{"meta":{"key":"s_ar--pass-01","task":"S_AR","title":"Arkansas provider market access and consumer fees","parent_title":"Arkansas debt and debt relief law","edition":"pass-01","path":"/research/s_ar--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":7,"claims":38,"sources":25,"review_status":"revise","review_complete":true,"sha256":"6d860c64f5e9b8e2d96c64710d45a34ccb8cfe85911829ebf6cae13192ff9b0a","headings":["Arkansas provider market access and consumer fees","Bottom-line determination","1. Current Arkansas definitions and classifications","1.1 Statutory definition","1.2 Classification matrix","1.3 Principal reduction versus concessions and distribution","1.4 Custodial versus noncustodial models","1.5 Consumer versus business-purpose debt","1.6 Arkansas resident and remote-provider nexus","2. Prohibition, authorization, and exclusions","2.1 Covered debt adjusting is prohibited, not ordinarily licensed","2.2 Statutory exclusions","2.3 Attorney connection is not presumed sufficient","2.4 Nonprofit status is not enough","2.5 Self-creditor and institutional boundaries","3. Applicable fee structures and current limits","3.1 Arkansas debt-adjusting fee results","3.2 No verified fixed or indexed amount","3.3 Meaning and limitations of “actual expenses incurred”","3.4 Arkansas Attorney General “nominal fee” language","3.5 Separate credit-repair overlap","4. When fees may be requested or received","4.1 Arkansas state-law timing","4.2 Federal TSR baseline—only when independently applicable","4.3 Federal dedicated-account requirements","4.4 State permission and federal timing must stay separate","5. Regulator permission, lookup, and application status","5.1 No debt-adjuster application or registry located","5.2 Public route results","5.3 Named-provider status","Example 1 — Covered custodial DMP; no lawful commercial fee calculation","Example 2 — Custodial settlement with a 20% proposed fee","Example 3 — Qualifying nonprofit DMP; actual-expense ceiling","Example 4 — Lower-debt nonprofit case","Example 5 — Cancellation or early termination after prior collection","Example 6 — Pure noncustodial settlement model","Example 7 — Federal proportional allocation, assuming the TSR applies","Example 8 — Federal percentage-of-savings calculation","Example 9 — Business-purpose and entity-debt boundary","Pass coverage and gap table","Actually read or directly inspected","Not read or not fully obtained","Currentness qualification"],"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_AR/pass-01","facets":{"geography":["us","us-ar"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Arkansas provider-access/fees component; broader state categories remain required","pending_corrections":0},"markdown":"# S_AR — PASS-01\n\n## Arkansas provider market access and consumer fees\n\n**Actual research mode:** Regular Chat, GPT-5.6 Sol Pro fallback; no Deep Research, Work, Chrome control, other chats, API access, purchases, contacts, applications, or account changes.\n**Baseline supplied:** October 22, 2026, America/Los_Angeles.\n**Actual public-source access date:** October 24, 2026, Pacific time.\n**Scope:** Provider classification, lawful market access, fees, and fee timing only. This is not the complete Arkansas dossier and does not imply Arkansas-state or A066 acceptance.\n\n## Bottom-line determination\n\nArkansas is best classified as a **statutory prohibition/exclusion state**, not an ordinary debt-settlement licensing state:\n\n1. A for-profit provider that receives a consumer’s money for distribution to creditors under a DMP falls within Arkansas’s first definition of “debt adjusting.”\n2. A for-profit settlement or negotiation provider that acts as an intermediary **and receives money or property for creditor payment or distribution** falls within the second definition.\n3. Covered conduct—including offering or attempting to perform it—is prohibited and classified as a Class A misdemeanor. Arkansas supplies injunction and receivership remedies but no ordinary debt-adjuster licensing pathway. [Justia Law+2](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n4. A qualifying nonprofit organization is excluded only when it provides “debt management service” free or charges no more than its **actual expenses incurred** in offering the service. Arkansas supplies no fixed dollar amount, percentage schedule, CPI adjustment, setup fee, monthly fee, settlement fee, or savings-fee formula for that exclusion. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/)\n5. A purely noncustodial negotiation model—consumer pays creditors directly and the provider never receives or controls settlement funds—may fall outside the literal receipt element of § 5-63-301(2)(B), but no controlling Arkansas decision or official interpretation resolving that question was located. That is a **legal-classification hold, not verified permission to launch or charge fees**.\n6. Other licenses—money transmission, currency exchange, mortgage, collection-agency, or similar—do not convert activity prohibited by § 5-63-302 into licensed debt adjusting. The public Arkansas Securities Department/NMLS routes reviewed cover other stated license categories, not debt adjusting. [Arkansas Securities Department+1](https://securities.arkansas.gov/)\n\n# A. Substantive answers\n\n## 1. Current Arkansas definitions and classifications\n\n### 1.1 Statutory definition\n\nArkansas Code § 5-63-301 uses two distinct operative branches:\n\n**Branch A — periodic payment and distribution model.** A debtor contracts with a person, agrees to pay that person periodically, and the person—for consideration—agrees to distribute or distributes the money among specified creditors under an agreed plan. This language directly captures the classic custodial debt-management plan or consolidated-payment model. It does not require principal reduction or even creditor concessions. **S_AR-P1-C001–C004.** [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n\n**Branch B — settlement/intermediation plus receipt model.** A person holds itself out, for consideration, as an intermediary between a debtor and creditors to settle, compound, or otherwise alter payment terms **and, to that end, receives money or property from or for the debtor for payment to or distribution among creditors**. This directly captures a custodial settlement model. **S_AR-P1-C005–C007.** [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n\nA “debt adjuster” includes a person who engages, attempts to engage, or offers to engage in debt adjusting. The prohibition separately covers engaging, offering, and attempting. Consequently, the analysis is not limited to completed settlements or completed receipt of funds. **S_AR-P1-C008.** [Justia Law+1](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n\n### 1.2 Classification matrix\n\n| Model or conduct | Arkansas classification for this pass | Conditions and boundary | Claim IDs |\n| --- | --- | --- | --- |\n| Custodial DMP; consumer pays provider and provider distributes among creditors | **Covered and prohibited unless a § 5-63-305 exclusion applies** | Branch A expressly covers periodic payments and distribution for consideration. Principal reduction is unnecessary. | C001–C004, C016 |\n| Settlement/negotiation provider receives settlement funds and pays creditors | **Covered and prohibited unless excluded** | Branch B covers intermediation to alter debt-payment terms plus receipt of money/property for creditor payment or distribution. | C005, C016 |\n| Provider negotiates concessions, but principal is not reduced | **Still potentially covered** | Branch A needs only payment distribution; Branch B includes altering “terms of payment,” not merely reducing principal. | C003–C005 |\n| Provider negotiates; consumer pays creditor directly; provider never receives or controls creditor funds | **Unresolved textual-boundary model** | Branch B’s receipt element may be absent; Branch A ordinarily would not fit if consumer money is never delivered for distribution. No Arkansas controlling interpretation was located. | C006–C007, C030 |\n| Consumer places money in independently administered dedicated account | **Fact-dependent and unresolved under Arkansas law** | Federal ownership/independence requirements do not answer whether the provider “receives” or constructively controls money under Arkansas law. Actual withdrawal authority, fee sweeps, creditor-payment instructions, account affiliation, and control matter. | C007, C026 |\n| Budget education or counseling with no consideration, no creditor intermediation, and no consumer-fund receipt | **Likely outside the two definitions** | Both branches require consideration; Branch B also requires intermediation and receipt. Indirect creditor payments, affiliate compensation, “voluntary contributions,” or lead payments may change the analysis. | C009 |\n| Creditor negotiates its own debt directly | **Likely outside Branch B’s “intermediary” formulation** | A creditor acting for itself is ordinarily not between itself and the debtor. Servicers, affiliates, assignees, and common-control entities require separate facts. | C010 |\n| Qualifying nonprofit DMP, free or fee no greater than actual expenses | **Conditionally excluded—not licensed** | Must actually be nonprofit, provide “debt management service,” and satisfy the fee condition. | C018–C021 |\n| Nonprofit principal-reduction settlement program | **Unresolved** | “Debt management service” is not defined in the reviewed subchapter; no controlling Arkansas interpretation was located extending § 305(6) to principal-reduction settlement. | C021 |\n| Attorney personally performing debt-adjusting work | **Textual exclusion for an “attorney at law”** | Does not establish that a nonlawyer company, lead generator, account administrator, affiliate, or nominal attorney arrangement is excluded. | C022 |\n| Bank or other listed institution | **Conditionally excluded** | Entity must meet the stated authorization/admission condition and perform adjusting in the regular course of its principal business. | C023 |\n| Association serving members | **Textual exclusion, scope unresolved** | “Association” and “for its members” are not defined here; no public registration pathway or interpretive authority was located. | C023 |\n| Individual’s business-purpose debt, including sole-proprietor debt | **Textually may be covered** | “Debtor” means an individual; the debt-adjusting definition has no personal/family/household-purpose qualifier. | C011 |\n| Debt owed solely by an LLC or corporation, without an individual obligor | **Likely outside the literal debtor definition** | The statutory “debtor” is an individual. An individual guaranty, joint liability, or personal obligation can change the result. | C011–C012 |\n\n### 1.3 Principal reduction versus concessions and distribution\n\nArkansas does not divide coverage according to the marketing term “settlement,” “DMP,” “credit counseling,” or “consolidation.”\n\n- A plan that merely collects one payment and distributes it may fit Branch A, even when creditors make no concessions.\n- An interest-rate reduction, fee waiver, extended term, or lower payment can fit Branch B’s language concerning alteration of payment terms.\n- A principal-reduction settlement fits Branch B when the provider also receives debtor money or property for payment or distribution.\n- Calling a service “financial coaching,” “legal support,” “credit restoration,” or “account administration” does not change the underlying functional elements. **S_AR-P1-C003–C008.**\n\nThe Arkansas Attorney General’s consumer page also distinguishes counseling/DMPs from settlement services and warns about advance charges and requiring payments before creditor acceptance, but that page is consumer guidance—not a license, fee schedule, or authoritative expansion of the statute. **S_AR-P1-C029.** [Arkansas Attorney General](https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/)\n\n### 1.4 Custodial versus noncustodial models\n\nThe custody issue is material because § 5-63-301(2)(B) does not end after describing negotiation. It adds that the intermediary “receives money or other property” for payment or distribution to creditors. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n\nAccordingly:\n\n- **Provider bank account or provider-controlled trust account:** strong coverage indication.\n- **Provider collects monthly consumer funds and remits them:** covered under Branch A and often Branch B.\n- **Independent account in the consumer’s name:** not automatically outside Arkansas law. The result can turn on withdrawal authority, payment-direction powers, contractual control, fee deductions, affiliation, and whether the provider or its agent effectively receives the property.\n- **Direct consumer-to-creditor payment:** strongest textual argument against the receipt element, but there is no verified Arkansas safe harbor or agency approval for that model.\n- **Provider receives only its own fee:** this may not be receipt of money “for the payment to or distribution among” creditors, but no Arkansas controlling decision located in this pass resolves whether the entire arrangement, related entities, or payment flow nevertheless satisfies the definition.\n\nNo launch conclusion should be based solely on moving money through a nominally independent account.\n\n### 1.5 Consumer versus business-purpose debt\n\nThe debt-adjusting subchapter defines “debtor” as an **individual**, including jointly or severally indebted individuals. It does not contain a personal, family, or household-purpose limitation. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/)\n\nThe best bounded textual reading is therefore:\n\n- An individual’s business-purpose debt can fall within the statute.\n- A sole proprietor is still an individual.\n- A corporation or LLC, standing alone, is not an “individual.”\n- An owner’s personal guaranty or joint liability can create an individual debtor even if the underlying loan financed business activity.\n- No controlling Arkansas decision resolving mixed individual/entity obligations under this subchapter was located.\n\nThat differs from Arkansas’s separate credit-repair statute, whose “extension of credit” definition is tied primarily to personal, family, or household purposes. [Justia Law](https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/)\n\n### 1.6 Arkansas resident and remote-provider nexus\n\nSection 5-63-302 prohibits debt adjusting “in this state.” Arkansas’s general territorial criminal statute permits conviction where conduct or a result that is an element occurs in Arkansas or where outside conduct constitutes an attempt to commit an offense within Arkansas. **S_AR-P1-C013.** [Justia Law+1](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/)\n\nTherefore, an out-of-state office is **not a categorical safe harbor**. Conduct involving an Arkansas debtor, an Arkansas-directed offer, communications performed into Arkansas, an Arkansas execution or payment event, or fund flows involving Arkansas can create material exposure.\n\nHowever, this pass did not locate a controlling Arkansas case deciding precisely whether any one of the following, standing alone, is sufficient under this offense:\n\n- a nationally available website viewed by an Arkansas resident;\n- an inbound Arkansas consumer call;\n- remote contract execution;\n- payments initiated from Arkansas;\n- an out-of-state provider’s negotiation with an out-of-state creditor.\n\nThose questions remain a case-law and fact-pattern hold. Act 736 of 2023 amended § 5-1-104(a)(6), but the more immediately relevant general paths for this offense remain § 5-1-104(a)(1)–(2). [Arkansas Legislature+1](https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F)\n\n## 2. Prohibition, authorization, and exclusions\n\n### 2.1 Covered debt adjusting is prohibited, not ordinarily licensed\n\nArkansas Code § 5-63-302 states that a person shall not engage in, offer to engage in, or attempt to engage in debt adjusting in Arkansas. Violation is a Class A misdemeanor. Official Act 1263 of 2015 placed the penalty in § 302 and repealed former § 304’s duplicative penalty section. **S_AR-P1-C014–C016.** [Justia Law+1](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/)\n\nThis architecture matters:\n\nA separate financial-services license cannot be treated as authorization to perform conduct that § 5-63-302 prohibits.\n\nThe Attorney General or a prosecuting attorney may seek an injunction. The circuit court may appoint a receiver over money and property used in the business to facilitate return of debtor money not paid to creditors. **S_AR-P1-C017.** [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/)\n\n### 2.2 Statutory exclusions\n\nSection 5-63-305 says the following persons are “not considered a debt adjuster” for this subchapter:\n\n| Excluded category | Exact operative condition | Important limitation |\n| --- | --- | --- |\n| Attorney at law | Person is an attorney at law | The text does not say that every entity using, retaining, or referring to an attorney is excluded. |\n| Bank, fiduciary, or financing/lending institution | Authorized and admitted to transact business in Arkansas and performs credit/financial adjusting in the regular course of its principal business | Both entity status and ordinary-course activity must be satisfied. |\n| Title insurer or abstract company | While doing an escrow business | Activity-specific, not a blanket exemption. |\n| Employer | For its employees | Does not cover services marketed to the general public. |\n| Judicial officer or another person | Acting pursuant to court order | Requires an actual court-order basis. |\n| Nonprofit organization | Gives debt-management service without charge, or charges no more than actual expenses incurred in offering the service | Nonprofit status alone is insufficient; fee and service conditions must be satisfied. |\n| Association | For its members | Scope of “association” and member-service boundaries were not resolved in reviewed authority. |\n\nThese are exclusions from the debt-adjuster classification, not an ordinary licensing program. **S_AR-P1-C018–C023.** [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/)\n\n### 2.3 Attorney connection is not presumed sufficient\n\nThe statute identifies “an attorney at law”; it does not expressly identify:\n\n- a nonlawyer debt-settlement company owned by or affiliated with an attorney;\n- a national marketing company that assigns consumers to local attorneys;\n- a lead generator;\n- an account administrator;\n- an operations vendor;\n- a law-firm-branded management company;\n- nonlawyer negotiators supervised only nominally by counsel.\n\nNo controlling Arkansas case or formal Attorney General opinion was located defining the exclusion’s treatment of those structures. An actual attorney’s inclusion in a workflow therefore should not be represented as established blanket permission. **S_AR-P1-C022, C030.**\n\nSeparately, the federal TSR does not provide a general attorney exemption for covered interstate telemarketing. The FTC’s guidance states that attorneys may fall outside the TSR for fact-specific reasons, such as no interstate telemarketing or a qualifying face-to-face transaction, but not merely because they are attorneys. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business)\n\n### 2.4 Nonprofit status is not enough\n\nThe nonprofit exclusion has at least three cumulative textual elements:\n\n1. The provider must be a nonprofit organization.\n2. It must be giving “debt management service.”\n3. The service must be free or its fee must not exceed actual expenses incurred in offering it.\n\nThe reviewed statute does not define “debt management service,” prescribe an expense-accounting method, identify permitted overhead allocations, or state that a nonprofit principal-reduction settlement program qualifies. No responsive rule or controlling interpretation was located. **S_AR-P1-C018–C021.**\n\n### 2.5 Self-creditor and institutional boundaries\n\nA creditor working out its own receivable is ordinarily not an intermediary “between a debtor and the debtor’s creditors.” That is a textual noncoverage conclusion rather than an express § 305 exclusion. The result becomes less certain when the negotiator is a servicer, affiliate, purchaser, common-control entity, or separate fee-taking company. **S_AR-P1-C010.**\n\nLikewise, a bank or fiduciary exclusion should not be extended to an unregulated affiliate merely because a bank account, lending institution, or trust company appears somewhere in the payment chain.\n\n## 3. Applicable fee structures and current limits\n\n### 3.1 Arkansas debt-adjusting fee results\n\n| Structure | Verified Arkansas fee rule | Dollar/percentage/index status | Result |\n| --- | --- | --- | --- |\n| Covered for-profit custodial DMP | No lawful commercial fee pathway established because the activity itself is prohibited | No setup, monthly, percentage, aggregate, or indexed ceiling authorizing the activity | **Prohibited activity, not a “$0 fee cap”** |\n| Covered for-profit custodial settlement | Same | No settlement, per-debt, enrolled-debt, savings, or performance-fee authorization | **Prohibited activity** |\n| Qualifying nonprofit debt-management service | Free, or fee no greater than actual expenses incurred in offering the service | No fixed dollar amount; no percentage; no CPI/index; no published adjustment notice found | **Conditional exclusion** |\n| Nonprofit principal-reduction settlement | Unresolved whether it is “debt management service” within § 305(6) | No amount should be treated as verified | **Hold** |\n| Attorney/institutional/association exclusion | The debt-adjusting subchapter supplies no special fee ceiling | Separate ethics, banking, consumer-protection, contract, or other law may govern | **Not evaluated as unrestricted** |\n| Pure noncustodial settlement | Underlying debt-adjuster classification unresolved | No fee permission established merely because custody is absent | **Hold** |\n| Free counseling/no consideration | Likely outside definition if genuinely free and no indirect consideration | No fee by hypothesis | **Conditional noncoverage** |\n\nThe only express debt-adjusting fee formula found is the nonprofit exclusion’s **actual-expenses** limit. **S_AR-P1-C024–C027.** [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/)\n\n### 3.2 No verified fixed or indexed amount\n\nNo reviewed current Arkansas debt-adjusting source establishes:\n\n- a maximum enrollment or setup fee;\n- a maximum monthly maintenance fee;\n- a percentage of payments;\n- a percentage of enrolled debt;\n- a percentage of settled debt;\n- a percentage of savings;\n- a per-creditor or per-account charge;\n- an aggregate program cap;\n- a CPI-linked amount;\n- an annual regulator adjustment.\n\nAccordingly, no dollar amount should be calculated by analogy to another state, a trade-association chart, an old multistate table, or a guessed CPI adjustment.\n\n### 3.3 Meaning and limitations of “actual expenses incurred”\n\nThe statute does not specify:\n\n- cash basis versus accrual basis;\n- direct costs versus indirect overhead;\n- organization-wide versus Arkansas-client allocation;\n- treatment of advertising, lead costs, fundraising, executive pay, affiliate charges, or reserves;\n- whether expenses may be collected prospectively and later reconciled;\n- documentation required;\n- treatment at early cancellation;\n- timing of refunds or credits.\n\nThe safest bounded interpretation is that the nonprofit cannot **retain** more than actual expenses properly attributable to offering the debt-management service. But the exact accounting methodology and legal consequence of temporary overcollection remain unresolved. **S_AR-P1-C019–C020, C025–C027.**\n\n### 3.4 Arkansas Attorney General “nominal fee” language\n\nThe Attorney General’s consumer page warns consumers about an organization that charges more than a nominal fee before settling debts. That statement is not an Arkansas statutory fee schedule, does not define “nominal,” and cannot authorize an advance charge that another law prohibits. **S_AR-P1-C029.** [Arkansas Attorney General](https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/)\n\n### 3.5 Separate credit-repair overlap\n\nA debt-relief provider can also enter Arkansas’s Credit Repair Services Organizations Act if, for consideration, it represents that it will improve credit history/rating, obtain credit, locate a lender, or provide related advice concerning covered consumer credit. That statute has its own exclusions and requirements. [Justia Law+1](https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/)\n\nUnder § 4-91-202(e)(1), a covered credit-repair organization may not charge or receive consideration before complete performance unless it both:\n\n- obtains a $10,000 surety bond; and\n- establishes a federally insured trust account at an Arkansas state or national bank or savings and loan association.\n\nThe contract has a five-day cancellation provision, and the statutory notice states that payments must be returned within ten days after receipt of a cancellation notice. **S_AR-P1-C028.** [Justia Law+1](https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/)\n\nThis credit-repair provision does **not** authorize debt adjusting prohibited by § 5-63-302. It is a separate cumulative overlay when its own definition is met.\n\n## 4. When fees may be requested or received\n\n### 4.1 Arkansas state-law timing\n\n**Covered for-profit debt adjusting:** There is no verified lawful point at which a provider can begin charging for covered prohibited conduct. The issue is prohibition, not merely premature collection.\n\n**Qualifying nonprofit:** Section 5-63-305(6) supplies no express enrollment, monthly-service, creditor-acceptance, settlement, consumer-payment, or completion trigger. It states only that the fee may not exceed actual expenses incurred. “Incurred” places a substantive ceiling on retained charges, but the statute does not supply an exact prepayment, reconciliation, cancellation, or refund timetable. **S_AR-P1-C024–C027.**\n\n**Attorney and other exclusions:** Section 5-63-305 does not supply their fee timing. Separate professional-conduct, fiduciary, contract, consumer-protection, banking, or other law must be evaluated in later passes.\n\n### 4.2 Federal TSR baseline—only when independently applicable\n\nThe federal TSR defines “debt relief service” broadly to include programs represented to renegotiate, settle, or alter the terms of unsecured debt, including balance, interest, or fees. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nWhere the TSR applies, 16 C.F.R. § 310.4(a)(5) prohibits requesting or receiving a fee until all three conditions are met for at least one debt:\n\n1. The provider has renegotiated, settled, reduced, or otherwise altered the debt under a valid agreement executed by the customer.\n2. The customer has made at least one payment under that agreement.\n3. For debts resolved individually, the fee is allocated either proportionally by enrolled debt or through a uniform percentage-of-savings method. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe savings base is:\n\nSavings=amount owed when enrolled−amount actually paid to satisfy the debt\\text{Savings}=\\text{amount owed when enrolled}-\\text{amount actually paid to satisfy the debt}Savings=amount owed when enrolled−amount actually paid to satisfy the debtThe percentage charged under that method cannot vary from one individual debt to another. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe inbound-call exemption generally does not protect calls made in response to advertisements for debt-relief services. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6)\n\n### 4.3 Federal dedicated-account requirements\n\nThe TSR permits requiring money to be placed in a dedicated account only if:\n\n- the account is at an insured financial institution;\n- the customer owns the funds and receives accrued interest, if any;\n- the administrator is not owned, controlled by, or affiliated with the debt-relief provider;\n- the administrator does not give or receive compensation for debt-relief referrals; and\n- the customer can withdraw without penalty and receive all funds other than properly earned fees within seven business days. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThose federal conditions do not decide whether a payment arrangement constitutes “receives money or other property” under Arkansas’s criminal statute.\n\n### 4.4 State permission and federal timing must stay separate\n\nCompliance with federal performance-based timing does not cure Arkansas’s state prohibition. Conversely, a state exclusion or state-law fee ceiling does not authorize advance fees prohibited by federal law.\n\nThe proper order is:\n\n1. Determine whether Arkansas prohibits, excludes, or does not cover the model.\n2. Determine whether other Arkansas laws apply.\n3. Determine independently whether the federal TSR applies.\n4. Apply the strictest cumulative conditions.\n\n## 5. Regulator permission, lookup, and application status\n\n### 5.1 No debt-adjuster application or registry located\n\nNo public Arkansas application, registration, license type, or provider registry was located for ordinary commercial debt adjusting under §§ 5-63-301–305. The statutory framework itself establishes a prohibition and conditional exclusions, not a license. **S_AR-P1-C014–C018, C031.**\n\nThe reviewed Arkansas Securities Department pages identify public pathways for securities, mortgage activities, money transmitters, and currency exchangers. The NMLS page states that its money-services application and public lookup concern money transmitters and currency exchangers; it does not identify debt adjusting as an NMLS license category. [Arkansas Securities Department+1](https://securities.arkansas.gov/)\n\n### 5.2 Public route results\n\n| Public route | What was actually found | What it does **not** establish |\n| --- | --- | --- |\n| Arkansas debt-adjusting statutes | Prohibition, enforcement, and exclusions | No license application or ordinary commercial authorization |\n| Arkansas Securities Department | Securities, mortgage, and money-services categories | No debt-adjuster license |\n| NMLS Consumer Access | Mortgage companies/personnel and money transmitter/currency exchanger records | No debt-adjuster status |\n| Arkansas collection-agency pages | Discovery results indicate a separate collection-agency licensing system; direct pages returned access errors during this check | A collection license is not debtor-side debt-adjusting authorization |\n| Code of Arkansas Rules | Official searchable rule database; targeted searches produced unrelated “debt” or “settlement” results, not a responsive debt-adjuster rule | Negative search is not proof that no obscure or uncodified rule exists |\n| Attorney General consumer page | Consumer warnings and descriptions | No permission, application, fee table, or named-provider authorization |\n| Attorney General opinion search | No responsive formal opinion located with targeted terms | Not proof that no opinion exists |\n| Public Arkansas case searches | No responsive controlling debt-adjuster interpretation located; false positives concerned creditor collection or insurance adjusters | Not a complete citator or unpublished-case search |\n\nThe official Code of Arkansas Rules database states that it became the official online codification on January 1, 2025, is updated weekly, may lag recent rulemaking, and was last updated October 19, 2026. Targeted public searches for debt adjusting, debt adjuster, debt settlement, and related phrases returned unrelated provisions rather than an operative provider rule. **S_AR-P1-C030–C031.** [Code of Arkansas Rules+2](https://codeofarrules.arkansas.gov/)\n\n### 5.3 Named-provider status\n\nNo named provider was submitted for verification, and this pass did not test a named company against corporate, charitable, attorney, money-services, or collection-agency records.\n\nA company’s website statement that it is “licensed,” “accredited,” “attorney backed,” “compliant,” or “available in Arkansas” is not proof of Arkansas debt-adjusting authorization.\n\n# B. Source table\n\nUnless otherwise stated, each source was accessed or attempted on **October 24, 2026, Pacific time**.\n\n| Source ID | Title / issuer | Direct literal URL | Exact pinpoint and version/status | Actual read/check and limitations |\n| --- | --- | --- | --- | --- |\n| **S_AR-P1-S001** | Arkansas Code § 5-63-301, Definitions; 2025 codification hosted by Justia | [https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/?utm_source=chatgpt.com) | § 5-63-301(1)–(4); displayed 2025 version | Freshly read full operative text. Secondary codification with express disclaimer; official current-code portal was inaccessible. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/) |\n| **S_AR-P1-S002** | Arkansas Code § 5-63-302, Debt adjusting—Prohibition | [https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/?utm_source=chatgpt.com) | § 5-63-302(a)–(b); history includes 2015 Act 1263 § 17 | Freshly read. Current displayed prohibition and Class A misdemeanor; corroborated by official Act 1263. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/) |\n| **S_AR-P1-S003** | Arkansas Code § 5-63-303, Injunction and receivership | [https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/?utm_source=chatgpt.com) | § 5-63-303(a)–(b) | Freshly read. Secondary codification; establishes AG/prosecutor action and receiver authority. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/) |\n| **S_AR-P1-S004** | Arkansas Code § 5-63-305, Exclusions | [https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/?utm_source=chatgpt.com) | § 5-63-305(1)–(7); history: Acts 1967 No. 61 and 1983 No. 189 | Freshly read. Source for all listed exclusions and nonprofit actual-expense condition. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/) |\n| **S_AR-P1-S005** | Act 1263 of 2015; Arkansas General Assembly | [https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F](https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F&utm_source=chatgpt.com) | PDF p. 21, §§ 17–18 | Freshly read and visually inspected. § 17 amends § 5-63-302 and inserts Class A misdemeanor; § 18 repeals former § 304. Primary official enactment. [Arkansas Legislature](https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F) |\n| **S_AR-P1-S006** | Arkansas Code § 5-1-104, Territorial applicability | [https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/](https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/?utm_source=chatgpt.com) | § 5-1-104(a)(1)–(6); displayed 2025 version | Freshly read. Relevant to remote/out-of-state activity; no debt-adjuster-specific application located. [Justia Law](https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/) |\n| **S_AR-P1-S007** | Act 736 of 2023; Arkansas General Assembly | [https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F](https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F&utm_source=chatgpt.com) | PDF p. 1, § 1 | Freshly read and visually inspected. Amends § 5-1-104(a)(6); does not decide the debt-adjusting remote-nexus scenarios. [Arkansas Legislature](https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F) |\n| **S_AR-P1-S008** | Arkansas State Legislature homepage/current session | [https://www.arkleg.state.ar.us/](https://www.arkleg.state.ar.us/?utm_source=chatgpt.com) | Fiscal Session of 95th General Assembly adjourned April 29, 2026; official-site statement | Freshly read for current-session context only. Does not itself prove no amendments. [Arkansas Legislature](https://www.arkleg.state.ar.us/) |\n| **S_AR-P1-S009** | Official Arkansas Code search portal | [https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/](https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/?utm_source=chatgpt.com) | Current-code portal | Attempted; route returned a 403/interactive-access barrier. No CAPTCHA workaround or permission change attempted. Exact official current code therefore was not retrieved from this route. |\n| **S_AR-P1-S010** | Code of Arkansas Rules; State of Arkansas | [https://codeofarrules.arkansas.gov/](https://codeofarrules.arkansas.gov/?utm_source=chatgpt.com) | Official-version statement; effective Jan. 1, 2025; last updated Oct. 19, 2026 | Freshly read. Database warns it may not reflect recent rulemaking. [Code of Arkansas Rules](https://codeofarrules.arkansas.gov/) |\n| **S_AR-P1-S011** | Code of Arkansas Rules search | [https://codeofarrules.arkansas.gov/Rules/Search](https://codeofarrules.arkansas.gov/Rules/Search?utm_source=chatgpt.com) | Exact/keyword searches for debt adjusting, debt adjuster, debt settlement, DMP-related terms | Fresh searches produced unrelated debt/check, gaming, tax, and other provisions. No responsive debt-adjuster rule found; negative result is limited by indexing and search behavior. [Code of Arkansas Rules+1](https://codeofarrules.arkansas.gov/Rules/Rule?chapterID=257&levelType=section&partID=1253&sectionID=49049&subChapterID=322&subPartID=7539&titleID=9) |\n| **S_AR-P1-S012** | Uncodified Historic Legislation; Arkansas General Assembly | [https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation](https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation?utm_source=chatgpt.com) | Historic-source availability statement | Freshly read. Official page states electronic copies of historic acts are unavailable from the site/BLR and identifies libraries from which copies may be obtained. No contact was made. [Arkansas Legislature](https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation) |\n| **S_AR-P1-S013** | Debt Relief Services/Fair Debt Collection; Arkansas Attorney General | [https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/](https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/?utm_source=chatgpt.com) | Consumer warnings and descriptions of counseling, DMP, and settlement | Freshly read. Undated operational/consumer guidance; not a statute, regulation, fee schedule, application, or formal opinion. [Arkansas Attorney General](https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/) |\n| **S_AR-P1-S014** | Arkansas Securities Department homepage | [https://securities.arkansas.gov/](https://securities.arkansas.gov/?utm_source=chatgpt.com) | Public categories: securities, mortgages, money services | Freshly read. No debt-adjuster license category identified. [Arkansas Securities Department](https://securities.arkansas.gov/) |\n| **S_AR-P1-S015** | NMLS—Arkansas Securities Department | [https://securities.arkansas.gov/money-services-2/7678-2/](https://securities.arkansas.gov/money-services-2/7678-2/?utm_source=chatgpt.com) | Money transmitter/currency exchanger application and public-search description; list dated Sept. 1, 2026 | Freshly read. Category-specific; not debt-adjuster authorization. [Arkansas Securities Department](https://securities.arkansas.gov/money-services-2/7678-2/) |\n| **S_AR-P1-S016** | Arkansas State Board of Collection Agencies route set | [https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/](https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/?utm_source=chatgpt.com) and [https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/](https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/?utm_source=chatgpt.com) | Public collection-agency licensing/lookup discovery routes | Search results were discovered, but direct pages returned access errors during this check. Collection licensing was not treated as debt-adjusting permission. |\n| **S_AR-P1-S017** | Arkansas Code § 4-91-202, Credit Repair Services Organizations Act | [https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/](https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/?utm_source=chatgpt.com) | § 4-91-202(a), (c)–(h); displayed 2025 version | Freshly read for overlap only. Five-day cancellation, ten-day payment return, advance-fee condition, $10,000 bond, and in-state insured trust requirements. Not a debt-adjusting authorization. [Justia Law+2](https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/) |\n| **S_AR-P1-S018** | 16 C.F.R. § 310.2; eCFR | [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com) | § 310.2(o), debt-relief-service definition; eCFR displayed current through Oct. 22, 2026 | Freshly read. Authoritative but unofficial eCFR. Federal common context only. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **S_AR-P1-S019** | 16 C.F.R. § 310.4; eCFR | [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com) | § 310.4(a)(5)(i)–(ii) | Freshly read. Exact performance triggers, proportional/savings allocation, and dedicated-account conditions. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_AR-P1-S020** | 16 C.F.R. § 310.6; eCFR | [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com) | § 310.6(b)(5)(i) | Freshly read. Debt-relief advertisements are carved out of the general inbound-ad-call exemption. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6) |\n| **S_AR-P1-S021** | Debt Relief Services and the TSR: Guide for Business; FTC | [https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com) | Coverage, fee collection, substantial assistance, attorney discussion | Freshly read. Staff compliance guidance, not itself the regulation; accurately distinguished from binding text. [Federal Trade Commission+1](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) |\n| **S_AR-P1-S022** | Debt Relief Services and the TSR: What People Are Asking; FTC | [https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com) | FTC staff Q&A | Freshly read for context. Staff answers; not treated as Arkansas authority. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking) |\n| **S_AR-P1-S023** | Arkansas Attorney General opinions search | [https://prod.opinions-search.arkansasag.gov/](https://prod.opinions-search.arkansasag.gov/?utm_source=chatgpt.com) | Searches for § 5-63-301, § 5-63-302, debt adjuster, debt adjusting, and debt settlement | Checked; no responsive formal opinion located. This is a limited negative search, not proof of nonexistence. |\n| **S_AR-P1-S024** | Arkansas public case-search route set | [https://law.justia.com/cases/arkansas/](https://law.justia.com/cases/arkansas/) | Exact statutory citations and distinctive definition phrases | Checked. Located false positives involving creditor collection and insurance adjusters, but no controlling interpretation of this subchapter. No subscription citator or unpublished-trial-record search was performed. [Justia Law+1](https://law.justia.com/cases/arkansas/supreme-court/2022/cv-22-43.html) |\n| **S_AR-P1-S025** | Code Sections Amended, 2026 Fiscal Session; Arkansas General Assembly | [https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F](https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F&utm_source=chatgpt.com) | Official session amendment-index route | Checked; page presentation was JavaScript-limited and did not provide a clean, independently searchable confirmation for every target section. Targeted official act searches found no responsive later debt-adjusting amendment, but absolute currentness remains qualified. |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Source IDs and pinpoint | Conditions, exceptions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_AR-P1-C001** | Branch A covers a contract under which a debtor periodically pays a provider that, for consideration, distributes the money among specified creditors under an agreed plan. | S001, § 5-63-301(2)(A) | **High confidence.** Direct statutory text. |\n| **C002** | A classic custodial DMP is within Branch A even without principal reduction. | S001, § 301(2)(A) | **High confidence textual application.** Distribution, not principal reduction, is the operative element. |\n| **C003** | Creditor concessions such as reduced interest or waived fees do not remove a DMP from Branch A. | S001, § 301(2)(A) | **High confidence textual application.** |\n| **C004** | A provider need not successfully complete distribution before risk attaches because “debt adjuster” includes attempts and offers. | S001, § 301(1); S002, § 302(a) | **High confidence.** |\n| **C005** | Branch B covers consideration-based intermediation to settle, compound, or alter payment terms when the provider receives debtor money/property for creditor payment or distribution. | S001, § 301(2)(B) | **High confidence.** |\n| **C006** | Pure noncustodial negotiation may lack Branch B’s receipt element. | S001, § 301(2)(B) | **Moderate textual inference; unresolved.** Not a safe harbor or launch approval. |\n| **C007** | A consumer-owned dedicated account does not automatically resolve Arkansas coverage. | S001, § 301(2)(B); S019, § 310.4(a)(5)(ii) | **Moderate.** Actual possession, control, agency, affiliation, and payment mechanics matter; no Arkansas interpretation located. |\n| **C008** | Marketing labels do not control classification; underlying conduct and fund flow do. | S001, § 301(1)–(2) | **High confidence.** |\n| **C009** | Truly free counseling with no consideration, creditor intermediation, or consumer-fund receipt likely falls outside both branches. | S001, § 301(2)(A)–(B) | **Moderate.** Indirect consideration or creditor-funded compensation may alter the analysis. |\n| **C010** | A creditor settling its own debt is likely not an “intermediary,” but affiliate and servicer structures remain unresolved. | S001, § 301(2)(B) | **Moderate textual inference.** |\n| **C011** | “Debtor” means an individual, with no personal/family/household-purpose qualifier in this subchapter. | S001, § 301(3) | **High confidence.** |\n| **C012** | Entity-only debt likely falls outside the literal debtor definition, while an individual guarantor or obligor may bring the matter within it. | S001, § 301(3) | **Moderate textual application; no controlling case located.** |\n| **C013** | Out-of-state location is not a categorical safe harbor when conduct or an offense element occurs in Arkansas or outside conduct is an attempt to commit the offense there. | S002, § 302(a); S006, § 5-1-104(a)(1)–(2) | **High for general rule; moderate for application to specific online/remote facts.** |\n| **C014** | Covered debt adjusting in Arkansas is prohibited. | S002, § 302(a); S005, § 17 | **High confidence.** |\n| **C015** | Violation is a Class A misdemeanor. | S002, § 302(b); S005, § 17 | **High confidence.** |\n| **C016** | The statute prohibits engaging, offering, and attempting; it is not merely a fund-custody licensing provision. | S001, § 301(1); S002, § 302(a) | **High confidence.** |\n| **C017** | The Attorney General or prosecutor may seek an injunction, and a circuit court may appoint a receiver to facilitate return of unremitted debtor property. | S003, § 303(a)–(b) | **High confidence.** |\n| **C018** | Section 305 lists conditional categories not considered debt adjusters. | S004, § 305(1)–(7) | **High confidence.** |\n| **C019** | A qualifying nonprofit may provide debt-management service free or charge no more than actual expenses incurred. | S004, § 305(6) | **High confidence as to text.** |\n| **C020** | Nonprofit status alone does not satisfy § 305(6). | S004, § 305(6) | **High confidence.** Service and fee conditions remain. |\n| **C021** | Whether nonprofit principal-reduction settlement is “debt management service” is unresolved. | S004, § 305(6); S023–S024 negative searches | **Held.** No controlling interpretation located. |\n| **C022** | The attorney exclusion does not establish blanket exclusion for nonlawyer entities or nominal attorney arrangements. | S004, § 305(1); S023–S024 | **High as to text; affiliate/entity application held.** |\n| **C023** | Institutional and association exclusions are conditional and should not be expanded beyond their terms. | S004, § 305(2)–(7) | **High as to stated conditions; unresolved peripheral scope.** |\n| **C024** | No lawful fee pathway was established for covered for-profit debt adjusting. | S002, § 302; S004, § 305 | **High.** This is prohibition, not a zero-dollar cap. |\n| **C025** | The nonprofit fee ceiling is an expense formula, not a fixed amount or percentage. | S004, § 305(6) | **High.** |\n| **C026** | No Arkansas debt-adjusting setup, monthly, per-debt, settlement, savings, aggregate, or indexed ceiling was located. | S004; S010–S011 | **High for reviewed sources; qualified negative-search conclusion.** |\n| **C027** | Arkansas’s debt-adjusting subchapter does not specify nonprofit prepayment, reconciliation, cancellation, refund, or expense-allocation procedures. | S004, § 305(6) | **High as to statutory omission; other-law consequences remain open.** |\n| **C028** | Credit-repair coverage can create separate contract, cancellation, bond, trust, and advance-fee duties but cannot authorize prohibited debt adjusting. | S017, § 4-91-202(a), (d)–(h); S002 | **High as to separate statutes; full overlap analysis reserved.** |\n| **C029** | The Arkansas AG consumer page is guidance, not a fee ceiling or licensing decision. | S013 | **High.** |\n| **C030** | No controlling reported Arkansas appellate decision or responsive formal AG opinion resolving the identified receipt, nonprofit, attorney, expense, or remote-nexus questions was located. | S023–S024 | **Limited negative-search conclusion, not proof of nonexistence.** |\n| **C031** | No ordinary debt-adjuster application, registration, or public provider registry was located. | S001–S004; S010–S016 | **High but not absolute.** Official code portal and some collection pages were inaccessible. |\n| **C032** | A money-transmitter, currency-exchanger, mortgage, or collection-agency license is not itself debt-adjusting authorization. | S002; S014–S016 | **High legal-architecture conclusion.** Separate overlays may still apply. |\n| **C033** | Where the federal TSR applies, fees require a valid debt result, customer agreement, and at least one customer payment. | S019, § 310.4(a)(5)(i)(A)–(B) | **High.** Federal rule; applicability is fact-specific. |\n| **C034** | Individually resolved debts require proportional or uniform percentage-of-savings allocation under the TSR. | S019, § 310.4(a)(5)(i)(C) | **High.** |\n| **C035** | Federal dedicated-account compliance does not constitute Arkansas market permission. | S019, § 310.4(a)(5)(ii); S002 | **High.** Independent cumulative legal systems. |\n| **C036** | Inbound calls responding to debt-relief advertising are not covered by the general inbound-ad-call exemption. | S020, § 310.6(b)(5)(i) | **High.** |\n| **C037** | The TSR has no general attorney exemption for covered interstate telemarketing. | S021, attorney section | **High as FTC guidance; exact application remains fact-specific.** |\n| **C038** | Currentness is high but not absolute because the official current-code portal was inaccessible and historic Acts 61/1967 and 189/1983 were not available electronically. | S005, S008–S012, S025 | **Explicit source limitation.** |\n\n# D. Worked examples and component coverage\n\n## Example 1 — Covered custodial DMP; no lawful commercial fee calculation\n\n**Inputs**\n\n- Consumer sends provider: $600 per month\n- Creditors: 4\n- Proposed setup fee: $50\n- Proposed monthly fee: $35\n- Provider distributes the remaining money among the creditors\n\n**Base**\n\nPeriodic consumer money delivered to the provider for distribution.\n\n**Operator**\n\n§ 5-63-301(2)(A) classification, followed by § 5-63-302 prohibition.\n\n**Intermediate**\n\n- Periodic payment to provider: yes\n- Distribution among specified creditors: yes\n- Consideration: yes\n- Express/implied plan: yes\n\n**Result**\n\nThe model is covered debt adjusting and prohibited unless an actual statutory exclusion applies. The calculation is **not** “maximum fee = $0.” The legally important result is that no lawful commercial fee pathway was established for the covered activity.\n\n**Units/rounding**\n\nDollars and dollars/month; no rounding issue.\n\n**Claims**\n\nC001–C004, C014–C016, C024.\n\n## Example 2 — Custodial settlement with a 20% proposed fee\n\n**Inputs**\n\n- Debt A: $5,000\n- Debt B: $10,000\n- Debt C: $15,000\n- Total enrolled debt: $30,000\n- Proposed fee: 20% of enrolled debt\n- Provider receives consumer settlement funds and pays creditors\n\n**Arithmetic**\n\n$30,000×20%=$6,000\\$30{,}000 \\times 20\\% = \\$6{,}000$30,000×20%=$6,000**Base**\n\nEnrolled debt.\n\n**Operator**\n\nMultiplication by 0.20.\n\n**Intermediate**\n\nProposed commercial fee = $6,000.\n\n**Legal result**\n\nThe arithmetic does not establish a collectible Arkansas fee. Because the provider acts as intermediary and receives money for creditor payment, the model fits § 5-63-301(2)(B) and is prohibited absent an exclusion.\n\n**Units/rounding**\n\nDollars; rounded to nearest cent: $6,000.00.\n\n**Claims**\n\nC005, C014, C024.\n\n## Example 3 — Qualifying nonprofit DMP; actual-expense ceiling\n\n**Assumptions**\n\n- The organization is genuinely nonprofit.\n- The service qualifies as “debt management service.”\n- No other disqualifying fact exists.\n- The stated costs are properly attributable actual expenses.\n\n**Inputs**\n\n- Intake expense: $40\n- Monthly servicing expense: $18\n- Service duration: 6 months\n- Proposed setup charge: $35\n- Proposed monthly charge: $20\n\n**Actual-expense computation**\n\n$40+(6×$18)=$148\\$40 + (6 \\times \\$18)=\\$148$40+(6×$18)=$148**Proposed-charge computation**\n\n$35+(6×$20)=$155\\$35 + (6 \\times \\$20)=\\$155$35+(6×$20)=$155**Difference**\n\n$155−$148=$7\\$155-\\$148=\\$7$155−$148=$7**Result**\n\nUnder the stated assumptions, $148 is the maximum amount supported by the statutory actual-expense formula. The proposed $155 exceeds that amount by $7.\n\n**Boundary**\n\nArkansas does not state how the expenses must be allocated, documented, accrued, or reconciled. The example demonstrates the statutory formula; it does not approve these specific expense categories.\n\n**Units/rounding**\n\nDollars; nearest cent.\n\n**Claims**\n\nC019–C020, C025–C027.\n\n## Example 4 — Lower-debt nonprofit case\n\n**Inputs**\n\n- Consumer debt: $1,000\n- Proposed fee: 5% of debt\n- Actual qualifying expense: $40\n\n**Percentage result**\n\n$1,000×5%=$50\\$1{,}000 \\times 5\\%=\\$50$1,000×5%=$50**Statutory comparison**\n\nmin⁡($50,$40)=$40\\min(\\$50,\\$40)=\\$40min($50,$40)=$40**Result**\n\nThe debt-based percentage does not set the Arkansas limit. Under the assumptions, the actual-expense ceiling would be $40, so $10 of the proposed $50 would exceed it.\n\n**Claims**\n\nC025–C027.\n\n## Example 5 — Cancellation or early termination after prior collection\n\n**Assumptions**\n\n- The nonprofit exclusion applies.\n- Consumer paid $100 before cancellation.\n- Properly attributable actual expenses incurred through cancellation equal $72.\n\n**Computation**\n\n$100−$72=$28\\$100-\\$72=\\$28$100−$72=$28**Result**\n\nAt least $28 cannot be retained within the § 5-63-305(6) actual-expense condition on those assumptions.\n\n**Unresolved point**\n\nThe debt-adjusting subchapter does not state a refund deadline, reconciliation date, credit method, or notice procedure. This example does not import the separate credit-repair statute’s ten-day deadline unless the provider independently meets that statute’s definition.\n\n**Claims**\n\nC019, C025–C028.\n\n## Example 6 — Pure noncustodial settlement model\n\n**Facts**\n\n- Provider negotiates with creditors.\n- Consumer pays each creditor directly.\n- Provider never receives, holds, directs, or controls money for creditors.\n- Provider charges only its own performance fee.\n\n**Classification steps**\n\n1. Branch A: no periodic money is paid to the provider for distribution.\n2. Branch B: provider is an intermediary for consideration, but the express receipt-for-payment/distribution element may be absent.\n3. No controlling Arkansas interpretation was located.\n4. No ordinary license or state fee authorization was located.\n\n**Result**\n\n**Classification and fee chargeability held.** This is not a verified lawful Arkansas scenario.\n\n**Claims**\n\nC006–C007, C024, C030–C031.\n\n## Example 7 — Federal proportional allocation, assuming the TSR applies\n\nThis calculation supplies only the federal allocation result; it does not override Arkansas law.\n\n**Inputs**\n\n- Debt A: $5,000\n- Total enrolled debt: $30,000\n- Total contracted fee: $6,000\n\n**Operator**\n\nDebt A share=$5,000$30,000\\text{Debt A share}=\\frac{\\$5{,}000}{\\$30{,}000}Debt A share=$30,000$5,000​Fee share=$5,000$30,000×$6,000\\text{Fee share}=\\frac{\\$5{,}000}{\\$30{,}000}\\times \\$6{,}000Fee share=$30,000$5,000​×$6,000**Result**\n\n$1,000\\$1{,}000$1,000The $1,000 cannot be requested or received merely because the debt was enrolled. The provider must first achieve a valid agreement for that debt and the customer must make at least one payment under it.\n\n**Units/rounding**\n\nDollars; $1,000.00 to nearest cent.\n\n**Arkansas condition**\n\nIf the underlying model is covered prohibited Arkansas debt adjusting, satisfying the federal trigger still does not authorize the fee.\n\n**Claims**\n\nC024, C033–C035.\n\n## Example 8 — Federal percentage-of-savings calculation\n\n**Inputs**\n\n- Amount owed when enrolled: $4,000\n- Amount actually paid to satisfy: $2,500\n- Uniform savings fee percentage: 25%\n\n**Savings**\n\n$4,000−$2,500=$1,500\\$4{,}000-\\$2{,}500=\\$1{,}500$4,000−$2,500=$1,500**Fee**\n\n$1,500×25%=$375\\$1{,}500\\times25\\%=\\$375$1,500×25%=$375**Result**\n\nFederal calculated fee = $375 after the TSR performance conditions are met.\n\n**Limitations**\n\n- The 25% rate must not change from one individual debt to another under that method.\n- The calculation is not an Arkansas fee authorization.\n- The underlying model’s Arkansas classification must first be resolved.\n\n**Claims**\n\nC024, C033–C035.\n\n## Example 9 — Business-purpose and entity-debt boundary\n\n**Scenario A**\n\nA sole proprietor personally owes $50,000 used for business inventory.\n\n**Result**\n\nThe debtor is an individual; the absence of a household-purpose element means the debt can textually fall within § 5-63-301.\n\n**Scenario B**\n\nAn LLC alone owes $50,000, with no personal guaranty or individual joint liability.\n\n**Result**\n\nThe entity does not fit the literal definition of “debtor” as an individual.\n\n**Scenario C**\n\nThe LLC owes the debt and the owner personally guarantees it.\n\n**Result**\n\nThe individual guarantor can be a debtor with respect to the personal obligation. Exact coverage depends on the contract and service provided.\n\n**Claims**\n\nC011–C012.\n\n## Pass coverage and gap table\n\n| Component | Status in PASS-01 | Claims | What was resolved | Exact missing evidence / next investigation |\n| --- | --- | --- | --- | --- |\n| Statutory debt-adjuster definition | **Answered** | C001–C012 | Two operative branches, consideration, receipt, distribution, debtor/person definitions | Obtain subscription annotations and any unpublished interpretations |\n| Custodial DMP classification | **Answered** | C001–C004, C014 | Covered and prohibited absent exclusion | Later agreement/fund-handling facts may create additional duties |\n| Custodial settlement classification | **Answered** | C005, C014 | Covered and prohibited absent exclusion | None for core classification |\n| Noncustodial settlement | **Unresolved/held** | C006–C007, C030 | Identified literal receipt issue | Citator search; appellate/trial enforcement; AG enforcement files or formal opinions; fact-specific counsel analysis |\n| Independent dedicated account | **Unresolved/held** | C007, C035 | Federal conditions identified; Arkansas conclusion not established | Arkansas authority on possession, agency, constructive receipt, or control |\n| Consumer/business-purpose boundary | **Partial** | C011–C012 | Individual definition and absence of purpose qualifier resolved | Cases involving sole proprietors, guarantors, mixed individual/entity debts |\n| Remote-provider nexus | **Partial** | C013 | General territorial statute identified | Cases applying § 5-1-104 to remote offers/contracts/payment businesses |\n| Core prohibition and criminal status | **Answered** | C014–C016 | Prohibition and Class A misdemeanor verified | Mental-state issues and criminal procedure reserved |\n| Injunction/receivership | **Answered only as needed** | C017 | Enforcement actors and receiver authority verified | Full remedies, standing, procedure, restitution, limitations reserved |\n| Ordinary debt-adjuster licensing | **Answered with source limitation** | C031–C032 | No application or registry located; statute is prohibition/exclusion architecture | Verify through official annotated code and any nonindexed agency materials |\n| Attorney exclusion | **Partial** | C022 | Textual attorney exclusion verified | Firm/entity/affiliate, nominal representation, unauthorized practice, fee ethics |\n| Nonprofit exclusion | **Partial** | C018–C021 | Nonprofit + debt-management service + actual-expense condition verified | Meaning of debt-management service; settlement inclusion; expense allocation; documentation |\n| Banks/fiduciaries/lenders | **Partial** | C023 | Textual exclusion conditions verified | Entity-by-entity charter, authorization, affiliate, and ordinary-course analysis |\n| Association/member exclusion | **Unresolved scope** | C023 | Text located | Definition of association, bona fide membership, commercial program treatment |\n| Self-creditor workout | **Partial** | C010 | Intermediary distinction identified | Servicer, assignee, affiliate, and common-control cases |\n| Arkansas fee schedules | **Answered** | C024–C027 | No commercial schedule; actual-expense formula only | Historic act scans and any nonindexed interpretive materials |\n| Fee indexing/adjustments | **Answered with negative-search limit** | C026 | No index or adjustment notice located | Continue legislative-history and agency archive check |\n| State fee timing | **Partial** | C024–C027 | No timing for prohibited activity; nonprofit statute has no express trigger | Actual-expense accrual, reconciliation, cancellation/refund authority |\n| Federal TSR timing | **Answered as common context** | C033–C037 | Exact performance, allocation, dedicated-account, inbound-ad, attorney rules | Provider-specific TSR applicability remains factual |\n| Credit-repair overlap | **Partial, boundary only** | C028 | Definition, five-day cancellation, ten-day return, bond/trust advance-fee condition | Full credit-repair contract, enforcement, exemptions, federal CROA interaction |\n| Public regulator instructions | **Answered** | C031–C032 | No debt-adjuster application; other category routes distinguished | Confirm with any future official debt-adjuster-specific page or enactment |\n| Named-provider authorization | **Excluded/not requested** | — | No provider claim made | Search exact entity, DBAs, owners, licenses, charitable status, and counsel only when supplied |\n| Current operative regulations | **Partial/high-confidence negative search** | C026, C030–C031 | Official rules database searched; no responsive rule found | Recent rulemaking dockets, emergency rules, agency-specific archives |\n| Controlling cases/formal opinions | **Unresolved evidence gap** | C030 | No responsive public authority located | Westlaw/Lexis/Bloomberg citator; Arkansas judiciary dockets; AG opinion archive variants |\n| Historic Acts 61/1967 and 189/1983 | **Unresolved source gap** | C038 | History citations identified | Obtain scans from listed repositories or licensed legislative-history database |\n| Agreements and disclosures | **Later pass** | — | Discussed only for credit-repair boundary | Full state agreement/e-sign/language/prohibited-term investigation |\n| Client funds/trust/escrow duties | **Later pass** | — | Only definition and federal dedicated-account boundary addressed | Full Arkansas trust, money-transmission, fiduciary, banking analysis |\n| Bonds | **Later pass** | — | $10,000 credit-repair overlap noted only | Full bond requirements by model and exemption |\n| Civil remedies, collection, litigation, limitations | **Later pass** | — | § 303 referenced only as necessary | Full remedies, private rights, UDAP, limitations, criminal enforcement |\n| Secured debt, mortgages, tax debt, student debt, medical debt, utilities | **Later pass** | — | Not resolved | Sector-by-sector statutory and regulator analysis |\n| Local, tribal, contract, constitutional, and preemption issues | **Later pass** | — | Not resolved | Separate focused investigations |\n| Full exemption architecture beyond current fee/access needs | **Later pass** | — | Only § 305 exclusions addressed | Entity/activity-specific exemption validation |\n\n# E. Researcher self-check\n\n## Actually read or directly inspected\n\n- The displayed 2025 text of Arkansas Code §§ 5-63-301, 5-63-302, 5-63-303, and 5-63-305.\n- Official Act 1263 of 2015, including the page amending § 5-63-302 and repealing § 5-63-304.\n- The displayed 2025 text of Arkansas’s territorial-applicability statute, § 5-1-104.\n- Official Act 736 of 2023’s amendment to § 5-1-104(a)(6).\n- The official Arkansas legislative homepage and 2026 session status.\n- The official Code of Arkansas Rules database description and targeted public search results.\n- The Arkansas Attorney General debt-relief consumer page.\n- Arkansas Securities Department and its NMLS money-services page.\n- Arkansas Code § 4-91-202 for the limited credit-repair overlap.\n- Current eCFR text for 16 C.F.R. §§ 310.2, 310.4, and 310.6, displayed current through October 22, 2026.\n- FTC debt-relief TSR guide and staff Q&A.\n- Targeted public searches for Arkansas cases and Attorney General opinions.\n\n## Not read or not fully obtained\n\n- A current official Arkansas Code rendering from the state code portal; that route returned an access barrier. The core text was therefore checked through the 2025 secondary codification, the official 2015 enactment, official session materials, and targeted amendment searches.\n- Original scans of Acts 61 of 1967 and 189 of 1983. The official historic-legislation page states that electronic copies are unavailable through that site/BLR.\n- Subscription annotations, citator treatment, unpublished trial-court orders, sealed matters, or complete enforcement-file databases.\n- Full direct content of the Arkansas collection-agency pages; discovered routes returned access errors during direct opening.\n- Any private provider records, application file, privileged legal analysis, borrower record, or authenticated regulator account.\n- Any provider-specific corporate, charitable, attorney, collection, money-services, or other status, because no named provider was submitted.\n- The later-required agreement, funds, bonds, remedies, litigation, limitations, secured-debt, sector, local, tribal, contract, and comprehensive case-law passes.\n\n## Currentness qualification\n\nThe core prohibition and exclusion text has **high currentness confidence**, supported by the 2025 codification, official enactment, official 2026 session context, and targeted official searches. It is not represented as absolute official-code verification because the state’s current-code portal was inaccessible and the amendment-index interface did not yield a clean machine-readable confirmation for every section.\n\nNo future-effective, proposed, stayed, vacated, withdrawn, or expired Arkansas debt-adjusting amendment was located in this pass. That is a bounded public-search result, not a guarantee that no unindexed or very recent material exists.\n\nThis report is the completed Arkansas **provider-market-access and consumer-fees component** with stated holds. It is not the full Arkansas dossier, not a provider authorization, not a qualified legal opinion, not an independent review, and not a claim of local saving or publication readiness.\n\n**END S_AR PASS-01.**\n\n","tables":[{"headers":["Model or conduct","Arkansas classification for this pass","Conditions and boundary","Claim IDs"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or conduct","Arkansas classification for this pass","Conditions and boundary","Claim IDs"],["Custodial DMP; consumer pays provider and provider distributes among creditors","Covered and prohibited unless a § 5-63-305 exclusion applies","Branch A expressly covers periodic payments and distribution for consideration. Principal reduction is unnecessary.","C001–C004, C016"],["Settlement/negotiation provider receives settlement funds and pays creditors","Covered and prohibited unless excluded","Branch B covers intermediation to alter debt-payment terms plus receipt of money/property for creditor payment or distribution.","C005, C016"],["Provider negotiates concessions, but principal is not reduced","Still potentially covered","Branch A needs only payment distribution; Branch B includes altering “terms of payment,” not merely reducing principal.","C003–C005"],["Provider negotiates; consumer pays creditor directly; provider never receives or controls creditor funds","Unresolved textual-boundary model","Branch B’s receipt element may be absent; Branch A ordinarily would not fit if consumer money is never delivered for distribution. No Arkansas controlling interpretation was located.","C006–C007, C030"],["Consumer places money in independently administered dedicated account","Fact-dependent and unresolved under Arkansas law","Federal ownership/independence requirements do not answer whether the provider “receives” or constructively controls money under Arkansas law. Actual withdrawal authority, fee sweeps, creditor-payment instructions, account affiliation, and control matter.","C007, C026"],["Budget education or counseling with no consideration, no creditor intermediation, and no consumer-fund receipt","Likely outside the two definitions","Both branches require consideration; Branch B also requires intermediation and receipt. Indirect creditor payments, affiliate compensation, “voluntary contributions,” or lead payments may change the analysis.","C009"],["Creditor negotiates its own debt directly","Likely outside Branch B’s “intermediary” formulation","A creditor acting for itself is ordinarily not between itself and the debtor. Servicers, affiliates, assignees, and common-control entities require separate facts.","C010"],["Qualifying nonprofit DMP, free or fee no greater than actual expenses","Conditionally excluded—not licensed","Must actually be nonprofit, provide “debt management service,” and satisfy the fee condition.","C018–C021"],["Nonprofit principal-reduction settlement program","Unresolved","“Debt management service” is not defined in the reviewed subchapter; no controlling Arkansas interpretation was located extending § 305(6) to principal-reduction settlement.","C021"],["Attorney personally performing debt-adjusting work","Textual exclusion for an “attorney at law”","Does not establish that a nonlawyer company, lead generator, account administrator, affiliate, or nominal attorney arrangement is excluded.","C022"],["Bank or other listed institution","Conditionally excluded","Entity must meet the stated authorization/admission condition and perform adjusting in the regular course of its principal business.","C023"],["Association serving members","Textual exclusion, scope unresolved","“Association” and “for its members” are not defined here; no public registration pathway or interpretive authority was located.","C023"],["Individual’s business-purpose debt, including sole-proprietor debt","Textually may be covered","“Debtor” means an individual; the debt-adjusting definition has no personal/family/household-purpose qualifier.","C011"],["Debt owed solely by an LLC or corporation, without an individual obligor","Likely outside the literal debtor definition","The statutory “debtor” is an individual. An individual guaranty, joint liability, or personal obligation can change the result.","C011–C012"]]},{"headers":["Excluded category","Exact operative condition","Important limitation"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Excluded category","Exact operative condition","Important limitation"],["Attorney at law","Person is an attorney at law","The text does not say that every entity using, retaining, or referring to an attorney is excluded."],["Bank, fiduciary, or financing/lending institution","Authorized and admitted to transact business in Arkansas and performs credit/financial adjusting in the regular course of its principal business","Both entity status and ordinary-course activity must be satisfied."],["Title insurer or abstract company","While doing an escrow business","Activity-specific, not a blanket exemption."],["Employer","For its employees","Does not cover services marketed to the general public."],["Judicial officer or another person","Acting pursuant to court order","Requires an actual court-order basis."],["Nonprofit organization","Gives debt-management service without charge, or charges no more than actual expenses incurred in offering the service","Nonprofit status alone is insufficient; fee and service conditions must be satisfied."],["Association","For its members","Scope of “association” and member-service boundaries were not resolved in reviewed authority."]]},{"headers":["Structure","Verified Arkansas fee rule","Dollar/percentage/index status","Result"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Structure","Verified Arkansas fee rule","Dollar/percentage/index status","Result"],["Covered for-profit custodial DMP","No lawful commercial fee pathway established because the activity itself is prohibited","No setup, monthly, percentage, aggregate, or indexed ceiling authorizing the activity","Prohibited activity, not a “$0 fee cap”"],["Covered for-profit custodial settlement","Same","No settlement, per-debt, enrolled-debt, savings, or performance-fee authorization","Prohibited activity"],["Qualifying nonprofit debt-management service","Free, or fee no greater than actual expenses incurred in offering the service","No fixed dollar amount; no percentage; no CPI/index; no published adjustment notice found","Conditional exclusion"],["Nonprofit principal-reduction settlement","Unresolved whether it is “debt management service” within § 305(6)","No amount should be treated as verified","Hold"],["Attorney/institutional/association exclusion","The debt-adjusting subchapter supplies no special fee ceiling","Separate ethics, banking, consumer-protection, contract, or other law may govern","Not evaluated as unrestricted"],["Pure noncustodial settlement","Underlying debt-adjuster classification unresolved","No fee permission established merely because custody is absent","Hold"],["Free counseling/no consideration","Likely outside definition if genuinely free and no indirect consideration","No fee by hypothesis","Conditional noncoverage"]]},{"headers":["Public route","What was actually found","What it does not establish"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Public route","What was actually found","What it does not establish"],["Arkansas debt-adjusting statutes","Prohibition, enforcement, and exclusions","No license application or ordinary commercial authorization"],["Arkansas Securities Department","Securities, mortgage, and money-services categories","No debt-adjuster license"],["NMLS Consumer Access","Mortgage companies/personnel and money transmitter/currency exchanger records","No debt-adjuster status"],["Arkansas collection-agency pages","Discovery results indicate a separate collection-agency licensing system; direct pages returned access errors during this check","A collection license is not debtor-side debt-adjusting authorization"],["Code of Arkansas Rules","Official searchable rule database; targeted searches produced unrelated “debt” or “settlement” results, not a responsive debt-adjuster rule","Negative search is not proof that no obscure or uncodified rule exists"],["Attorney General consumer page","Consumer warnings and descriptions","No permission, application, fee table, or named-provider authorization"],["Attorney General opinion search","No responsive formal opinion located with targeted terms","Not proof that no opinion exists"],["Public Arkansas case searches","No responsive controlling debt-adjuster interpretation located; false positives concerned creditor collection or insurance adjusters","Not a complete citator or unpublished-case search"]]},{"headers":["Source ID","Title / issuer","Direct literal URL","Exact pinpoint and version/status","Actual read/check and limitations"],"index":4,"links":[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/","text":"Justia Law"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/","text":"Justia 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Law"},{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F&utm_source=chatgpt.com","text":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F"},{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F","text":"Arkansas Legislature"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/","text":"Justia 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Legislature"},{"href":"https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/?utm_source=chatgpt.com","text":"https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/"},{"href":"https://codeofarrules.arkansas.gov/?utm_source=chatgpt.com","text":"https://codeofarrules.arkansas.gov/"},{"href":"https://codeofarrules.arkansas.gov/","text":"Code of Arkansas Rules"},{"href":"https://codeofarrules.arkansas.gov/Rules/Search?utm_source=chatgpt.com","text":"https://codeofarrules.arkansas.gov/Rules/Search"},{"href":"https://codeofarrules.arkansas.gov/Rules/Rule?chapterID=257&levelType=section&partID=1253&sectionID=49049&subChapterID=322&subPartID=7539&titleID=9","text":"Code of Arkansas Rules\n+1"},{"href":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation?utm_source=chatgpt.com","text":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation"},{"href":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation","text":"Arkansas Legislature"},{"href":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/?utm_source=chatgpt.com","text":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/"},{"href":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/","text":"Arkansas Attorney General"},{"href":"https://securities.arkansas.gov/?utm_source=chatgpt.com","text":"https://securities.arkansas.gov/"},{"href":"https://securities.arkansas.gov/","text":"Arkansas Securities Department"},{"href":"https://securities.arkansas.gov/money-services-2/7678-2/?utm_source=chatgpt.com","text":"https://securities.arkansas.gov/money-services-2/7678-2/"},{"href":"https://securities.arkansas.gov/money-services-2/7678-2/","text":"Arkansas Securities Department"},{"href":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/?utm_source=chatgpt.com","text":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/"},{"href":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/?utm_source=chatgpt.com","text":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/"},{"href":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/"},{"href":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/","text":"Justia Law\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+1"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission"},{"href":"https://prod.opinions-search.arkansasag.gov/?utm_source=chatgpt.com","text":"https://prod.opinions-search.arkansasag.gov/"},{"href":"https://law.justia.com/cases/arkansas/","text":"https://law.justia.com/cases/arkansas/"},{"href":"https://law.justia.com/cases/arkansas/supreme-court/2022/cv-22-43.html","text":"Justia Law\n+1"},{"href":"https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F&utm_source=chatgpt.com","text":"https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F"}],"row_links":[[],[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/","text":"Justia Law"}],[{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F&utm_source=chatgpt.com","text":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F"},{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F","text":"Arkansas Legislature"}],[{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/"},{"href":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/","text":"Justia Law"}],[{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F&utm_source=chatgpt.com","text":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F"},{"href":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F","text":"Arkansas Legislature"}],[{"href":"https://www.arkleg.state.ar.us/?utm_source=chatgpt.com","text":"https://www.arkleg.state.ar.us/"},{"href":"https://www.arkleg.state.ar.us/","text":"Arkansas Legislature"}],[{"href":"https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/?utm_source=chatgpt.com","text":"https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/"}],[{"href":"https://codeofarrules.arkansas.gov/?utm_source=chatgpt.com","text":"https://codeofarrules.arkansas.gov/"},{"href":"https://codeofarrules.arkansas.gov/","text":"Code of Arkansas Rules"}],[{"href":"https://codeofarrules.arkansas.gov/Rules/Search?utm_source=chatgpt.com","text":"https://codeofarrules.arkansas.gov/Rules/Search"},{"href":"https://codeofarrules.arkansas.gov/Rules/Rule?chapterID=257&levelType=section&partID=1253&sectionID=49049&subChapterID=322&subPartID=7539&titleID=9","text":"Code of Arkansas Rules\n+1"}],[{"href":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation?utm_source=chatgpt.com","text":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation"},{"href":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation","text":"Arkansas Legislature"}],[{"href":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/?utm_source=chatgpt.com","text":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/"},{"href":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/","text":"Arkansas Attorney General"}],[{"href":"https://securities.arkansas.gov/?utm_source=chatgpt.com","text":"https://securities.arkansas.gov/"},{"href":"https://securities.arkansas.gov/","text":"Arkansas Securities Department"}],[{"href":"https://securities.arkansas.gov/money-services-2/7678-2/?utm_source=chatgpt.com","text":"https://securities.arkansas.gov/money-services-2/7678-2/"},{"href":"https://securities.arkansas.gov/money-services-2/7678-2/","text":"Arkansas Securities Department"}],[{"href":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/?utm_source=chatgpt.com","text":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/"},{"href":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/?utm_source=chatgpt.com","text":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/"}],[{"href":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/"},{"href":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/","text":"Justia Law\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+1"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission"}],[{"href":"https://prod.opinions-search.arkansasag.gov/?utm_source=chatgpt.com","text":"https://prod.opinions-search.arkansasag.gov/"}],[{"href":"https://law.justia.com/cases/arkansas/","text":"https://law.justia.com/cases/arkansas/"},{"href":"https://law.justia.com/cases/arkansas/supreme-court/2022/cv-22-43.html","text":"Justia Law\n+1"}],[{"href":"https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F&utm_source=chatgpt.com","text":"https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F"}]],"rows":[["Source ID","Title / issuer","Direct literal URL","Exact pinpoint and version/status","Actual read/check and limitations"],["S_AR-P1-S001","Arkansas Code § 5-63-301, Definitions; 2025 codification hosted by Justia","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/","§ 5-63-301(1)–(4); displayed 2025 version","Freshly read full operative text. Secondary codification with express disclaimer; official current-code portal was inaccessible. \nJustia Law"],["S_AR-P1-S002","Arkansas Code § 5-63-302, Debt adjusting—Prohibition","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/","§ 5-63-302(a)–(b); history includes 2015 Act 1263 § 17","Freshly read. Current displayed prohibition and Class A misdemeanor; corroborated by official Act 1263. \nJustia Law"],["S_AR-P1-S003","Arkansas Code § 5-63-303, Injunction and receivership","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/","§ 5-63-303(a)–(b)","Freshly read. Secondary codification; establishes AG/prosecutor action and receiver authority. \nJustia Law"],["S_AR-P1-S004","Arkansas Code § 5-63-305, Exclusions","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/","§ 5-63-305(1)–(7); history: Acts 1967 No. 61 and 1983 No. 189","Freshly read. Source for all listed exclusions and nonprofit actual-expense condition. \nJustia Law"],["S_AR-P1-S005","Act 1263 of 2015; Arkansas General Assembly","https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F","PDF p. 21, §§ 17–18","Freshly read and visually inspected. § 17 amends § 5-63-302 and inserts Class A misdemeanor; § 18 repeals former § 304. Primary official enactment. \nArkansas Legislature"],["S_AR-P1-S006","Arkansas Code § 5-1-104, Territorial applicability","https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/","§ 5-1-104(a)(1)–(6); displayed 2025 version","Freshly read. Relevant to remote/out-of-state activity; no debt-adjuster-specific application located. \nJustia Law"],["S_AR-P1-S007","Act 736 of 2023; Arkansas General Assembly","https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F","PDF p. 1, § 1","Freshly read and visually inspected. Amends § 5-1-104(a)(6); does not decide the debt-adjusting remote-nexus scenarios. \nArkansas Legislature"],["S_AR-P1-S008","Arkansas State Legislature homepage/current session","https://www.arkleg.state.ar.us/","Fiscal Session of 95th General Assembly adjourned April 29, 2026; official-site statement","Freshly read for current-session context only. Does not itself prove no amendments. \nArkansas Legislature"],["S_AR-P1-S009","Official Arkansas Code search portal","https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/","Current-code portal","Attempted; route returned a 403/interactive-access barrier. No CAPTCHA workaround or permission change attempted. Exact official current code therefore was not retrieved from this route."],["S_AR-P1-S010","Code of Arkansas Rules; State of Arkansas","https://codeofarrules.arkansas.gov/","Official-version statement; effective Jan. 1, 2025; last updated Oct. 19, 2026","Freshly read. Database warns it may not reflect recent rulemaking. \nCode of Arkansas Rules"],["S_AR-P1-S011","Code of Arkansas Rules search","https://codeofarrules.arkansas.gov/Rules/Search","Exact/keyword searches for debt adjusting, debt adjuster, debt settlement, DMP-related terms","Fresh searches produced unrelated debt/check, gaming, tax, and other provisions. No responsive debt-adjuster rule found; negative result is limited by indexing and search behavior. \nCode of Arkansas Rules\n+1"],["S_AR-P1-S012","Uncodified Historic Legislation; Arkansas General Assembly","https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation","Historic-source availability statement","Freshly read. Official page states electronic copies of historic acts are unavailable from the site/BLR and identifies libraries from which copies may be obtained. No contact was made. \nArkansas Legislature"],["S_AR-P1-S013","Debt Relief Services/Fair Debt Collection; Arkansas Attorney General","https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/","Consumer warnings and descriptions of counseling, DMP, and settlement","Freshly read. Undated operational/consumer guidance; not a statute, regulation, fee schedule, application, or formal opinion. \nArkansas Attorney General"],["S_AR-P1-S014","Arkansas Securities Department homepage","https://securities.arkansas.gov/","Public categories: securities, mortgages, money services","Freshly read. No debt-adjuster license category identified. \nArkansas Securities Department"],["S_AR-P1-S015","NMLS—Arkansas Securities Department","https://securities.arkansas.gov/money-services-2/7678-2/","Money transmitter/currency exchanger application and public-search description; list dated Sept. 1, 2026","Freshly read. Category-specific; not debt-adjuster authorization. \nArkansas Securities Department"],["S_AR-P1-S016","Arkansas State Board of Collection Agencies route set","https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/ and https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/","Public collection-agency licensing/lookup discovery routes","Search results were discovered, but direct pages returned access errors during this check. Collection licensing was not treated as debt-adjusting permission."],["S_AR-P1-S017","Arkansas Code § 4-91-202, Credit Repair Services Organizations Act","https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/","§ 4-91-202(a), (c)–(h); displayed 2025 version","Freshly read for overlap only. Five-day cancellation, ten-day payment return, advance-fee condition, $10,000 bond, and in-state insured trust requirements. Not a debt-adjusting authorization. \nJustia Law\n+2"],["S_AR-P1-S018","16 C.F.R. § 310.2; eCFR","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","§ 310.2(o), debt-relief-service definition; eCFR displayed current through Oct. 22, 2026","Freshly read. Authoritative but unofficial eCFR. Federal common context only. \neCFR\n+1"],["S_AR-P1-S019","16 C.F.R. § 310.4; eCFR","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§ 310.4(a)(5)(i)–(ii)","Freshly read. Exact performance triggers, proportional/savings allocation, and dedicated-account conditions. \neCFR\n+1"],["S_AR-P1-S020","16 C.F.R. § 310.6; eCFR","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","§ 310.6(b)(5)(i)","Freshly read. Debt-relief advertisements are carved out of the general inbound-ad-call exemption. \neCFR"],["S_AR-P1-S021","Debt Relief Services and the TSR: Guide for Business; FTC","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Coverage, fee collection, substantial assistance, attorney discussion","Freshly read. Staff compliance guidance, not itself the regulation; accurately distinguished from binding text. \nFederal Trade Commission\n+1"],["S_AR-P1-S022","Debt Relief Services and the TSR: What People Are Asking; FTC","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","FTC staff Q&A","Freshly read for context. Staff answers; not treated as Arkansas authority. \nFederal Trade Commission"],["S_AR-P1-S023","Arkansas Attorney General opinions search","https://prod.opinions-search.arkansasag.gov/","Searches for § 5-63-301, § 5-63-302, debt adjuster, debt adjusting, and debt settlement","Checked; no responsive formal opinion located. This is a limited negative search, not proof of nonexistence."],["S_AR-P1-S024","Arkansas public case-search route set","https://law.justia.com/cases/arkansas/","Exact statutory citations and distinctive definition phrases","Checked. Located false positives involving creditor collection and insurance adjusters, but no controlling interpretation of this subchapter. No subscription citator or unpublished-trial-record search was performed. \nJustia Law\n+1"],["S_AR-P1-S025","Code Sections Amended, 2026 Fiscal Session; Arkansas General Assembly","https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F","Official session amendment-index route","Checked; page presentation was JavaScript-limited and did not provide a clean, independently searchable confirmation for every target section. Targeted official act searches found no responsive later debt-adjusting amendment, but absolute currentness remains qualified."]]},{"headers":["Claim ID","Precise assertion","Source IDs and pinpoint","Conditions, exceptions, currentness, and confidence"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source IDs and pinpoint","Conditions, exceptions, currentness, and confidence"],["S_AR-P1-C001","Branch A covers a contract under which a debtor periodically pays a provider that, for consideration, distributes the money among specified creditors under an agreed plan.","S001, § 5-63-301(2)(A)","High confidence. Direct statutory text."],["C002","A classic custodial DMP is within Branch A even without principal reduction.","S001, § 301(2)(A)","High confidence textual application. Distribution, not principal reduction, is the operative element."],["C003","Creditor concessions such as reduced interest or waived fees do not remove a DMP from Branch A.","S001, § 301(2)(A)","High confidence textual application."],["C004","A provider need not successfully complete distribution before risk attaches because “debt adjuster” includes attempts and offers.","S001, § 301(1); S002, § 302(a)","High confidence."],["C005","Branch B covers consideration-based intermediation to settle, compound, or alter payment terms when the provider receives debtor money/property for creditor payment or distribution.","S001, § 301(2)(B)","High confidence."],["C006","Pure noncustodial negotiation may lack Branch B’s receipt element.","S001, § 301(2)(B)","Moderate textual inference; unresolved. Not a safe harbor or launch approval."],["C007","A consumer-owned dedicated account does not automatically resolve Arkansas coverage.","S001, § 301(2)(B); S019, § 310.4(a)(5)(ii)","Moderate. Actual possession, control, agency, affiliation, and payment mechanics matter; no Arkansas interpretation located."],["C008","Marketing labels do not control classification; underlying conduct and fund flow do.","S001, § 301(1)–(2)","High confidence."],["C009","Truly free counseling with no consideration, creditor intermediation, or consumer-fund receipt likely falls outside both branches.","S001, § 301(2)(A)–(B)","Moderate. Indirect consideration or creditor-funded compensation may alter the analysis."],["C010","A creditor settling its own debt is likely not an “intermediary,” but affiliate and servicer structures remain unresolved.","S001, § 301(2)(B)","Moderate textual inference."],["C011","“Debtor” means an individual, with no personal/family/household-purpose qualifier in this subchapter.","S001, § 301(3)","High confidence."],["C012","Entity-only debt likely falls outside the literal debtor definition, while an individual guarantor or obligor may bring the matter within it.","S001, § 301(3)","Moderate textual application; no controlling case located."],["C013","Out-of-state location is not a categorical safe harbor when conduct or an offense element occurs in Arkansas or outside conduct is an attempt to commit the offense there.","S002, § 302(a); S006, § 5-1-104(a)(1)–(2)","High for general rule; moderate for application to specific online/remote facts."],["C014","Covered debt adjusting in Arkansas is prohibited.","S002, § 302(a); S005, § 17","High confidence."],["C015","Violation is a Class A misdemeanor.","S002, § 302(b); S005, § 17","High confidence."],["C016","The statute prohibits engaging, offering, and attempting; it is not merely a fund-custody licensing provision.","S001, § 301(1); S002, § 302(a)","High confidence."],["C017","The Attorney General or prosecutor may seek an injunction, and a circuit court may appoint a receiver to facilitate return of unremitted debtor property.","S003, § 303(a)–(b)","High confidence."],["C018","Section 305 lists conditional categories not considered debt adjusters.","S004, § 305(1)–(7)","High confidence."],["C019","A qualifying nonprofit may provide debt-management service free or charge no more than actual expenses incurred.","S004, § 305(6)","High confidence as to text."],["C020","Nonprofit status alone does not satisfy § 305(6).","S004, § 305(6)","High confidence. Service and fee conditions remain."],["C021","Whether nonprofit principal-reduction settlement is “debt management service” is unresolved.","S004, § 305(6); S023–S024 negative searches","Held. No controlling interpretation located."],["C022","The attorney exclusion does not establish blanket exclusion for nonlawyer entities or nominal attorney arrangements.","S004, § 305(1); S023–S024","High as to text; affiliate/entity application held."],["C023","Institutional and association exclusions are conditional and should not be expanded beyond their terms.","S004, § 305(2)–(7)","High as to stated conditions; unresolved peripheral scope."],["C024","No lawful fee pathway was established for covered for-profit debt adjusting.","S002, § 302; S004, § 305","High. This is prohibition, not a zero-dollar cap."],["C025","The nonprofit fee ceiling is an expense formula, not a fixed amount or percentage.","S004, § 305(6)","High."],["C026","No Arkansas debt-adjusting setup, monthly, per-debt, settlement, savings, aggregate, or indexed ceiling was located.","S004; S010–S011","High for reviewed sources; qualified negative-search conclusion."],["C027","Arkansas’s debt-adjusting subchapter does not specify nonprofit prepayment, reconciliation, cancellation, refund, or expense-allocation procedures.","S004, § 305(6)","High as to statutory omission; other-law consequences remain open."],["C028","Credit-repair coverage can create separate contract, cancellation, bond, trust, and advance-fee duties but cannot authorize prohibited debt adjusting.","S017, § 4-91-202(a), (d)–(h); S002","High as to separate statutes; full overlap analysis reserved."],["C029","The Arkansas AG consumer page is guidance, not a fee ceiling or licensing decision.","S013","High."],["C030","No controlling reported Arkansas appellate decision or responsive formal AG opinion resolving the identified receipt, nonprofit, attorney, expense, or remote-nexus questions was located.","S023–S024","Limited negative-search conclusion, not proof of nonexistence."],["C031","No ordinary debt-adjuster application, registration, or public provider registry was located.","S001–S004; S010–S016","High but not absolute. Official code portal and some collection pages were inaccessible."],["C032","A money-transmitter, currency-exchanger, mortgage, or collection-agency license is not itself debt-adjusting authorization.","S002; S014–S016","High legal-architecture conclusion. Separate overlays may still apply."],["C033","Where the federal TSR applies, fees require a valid debt result, customer agreement, and at least one customer payment.","S019, § 310.4(a)(5)(i)(A)–(B)","High. Federal rule; applicability is fact-specific."],["C034","Individually resolved debts require proportional or uniform percentage-of-savings allocation under the TSR.","S019, § 310.4(a)(5)(i)(C)","High."],["C035","Federal dedicated-account compliance does not constitute Arkansas market permission.","S019, § 310.4(a)(5)(ii); S002","High. Independent cumulative legal systems."],["C036","Inbound calls responding to debt-relief advertising are not covered by the general inbound-ad-call exemption.","S020, § 310.6(b)(5)(i)","High."],["C037","The TSR has no general attorney exemption for covered interstate telemarketing.","S021, attorney section","High as FTC guidance; exact application remains fact-specific."],["C038","Currentness is high but not absolute because the official current-code portal was inaccessible and historic Acts 61/1967 and 189/1983 were not available electronically.","S005, S008–S012, S025","Explicit source limitation."]]},{"headers":["Component","Status in PASS-01","Claims","What was resolved","Exact missing evidence / next investigation"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status in PASS-01","Claims","What was resolved","Exact missing evidence / next investigation"],["Statutory debt-adjuster definition","Answered","C001–C012","Two operative branches, consideration, receipt, distribution, debtor/person definitions","Obtain subscription annotations and any unpublished interpretations"],["Custodial DMP classification","Answered","C001–C004, C014","Covered and prohibited absent exclusion","Later agreement/fund-handling facts may create additional duties"],["Custodial settlement classification","Answered","C005, C014","Covered and prohibited absent exclusion","None for core classification"],["Noncustodial settlement","Unresolved/held","C006–C007, C030","Identified literal receipt issue","Citator search; appellate/trial enforcement; AG enforcement files or formal opinions; fact-specific counsel analysis"],["Independent dedicated account","Unresolved/held","C007, C035","Federal conditions identified; Arkansas conclusion not established","Arkansas authority on possession, agency, constructive receipt, or control"],["Consumer/business-purpose boundary","Partial","C011–C012","Individual definition and absence of purpose qualifier resolved","Cases involving sole proprietors, guarantors, mixed individual/entity debts"],["Remote-provider nexus","Partial","C013","General territorial statute identified","Cases applying § 5-1-104 to remote offers/contracts/payment businesses"],["Core prohibition and criminal status","Answered","C014–C016","Prohibition and Class A misdemeanor verified","Mental-state issues and criminal procedure reserved"],["Injunction/receivership","Answered only as needed","C017","Enforcement actors and receiver authority verified","Full remedies, standing, procedure, restitution, limitations reserved"],["Ordinary debt-adjuster licensing","Answered with source limitation","C031–C032","No application or registry located; statute is prohibition/exclusion architecture","Verify through official annotated code and any nonindexed agency materials"],["Attorney exclusion","Partial","C022","Textual attorney exclusion verified","Firm/entity/affiliate, nominal representation, unauthorized practice, fee ethics"],["Nonprofit exclusion","Partial","C018–C021","Nonprofit + debt-management service + actual-expense condition verified","Meaning of debt-management service; settlement inclusion; expense allocation; documentation"],["Banks/fiduciaries/lenders","Partial","C023","Textual exclusion conditions verified","Entity-by-entity charter, authorization, affiliate, and ordinary-course analysis"],["Association/member exclusion","Unresolved scope","C023","Text located","Definition of association, bona fide membership, commercial program treatment"],["Self-creditor workout","Partial","C010","Intermediary distinction identified","Servicer, assignee, affiliate, and common-control cases"],["Arkansas fee schedules","Answered","C024–C027","No commercial schedule; actual-expense formula only","Historic act scans and any nonindexed interpretive materials"],["Fee indexing/adjustments","Answered with negative-search limit","C026","No index or adjustment notice located","Continue legislative-history and agency archive check"],["State fee timing","Partial","C024–C027","No timing for prohibited activity; nonprofit statute has no express trigger","Actual-expense accrual, reconciliation, cancellation/refund authority"],["Federal TSR timing","Answered as common context","C033–C037","Exact performance, allocation, dedicated-account, inbound-ad, attorney rules","Provider-specific TSR applicability remains factual"],["Credit-repair overlap","Partial, boundary only","C028","Definition, five-day cancellation, ten-day return, bond/trust advance-fee condition","Full credit-repair contract, enforcement, exemptions, federal CROA interaction"],["Public regulator instructions","Answered","C031–C032","No debt-adjuster application; other category routes distinguished","Confirm with any future official debt-adjuster-specific page or enactment"],["Named-provider authorization","Excluded/not requested","—","No provider claim made","Search exact entity, DBAs, owners, licenses, charitable status, and counsel only when supplied"],["Current operative regulations","Partial/high-confidence negative search","C026, C030–C031","Official rules database searched; no responsive rule found","Recent rulemaking dockets, emergency rules, agency-specific archives"],["Controlling cases/formal opinions","Unresolved evidence gap","C030","No responsive public authority located","Westlaw/Lexis/Bloomberg citator; Arkansas judiciary dockets; AG opinion archive variants"],["Historic Acts 61/1967 and 189/1983","Unresolved source gap","C038","History citations identified","Obtain scans from listed repositories or licensed legislative-history database"],["Agreements and disclosures","Later pass","—","Discussed only for credit-repair boundary","Full state agreement/e-sign/language/prohibited-term investigation"],["Client funds/trust/escrow duties","Later pass","—","Only definition and federal dedicated-account boundary addressed","Full Arkansas trust, money-transmission, fiduciary, banking analysis"],["Bonds","Later pass","—","$10,000 credit-repair overlap noted only","Full bond requirements by model and exemption"],["Civil remedies, collection, litigation, limitations","Later pass","—","§ 303 referenced only as necessary","Full remedies, private rights, UDAP, limitations, criminal enforcement"],["Secured debt, mortgages, tax debt, student debt, medical debt, utilities","Later pass","—","Not resolved","Sector-by-sector statutory and regulator analysis"],["Local, tribal, contract, constitutional, and preemption issues","Later pass","—","Not resolved","Separate focused investigations"],["Full exemption architecture beyond current fee/access needs","Later pass","—","Only § 305 exclusions addressed","Entity/activity-specific exemption validation"]]}],"claims":[{"claim_id":"S_AR-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_AR-P1-C001","Precise assertion":"Branch A covers a contract under which a debtor periodically pays a provider that, for consideration, distributes the money among specified creditors under an agreed plan.","Source IDs and pinpoint":"S001, § 5-63-301(2)(A)","Conditions, exceptions, currentness, and confidence":"High confidence. Direct statutory text."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"A classic custodial DMP is within Branch A even without principal reduction.","Source IDs and pinpoint":"S001, § 301(2)(A)","Conditions, exceptions, currentness, and confidence":"High confidence textual application. Distribution, not principal reduction, is the operative element."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"Creditor concessions such as reduced interest or waived fees do not remove a DMP from Branch A.","Source IDs and pinpoint":"S001, § 301(2)(A)","Conditions, exceptions, currentness, and confidence":"High confidence textual application."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"A provider need not successfully complete distribution before risk attaches because “debt adjuster” includes attempts and offers.","Source IDs and pinpoint":"S001, § 301(1); S002, § 302(a)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"Branch B covers consideration-based intermediation to settle, compound, or alter payment terms when the provider receives debtor money/property for creditor payment or distribution.","Source IDs and pinpoint":"S001, § 301(2)(B)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Pure noncustodial negotiation may lack Branch B’s receipt element.","Source IDs and pinpoint":"S001, § 301(2)(B)","Conditions, exceptions, currentness, and confidence":"Moderate textual inference; unresolved. Not a safe harbor or launch approval."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"A consumer-owned dedicated account does not automatically resolve Arkansas coverage.","Source IDs and pinpoint":"S001, § 301(2)(B); S019, § 310.4(a)(5)(ii)","Conditions, exceptions, currentness, and confidence":"Moderate. Actual possession, control, agency, affiliation, and payment mechanics matter; no Arkansas interpretation located."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"Marketing labels do not control classification; underlying conduct and fund flow do.","Source IDs and pinpoint":"S001, § 301(1)–(2)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"Truly free counseling with no consideration, creditor intermediation, or consumer-fund receipt likely falls outside both branches.","Source IDs and pinpoint":"S001, § 301(2)(A)–(B)","Conditions, exceptions, currentness, and confidence":"Moderate. Indirect consideration or creditor-funded compensation may alter the analysis."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"A creditor settling its own debt is likely not an “intermediary,” but affiliate and servicer structures remain unresolved.","Source IDs and pinpoint":"S001, § 301(2)(B)","Conditions, exceptions, currentness, and confidence":"Moderate textual inference."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"“Debtor” means an individual, with no personal/family/household-purpose qualifier in this subchapter.","Source IDs and pinpoint":"S001, § 301(3)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"Entity-only debt likely falls outside the literal debtor definition, while an individual guarantor or obligor may bring the matter within it.","Source IDs and pinpoint":"S001, § 301(3)","Conditions, exceptions, currentness, and confidence":"Moderate textual application; no controlling case located."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"Out-of-state location is not a categorical safe harbor when conduct or an offense element occurs in Arkansas or outside conduct is an attempt to commit the offense there.","Source IDs and pinpoint":"S002, § 302(a); S006, § 5-1-104(a)(1)–(2)","Conditions, exceptions, currentness, and confidence":"High for general rule; moderate for application to specific online/remote facts."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"Covered debt adjusting in Arkansas is prohibited.","Source IDs and pinpoint":"S002, § 302(a); S005, § 17","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Violation is a Class A misdemeanor.","Source IDs and pinpoint":"S002, § 302(b); S005, § 17","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"The statute prohibits engaging, offering, and attempting; it is not merely a fund-custody licensing provision.","Source IDs and pinpoint":"S001, § 301(1); S002, § 302(a)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"The Attorney General or prosecutor may seek an injunction, and a circuit court may appoint a receiver to facilitate return of unremitted debtor property.","Source IDs and pinpoint":"S003, § 303(a)–(b)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"Section 305 lists conditional categories not considered debt adjusters.","Source IDs and pinpoint":"S004, § 305(1)–(7)","Conditions, exceptions, currentness, and confidence":"High confidence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"A qualifying nonprofit may provide debt-management service free or charge no more than actual expenses incurred.","Source IDs and pinpoint":"S004, § 305(6)","Conditions, exceptions, currentness, and confidence":"High confidence as to text."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"Nonprofit status alone does not satisfy § 305(6).","Source IDs and pinpoint":"S004, § 305(6)","Conditions, exceptions, currentness, and confidence":"High confidence. Service and fee conditions remain."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"Whether nonprofit principal-reduction settlement is “debt management service” is unresolved.","Source IDs and pinpoint":"S004, § 305(6); S023–S024 negative searches","Conditions, exceptions, currentness, and confidence":"Held. No controlling interpretation located."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"The attorney exclusion does not establish blanket exclusion for nonlawyer entities or nominal attorney arrangements.","Source IDs and pinpoint":"S004, § 305(1); S023–S024","Conditions, exceptions, currentness, and confidence":"High as to text; affiliate/entity application held."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"Institutional and association exclusions are conditional and should not be expanded beyond their terms.","Source IDs and pinpoint":"S004, § 305(2)–(7)","Conditions, exceptions, currentness, and confidence":"High as to stated conditions; unresolved peripheral scope."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"No lawful fee pathway was established for covered for-profit debt adjusting.","Source IDs and pinpoint":"S002, § 302; S004, § 305","Conditions, exceptions, currentness, and confidence":"High. This is prohibition, not a zero-dollar cap."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"The nonprofit fee ceiling is an expense formula, not a fixed amount or percentage.","Source IDs and pinpoint":"S004, § 305(6)","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise assertion":"No Arkansas debt-adjusting setup, monthly, per-debt, settlement, savings, aggregate, or indexed ceiling was located.","Source IDs and pinpoint":"S004; S010–S011","Conditions, exceptions, currentness, and confidence":"High for reviewed sources; qualified negative-search conclusion."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise assertion":"Arkansas’s debt-adjusting subchapter does not specify nonprofit prepayment, reconciliation, cancellation, refund, or expense-allocation procedures.","Source IDs and pinpoint":"S004, § 305(6)","Conditions, exceptions, currentness, and confidence":"High as to statutory omission; other-law consequences remain open."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise assertion":"Credit-repair coverage can create separate contract, cancellation, bond, trust, and advance-fee duties but cannot authorize prohibited debt adjusting.","Source IDs and pinpoint":"S017, § 4-91-202(a), (d)–(h); S002","Conditions, exceptions, currentness, and confidence":"High as to separate statutes; full overlap analysis reserved."},"coordinator_verification_status":"required_wording_correction_federal_overlay_or_currentness_qualification","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise assertion":"The Arkansas AG consumer page is guidance, not a fee ceiling or licensing decision.","Source IDs and pinpoint":"S013","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise assertion":"No controlling reported Arkansas appellate decision or responsive formal AG opinion resolving the identified receipt, nonprofit, attorney, expense, or remote-nexus questions was located.","Source IDs and pinpoint":"S023–S024","Conditions, exceptions, currentness, and confidence":"Limited negative-search conclusion, not proof of nonexistence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C031","Precise assertion":"No ordinary debt-adjuster application, registration, or public provider registry was located.","Source IDs and pinpoint":"S001–S004; S010–S016","Conditions, exceptions, currentness, and confidence":"High but not absolute. Official code portal and some collection pages were inaccessible."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C032","Precise assertion":"A money-transmitter, currency-exchanger, mortgage, or collection-agency license is not itself debt-adjusting authorization.","Source IDs and pinpoint":"S002; S014–S016","Conditions, exceptions, currentness, and confidence":"High legal-architecture conclusion. Separate overlays may still apply."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C033","Precise assertion":"Where the federal TSR applies, fees require a valid debt result, customer agreement, and at least one customer payment.","Source IDs and pinpoint":"S019, § 310.4(a)(5)(i)(A)–(B)","Conditions, exceptions, currentness, and confidence":"High. Federal rule; applicability is fact-specific."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C034","Precise assertion":"Individually resolved debts require proportional or uniform percentage-of-savings allocation under the TSR.","Source IDs and pinpoint":"S019, § 310.4(a)(5)(i)(C)","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C035","Precise assertion":"Federal dedicated-account compliance does not constitute Arkansas market permission.","Source IDs and pinpoint":"S019, § 310.4(a)(5)(ii); S002","Conditions, exceptions, currentness, and confidence":"High. Independent cumulative legal systems."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C036","Precise assertion":"Inbound calls responding to debt-relief advertising are not covered by the general inbound-ad-call exemption.","Source IDs and pinpoint":"S020, § 310.6(b)(5)(i)","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C037","Precise assertion":"The TSR has no general attorney exemption for covered interstate telemarketing.","Source IDs and pinpoint":"S021, attorney section","Conditions, exceptions, currentness, and confidence":"High as FTC guidance; exact application remains fact-specific."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_AR-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C038","Precise assertion":"Currentness is high but not absolute because the official current-code portal was inaccessible and historic Acts 61/1967 and 189/1983 were not available electronically.","Source IDs and pinpoint":"S005, S008–S012, S025","Conditions, exceptions, currentness, and confidence":"Explicit source limitation."},"coordinator_verification_status":"required_wording_correction_federal_overlay_or_currentness_qualification","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_AR-P1-S001","urls":["https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S001","Title / issuer":"Arkansas Code § 5-63-301, Definitions; 2025 codification hosted by Justia","Direct literal URL":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-301/","Exact pinpoint and version/status":"§ 5-63-301(1)–(4); displayed 2025 version","Actual read/check and limitations":"Freshly read full operative text. Secondary codification with express disclaimer; official current-code portal was inaccessible. \nJustia Law"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S002","urls":["https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S002","Title / issuer":"Arkansas Code § 5-63-302, Debt adjusting—Prohibition","Direct literal URL":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-302/","Exact pinpoint and version/status":"§ 5-63-302(a)–(b); history includes 2015 Act 1263 § 17","Actual read/check and limitations":"Freshly read. Current displayed prohibition and Class A misdemeanor; corroborated by official Act 1263. \nJustia Law"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S003","urls":["https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S003","Title / issuer":"Arkansas Code § 5-63-303, Injunction and receivership","Direct literal URL":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-303/","Exact pinpoint and version/status":"§ 5-63-303(a)–(b)","Actual read/check and limitations":"Freshly read. Secondary codification; establishes AG/prosecutor action and receiver authority. \nJustia Law"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S004","urls":["https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/","https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S004","Title / issuer":"Arkansas Code § 5-63-305, Exclusions","Direct literal URL":"https://law.justia.com/codes/arkansas/title-5/subtitle-6/chapter-63/subchapter-3/section-5-63-305/","Exact pinpoint and version/status":"§ 5-63-305(1)–(7); history: Acts 1967 No. 61 and 1983 No. 189","Actual read/check and limitations":"Freshly read. Source for all listed exclusions and nonprofit actual-expense condition. \nJustia Law"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S005","urls":["https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F","https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S005","Title / issuer":"Act 1263 of 2015; Arkansas General Assembly","Direct literal URL":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2015%2F2015R&file=1263.pdf&path=%2FACTS%2F2015R%2FPublic%2F","Exact pinpoint and version/status":"PDF p. 21, §§ 17–18","Actual read/check and limitations":"Freshly read and visually inspected. § 17 amends § 5-63-302 and inserts Class A misdemeanor; § 18 repeals former § 304. Primary official enactment. \nArkansas Legislature"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S006","urls":["https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/","https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S006","Title / issuer":"Arkansas Code § 5-1-104, Territorial applicability","Direct literal URL":"https://law.justia.com/codes/arkansas/title-5/subtitle-1/chapter-1/section-5-1-104/","Exact pinpoint and version/status":"§ 5-1-104(a)(1)–(6); displayed 2025 version","Actual read/check and limitations":"Freshly read. Relevant to remote/out-of-state activity; no debt-adjuster-specific application located. \nJustia Law"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S007","urls":["https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F","https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S007","Title / issuer":"Act 736 of 2023; Arkansas General Assembly","Direct literal URL":"https://arkleg.state.ar.us/Acts/FTPDocument?ddBienniumSession=2023%2F2023R&file=736.pdf&path=%2FACTS%2F2023R%2FPublic%2F","Exact pinpoint and version/status":"PDF p. 1, § 1","Actual read/check and limitations":"Freshly read and visually inspected. Amends § 5-1-104(a)(6); does not decide the debt-adjusting remote-nexus scenarios. \nArkansas Legislature"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S008","urls":["https://www.arkleg.state.ar.us/","https://www.arkleg.state.ar.us/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S008","Title / issuer":"Arkansas State Legislature homepage/current session","Direct literal URL":"https://www.arkleg.state.ar.us/","Exact pinpoint and version/status":"Fiscal Session of 95th General Assembly adjourned April 29, 2026; official-site statement","Actual read/check and limitations":"Freshly read for current-session context only. Does not itself prove no amendments. \nArkansas Legislature"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S009","urls":["https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/","https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S009","Title / issuer":"Official Arkansas Code search portal","Direct literal URL":"https://portal.arkansas.gov/service/arkansas-code-search-laws-and-statutes/","Exact pinpoint and version/status":"Current-code portal","Actual read/check and limitations":"Attempted; route returned a 403/interactive-access barrier. No CAPTCHA workaround or permission change attempted. Exact official current code therefore was not retrieved from this route."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S010","urls":["https://codeofarrules.arkansas.gov/","https://codeofarrules.arkansas.gov/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S010","Title / issuer":"Code of Arkansas Rules; State of Arkansas","Direct literal URL":"https://codeofarrules.arkansas.gov/","Exact pinpoint and version/status":"Official-version statement; effective Jan. 1, 2025; last updated Oct. 19, 2026","Actual read/check and limitations":"Freshly read. Database warns it may not reflect recent rulemaking. \nCode of Arkansas Rules"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S011","urls":["https://codeofarrules.arkansas.gov/Rules/Search","https://codeofarrules.arkansas.gov/Rules/Search?utm_source=chatgpt.com","https://codeofarrules.arkansas.gov/Rules/Rule?chapterID=257&levelType=section&partID=1253&sectionID=49049&subChapterID=322&subPartID=7539&titleID=9"],"researcher_record":{"Source ID":"S_AR-P1-S011","Title / issuer":"Code of Arkansas Rules search","Direct literal URL":"https://codeofarrules.arkansas.gov/Rules/Search","Exact pinpoint and version/status":"Exact/keyword searches for debt adjusting, debt adjuster, debt settlement, DMP-related terms","Actual read/check and limitations":"Fresh searches produced unrelated debt/check, gaming, tax, and other provisions. No responsive debt-adjuster rule found; negative result is limited by indexing and search behavior. \nCode of Arkansas Rules\n+1"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S012","urls":["https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation","https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S012","Title / issuer":"Uncodified Historic Legislation; Arkansas General Assembly","Direct literal URL":"https://www.arkleg.state.ar.us/ArkansasLaw/HistoricLegislation","Exact pinpoint and version/status":"Historic-source availability statement","Actual read/check and limitations":"Freshly read. Official page states electronic copies of historic acts are unavailable from the site/BLR and identifies libraries from which copies may be obtained. No contact was made. \nArkansas Legislature"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S013","urls":["https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/","https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S013","Title / issuer":"Debt Relief Services/Fair Debt Collection; Arkansas Attorney General","Direct literal URL":"https://arkansasag.gov/divisions/public-protection/finances/debt-relief-services-fair-debt-collection/","Exact pinpoint and version/status":"Consumer warnings and descriptions of counseling, DMP, and settlement","Actual read/check and limitations":"Freshly read. Undated operational/consumer guidance; not a statute, regulation, fee schedule, application, or formal opinion. \nArkansas Attorney General"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S014","urls":["https://securities.arkansas.gov/","https://securities.arkansas.gov/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S014","Title / issuer":"Arkansas Securities Department homepage","Direct literal URL":"https://securities.arkansas.gov/","Exact pinpoint and version/status":"Public categories: securities, mortgages, money services","Actual read/check and limitations":"Freshly read. No debt-adjuster license category identified. \nArkansas Securities Department"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S015","urls":["https://securities.arkansas.gov/money-services-2/7678-2/","https://securities.arkansas.gov/money-services-2/7678-2/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S015","Title / issuer":"NMLS—Arkansas Securities Department","Direct literal URL":"https://securities.arkansas.gov/money-services-2/7678-2/","Exact pinpoint and version/status":"Money transmitter/currency exchanger application and public-search description; list dated Sept. 1, 2026","Actual read/check and limitations":"Freshly read. Category-specific; not debt-adjuster authorization. \nArkansas Securities Department"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S016","urls":["https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/","https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/","https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/?utm_source=chatgpt.com","https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S016","Title / issuer":"Arkansas State Board of Collection Agencies route set","Direct literal URL":"https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/ and https://labor.arkansas.gov/licensing/arkansas-state-board-of-collection-agencies/search-for-licensed-collection-agencies/","Exact pinpoint and version/status":"Public collection-agency licensing/lookup discovery routes","Actual read/check and limitations":"Search results were discovered, but direct pages returned access errors during this check. Collection licensing was not treated as debt-adjusting permission."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S017","urls":["https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/","https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S017","Title / issuer":"Arkansas Code § 4-91-202, Credit Repair Services Organizations Act","Direct literal URL":"https://law.justia.com/codes/arkansas/title-4/subtitle-7/chapter-91/subchapter-2/section-4-91-202/","Exact pinpoint and version/status":"§ 4-91-202(a), (c)–(h); displayed 2025 version","Actual read/check and limitations":"Freshly read for overlap only. Five-day cancellation, ten-day payment return, advance-fee condition, $10,000 bond, and in-state insured trust requirements. Not a debt-adjusting authorization. \nJustia Law\n+2"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S018","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S018","Title / issuer":"16 C.F.R. § 310.2; eCFR","Direct literal URL":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","Exact pinpoint and version/status":"§ 310.2(o), debt-relief-service definition; eCFR displayed current through Oct. 22, 2026","Actual read/check and limitations":"Freshly read. Authoritative but unofficial eCFR. Federal common context only. \neCFR\n+1"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S019","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S019","Title / issuer":"16 C.F.R. § 310.4; eCFR","Direct literal URL":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact pinpoint and version/status":"§ 310.4(a)(5)(i)–(ii)","Actual read/check and limitations":"Freshly read. Exact performance triggers, proportional/savings allocation, and dedicated-account conditions. \neCFR\n+1"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S020","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S020","Title / issuer":"16 C.F.R. § 310.6; eCFR","Direct literal URL":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Exact pinpoint and version/status":"§ 310.6(b)(5)(i)","Actual read/check and limitations":"Freshly read. Debt-relief advertisements are carved out of the general inbound-ad-call exemption. \neCFR"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S021","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S021","Title / issuer":"Debt Relief Services and the TSR: Guide for Business; FTC","Direct literal URL":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact pinpoint and version/status":"Coverage, fee collection, substantial assistance, attorney discussion","Actual read/check and limitations":"Freshly read. Staff compliance guidance, not itself the regulation; accurately distinguished from binding text. \nFederal Trade Commission\n+1"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S022","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S022","Title / issuer":"Debt Relief Services and the TSR: What People Are Asking; FTC","Direct literal URL":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","Exact pinpoint and version/status":"FTC staff Q&A","Actual read/check and limitations":"Freshly read for context. Staff answers; not treated as Arkansas authority. \nFederal Trade Commission"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S023","urls":["https://prod.opinions-search.arkansasag.gov/","https://prod.opinions-search.arkansasag.gov/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S023","Title / issuer":"Arkansas Attorney General opinions search","Direct literal URL":"https://prod.opinions-search.arkansasag.gov/","Exact pinpoint and version/status":"Searches for § 5-63-301, § 5-63-302, debt adjuster, debt adjusting, and debt settlement","Actual read/check and limitations":"Checked; no responsive formal opinion located. This is a limited negative search, not proof of nonexistence."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S024","urls":["https://law.justia.com/cases/arkansas/","https://law.justia.com/cases/arkansas/supreme-court/2022/cv-22-43.html"],"researcher_record":{"Source ID":"S_AR-P1-S024","Title / issuer":"Arkansas public case-search route set","Direct literal URL":"https://law.justia.com/cases/arkansas/","Exact pinpoint and version/status":"Exact statutory citations and distinctive definition phrases","Actual read/check and limitations":"Checked. Located false positives involving creditor collection and insurance adjusters, but no controlling interpretation of this subchapter. No subscription citator or unpublished-trial-record search was performed. \nJustia Law\n+1"},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_AR-P1-S025","urls":["https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F","https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_AR-P1-S025","Title / issuer":"Code Sections Amended, 2026 Fiscal Session; Arkansas General Assembly","Direct literal URL":"https://www.arkleg.state.ar.us/Acts/CodeSectionsAmended?ddBienniumSession=2025%2F2026F","Exact pinpoint and version/status":"Official session amendment-index route","Actual read/check and limitations":"Checked; page presentation was JavaScript-limited and did not provide a clean, independently searchable confirmation for every target section. Targeted official act searches found no responsive later debt-adjusting amendment, but absolute currentness remains qualified."},"coordinator_verification_status":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"coverage":[{"topic":"Statutory debt-adjuster definition","researcher_record":{"Component":"Statutory debt-adjuster definition","Status in PASS-01":"Answered","Claims":"C001–C012","What was resolved":"Two operative branches, consideration, receipt, distribution, debtor/person definitions","Exact missing evidence / next investigation":"Obtain subscription annotations and any unpublished interpretations"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Custodial DMP classification","researcher_record":{"Component":"Custodial DMP classification","Status in PASS-01":"Answered","Claims":"C001–C004, C014","What was resolved":"Covered and prohibited absent exclusion","Exact missing evidence / next investigation":"Later agreement/fund-handling facts may create additional duties"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Custodial settlement classification","researcher_record":{"Component":"Custodial settlement classification","Status in PASS-01":"Answered","Claims":"C005, C014","What was resolved":"Covered and prohibited absent exclusion","Exact missing evidence / next investigation":"None for core classification"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Noncustodial settlement","researcher_record":{"Component":"Noncustodial settlement","Status in PASS-01":"Unresolved/held","Claims":"C006–C007, C030","What was resolved":"Identified literal receipt issue","Exact missing evidence / next investigation":"Citator search; appellate/trial enforcement; AG enforcement files or formal opinions; fact-specific counsel analysis"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Independent dedicated account","researcher_record":{"Component":"Independent dedicated account","Status in PASS-01":"Unresolved/held","Claims":"C007, C035","What was resolved":"Federal conditions identified; Arkansas conclusion not established","Exact missing evidence / next investigation":"Arkansas authority on possession, agency, constructive receipt, or control"},"coordinator_acceptance":"scoped_review_remaining_primary_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 boundary","researcher_record":{"Component":"Consumer/business-purpose boundary","Status in PASS-01":"Partial","Claims":"C011–C012","What was resolved":"Individual definition and absence of purpose qualifier resolved","Exact missing evidence / next investigation":"Cases involving sole proprietors, guarantors, mixed individual/entity debts"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Remote-provider nexus","researcher_record":{"Component":"Remote-provider nexus","Status in PASS-01":"Partial","Claims":"C013","What was resolved":"General territorial statute identified","Exact missing evidence / next investigation":"Cases applying § 5-1-104 to remote offers/contracts/payment businesses"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Core prohibition and criminal status","researcher_record":{"Component":"Core prohibition and criminal status","Status in PASS-01":"Answered","Claims":"C014–C016","What was resolved":"Prohibition and Class A misdemeanor verified","Exact missing evidence / next investigation":"Mental-state issues and criminal procedure reserved"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Injunction/receivership","researcher_record":{"Component":"Injunction/receivership","Status in PASS-01":"Answered only as needed","Claims":"C017","What was resolved":"Enforcement actors and receiver authority verified","Exact missing evidence / next investigation":"Full remedies, standing, procedure, restitution, limitations reserved"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Ordinary debt-adjuster licensing","researcher_record":{"Component":"Ordinary debt-adjuster licensing","Status in PASS-01":"Answered with source limitation","Claims":"C031–C032","What was resolved":"No application or registry located; statute is prohibition/exclusion architecture","Exact missing evidence / next investigation":"Verify through official annotated code and any nonindexed agency materials"},"coordinator_acceptance":"scoped_review_remaining_primary_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 in PASS-01":"Partial","Claims":"C022","What was resolved":"Textual attorney exclusion verified","Exact missing evidence / next investigation":"Firm/entity/affiliate, nominal representation, unauthorized practice, fee ethics"},"coordinator_acceptance":"scoped_review_remaining_primary_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 in PASS-01":"Partial","Claims":"C018–C021","What was resolved":"Nonprofit + debt-management service + actual-expense condition verified","Exact missing evidence / next investigation":"Meaning of debt-management service; settlement inclusion; expense allocation; documentation"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Banks/fiduciaries/lenders","researcher_record":{"Component":"Banks/fiduciaries/lenders","Status in PASS-01":"Partial","Claims":"C023","What was resolved":"Textual exclusion conditions verified","Exact missing evidence / next investigation":"Entity-by-entity charter, authorization, affiliate, and ordinary-course analysis"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Association/member exclusion","researcher_record":{"Component":"Association/member exclusion","Status in PASS-01":"Unresolved scope","Claims":"C023","What was resolved":"Text located","Exact missing evidence / next investigation":"Definition of association, bona fide membership, commercial program treatment"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Self-creditor workout","researcher_record":{"Component":"Self-creditor workout","Status in PASS-01":"Partial","Claims":"C010","What was resolved":"Intermediary distinction identified","Exact missing evidence / next investigation":"Servicer, assignee, affiliate, and common-control cases"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Arkansas fee schedules","researcher_record":{"Component":"Arkansas fee schedules","Status in PASS-01":"Answered","Claims":"C024–C027","What was resolved":"No commercial schedule; actual-expense formula only","Exact missing evidence / next investigation":"Historic act scans and any nonindexed interpretive materials"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Fee indexing/adjustments","researcher_record":{"Component":"Fee indexing/adjustments","Status in PASS-01":"Answered with negative-search limit","Claims":"C026","What was resolved":"No index or adjustment notice located","Exact missing evidence / next investigation":"Continue legislative-history and agency archive check"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"State fee timing","researcher_record":{"Component":"State fee timing","Status in PASS-01":"Partial","Claims":"C024–C027","What was resolved":"No timing for prohibited activity; nonprofit statute has no express trigger","Exact missing evidence / next investigation":"Actual-expense accrual, reconciliation, cancellation/refund authority"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Federal TSR timing","researcher_record":{"Component":"Federal TSR timing","Status in PASS-01":"Answered as common context","Claims":"C033–C037","What was resolved":"Exact performance, allocation, dedicated-account, inbound-ad, attorney rules","Exact missing evidence / next investigation":"Provider-specific TSR applicability remains factual"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Credit-repair overlap","researcher_record":{"Component":"Credit-repair overlap","Status in PASS-01":"Partial, boundary only","Claims":"C028","What was resolved":"Definition, five-day cancellation, ten-day return, bond/trust advance-fee condition","Exact missing evidence / next investigation":"Full credit-repair contract, enforcement, exemptions, federal CROA interaction"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Public regulator instructions","researcher_record":{"Component":"Public regulator instructions","Status in PASS-01":"Answered","Claims":"C031–C032","What was resolved":"No debt-adjuster application; other category routes distinguished","Exact missing evidence / next investigation":"Confirm with any future official debt-adjuster-specific page or enactment"},"coordinator_acceptance":"scoped_review_remaining_primary_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 in PASS-01":"Excluded/not requested","Claims":"—","What was resolved":"No provider claim made","Exact missing evidence / next investigation":"Search exact entity, DBAs, owners, licenses, charitable status, and counsel only when supplied"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current operative regulations","researcher_record":{"Component":"Current operative regulations","Status in PASS-01":"Partial/high-confidence negative search","Claims":"C026, C030–C031","What was resolved":"Official rules database searched; no responsive rule found","Exact missing evidence / next investigation":"Recent rulemaking dockets, emergency rules, agency-specific archives"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Controlling cases/formal opinions","researcher_record":{"Component":"Controlling cases/formal opinions","Status in PASS-01":"Unresolved evidence gap","Claims":"C030","What was resolved":"No responsive public authority located","Exact missing evidence / next investigation":"Westlaw/Lexis/Bloomberg citator; Arkansas judiciary dockets; AG opinion archive variants"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Historic Acts 61/1967 and 189/1983","researcher_record":{"Component":"Historic Acts 61/1967 and 189/1983","Status in PASS-01":"Unresolved source gap","Claims":"C038","What was resolved":"History citations identified","Exact missing evidence / next investigation":"Obtain scans from listed repositories or licensed legislative-history database"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Agreements and disclosures","researcher_record":{"Component":"Agreements and disclosures","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"Discussed only for credit-repair boundary","Exact missing evidence / next investigation":"Full state agreement/e-sign/language/prohibited-term investigation"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Client funds/trust/escrow duties","researcher_record":{"Component":"Client funds/trust/escrow duties","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"Only definition and federal dedicated-account boundary addressed","Exact missing evidence / next investigation":"Full Arkansas trust, money-transmission, fiduciary, banking analysis"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Bonds","researcher_record":{"Component":"Bonds","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"$10,000 credit-repair overlap noted only","Exact missing evidence / next investigation":"Full bond requirements by model and exemption"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Civil remedies, collection, litigation, limitations","researcher_record":{"Component":"Civil remedies, collection, litigation, limitations","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"§ 303 referenced only as necessary","Exact missing evidence / next investigation":"Full remedies, private rights, UDAP, limitations, criminal enforcement"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Secured debt, mortgages, tax debt, student debt, medical debt, utilities","researcher_record":{"Component":"Secured debt, mortgages, tax debt, student debt, medical debt, utilities","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"Not resolved","Exact missing evidence / next investigation":"Sector-by-sector statutory and regulator analysis"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Local, tribal, contract, constitutional, and preemption issues","researcher_record":{"Component":"Local, tribal, contract, constitutional, and preemption issues","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"Not resolved","Exact missing evidence / next investigation":"Separate focused investigations"},"coordinator_acceptance":"scoped_review_remaining_primary_currentness_and_application_holds","coordinator_review":"[internal evidence reference]","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Full exemption architecture beyond current fee/access needs","researcher_record":{"Component":"Full exemption architecture beyond current fee/access needs","Status in PASS-01":"Later pass","Claims":"—","What was resolved":"Only § 305 exclusions addressed","Exact missing evidence / next investigation":"Entity/activity-specific exemption validation"},"coordinator_acceptance":"scoped_review_remaining_primary_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":[]}