n+1","FTC staff guide expressly states it is nonbinding; eCFR text controls."],["S_AK-P1-S018","Alaska v. FirstChoice press release: https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html","August 31, 2023; allegations concerning debt-relief advertisements designed to resemble government assistance. \nAlaska Department of Law","Enforcement allegation and agency statement, not a merits judgment or licensing interpretation."],["S_AK-P1-S019","Alaska Statutes endpoint: https://www.akleg.gov/basis/statutes.asp • Official bill text attempts: https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0249Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0086Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0252Z","Official site identifies “Alaska Statutes 2025”; direct statute and bill-text routes returned 403 in the public browsing tool. Targeted official-site searches for “debt adjuster,” “debt adjustment,” “debt settlement,” “debt management,” and “credit counseling” produced no dedicated current chapter. \nAlaska State Legislature","This is the preserved failed-route/search log. Negative search results are not conclusive legal proof."]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, and confidence"],"index":5,"links":[{"href":"https://law.alaska.gov/department/civil/consumer/laws.html","text":"Alaska Department of Law\n+3"},{"href":"https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","text":"Alaska Department of Commerce\n+1"},{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+1"},{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+1"},{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/","text":"Justia Law"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"},{"href":"https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf","text":"Alaska Department of Law\n+2"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/","text":"Justia Law"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/","text":"Justia Law\n+1"},{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs","text":"Alaska Department of Commerce\n+2"},{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/","text":"Justia Law\n+2"},{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+3"},{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing","text":"Alaska Department of Commerce\n+3"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/","text":"Justia Law\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"},{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+3"},{"href":"https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf","text":"LegiScan\n+1"},{"href":"https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf","text":"LegiScan"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+2"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+4"},{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/","text":"Justia Law"},{"href":"https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","text":"Alaska Department of Law\n+1"},{"href":"https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060","text":"Legal Information Institute\n+2"}],"row_links":[[],[{"href":"https://law.alaska.gov/department/civil/consumer/laws.html","text":"Alaska Department of Law\n+3"}],[{"href":"https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","text":"Alaska Department of Commerce\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+1"}],[{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"}],[{"href":"https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf","text":"Alaska Department of Law\n+2"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/","text":"Justia Law\n+1"}],[{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs","text":"Alaska Department of Commerce\n+2"}],[{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/","text":"Justia Law\n+1"}],[],[{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/","text":"Justia Law\n+2"}],[{"href":"https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","text":"Justia Law\n+3"}],[{"href":"https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing","text":"Alaska Department of Commerce\n+3"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/","text":"Justia Law\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR"}],[{"href":"https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com","text":"LegiScan\n+3"}],[{"href":"https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf","text":"LegiScan\n+1"}],[{"href":"https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf","text":"LegiScan"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+2"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+4"}],[{"href":"https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/","text":"Justia Law"}],[{"href":"https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","text":"Alaska Department of Law\n+1"}],[{"href":"https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060","text":"Legal Information Institute\n+2"}]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, and confidence"],["S_AK-P1-C001","No dedicated Alaska debt-adjuster/debt-settlement/DMP licensing and consumer-fee regime was located or verified.","S001, S007, S019. \nAlaska Department of Law\n+3","Moderate-high, bounded negative finding. Not an absolute proof of nonexistence."],["S_AK-P1-C002","Alaska classification must follow actual conduct rather than the provider’s “settlement,” “counseling,” “law firm,” or “nonprofit” label.","S007 form expressly separates activity disclosure from licensing authority; S002 prohibits false approval/status. \nAlaska Department of Commerce\n+1","High as a compliance principle; exact classification remains fact-specific."],["S_AK-P1-C003","Noncustodial negotiation that never receives consumer funds is not, on the face of current AS 06.55’s definition, money transmission.","S009 § .101; S012 § 3. \nJustia Law\n+1","Moderate. Statutory-text inference; no Alaska debt-relief interpretive opinion found."],["S_AK-P1-C004","Receiving consumer funds for remittance to creditors or collectors likely constitutes money transmission.","S012 § 3; S009 § .101. \nLegiScan\n+1","High on ordinary text; moderate-high overall because no DMP-specific Alaska opinion was located."],["S_AK-P1-C005","Pure education with no represented debt alteration and no fund receipt is not itself the conduct defined as money transmission or federal debt relief.","S009; S016 § 310.2(o). \nJustia Law\n+1","High, assuming the stated facts are true and marketing does not imply creditor-term alteration."],["S_AK-P1-C006","A qualifying campaign using substantially the same offer and terms to two or more people requires Alaska telephonic registration unless exempt.","S003 § .010(a), § .100(4). \nJustia Law\n+1","High."],["S_AK-P1-C007","Alaska “telephonic means” includes electronic communication and certain written prompts encouraging contact.","S003 § .100(6). \nJustia Law","High. Application to a particular web funnel requires factual analysis."],["S_AK-P1-C008","Registration must precede the campaign by at least 30 days, requires a separate notice per campaign, and is complete only upon Department acknowledgment.","S003 § .010(a)–(c); S005 form p.1. \nJustia Law\n+1","High."],["S_AK-P1-C009","The current telephonic registration fee is $200 per campaign and nonrefundable; material changes and salesperson lists have update duties.","S004 §§ .020, .060; S005 form. \nAlaska Department of Law\n+2","High."],["S_AK-P1-C010","AS 45.63’s exemptions are conditional and do not eliminate every chapter duty.","S003 § .080(a), which names only .010, .015, .020, and .030(c)–(d). \nJustia Law\n+1","High."],["S_AK-P1-C011","A telephone seller must receive a signed written contract before soliciting or accepting payment or charging payment instruments.","S003 § .020. \nJustia Law","High. This is not advance-fee authorization under federal law."],["S_AK-P1-C012","A buyer may request a refund or credit within seven days after paying for services if services have not yet been provided; misrepresented or undelivered services have separate protection.","S003 § .030(a)–(b); S014 confirms 2026 wording. \nJustia Law\n+1","High."],["S_AK-P1-C013","Alaska business licensing is activity-based, not physical-presence-based; ordinary fee is $50/year.","S008. \nAlaska Department of Commerce\n+2","High as agency guidance/statutory baseline. Edge nexus facts remain case-specific."],["S_AK-P1-C014","Alaska collection licensing principally addresses collecting claims for creditors, not a conventional debtor-retained negotiator.","S015 §§ .090, .380. \nJustia Law\n+1","Moderate-high. Hybrid creditor relationships remain unresolved."],["S_AK-P1-C015","No Alaska numerical debt-relief setup, monthly, settlement, per-debt, savings, percentage, aggregate, or indexed cap was located.","S001, S007, S019.","Moderate-high bounded negative finding. No conclusion of “unlimited fees.”"],["S_AK-P1-C016","A money transmitter generally must transmit net value within ten business days, disclose the amount and total fee, and honor qualifying written refund requests.","S009 §§ .820, .830, .840. \nJustia Law\n+2","High. Does not authorize debt-relief service fees."],["S_AK-P1-C017","Custodial access paths include Alaska licensure, authorized-delegate status, or qualifying approval under AS 06.55.103; an actual exclusion may also remove coverage.","S009 §§ .101, .103, .802; S010. \nJustia Law\n+3","High."],["S_AK-P1-C018","Official public routes exist for business-license, telephonic-registration, money-services, and professional-license verification.","S005, S008, S011, S015. \nAlaska Department of Commerce\n+3","High. Some external/NMLS status searches may require separate interaction."],["S_AK-P1-C019","Appearance on the registered-telemarketer list proves telephonic registration only.","S003 scope; S006 list. \nJustia Law\n+1","High. No broader authorization inferred."],["S_AK-P1-C020","Misrepresenting government, regulator, attorney, nonprofit, or license approval can violate Alaska’s UTPA.","S002 § .471(b)(3)–(4); S018 enforcement example. \nJustia Law\n+1","High for statutory rule; enforcement example is nonprecedential."],["S_AK-P1-C021","For a TSR-covered debt-relief service, no provider fee may be requested or received until one debt is altered under a valid agreement and the customer makes the first payment under that agreement.","S016 § 310.4(a)(5)(i)(A)–(B). \neCFR","High. Federal coverage facts must exist."],["S_AK-P1-C022","When debts are resolved individually, one permitted TSR allocation is the enrolled-debt proportional method.","S016 § 310.4(a)(5)(i)(C)(1). \neCFR","High."],["S_AK-P1-C023","The alternative TSR allocation is a consistent percentage of actual savings across debts.","S016 § 310.4(a)(5)(i)(C)(2). \neCFR","High. It is an alternative calculation method, not an Alaska cap."],["S_AK-P1-C024","A TSR-compliant dedicated account must be insured, consumer-owned, independently administered, free from referral compensation, and withdrawable without penalty.","S016 § 310.4(a)(5)(ii). \neCFR","High federally; Alaska MT classification remains fact-dependent."],["S_AK-P1-C025","SB 249 is current as of this pass, amended transmission nexus, and created a 10% cap only for virtual-currency kiosk transactions.","S012 §§ 3, 6 and kiosk § .172. \nLegiScan\n+3","High. Effective October 1, 2026."],["S_AK-P1-C026","SB 86’s broad replacement money-transmission provisions are future-effective on July 1, 2027, not the October 2026 governing regime.","S013 §§ 78–82. \nLegiScan\n+1","High."],["S_AK-P1-C027","SB 252 did not alter the substantive seven-day service cancellation rule; it added the AS 45.36 UCC reference.","S014 §§ 185–186. \nLegiScan","High. Effective September 30, 2026."],["S_AK-P1-C028","A nonprofit designation is not a generic Alaska business, telephonic, or money-transmission exemption.","S003 § .080(a)(9); S008; S009 § .802. \nJustia Law\n+2","High. Federal bona fide nonprofit treatment is separate."],["S_AK-P1-C029","Attorney status creates no blanket Alaska telephonic or money-transmission exemption; attorneys do have a regular-course collection-agency exclusion.","S003 § .080; S009 § .802; S015 § .090(b)(1); S017. \nJustia Law\n+4","High on text; professional-practice facts can matter."],["S_AK-P1-C030","Supervised financial institutions have a conditional AS 45.63 exemption; banks and related institutions have a separate conditional AS 06.55 exclusion.","S003 § .080(a)(16); S009 § .802(4). \nJustia Law\n+1","High. Scope must match statutory conditions."],["S_AK-P1-C031","A creditor collecting its own claim in its own name is outside the core “claims owed another” definition, but using a different name to imply third-party collection can bring it within the chapter.","S015 § .380(2)(A). \nJustia Law","High."],["S_AK-P1-C032","No named provider’s full Alaska authorization was determined in this pass.","S006 telemarketing list; S011 older MSB roster. \nAlaska Department of Law\n+1","Express hold. A current multi-registry review is required per provider."],["S_AK-P1-C033","The verified $200, $50, and AS 06.55 filing/license amounts are provider-side governmental fees, not consumer debt-relief fee ceilings.","S004, S008, S010. \nLegal Information Institute\n+2","High."]]},{"headers":["Component","Status","Claims","What was answered","Exact missing evidence / next investigation"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","What was answered","Exact missing evidence / next investigation"],["Dedicated debt-adjuster/debt-settlement regime","Answered, bounded","C001, C015","No dedicated Alaska regime or fee table located or verified","Repeat against later official codification and any post-10/24/26 enactments; inspect uncodified historical acts if needed"],["Marketing labels versus actual functions","Answered","C002, C025","Labels and legacy activity checkboxes do not create permission","Provider-specific contracts, disclosures, and operational flow"],["Pure counseling","Answered with conditions","C005","No MT classification when no debt alteration representation or fund handling","Review actual advertising and counseling agreement"],["Noncustodial principal-reduction settlement","Answered with interpretive limitation","C003","No receipt/transmission on stated facts","Alaska DBS published or nonpublic interpretation; controlling case"],["Noncustodial concession/DMP model","Answered with interpretive limitation","C003, C005","Same functional rule","Actual creditor communications and promises"],["Custodial DMP/distribution","Partial but operationally material","C004, C017","Likely AS 06.55 money transmission","Alaska DBS debt-management interpretation and exact fund-flow documents"],["Custodial settlement payments","Partial but operationally material","C004, C017","Likely AS 06.55 money transmission","Provider/administrator account and remittance documents"],["Consumer-owned dedicated account","Unresolved/fact-specific","C024","Federal requirements established; no Alaska safe harbor located","Ownership, administrator, control, payment authority, affiliate and licensing evidence"],["Consumer/business-purpose distinction","Answered for this pass","C006, C007; federal context C021","State statutes use person/activity/nexus rather than household-purpose language; TSR B2B rule separate","Business-purpose UTPA and contract issues if commercially material"],["Resident/remote-provider nexus","Answered with edge hold","C007, C013, C025","No physical-presence requirement; broad telephonic and transmission nexus","Constitutional and fact-intensive nexus analysis for unusual models"],["Alaska business license","Answered","C013, C018","Requirement, fee, application and search routes","Named-provider lookup not performed"],["Telephonic campaign registration","Answered","C006–C012, C018–C019","Trigger, timing, fee, contract, refund, exemptions, application, list","Campaign-specific exemption and script review"],["Money-transmission authorization pathways","Answered procedurally","C017–C018","License, delegate, other-state approval, exclusions, NMLS route","Named-provider current NMLS status and authorized-delegate appointments"],["Collection-agency crossover","Partial","C014, C029, C031","Creditor-side text and regulator guidance","Hybrid DMP contracts, creditor compensation, agency authority, appellate interpretation"],["Attorney exclusion","Answered for access scope","C029","No blanket telephonic/MT exemption; collection exclusion exists","Practice-of-law, ownership, fee-sharing, and ethics analysis reserved"],["Nonprofit exclusion","Answered for access scope","C028","No generic Alaska exemption","Organizational bona fides, AS 45.68 scope, tax status, and compensation structure"],["Financial-institution exclusions","Answered for access scope","C030","Conditional telephonic and MT exclusions","Institution and affiliate status, exact activity within exclusion"],["Self-creditor","Answered for boundary","C031","Own-name collection generally outside core definition; faux third-party risk","UTPA/FDCPA and sector rules later"],["Alaska debt-relief numerical fee caps","Answered, bounded negative","C015","No setup/monthly/per-debt/savings/percentage/aggregate cap found","Any agency unpublished interpretation or future enactment"],["Indexing/adjusted debt-relief amounts","Answered, bounded negative","C015","No indexed debt-relief schedule found; no CPI calculation invented","Later bulletin or enactment search"],["Provider filing and license fees","Answered","C009, C013, C033","Telephonic, business, and MT amounts","Collection-agency fee schedule excluded because no collection model established"],["Fee request/receipt timing","Answered","C011, C021–C024","Alaska signed-contract threshold and federal performance trigger separated","Provider-specific federal coverage and actual performance records"],["Telephonic cancellation/refund","Answered","C012, C027","Seven-day pre-service right and 2026 amendment reconciliation","Full contract/remedies pass"],["Money-transmission receipt/refund","Answered to access/fee extent","C016, C025","Net transmission, receipt, written refund rule and kiosk exception","Full client-funds/remedies pass"],["Current telemarketer lookup","Answered","C018–C019","Official list dated 10/15/26 read","Named-provider registration certificate and campaign expiration if needed"],["Current MSB lookup","Partial","C018, C032","Official route and older Alaska roster identified","Current NMLS Consumer Access verification per provider"],["Current business/professional lookup","Answered procedurally","C018","Official search routes identified","Named-provider status not requested or determined"],["2026 statutory updates","Answered","C025–C027","SB 249 current; SB 252 current; SB 86 future","Monitor implementing regulations and pre-7/1/27 transition work"],["Controlling Alaska decisions on debt-settlement classification","Unresolved","C003, C004, C014","Targeted searches found no directly controlling decision","Broader Alaska appellate, administrative, trial-docket, and paid-database review"],["Agreement form and complete disclosures","Excluded/later pass","—","Only AS 45.63 threshold discussed as needed for timing","Full contract/agreement pass"],["Client-money segregation, trust, reconciliation, and administrator duties","Excluded/later pass","—","Only AS 06.55 transmission/receipt/refund rules needed here","Full funds pass"],["Bonds, security, net worth, permissible investments","Excluded/later pass","—","Application security requirement noted only","Full market-access financial-condition pass"],["Remedies, civil penalties, criminal exposure, private actions","Excluded/later pass","—","UTPA relevance noted; no complete remedies analysis","Remedies/enforcement pass"],["Full collection, litigation, and limitations coverage","Excluded/later pass","—","Collection boundary only","Dedicated collection/litigation/limitations passes"],["Secured debts, mortgage relief, tax debts, student loans, and sector products","Excluded/later pass","—","No substantive sector conclusion","Product-specific passes"],["Local, municipal, tribal, and Alaska Native law","Excluded/later pass","—","No conclusion","Local/tribal jurisdictional investigation"],["Named-provider authorization","Expressly not determined","C032","No marketing statement treated as authorization","Current searches in every applicable registry and underlying certificates"]]}],"claims":[{"claim_id":"S_AK-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C001","Precise assertion":"No dedicated Alaska debt-adjuster/debt-settlement/DMP licensing and consumer-fee regime was located or verified.","Sources and pinpoints":"S001, S007, S019. \nAlaska Department of Law\n+3","Conditions, currentness, and confidence":"Moderate-high, bounded negative finding. Not an absolute proof of nonexistence."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C002","Precise assertion":"Alaska classification must follow actual conduct rather than the provider’s “settlement,” “counseling,” “law firm,” or “nonprofit” label.","Sources and pinpoints":"S007 form expressly separates activity disclosure from licensing authority; S002 prohibits false approval/status. \nAlaska Department of Commerce\n+1","Conditions, currentness, and confidence":"High as a compliance principle; exact classification remains fact-specific."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C003","Precise assertion":"Noncustodial negotiation that never receives consumer funds is not, on the face of current AS 06.55’s definition, money transmission.","Sources and pinpoints":"S009 § .101; S012 § 3. \nJustia Law\n+1","Conditions, currentness, and confidence":"Moderate. Statutory-text inference; no Alaska debt-relief interpretive opinion found."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C004","Precise assertion":"Receiving consumer funds for remittance to creditors or collectors likely constitutes money transmission.","Sources and pinpoints":"S012 § 3; S009 § .101. \nLegiScan\n+1","Conditions, currentness, and confidence":"High on ordinary text; moderate-high overall because no DMP-specific Alaska opinion was located."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C005","Precise assertion":"Pure education with no represented debt alteration and no fund receipt is not itself the conduct defined as money transmission or federal debt relief.","Sources and pinpoints":"S009; S016 § 310.2(o). \nJustia Law\n+1","Conditions, currentness, and confidence":"High, assuming the stated facts are true and marketing does not imply creditor-term alteration."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C006","Precise assertion":"A qualifying campaign using substantially the same offer and terms to two or more people requires Alaska telephonic registration unless exempt.","Sources and pinpoints":"S003 § .010(a), § .100(4). \nJustia Law\n+1","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C007","Precise assertion":"Alaska “telephonic means” includes electronic communication and certain written prompts encouraging contact.","Sources and pinpoints":"S003 § .100(6). \nJustia Law","Conditions, currentness, and confidence":"High. Application to a particular web funnel requires factual analysis."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C008","Precise assertion":"Registration must precede the campaign by at least 30 days, requires a separate notice per campaign, and is complete only upon Department acknowledgment.","Sources and pinpoints":"S003 § .010(a)–(c); S005 form p.1. \nJustia Law\n+1","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C009","Precise assertion":"The current telephonic registration fee is $200 per campaign and nonrefundable; material changes and salesperson lists have update duties.","Sources and pinpoints":"S004 §§ .020, .060; S005 form. \nAlaska Department of Law\n+2","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C010","Precise assertion":"AS 45.63’s exemptions are conditional and do not eliminate every chapter duty.","Sources and pinpoints":"S003 § .080(a), which names only .010, .015, .020, and .030(c)–(d). \nJustia Law\n+1","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C011","Precise assertion":"A telephone seller must receive a signed written contract before soliciting or accepting payment or charging payment instruments.","Sources and pinpoints":"S003 § .020. \nJustia Law","Conditions, currentness, and confidence":"High. This is not advance-fee authorization under federal law."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C012","Precise assertion":"A buyer may request a refund or credit within seven days after paying for services if services have not yet been provided; misrepresented or undelivered services have separate protection.","Sources and pinpoints":"S003 § .030(a)–(b); S014 confirms 2026 wording. \nJustia Law\n+1","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C013","Precise assertion":"Alaska business licensing is activity-based, not physical-presence-based; ordinary fee is $50/year.","Sources and pinpoints":"S008. \nAlaska Department of Commerce\n+2","Conditions, currentness, and confidence":"High as agency guidance/statutory baseline. Edge nexus facts remain case-specific."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C014","Precise assertion":"Alaska collection licensing principally addresses collecting claims for creditors, not a conventional debtor-retained negotiator.","Sources and pinpoints":"S015 §§ .090, .380. \nJustia Law\n+1","Conditions, currentness, and confidence":"Moderate-high. Hybrid creditor relationships remain unresolved."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C015","Precise assertion":"No Alaska numerical debt-relief setup, monthly, settlement, per-debt, savings, percentage, aggregate, or indexed cap was located.","Sources and pinpoints":"S001, S007, S019.","Conditions, currentness, and confidence":"Moderate-high bounded negative finding. No conclusion of “unlimited fees.”"},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C016","Precise assertion":"A money transmitter generally must transmit net value within ten business days, disclose the amount and total fee, and honor qualifying written refund requests.","Sources and pinpoints":"S009 §§ .820, .830, .840. \nJustia Law\n+2","Conditions, currentness, and confidence":"High. Does not authorize debt-relief service fees."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C017","Precise assertion":"Custodial access paths include Alaska licensure, authorized-delegate status, or qualifying approval under AS 06.55.103; an actual exclusion may also remove coverage.","Sources and pinpoints":"S009 §§ .101, .103, .802; S010. \nJustia Law\n+3","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C018","Precise assertion":"Official public routes exist for business-license, telephonic-registration, money-services, and professional-license verification.","Sources and pinpoints":"S005, S008, S011, S015. \nAlaska Department of Commerce\n+3","Conditions, currentness, and confidence":"High. Some external/NMLS status searches may require separate interaction."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C019","Precise assertion":"Appearance on the registered-telemarketer list proves telephonic registration only.","Sources and pinpoints":"S003 scope; S006 list. \nJustia Law\n+1","Conditions, currentness, and confidence":"High. No broader authorization inferred."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C020","Precise assertion":"Misrepresenting government, regulator, attorney, nonprofit, or license approval can violate Alaska’s UTPA.","Sources and pinpoints":"S002 § .471(b)(3)–(4); S018 enforcement example. \nJustia Law\n+1","Conditions, currentness, and confidence":"High for statutory rule; enforcement example is nonprecedential."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C021","Precise assertion":"For a TSR-covered debt-relief service, no provider fee may be requested or received until one debt is altered under a valid agreement and the customer makes the first payment under that agreement.","Sources and pinpoints":"S016 § 310.4(a)(5)(i)(A)–(B). \neCFR","Conditions, currentness, and confidence":"High. Federal coverage facts must exist."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C022","Precise assertion":"When debts are resolved individually, one permitted TSR allocation is the enrolled-debt proportional method.","Sources and pinpoints":"S016 § 310.4(a)(5)(i)(C)(1). \neCFR","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C023","Precise assertion":"The alternative TSR allocation is a consistent percentage of actual savings across debts.","Sources and pinpoints":"S016 § 310.4(a)(5)(i)(C)(2). \neCFR","Conditions, currentness, and confidence":"High. It is an alternative calculation method, not an Alaska cap."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C024","Precise assertion":"A TSR-compliant dedicated account must be insured, consumer-owned, independently administered, free from referral compensation, and withdrawable without penalty.","Sources and pinpoints":"S016 § 310.4(a)(5)(ii). \neCFR","Conditions, currentness, and confidence":"High federally; Alaska MT classification remains fact-dependent."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C025","Precise assertion":"SB 249 is current as of this pass, amended transmission nexus, and created a 10% cap only for virtual-currency kiosk transactions.","Sources and pinpoints":"S012 §§ 3, 6 and kiosk § .172. \nLegiScan\n+3","Conditions, currentness, and confidence":"High. Effective October 1, 2026."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C026","Precise assertion":"SB 86’s broad replacement money-transmission provisions are future-effective on July 1, 2027, not the October 2026 governing regime.","Sources and pinpoints":"S013 §§ 78–82. \nLegiScan\n+1","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C027","Precise assertion":"SB 252 did not alter the substantive seven-day service cancellation rule; it added the AS 45.36 UCC reference.","Sources and pinpoints":"S014 §§ 185–186. \nLegiScan","Conditions, currentness, and confidence":"High. Effective September 30, 2026."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C028","Precise assertion":"A nonprofit designation is not a generic Alaska business, telephonic, or money-transmission exemption.","Sources and pinpoints":"S003 § .080(a)(9); S008; S009 § .802. \nJustia Law\n+2","Conditions, currentness, and confidence":"High. Federal bona fide nonprofit treatment is separate."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C029","Precise assertion":"Attorney status creates no blanket Alaska telephonic or money-transmission exemption; attorneys do have a regular-course collection-agency exclusion.","Sources and pinpoints":"S003 § .080; S009 § .802; S015 § .090(b)(1); S017. \nJustia Law\n+4","Conditions, currentness, and confidence":"High on text; professional-practice facts can matter."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C030","Precise assertion":"Supervised financial institutions have a conditional AS 45.63 exemption; banks and related institutions have a separate conditional AS 06.55 exclusion.","Sources and pinpoints":"S003 § .080(a)(16); S009 § .802(4). \nJustia Law\n+1","Conditions, currentness, and confidence":"High. Scope must match statutory conditions."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C031","Precise assertion":"A creditor collecting its own claim in its own name is outside the core “claims owed another” definition, but using a different name to imply third-party collection can bring it within the chapter.","Sources and pinpoints":"S015 § .380(2)(A). \nJustia Law","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C032","Precise assertion":"No named provider’s full Alaska authorization was determined in this pass.","Sources and pinpoints":"S006 telemarketing list; S011 older MSB roster. \nAlaska Department of Law\n+1","Conditions, currentness, and confidence":"Express hold. A current multi-registry review is required per provider."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AK-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AK-P1-C033","Precise assertion":"The verified $200, $50, and AS 06.55 filing/license amounts are provider-side governmental fees, not consumer debt-relief fee ceilings.","Sources and pinpoints":"S004, S008, S010. \nLegal Information Institute\n+2","Conditions, currentness, and confidence":"High."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_AK-P1-S001","urls":["https://law.alaska.gov/department/civil/consumer/laws.html","https://www.commerce.alaska.gov/web/cbpl/professionallicensing"],"researcher_record":{"Source ID":"S_AK-P1-S001","Title / issuer and direct literal URL":"Alaska Consumer Laws—Department of Law: https://law.alaska.gov/department/civil/consumer/laws.html • Professional Licensing—DCCED: https://www.commerce.alaska.gov/web/cbpl/professionallicensing","Exact passages, version, and legal status":"Consumer-law index, list at page lines 51–73; licensed-professions list beginning at lines 53–99. Current agency pages. \nAlaska Department of Law\n+1","Limitations":"Negative corroboration only. An index omission is not conclusive proof that no provision exists elsewhere."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S002","urls":["https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/","https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-481/"],"researcher_record":{"Source ID":"S_AK-P1-S002","Title / issuer and direct literal URL":"AS 45.50.471: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-471/ • AS 45.50.481: https://law.justia.com/codes/alaska/title-45/chapter-50/article-3/section-45-50-481/","Exact passages, version, and legal status":"§ .471(a), (b)(3)–(4), lines 58–67; § .481(a)–(c), lines 59–66. 2025 codification mirror. \nJustia Law\n+1","Limitations":"No debt-relief-specific holding inferred from general UTPA text."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S003","urls":["https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/","https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/","https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/","https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/","https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/"],"researcher_record":{"Source ID":"S_AK-P1-S003","Title / issuer and direct literal URL":"AS 45.63.010: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-010/ • .020: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-020/ • .030: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-030/ • .080: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-080/ • .100: https://law.justia.com/codes/alaska/title-45/chapter-63/section-45-63-100/","Exact passages, version, and legal status":"Registration: § .010(a)–(c); written contract: § .020; refunds: § .030(a)–(c); exemptions: § .080(a)(1)–(19); definitions: § .100(1), (4)–(6). 2025 codification reconciled with S014. \nJustia Law\n+5","Limitations":"Mirror. SB 252’s 2026 amendment must be read with § .030."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S004","urls":["https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010","https://www.law.cornell.edu/regulations/alaska/9-AAC-14.020","https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060"],"researcher_record":{"Source ID":"S_AK-P1-S004","Title / issuer and direct literal URL":"9 AAC 14.010: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.010 • .020: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.020 • .060: https://www.law.cornell.edu/regulations/alaska/9-AAC-14.060","Exact passages, version, and legal status":"Application contents; 10-day and 90-day updates; $200 registration fee. Cornell quarterly regulatory text. \nLegal Information Institute\n+2","Limitations":"Cornell is not the official Alaska publisher, but the current official DOL form confirms the operative requirements and fee."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S005","urls":["https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html","https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf"],"researcher_record":{"Source ID":"S_AK-P1-S005","Title / issuer and direct literal URL":"DOL telemarketer page: https://www.law.alaska.gov/department/civil/consumer/telemarketreg.html • Official form: https://www.law.alaska.gov/pdf/consumer/FORM_telemarket.pdf","Exact passages, version, and legal status":"Agency instructions; form p.1 lines 9–20 and p.2 lines 51–60. Form revised October 2019 and currently posted. \nAlaska Department of Law\n+2","Limitations":"Procedure evidence, not substantive debt-relief authorization."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S006","urls":["https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf"],"researcher_record":{"Source ID":"S_AK-P1-S006","Title / issuer and direct literal URL":"Registered Telemarketers—Alaska DOL: https://law.alaska.gov/pdf/consumer/registered_telemarketers.pdf","Exact passages, version, and legal status":"PDF dated October 15, 2026; Beyond Finance p.1; Century, ClearOne, DebtBlue p.2. \nAlaska Department of Law\n+1","Limitations":"Proves telephonic registration description only; does not establish any other license or compliance."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S007","urls":["https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827"],"researcher_record":{"Source ID":"S_AK-P1-S007","Title / issuer and direct literal URL":"Alaska Company Uniform Application Form: https://www.commerce.alaska.gov/web/Portals/3/pub/Alaska%20Company%20Uniform%20Application%20Form.pdf?ver=2017-02-09-160149-827","Exact passages, version, and legal status":"Rev. 9/2016; p.2 lines 41–43 says activities include ones for which no licensing authority is sought; lines 84–97 list debt activities. \nAlaska Department of Commerce\n+1","Limitations":"Historical/legacy form; not a current debt-settlement application and not legal permission."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S008","urls":["https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing","https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs","https://www.commerce.alaska.gov/cbp/businesslicense/search/License","https://law.justia.com/codes/alaska/title-43/chapter-70/section-43-70-020/"],"researcher_record":{"Source ID":"S_AK-P1-S008","Title / issuer and direct literal URL":"Business Licensing: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing • FAQs: https://www.commerce.alaska.gov/web/cbpl/BusinessLicensing/BusinessLicensingFAQs • Search: https://www.commerce.alaska.gov/cbp/businesslicense/search/License • AS 43.70.020: https://law.justia.com/codes/alaska/title-43/chapter-70/section-43-70-020/","Exact passages, version, and legal status":"Remote activity guidance; $50/year; nonrefundability after issuance; separate regulatory compliance under § .020(d). \nAlaska Department of Commerce\n+3","Limitations":"Business license is not a professional or financial-services authorization. Statute text is a mirror."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S009","urls":["https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/","https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-103/","https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-802/","https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/","https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-830/","https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-840/"],"researcher_record":{"Source ID":"S_AK-P1-S009","Title / issuer and direct literal URL":"AS 06.55.101: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-101/ • .103: https://law.justia.com/codes/alaska/title-6/chapter-55/article-1/section-06-55-103/ • .802: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-802/ • .820: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-820/ • .830: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-830/ • .840: https://law.justia.com/codes/alaska/title-6/chapter-55/article-8/section-06-55-840/","Exact passages, version, and legal status":"License/delegate prohibition; other-state approval; complete exclusions; ten-business-day transmission; receipt; refund. 2025 codification reconciled with SB 249 and SB 86. \nJustia Law\n+5","Limitations":"Mirror. Current definition in SB 249 supersedes the unreconciled 2025 definition text."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S010","urls":["https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010","https://www.law.cornell.edu/regulations/alaska/3-AAC-13.020","https://www.law.cornell.edu/regulations/alaska/3-AAC-13.840","https://www.commerce.alaska.gov/web/portals/3/pub/JU2017200431.pdf","https://www.commerce.alaska.gov/web/Portals/3/pub/2022200373%203%20AAC%2013%20Virtual%20Currency%20Regs%20Final%20-%20Signed%20by%20Lt.%20Gov%20Eff%201-1-2023.pdf?ver=2022-12-01-104939-013"],"researcher_record":{"Source ID":"S_AK-P1-S010","Title / issuer and direct literal URL":"3 AAC 13.010: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.010 • .020: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.020 • .840: https://www.law.cornell.edu/regulations/alaska/3-AAC-13.840 • 2017 adoption order: https://www.commerce.alaska.gov/web/portals/3/pub/JU2017200431.pdf • 2023 order: https://www.commerce.alaska.gov/web/Portals/3/pub/2022200373%203%20AAC%2013%20Virtual%20Currency%20Regs%20Final%20-%20Signed%20by%20Lt.%20Gov%20Eff%201-1-2023.pdf?ver=2022-12-01-104939-013","Exact passages, version, and legal status":"Application and approval requirements; fee schedule; 2017 order pp.10–12; 2023 order p.1 effective January 1, 2023. \nLegal Information Institute\n+4","Limitations":"Regulations read through Cornell plus official adoption orders."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S011","urls":["https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses","https://www.commerce.alaska.gov/web/Portals/3/pub/MSB%20Roster%2020260319.pdf?ver=I4DJq-khBB6DzfDe3jjgPw%3D%3D"],"researcher_record":{"Source ID":"S_AK-P1-S011","Title / issuer and direct literal URL":"DBS Money Service Businesses: https://www.commerce.alaska.gov/web/dbs/ConsumerFinance/MoneyServiceBusinesses • Alaska roster: https://www.commerce.alaska.gov/web/Portals/3/pub/MSB%20Roster%2020260319.pdf?ver=I4DJq-khBB6DzfDe3jjgPw%3D%3D","Exact passages, version, and legal status":"Official page lines 16–31; all licensing through NMLS. Roster filename/date March 19, 2026. \nAlaska Department of Commerce\n+1","Limitations":"Roster is older than current access date; current provider status must be separately verified."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S012","urls":["https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf","https://www.akleg.gov/basis/Bill/Detail/34?Root=SB249","https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf?utm_campaign=alaska-s-bitcoin-atm-law-takes-effect-oct-1-the-industry-has-itself-to-blame&utm_medium=referral&utm_source=bitcoinnews.com"],"researcher_record":{"Source ID":"S_AK-P1-S012","Title / issuer and direct literal URL":"SB 249 enrolled text mirror: https://legiscan.com/AK/text/SB249/id/3447234/Alaska-2025-SB249-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB249","Exact passages, version, and legal status":"Enrolled §§ 2–3 and 6; money-transmission definition p.10 lines 258–267; kiosk cap p.8 lines 192–194; effective October 1, 2026. Chapter 50 SLA 2026. \nLegiScan\n+3","Limitations":"Official bill-detail/text route returned 403 in the public tool; enrolled text was read from the mirror, with chapter/effective status corroborated by official search results and status record."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S013","urls":["https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf","https://www.akleg.gov/basis/Bill/Detail/34?Root=SB86"],"researcher_record":{"Source ID":"S_AK-P1-S013","Title / issuer and direct literal URL":"SB 86 enrolled text mirror: https://legiscan.com/AK/text/SB86/id/3446455/Alaska-2025-SB86-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB86","Exact passages, version, and legal status":"Transition § 78, p.59; regulation transition § 79; effective-date § 82, p.60: operative §§ 1–65 and 75–78 effective July 1, 2027. Chapter 48 SLA 2026. \nLegiScan\n+2","Limitations":"Future law for this pass; not substituted for current AS 06.55. Official route returned 403."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S014","urls":["https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf","https://www.akleg.gov/basis/Bill/Detail/34?Root=SB252"],"researcher_record":{"Source ID":"S_AK-P1-S014","Title / issuer and direct literal URL":"SB 252 enrolled text mirror: https://legiscan.com/AK/text/SB252/id/3446477/Alaska-2025-SB252-Enrolled.pdf • Official bill page attempted: https://www.akleg.gov/basis/Bill/Detail/34?Root=SB252","Exact passages, version, and legal status":"§§ 185–186, pp.86–87; adds AS 45.36 cross-reference without changing seven-day service language. Effective September 30, 2026; Chapter 49 SLA 2026. \nLegiScan\n+2","Limitations":"Official bill route returned 403; enrolled text read from mirror."},"coordinator_verification_status":"held_for_primary_currentness_or_enactment_authentication_qualification","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S015","urls":["https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/","https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/","https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/CollectionAgencies","https://www.commerce.alaska.gov/web/cbpl/LicenseVerification"],"researcher_record":{"Source ID":"S_AK-P1-S015","Title / issuer and direct literal URL":"AS 08.24.090: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-090/ • .380: https://law.justia.com/codes/alaska/title-8/chapter-24/section-08-24-380/ • Regulator: https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/CollectionAgencies • Verification: https://www.commerce.alaska.gov/web/cbpl/LicenseVerification","Exact passages, version, and legal status":"Creditor-side licensing and exemptions; definition; regulator’s out-of-state guidance; professional license search. \nJustia Law\n+3","Limitations":"Debt-relief/DMP crossover remains fact-specific; statute text read from mirror."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S016","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310"],"researcher_record":{"Source ID":"S_AK-P1-S016","Title / issuer and direct literal URL":"16 C.F.R. Part 310—eCFR: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","Exact passages, version, and legal status":"§ 310.2(o), debt-relief definition; § 310.4(a)(5), fee trigger and allocation; § 310.6(b)(7), business calls. eCFR shown current through October 22, 2026. \neCFR\n+3","Limitations":"Federal baseline only; does not establish Alaska authorization."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S017","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"],"researcher_record":{"Source ID":"S_AK-P1-S017","Title / issuer and direct literal URL":"FTC Debt Relief Services & TSR Guide: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact passages, version, and legal status":"Coverage, bona fide nonprofit treatment, attorney discussion, inbound/outbound examples. \nFederal Trade Commission\n+1","Limitations":"FTC staff guide expressly states it is nonbinding; eCFR text controls."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S018","urls":["https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html"],"researcher_record":{"Source ID":"S_AK-P1-S018","Title / issuer and direct literal URL":"Alaska v. FirstChoice press release: https://law.alaska.gov/press/releases/2023/083123-FirstChoice.html","Exact passages, version, and legal status":"August 31, 2023; allegations concerning debt-relief advertisements designed to resemble government assistance. \nAlaska Department of Law","Limitations":"Enforcement allegation and agency statement, not a merits judgment or licensing interpretation."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AK-P1-S019","urls":["https://www.akleg.gov/basis/statutes.asp","https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0249Z","https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0086Z","https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0252Z"],"researcher_record":{"Source ID":"S_AK-P1-S019","Title / issuer and direct literal URL":"Alaska Statutes endpoint: https://www.akleg.gov/basis/statutes.asp • Official bill text attempts: https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0249Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0086Z, https://www.akleg.gov/basis/Bill/Text/34?Hsid=SB0252Z","Exact passages, version, and legal status":"Official site identifies “Alaska Statutes 2025”; direct statute and bill-text routes returned 403 in the public browsing tool. Targeted official-site searches for “debt adjuster,” “debt adjustment,” “debt settlement,” “debt management,” and “credit counseling” produced no dedicated current chapter. \nAlaska State Legislature","Limitations":"This is the preserved failed-route/search log. Negative search results are not conclusive legal proof."},"coordinator_verification_status":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"coverage":[{"topic":"Dedicated debt-adjuster/debt-settlement regime","researcher_record":{"Component":"Dedicated debt-adjuster/debt-settlement regime","Status":"Answered, bounded","Claims":"C001, C015","What was answered":"No dedicated Alaska regime or fee table located or verified","Exact missing evidence / next investigation":"Repeat against later official codification and any post-10/24/26 enactments; inspect uncodified historical acts if needed"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Marketing labels versus actual functions","researcher_record":{"Component":"Marketing labels versus actual functions","Status":"Answered","Claims":"C002, C025","What was answered":"Labels and legacy activity checkboxes do not create permission","Exact missing evidence / next investigation":"Provider-specific contracts, disclosures, and operational flow"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Pure counseling","researcher_record":{"Component":"Pure counseling","Status":"Answered with conditions","Claims":"C005","What was answered":"No MT classification when no debt alteration representation or fund handling","Exact missing evidence / next investigation":"Review actual advertising and counseling agreement"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Noncustodial principal-reduction settlement","researcher_record":{"Component":"Noncustodial principal-reduction settlement","Status":"Answered with interpretive limitation","Claims":"C003","What was answered":"No receipt/transmission on stated facts","Exact missing evidence / next investigation":"Alaska DBS published or nonpublic interpretation; controlling case"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Noncustodial concession/DMP model","researcher_record":{"Component":"Noncustodial concession/DMP model","Status":"Answered with interpretive limitation","Claims":"C003, C005","What was answered":"Same functional rule","Exact missing evidence / next investigation":"Actual creditor communications and promises"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Custodial DMP/distribution","researcher_record":{"Component":"Custodial DMP/distribution","Status":"Partial but operationally material","Claims":"C004, C017","What was answered":"Likely AS 06.55 money transmission","Exact missing evidence / next investigation":"Alaska DBS debt-management interpretation and exact fund-flow documents"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Custodial settlement payments","researcher_record":{"Component":"Custodial settlement payments","Status":"Partial but operationally material","Claims":"C004, C017","What was answered":"Likely AS 06.55 money transmission","Exact missing evidence / next investigation":"Provider/administrator account and remittance documents"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Consumer-owned dedicated account","researcher_record":{"Component":"Consumer-owned dedicated account","Status":"Unresolved/fact-specific","Claims":"C024","What was answered":"Federal requirements established; no Alaska safe harbor located","Exact missing evidence / next investigation":"Ownership, administrator, control, payment authority, affiliate and licensing evidence"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Consumer/business-purpose distinction","researcher_record":{"Component":"Consumer/business-purpose distinction","Status":"Answered for this pass","Claims":"C006, C007; federal context C021","What was answered":"State statutes use person/activity/nexus rather than household-purpose language; TSR B2B rule separate","Exact missing evidence / next investigation":"Business-purpose UTPA and contract issues if commercially material"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Resident/remote-provider nexus","researcher_record":{"Component":"Resident/remote-provider nexus","Status":"Answered with edge hold","Claims":"C007, C013, C025","What was answered":"No physical-presence requirement; broad telephonic and transmission nexus","Exact missing evidence / next investigation":"Constitutional and fact-intensive nexus analysis for unusual models"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Alaska business license","researcher_record":{"Component":"Alaska business license","Status":"Answered","Claims":"C013, C018","What was answered":"Requirement, fee, application and search routes","Exact missing evidence / next investigation":"Named-provider lookup not performed"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Telephonic campaign registration","researcher_record":{"Component":"Telephonic campaign registration","Status":"Answered","Claims":"C006–C012, C018–C019","What was answered":"Trigger, timing, fee, contract, refund, exemptions, application, list","Exact missing evidence / next investigation":"Campaign-specific exemption and script review"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Money-transmission authorization pathways","researcher_record":{"Component":"Money-transmission authorization pathways","Status":"Answered procedurally","Claims":"C017–C018","What was answered":"License, delegate, other-state approval, exclusions, NMLS route","Exact missing evidence / next investigation":"Named-provider current NMLS status and authorized-delegate appointments"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Collection-agency crossover","researcher_record":{"Component":"Collection-agency crossover","Status":"Partial","Claims":"C014, C029, C031","What was answered":"Creditor-side text and regulator guidance","Exact missing evidence / next investigation":"Hybrid DMP contracts, creditor compensation, agency authority, appellate interpretation"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Attorney exclusion","researcher_record":{"Component":"Attorney exclusion","Status":"Answered for access scope","Claims":"C029","What was answered":"No blanket telephonic/MT exemption; collection exclusion exists","Exact missing evidence / next investigation":"Practice-of-law, ownership, fee-sharing, and ethics analysis reserved"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Nonprofit exclusion","researcher_record":{"Component":"Nonprofit exclusion","Status":"Answered for access scope","Claims":"C028","What was answered":"No generic Alaska exemption","Exact missing evidence / next investigation":"Organizational bona fides, AS 45.68 scope, tax status, and compensation structure"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Financial-institution exclusions","researcher_record":{"Component":"Financial-institution exclusions","Status":"Answered for access scope","Claims":"C030","What was answered":"Conditional telephonic and MT exclusions","Exact missing evidence / next investigation":"Institution and affiliate status, exact activity within exclusion"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Self-creditor","researcher_record":{"Component":"Self-creditor","Status":"Answered for boundary","Claims":"C031","What was answered":"Own-name collection generally outside core definition; faux third-party risk","Exact missing evidence / next investigation":"UTPA/FDCPA and sector rules later"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Alaska debt-relief numerical fee caps","researcher_record":{"Component":"Alaska debt-relief numerical fee caps","Status":"Answered, bounded negative","Claims":"C015","What was answered":"No setup/monthly/per-debt/savings/percentage/aggregate cap found","Exact missing evidence / next investigation":"Any agency unpublished interpretation or future enactment"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Indexing/adjusted debt-relief amounts","researcher_record":{"Component":"Indexing/adjusted debt-relief amounts","Status":"Answered, bounded negative","Claims":"C015","What was answered":"No indexed debt-relief schedule found; no CPI calculation invented","Exact missing evidence / next investigation":"Later bulletin or enactment search"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Provider filing and license fees","researcher_record":{"Component":"Provider filing and license fees","Status":"Answered","Claims":"C009, C013, C033","What was answered":"Telephonic, business, and MT amounts","Exact missing evidence / next investigation":"Collection-agency fee schedule excluded because no collection model established"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Fee request/receipt timing","researcher_record":{"Component":"Fee request/receipt timing","Status":"Answered","Claims":"C011, C021–C024","What was answered":"Alaska signed-contract threshold and federal performance trigger separated","Exact missing evidence / next investigation":"Provider-specific federal coverage and actual performance records"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Telephonic cancellation/refund","researcher_record":{"Component":"Telephonic cancellation/refund","Status":"Answered","Claims":"C012, C027","What was answered":"Seven-day pre-service right and 2026 amendment reconciliation","Exact missing evidence / next investigation":"Full contract/remedies pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Money-transmission receipt/refund","researcher_record":{"Component":"Money-transmission receipt/refund","Status":"Answered to access/fee extent","Claims":"C016, C025","What was answered":"Net transmission, receipt, written refund rule and kiosk exception","Exact missing evidence / next investigation":"Full client-funds/remedies pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current telemarketer lookup","researcher_record":{"Component":"Current telemarketer lookup","Status":"Answered","Claims":"C018–C019","What was answered":"Official list dated 10/15/26 read","Exact missing evidence / next investigation":"Named-provider registration certificate and campaign expiration if needed"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current MSB lookup","researcher_record":{"Component":"Current MSB lookup","Status":"Partial","Claims":"C018, C032","What was answered":"Official route and older Alaska roster identified","Exact missing evidence / next investigation":"Current NMLS Consumer Access verification per provider"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current business/professional lookup","researcher_record":{"Component":"Current business/professional lookup","Status":"Answered procedurally","Claims":"C018","What was answered":"Official search routes identified","Exact missing evidence / next investigation":"Named-provider status not requested or determined"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"2026 statutory updates","researcher_record":{"Component":"2026 statutory updates","Status":"Answered","Claims":"C025–C027","What was answered":"SB 249 current; SB 252 current; SB 86 future","Exact missing evidence / next investigation":"Monitor implementing regulations and pre-7/1/27 transition work"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Controlling Alaska decisions on debt-settlement classification","researcher_record":{"Component":"Controlling Alaska decisions on debt-settlement classification","Status":"Unresolved","Claims":"C003, C004, C014","What was answered":"Targeted searches found no directly controlling decision","Exact missing evidence / next investigation":"Broader Alaska appellate, administrative, trial-docket, and paid-database review"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Agreement form and complete disclosures","researcher_record":{"Component":"Agreement form and complete disclosures","Status":"Excluded/later pass","Claims":"—","What was answered":"Only AS 45.63 threshold discussed as needed for timing","Exact missing evidence / next investigation":"Full contract/agreement pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Client-money segregation, trust, reconciliation, and administrator duties","researcher_record":{"Component":"Client-money segregation, trust, reconciliation, and administrator duties","Status":"Excluded/later pass","Claims":"—","What was answered":"Only AS 06.55 transmission/receipt/refund rules needed here","Exact missing evidence / next investigation":"Full funds pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Bonds, security, net worth, permissible investments","researcher_record":{"Component":"Bonds, security, net worth, permissible investments","Status":"Excluded/later pass","Claims":"—","What was answered":"Application security requirement noted only","Exact missing evidence / next investigation":"Full market-access financial-condition pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Remedies, civil penalties, criminal exposure, private actions","researcher_record":{"Component":"Remedies, civil penalties, criminal exposure, private actions","Status":"Excluded/later pass","Claims":"—","What was answered":"UTPA relevance noted; no complete remedies analysis","Exact missing evidence / next investigation":"Remedies/enforcement pass"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Full collection, litigation, and limitations coverage","researcher_record":{"Component":"Full collection, litigation, and limitations coverage","Status":"Excluded/later pass","Claims":"—","What was answered":"Collection boundary only","Exact missing evidence / next investigation":"Dedicated collection/litigation/limitations passes"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Secured debts, mortgage relief, tax debts, student loans, and sector products","researcher_record":{"Component":"Secured debts, mortgage relief, tax debts, student loans, and sector products","Status":"Excluded/later pass","Claims":"—","What was answered":"No substantive sector conclusion","Exact missing evidence / next investigation":"Product-specific passes"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Local, municipal, tribal, and Alaska Native law","researcher_record":{"Component":"Local, municipal, tribal, and Alaska Native law","Status":"Excluded/later pass","Claims":"—","What was answered":"No conclusion","Exact missing evidence / next investigation":"Local/tribal jurisdictional investigation"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Named-provider authorization","researcher_record":{"Component":"Named-provider authorization","Status":"Expressly not determined","Claims":"C032","What was answered":"No marketing statement treated as authorization","Exact missing evidence / next investigation":"Current searches in every applicable registry and underlying certificates"},"coordinator_acceptance":"scoped_review_remaining_authority_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}