{"meta":{"key":"s_co--pass-01","task":"S_CO","title":"SCO Colorado provider market access and consumer fees","parent_title":"Colorado debt and debt relief law","edition":"pass-01","path":"/research/s_co--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-23","tables":8,"claims":37,"sources":23,"review_status":"revise","review_complete":true,"sha256":"5c4f5a45f73d2cc5358d011dcca7f4e7f6357f9b6b67d07c2ce3d66947d283bd","headings":["A. Substantive findings","1. Classification: what conduct Colorado regulates","2. Market access, exclusions, and failure cases","3. Consumer fee structures, amounts, indexing, and refunds","4. When fees may actually be requested or received","5. Actual application, renewal, lookup, and legal status","6–7. Worked examples and component coverage","B. Source table","C. Claim table","D. Worked examples and coverage","D.1 Bounded plain-text examples","D.2 Component coverage and exact next investigations","E. Researcher self-check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","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_CO/pass-01","facets":{"geography":["us","us-co"],"debt_type":["unknown"],"stage":[],"subject":["definitions-classification","fees-outcomes","provider-licensing"]},"scope":"Provider market access and consumer fee framework only; allotherstatecategories remainrequired","pending_corrections":0},"markdown":"# S_CO PASS-01 — Colorado provider market access and consumer fees\n\n**Baseline:** October 22, 2026, Pacific.\n**Actual access:** October 22, 2026, PDT, corresponding to October 23, 2026, UTC.\n\n**Finding:** Colorado establishes a **registration pathway for covered debt-management providers**, including concession-based debt management plans and principal-reduction settlement. Coverage turns on the actual intermediary services, compensation, customer, and relationship—not the marketing label or whether the provider holds consumer funds. The current statute directly verifies the DMP dollar limits, settlement performance triggers, completed-plan aggregate protection, and several refund and anti-evasion requirements. [Colorado Revised Statutes 2026+2](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n**Three material matters remain held:** the full official text of the March 30, 2025 rule; the dated administrative instrument establishing today’s provider registration fees; and any named provider’s actual registration status. Those limitations affect the conclusions identified below. **This component does not establish SettleADebt.com’s authorization, complete the Colorado dossier, or imply state or A066 acceptance.**\n\nFor readability, **S001** means **S_CO-P1-S001**, and **C001** means **S_CO-P1-C001**. The source and claim tables give the full identifiers.\n\n## A. Substantive findings\n\n### 1. Classification: what conduct Colorado regulates\n\nThe governing statute is the **Colorado Uniform Debt-Management Services Act**, C.R.S. Title 5, Article 19, Part 2.\n\nUnder §5-19-202(8), debt-management services involve acting as an intermediary between an individual and one or more creditors to obtain concessions. “Concessions” are repayment terms more favorable than the original credit contract. A provider includes someone who provides, offers, or agrees to provide those services, directly or through others. An “individual” is a natural person. **[C001–C002; S001, §202(6), (8), (11), (15)]**\n\n| Actual activity or relationship | Classification and boundary |\n| --- | --- |\n| Negotiating acceptance of less than the statutory principal amount | Principal-reduction settlement under §223(d)(2). The statutory definition of principal uses the debt amount **at the time of the provider agreement**, not necessarily the original loan principal. |\n| Obtaining reduced interest, finance charges, late fees, default fees, or delinquency fees while arranging repayment | Concession-based services; the fee structure in §223(d)(1) applies to plans contemplating those concessions. |\n| Receiving one payment and distributing it among creditors while obtaining concessions | Covered intermediary activity. Custody creates additional obligations; it is not the element that creates coverage. |\n| Negotiating concessions while consumers pay creditors themselves | Potentially covered on the same definition. No custody requirement appears in §202(8). |\n| Arranging an independent dedicated account | Does not remove the provider from coverage. The current application expressly accommodates noncustodial providers that suggest or arrange third-party accounts. |\n| Financial education without offering or performing intermediary concession services | May fall outside the core definition. A provider offering subsequent negotiation cannot establish exclusion merely by calling the first service “education.” |\n| Bill payment without concession activity | May fall outside the definition; §203(c)(4) also supplies a specific incidental-services exclusion, discussed below. |\n| A creditor negotiating only its own receivable directly with its debtor | **Definition-based inference:** ordinarily there is no intermediary between the debtor and another creditor. This is not an express general “self-creditor exemption,” and it does not automatically resolve collectors, servicers, affiliates, or debt purchasers. |\n| Credit repair combined with negotiation or a DMP | §5-19-114 requires compliance with Part 2 when a credit services organization also performs debt-management services; Part 2 controls a conflict between the two parts. |\n\n**[C002–C006; S001, §§114, 202, 203, 223; S010, p. 9.]** The statute and current application support the custody distinction directly. [Colorado Revised Statutes 2026+2](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n#### Consumer versus business purpose\n\nThe statutory customer definition focuses on natural persons. Section 203(b)(3) separately excludes a provider to the extent it provides debt-management services **only to persons who incurred debt in the conduct of business**. A business-owner label does not establish that a particular personal credit-card balance was incurred in business. Mixed-purpose debts, personal guarantees, and a provider serving both consumer and business segments require factual analysis. **[C004]**\n\n#### Colorado resident and remote-provider nexus\n\nSection 204(a) requires registration when the provider reasonably should know the individual resides in Colorado when it agrees to provide services. Sections 203(a) and 203(b)(1) address agreements or services where the provider has no reason to know of Colorado residence at the relevant agreement time.\n\nAn out-of-state office does not eliminate that nexus. Section 206(3) expressly allows an application stating that the applicant has no Colorado service location. Section 206.7 separately permits registered-provider employees to work remotely under specified privacy, supervision, record-access, and location safeguards. **[C003; S001, §§203–204, 206(3), 206.7.]** [Colorado Revised Statutes 2026+1](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n### 2. Market access, exclusions, and failure cases\n\n#### Ordinary covered providers: registration is legally available and required\n\nThe legal pathway comes from **§§204–212**, not from an agency webpage’s description of its programs. The administrator is the assistant attorney general designated under §5-6-103; operational administration is through the Colorado Department of Law’s Consumer Credit Unit. **[C001, C012–C015]**\n\nCovered for-profit and nonprofit providers can use that registration pathway. Neither principal-reduction settlement nor noncustodial operation is categorically prohibited by the provisions reviewed. **Operating without required registration is prohibited; an application alone is insufficient.**\n\nApplications must satisfy §§205–206, including prescribed information, fees, applicable entity qualifications, financial-responsibility documents, and other supporting materials. Section 209 provides substantive issuance and denial standards. It also allows a regulator-issued temporary certificate, for no more than 120 days, in the specified delayed-criminal-record-check circumstances. Section 210’s agency decision deadline does not create automatic approval: the remedy for failure to act is an appeal/hearing request. **[C013]**\n\nRegistration also does not authorize every proposed plan. Section 217 requires personal-finance education and financial analysis; for regular periodic payments, it additionally requires a plan, a suitability and ability-to-pay determination, and a belief that participating creditors will accept the planned payments. **[C017]** [Colorado Revised Statutes 2026+2](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n#### Exclusions must fit the actual activity and entity\n\n| Exclusion or special situation | Required conditions and failure cases |\n| --- | --- |\n| **Attorney legal services** | Actual legal services in an attorney-client relationship, provided by an attorney licensed to practice in Colorado. A lawyer’s ownership, referral, retainer label, or nominal affiliation is insufficient. The professional exclusion does not extend to a nonemployee merely providing services on the professional’s behalf. |\n| **Out-of-state attorney** | *Coffman v. Williamson* recognizes that qualifying limited Colorado authorization under C.R.C.P. 205.1 can satisfy the licensing element. It also holds that attorney status alone does not establish the other elements. A particular practice’s current eligibility under the admission rules remains to be verified. |\n| **CPA** | Accounting services in an accountant-client relationship by a CPA certified or authorized by Colorado’s accountancy board. The nonemployee restriction also applies. |\n| **Enrolled agent** | Treasury-authorized, good-standing enrolled agent; tax representation before the IRS, Colorado Department of Revenue, or Colorado Department of Labor and Employment; enrolled-agent/client relationship; no other debt-management services. |\n| **No-compensation provider** | No compensation for the services from or on behalf of the individuals **or from their creditors**. “Free to the consumer” fails this exclusion if the creditor compensates the provider. |\n| **Nonprofit** | No general nonprofit exclusion. Applicants must substantiate applicable status, and §209 imposes board-independence conditions. A nonprofit or tax-exempt label alone is insufficient. |\n| **Bank** | Must meet §202(4)’s charter, banking-business, and banking-regulation definition. The definition lists several institutional forms; their names alone are not the complete test. |\n| **Bank affiliate** | The relevant control relationship must exist, and the affiliate itself must be regulated by a federal or state banking regulatory authority. |\n| **Judicial or ordered activity** | Judicial officer, person acting under court or administrative-agency order, or assignee for benefit of creditors, acting within the specified regular-course condition. |\n| **Incidental bill payment** | Title insurer, escrow company, or other bill-paying person, where debt-management services are incidental to bill-paying services, within the regular-course condition. |\n| **Foreclosure-protection activity** | Section 203(b)(4) excludes a provider subject to the Colorado Foreclosure Protection Act. This allocates activity to another legal regime; it does not establish a settlement-fee permission under that other regime. |\n| **Employee or agent of registered provider** | Section 204(b) removes the separate §204(a) registration requirement. This provision includes agents and is distinct from the professional exclusion’s nonemployee restriction. |\n| **Registration elsewhere** | Section 212 permits substitute application documentation under conditions. It does not make another state’s license automatic Colorado authorization. |\n\n**[C007–C012; S001, §§202–204, 209, 212; S013.]** [Colorado Revised Statutes 2026+3](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\nIn *Coffman*, the Colorado Supreme Court rejected an exemption theory involving a company whose purported attorney relationship did not provide meaningful attorney direction and supervision. Its discussion of the original statute must be distinguished from the amended statute’s express employee condition. **[C008; S013, ¶¶31–40 and footnote 4.]**\n\nAn exclusion from Part 2 does not establish unrestricted fees, authority to practice law, or exemption from independently applicable federal law.\n\n### 3. Consumer fee structures, amounts, indexing, and refunds\n\n#### Verified statutory amounts and restrictions\n\n| Fee or charge | Verified statutory treatment | Conditions or limitation |\n| --- | --- | --- |\n| **DMP setup** | Up to **$50** for consultation, obtaining a credit report, and setting up an account. | §223(d)(1)(A); applicable concession-based plan and compliant signed agreement. |\n| **DMP monthly service** | Up to **$10 × creditors remaining in the plan when assessed**, capped at **$50 in any month**. | The statutory unit is **creditors**, not accounts, original enrolled debts, or original creditor count. |\n| **DMP lifetime or debt-percentage cap** | Section 223(d)(1) supplies setup and monthly limits, not a separate debt-percentage or plan-lifetime ceiling. | This does not remove suitability, unfairness, agreement, or other-law constraints. |\n| **Principal-reduction settlement fee** | No payment request or receipt before the state performance conditions in §223(d)(2)(A). | Any fee or consideration is covered; relabeling a charge as enrollment or setup does not bypass the condition. |\n| **Completed settlement plan aggregate** | Fees plus the aggregate settlement offers obtained may not exceed agreement-date principal when the individual completes all obligations under the agreement. | §223(d)(2)(B). Preserve the completion condition and the statutory “offers of settlement” measure. |\n| **Fixed numerical settlement percentage** | **No current fixed percentage ceiling was established from the verified current primary text.** | Do not use 18%, 20%, 25%, or another commercial rate as a verified Colorado cap. Full current Rule 4 remains a primary-text hold. |\n| **Education/counseling after assent to a provider agreement** | Generally no separate charge. The administrator may authorize a fee based on the nature and extent of the services; §228(d) also matters. | No particular provider’s authorization or approved amount was verified. |\n| **DMP plus settlement fee stacking** | Fees may not be imposed or received under both §223(d)(1) and §223(d)(2). | §223(d)(3). |\n| **Dishonored consumer payment** | Reasonable charge no greater than the lesser of **$25** and the amount permitted by other law. | $25 is not automatic authorization; the other-law ceiling and reasonableness must also be satisfied. |\n| **“Voluntary” contribution** | May not be solicited from the individual or affiliate. Accepted contributions count toward the permitted aggregate through 30 days after plan completion or termination. | §224 prevents using contributions to exceed ordinary limits during that period. |\n| **Settlement-fee financing** | Deferral is permitted only at no additional expense to the individual. | §228(b)(3). |\n| **Unrelated products and referral compensation** | Restrictions cover unrelated insurance, clubs, coupons, computer access, and specified compensation for arranging credit or other services. | §§228(b)(7), 228(d); the latter includes a government-program education/counseling exception. |\n\n**[C018–C028; S001, §§223–224, 228.]** [Colorado Revised Statutes 2026+1](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n#### The 2025 rule: corroborated provisions, with an explicit primary-text hold\n\nThe Secretary of State’s official index and docket identify a permanent **4 CCR 902-2** rule adopted **February 7, 2025**, published **March 10, 2025**, and effective **March 30, 2025**. The docket explains that the administrator considered fee caps but chose to retain the former statutory fee structure in regulation. **[C034; S004–S005]**\n\nThe official adopted DOCX and basis-and-purpose attachment could not be successfully read. The current official PDF link did not yield a usable current document through the available retrieval route. I did read the full Cornell reproduction of Rule 4, which reports:\n\n- Proportional allocation of a total fee using enrollment-date debt amounts, or a fixed percentage of savings measured against enrollment-date debt.\n- The same savings percentage from one debt to another.\n- A standalone education/counseling provision of up to $100, with administrator approval for a larger amount.\n- A refund if the individual enters an agreement before 90 days after completion or termination of those educational services.\n\n**These are reported as corroborated reproduction text, not as fully verified operative Colorado rule text.** The reproduction’s refund clause also retains a reference to “subsection (d)(4),” although that statutory provision was repealed and Rule 4 has no corresponding subsection. I have not silently repaired that cross-reference or determined its legal consequence. **The standalone $100 pathway and its refund implementation remain held. [C022, C024]** [sos.state.co.us+2](https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980&utm_source=chatgpt.com)\n\nThe state performance triggers and aggregate protection remain independently verified in the statute. Federal allocation rules, where applicable, are independently verified below.\n\n#### Historical amounts and CPI reconciliation\n\n| Historical material | Reconciliation with this baseline |\n| --- | --- |\n| Former **18% aggregate / 4% setup** settlement structure described in the AG’s 2011 annual report | Historical, not a current fee schedule. The official 2011 legislative digest describes removal of the former statutory settlement fee cap effective July 1, 2011. |\n| Archived Rule 2 CPI mechanism | Cannot support a newly calculated 2026 amount. The official Red Book records repeal of former §12-14.5-232(f)–(g), effective July 1, 2011. |\n| AG’s 2013 regulatory agenda | Calls the CPI rule outdated and proposes repeal. This is evidence of historical agency treatment, **not proof that the proposed rule repeal was completed**. |\n| Current §223 and current AG consumer guidance | Support the $50 setup and $10-per-remaining-creditor/$50-monthly statutory structure. No higher current adjusted amount was verified. |\n| HB24-1380 | Replaced the former statutory settlement allocation language with a rule-compliance requirement and repealed the standalone education/refund subsections effective March 1, 2025. |\n| March 30, 2025 rule | Its listed effective date is later than the March 1 statutory changes. This pass does not resolve the historical March 1–29 transition period. |\n| SB26-083 | Postponed the annual expiration of covered Department of Law rules adopted in the relevant 2024–2025 window. This supports continued listed status; it does not cure substantive defects or prove absence of a judicial restriction. |\n\n**[C032–C034; S003–S008, S014–S017, S020.]** No CPI calculation has been invented. [Colorado General Assembly+4](https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011?utm_source=chatgpt.com)\n\n### 4. When fees may actually be requested or received\n\n#### Colorado conditions\n\n**General gate:** §223(b) prohibits imposing charges or receiving payment for debt-management services before the provider and individual sign an agreement complying with §§219 and 228. Required advance disclosure of a fee schedule under §217 is distinct from demanding payment. **[C018]**\n\n**DMP:** The state statute permits the specified setup and monthly fee structure for the applicable concession plan after the agreement requirement is met. It does not impose §223(d)(2)’s settlement-specific performance trigger on §223(d)(1). That distinction does not displace federal timing where applicable. **[C019]**\n\n**Principal-reduction settlement:** Before requesting or receiving any fee or consideration:\n\n1. The provider must have settled at least one debt under a valid agreement executed by the individual.\n2. The individual must have made at least one payment under that agreement with the creditor or collector.\n3. The fee must satisfy the applicable administrator rules.\n\nA provider contract, negotiated offer not accepted by the consumer, deposit into savings, or payment to the provider alone does not satisfy those stated conditions. Full payment of the settlement is not the statutory first-payment trigger, although final savings calculations can require additional facts. **[C020–C022]** [Colorado Revised Statutes 2026](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n#### Federal TSR: common context, separately applicable\n\nFor covered telemarketing, **16 CFR §310.4(a)(5)(i)** independently requires an executed agreement changing at least one debt’s terms, at least one payment under that agreement, and the prescribed proportional or savings-based allocation for individually resolved debts.\n\nThe federal definition reaches services represented as changing unsecured-creditor or debt-collector obligations, including interest and fees. Covered inbound calls responding to debt-relief advertising or direct mail do not receive the ordinary exemptions for those categories of inbound calls. Applicability still requires the federal jurisdictional and transactional analysis; it is not established merely because a business provides Colorado services. **[C035–C036]**\n\nConsequently, **Colorado’s $50 DMP setup ceiling is not federal permission to collect $50 at signup**. The FTC’s guidance also distinguishes bona fide nonprofits from falsely claimed nonprofit status and supplies no general debt-relief attorney exemption. [ecfr.gov+3](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com)\n\n#### Deposits are not earned fees\n\nColorado §202(20)(B) and federal §310.4(a)(5)(ii) recognize qualifying dedicated accounts: insured institution, consumer ownership and interest, independent administrator, no specified referral compensation, and withdrawal protection. Funds in such an account are not thereby provider revenue.\n\nColorado requires immediate return of the relevant consumer funds on withdrawal/termination, subject to properly earned fees; the federal account provision supplies its own seven-business-day return requirement. The federal period does not relax the Colorado requirement. **[C030, C037]**\n\n#### Cancellation and termination\n\n- **Three-business-day cancellation:** §220 provides cancellation and the prescribed notice promises refund of all money paid. Specified agreement defects extend the cancellation period to 30 days.\n- **Emergency waiver:** The narrow statutory waiver requires a signed, dated statement in the consumer’s own words describing the financial emergency; a standard-form waiver is void.\n- **Later termination:** The consumer may terminate without penalty or obligation. Unexpended debt funds and consumer trust funds must be returned under the relevant provisions. Later termination does not automatically require return of every fee already lawfully earned and paid.\n- **Failed plans:** §222(h) requires prompt return of money not paid to creditors, less fees actually payable under §223. No universal rule requiring refund of an otherwise earned settlement fee after a later installment default was established in this pass.\n\n**[C029–C031, C037; S001, §§202(20)(B), 219(d), 220, 222(h), 226(b), 228(a)(4).]** [Colorado Revised Statutes 2026+3](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com)\n\n### 5. Actual application, renewal, lookup, and legal status\n\nThe current AG registration page links an actual **33-page application and instructions**, with a filename ending 10.26.pdf. Its instructions provide an initial application route by completed PDF submitted to the Department of Law; renewals use the licensing portal. Page 9 expressly distinguishes providers that hold funds, do not hold or arrange third-party accounts, and do not hold funds but arrange or suggest those accounts. **[C015; S009–S010]**\n\nThe observed current administrative charges are:\n\n| Provider activity | Current registration/renewal amount displayed by AG |\n| --- | --- |\n| Credit counseling | $1,500 |\n| Debt settlement | $5,000 |\n| Both | $5,000 |\n\nThese are **provider administrative charges**, not additional consumer fees. Sections 205(b)(1) and 232(e) supply fee-setting authority. The exact dated instrument setting these amounts was not found; therefore the current operational amounts are verified, while their precise change/effective-date chain remains held. The older Rule 1’s $1,000 figure does not establish today’s application amount. **[C015]** [Colorado Attorney General+2](https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/?utm_source=chatgpt.com)\n\nRegistrations renew annually by July 1. A timely, complete renewal with the required fee preserves registration while the application is pending under §211(d); failure to file the complete application and fee by July 1 causes automatic expiration under §211(f). The AG warns that a displayed prior July 1 expiration may reflect a pending renewal. Neither a stale displayed date nor the provider’s assertion alone resolves actual status. **[C014]**\n\nThe actual public-report route is:\n\n[https://licensing.coag.gov/s/public-reports](https://licensing.coag.gov/s/public-reports?utm_source=chatgpt.com)\n\nThat route returned a loading/CSS error during this research. This is an access failure, **not a no-match result and not proof that the registry is universally unavailable**. No named provider’s registration, activity category, renewal, or disciplinary status was established. **[C016]**\n\nThe statute is currently operative in the 2026 compilation; §242 schedules repeal for September 1, 2035. That future repeal is not a present expiration. **[C001]**\n\n### 6–7. Worked examples and component coverage\n\nThe calculations appear in **D.1**. The full component coverage and exact next investigations appear in **D.2**. They preserve the distinction between verified limits, conditional calculations, and unresolved permission.\n\n## B. Source table\n\n**Access code A:** actually accessed or attempted October 22, 2026, PDT / October 23, 2026, UTC. “Read” means operative content was retrieved, not merely a title or search snippet.\n\n| Source ID | Document / issuer and direct literal URL | Exact pinpoint, version, legal status, and access limitation |\n| --- | --- | --- |\n| **S_CO-P1-S001** | **Colorado Revised Statutes 2026, Title 5**, OLLS. [https://olls.info/crs/crs2026-title-05.htm](https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com) ; [https://olls.info/crs/crs2026-title-05.pdf](https://olls.info/crs/crs2026-title-05.pdf?utm_source=chatgpt.com) | **A—read relevant operative passages.** §§5-19-114; 202–212; 217; 219–228; 231–232; 242. Current 2026 compilation. One document ID reused across sections and formats. Colorado substantive law; selected relevant provisions, not every page of Title 5. |\n| **S_CO-P1-S002** | **2026 CRS Titles Download**, Colorado General Assembly/OLLS. [https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download](https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download?utm_source=chatgpt.com) | **A—read.** Official publication route linking the 2026 title files. Establishes provenance/current compilation, not a substitute for statutory text. |\n| **S_CO-P1-S003** | **HB24-1380, signed act**, Colorado General Assembly. [https://leg.colorado.gov/bill_files/44318/download](https://leg.colorado.gov/bill_files/44318/download?utm_source=chatgpt.com) | **A—read.** §5, pp. 4–6; §6 effective-date provisions. Rule authority effective August 7, 2024; specified fee amendment/repeals effective March 1, 2025. Enacted law, not proposed bill text. |\n| **S_CO-P1-S004** | **4 CCR 902-2 official version index**, Colorado Secretary of State. [https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980](https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980&utm_source=chatgpt.com) | **A—read.** “Current version” row: adopted February 7, 2025; published March 10; effective March 30. Also identifies archived versions. Metadata verified; full current rule text not retrieved from this index. |\n| **S_CO-P1-S005** | **eDocket 2024-00603**, Colorado Secretary of State. [https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603](https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603&utm_source=chatgpt.com) | **A—read.** Purpose/objective, adopted-rule section, dates and attachment links. Confirms permanent filing and stated intent to retain former fee structure. Its statutory-authority field contains a subsection-reference inconsistency; enacted §223(d)(2)(C) controls. |\n| **S_CO-P1-S006** | **Official adopted rule attachment**, Department of Law/SOS. [https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx](https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx) | **A—attempted, not read.** Unsupported-document/HTTP retrieval failures. Full operative wording remains held. Related basis attachment also failed: [https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc](https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc). No inference that either document is legally absent. |\n| **S_CO-P1-S007** | **4 CCR 902-2, Rule 4 reproduction**, Cornell LII. [https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4](https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4?utm_source=chatgpt.com) | **A—full reproduced Rule 4 read.** Clauses (a)(1), (b), (b)(1); note reports March 30, 2025 effectiveness. **Secondary transcription**, not primary adoption verification. Refund cross-reference problem preserved. |\n| **S_CO-P1-S008** | **SB26-083, chapter 106, Administrative Rule Review**, Colorado General Assembly. [https://leg.colorado.gov/laws/session-laws/SB26-083/106/download](https://leg.colorado.gov/laws/session-laws/SB26-083/106/download?utm_source=chatgpt.com) | **A—full two-page act read.** §1(1), especially (i), printed pp. 433–434; §2; approved May 5, 2026. Postpones annual expiration of covered Department of Law rules. Does not establish substantive validity or lack of injunction. |\n| **S_CO-P1-S009** | **Debt Management Registration**, Colorado AG. [https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/](https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/?utm_source=chatgpt.com) | **A—read.** Opening coverage description; application link; renewal dates; administrative fees; pending-renewal note. Current operational evidence, not independent legal authority for consumer charges. |\n| **S_CO-P1-S010** | **Debt Management Services Provider Application & Instructions**, Colorado Department of Law. [https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf](https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf?utm_source=chatgpt.com) | **A—relevant instructions/checklist and model fields read.** p. 1 submission and fees; pp. 2–7 requirements; p. 9 custody/third-party-account categories. Current linked 33-page application. Filename is not a legal effective date. “Notification” heading and erroneous rule-number reference do not supersede the statute. |\n| **S_CO-P1-S011** | **Debt Management: Consumers**, Colorado AG. [https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/](https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/?utm_source=chatgpt.com) | **A—read.** Consumer fee and cancellation explanations; lookup route. Agency summary. Its “debts” wording does not replace §223(d)(1)(B)’s “creditors” measure. |\n| **S_CO-P1-S012** | **Public Reports**, Colorado AG licensing system. [https://licensing.coag.gov/s/public-reports](https://licensing.coag.gov/s/public-reports?utm_source=chatgpt.com) | **A—attempted; error page read.** Loading/CSS failure. No provider record or search result verified. |\n| **S_CO-P1-S013** | ***Coffman v. Williamson*, 2015 CO 35, 348 P.3d 929**, Colorado Supreme Court. [https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf](https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf?utm_source=chatgpt.com) | **A—relevant opinion passages read.** ¶¶21, 31–42, 48–55; footnote 4. Colorado Supreme Court construction of professional exclusion and constitutional issues. Original-statute analysis distinguished from amended law. No exhaustive subsequent-history certification. |\n| **S_CO-P1-S014** | **Red Book 2011**, Colorado General Assembly/OLLS. [https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011](https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011?utm_source=chatgpt.com) | **A—relevant entries read.** Former §12-14.5-232(f), (g): repeal by HB11-1206, ch. 113, §17, July 1, 2011. Official legislative disposition table; historical evidence. |\n| **S_CO-P1-S015** | **2011 Digest of Bills**, Colorado General Assembly. [https://leg.colorado.gov/sites/default/files/digest2011.pdf](https://leg.colorado.gov/sites/default/files/digest2011.pdf?utm_source=chatgpt.com) | **A—HB11-1206 entry read.** Printed pp. 134–135. Describes repeal of settlement cap and inflation-adjustment mandate; effective July 1, 2011. Official legislative summary, not the enacted act itself. |\n| **S_CO-P1-S016** | **Archived 4 CCR 902-2**, SOS, ruleVersionId 7291. [https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291](https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291&utm_source=chatgpt.com) | **A—two-page document read.** Rules 1–3: $1,000 administrative fee, CPI mechanism, insurance notice. Archived September 21, 2017 correction of older rules. Does not contain current Rule 4 and is not treated as the full current regulation. |\n| **S_CO-P1-S017** | **Department of Law Regulatory Agenda for Calendar Year 2013**, Colorado AG. [https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf](https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf?utm_source=chatgpt.com) | **A—full page read.** Items 1(c), 3, 4. Describes outdated CPI/insurance rules and contemplated repeal. Historical proposed agenda, not an adoption order. |\n| **S_CO-P1-S018** | **16 CFR Part 310**, eCFR/Federal Register system. [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) ; [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) ; [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) | **A—operative provisions read.** §§310.2(o), (ii); 310.4(a)(5)(i)–(ii); 310.6(b)(5)(i), (6)(i). eCFR displayed up to date October 21, 2026. One Part 310 source ID reused. Federal coverage conditional; eCFR is authoritative but unofficial. |\n| **S_CO-P1-S019** | **Debt Relief Services & the TSR: A 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) | **A—relevant sections read.** “Who’s Covered,” nonprofit/attorney explanations, collecting fees and dedicated accounts. Agency staff guidance, expressly nonbinding; current regulation controls. |\n| **S_CO-P1-S020** | **2011 Annual Report—Colorado Debt-Management Services Providers**, Department of Law, state-library copy. [https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf](https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf) | **A—read by parallel research agent; synthesis retrieval retries timed out.** p. 1, footnote 4, former 18%/4% structure and 2010/2011 timing changes. Historical agency report; not a current fee authorization. |\n| **S_CO-P1-S021** | **Rules Governing Admission to Practice Law in Colorado**, hosted by Colorado attorney-regulation office. [https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf](https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf?utm_source=chatgpt.com) | **A—Rule 205.1, printed p. 26, read.** Corroborates limited-practice framework. Compilation’s current amendment status was not established; not used to clear a particular attorney’s present eligibility. |\n| **S_CO-P1-S022** | **Proposed Statement of Basis and Purpose—DMSA Fees**, Colorado AG. [https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf](https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf?utm_source=chatgpt.com) | **A—read.** December 2024 rulemaking material. **Proposed**, not a substitute for the unread final adopted attachment. |\n| **S_CO-P1-S023** | **HB11-1206 original session-law retrieval route**, CU Law repository. [https://scholar.law.colorado.edu/session-laws-2001-2050/4873/](https://scholar.law.colorado.edu/session-laws-2001-2050/4873/) ; [https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050](https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050) | **A—metadata/discovery and failed full-text route.** Full act retrieval returned access failure; not treated as freshly read enacted text. Current conclusions instead rest on S001 and the identified official historical corroboration. |\n\n## C. Claim table\n\n“Verified” refers to the identified legal text or operational evidence, not approval of an unseen business model.\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, currentness, confidence limits |\n| --- | --- | --- | --- |\n| **S_CO-P1-C001** | Part 2 establishes Colorado’s debt-management registration regime, administered by the designated AG official; current §242 schedules repeal September 1, 2035. | S001 §§202(1), 204–212, 242; S002 | **Verified current statutory framework.** Future repeal is not current expiration. |\n| **S_CO-P1-C002** | Coverage turns on intermediary concession services for a natural person; providers include offers and services through others; statutory principal is agreement-date debt. | S001 §202(6), (8), (11), (14), (15), (17) | **Verified.** Marketing labels and original-loan principal are not substitutes for these definitions. |\n| **S_CO-P1-C003** | Custody is not a coverage prerequisite; Colorado-resident agreement nexus can reach remote providers. | S001 §§202(8), 203(a)–(b)(1), 204(a), 206(3), 206.7; S010 p. 9 | **Verified**, subject to knowledge standard and exclusions. Remote employee permission has separate safeguards. |\n| **S_CO-P1-C004** | Natural-person focus and the business-debt exclusion limit scope; mixed-purpose facts cannot be resolved by a business label. | S001 §§202(11)–(12), 203(b)(3) | Text **verified**; mixed-purpose/guarantor application **unresolved**. |\n| **S_CO-P1-C005** | Pure education or bill payment may lack intermediary concession activity; direct own-creditor negotiation may likewise fall outside the definition. | S001 §§202(8), (15), 203(c)(4) | **Qualified inference**, not a general exemption or clearance under other laws. |\n| **S_CO-P1-C006** | A credit services organization also performing debt-management services must comply with Part 2; Part 2 controls a conflict. | S001 §114 | **Verified.** Full credit-repair analysis remains outside this pass. |\n| **S_CO-P1-C007** | Attorney, CPA, and enrolled-agent exclusions require the specified professional services, relationships, and qualifications; nonemployee service providers do not inherit them. | S001 §202(8)(A)–(B) | **Verified.** Enrolled-agent exclusion additionally excludes other debt-management services. |\n| **S_CO-P1-C008** | Attorney status or affiliation alone is insufficient; *Coffman* requires real qualifying services and recognizes qualifying limited Colorado authorization. | S013 ¶¶31–42, 53; footnote 4; S001 §202(8) | **Verified holding**, with original/amended statute distinction. Current individual Rule 205.1 eligibility and exhaustive subsequent history not certified. |\n| **S_CO-P1-C009** | Nonprofit status alone does not exempt a provider; no-compensation exclusion includes creditor compensation; nonprofit applicants face independence requirements. | S001 §§203(b)(2), 205(b)(5), 209(c)–(d) | **Verified.** More than one-fourth of board members within the specified relationships defeats statutory independence. |\n| **S_CO-P1-C010** | Institutional and ordered-activity exclusions apply only to specified persons, relationships, regulation, incidental services, and regular-course activity. | S001 §§202(4), 203(c) | **Verified.** Bank affiliation alone is insufficient. |\n| **S_CO-P1-C011** | Foreclosure-protection exclusion does not establish a DMSA fee permission for that excluded activity. | S001 §203(b)(4) | Exclusion **verified**; alternative statute’s requirements **open**. |\n| **S_CO-P1-C012** | Employees/agents of registered providers need not separately register under §204(a); another-state registration only supports substitute application documentation. | S001 §§204(b), 212 | **Verified.** Does not establish factual agency or automatically authorize Colorado operation. |\n| **S_CO-P1-C013** | Issuance requires statutory application compliance; denial standards apply; limited temporary approval requires regulator action; delay does not create deemed approval. | S001 §§205–206, 209–210 | **Verified.** Temporary criminal-check approval limited to statutory conditions and no more than 120 days. |\n| **S_CO-P1-C014** | Annual July 1 renewal requires a complete application and fee; timely pending renewal can preserve status. | S001 §211(d)–(f); S009 renewal sections | **Verified.** Late/incomplete filing and stale displayed dates cannot be treated as proof of continuation. |\n| **S_CO-P1-C015** | Current instructions request $1,500 for counseling, $5,000 settlement, $5,000 both; initial PDF application and portal renewal routes are available. | S009 fee/renewal sections; S010 p. 1; S001 §§205(b)(1), 232(e) | **Operationally verified.** Dated fee-setting instrument held; no consumer pass-through authorization established. |\n| **S_CO-P1-C016** | No named provider’s registration status was verified. | S012 actual retrieval; S009 lookup context | **Access finding.** Loading/CSS failure is not a no-match search result. |\n| **S_CO-P1-C017** | Education and financial analysis precede contracting; periodic-payment plans also require suitability, ability-to-pay, and creditor-acceptance determinations. | S001 §217(a)–(c) | **Verified.** Registration and numerical fee compliance alone do not satisfy these conditions. |\n| **S_CO-P1-C018** | Direct/indirect fees must be authorized; charges/payment require a compliant agreement signed by both parties. | S001 §223(a)–(b); §§217(a), 219(a)(6)(B) | **Verified.** Required fee disclosure is distinct from a payment demand. |\n| **S_CO-P1-C019** | Applicable DMP setup cap is $50; monthly cap is min($10 × remaining creditors, $50). | S001 §223(d)(1)(A)–(B); S011 | **Verified statutory figures.** Federal timing and other legal constraints remain separate. |\n| **S_CO-P1-C020** | Principal-reduction fees cannot be requested/received until an executed settlement, at least one creditor/collector payment, and applicable-rule compliance. | S001 §223(d)(2)(A)(i)–(iii); §228(a)(2) | **Verified state trigger.** A savings deposit or provider payment alone does not meet it. |\n| **S_CO-P1-C021** | For a consumer completing all agreement obligations, fees plus aggregate settlement offers obtained cannot exceed agreement-date principal. | S001 §§202(14), 223(d)(2)(B) | **Verified.** Do not erase completion condition or replace statutory offer measure with an unsupported measure. |\n| **S_CO-P1-C022** | Rule 4 reproduction reports proportional enrollment-debt or invariant savings-percentage methods; no numerical settlement percentage is cleared by this pass. | S007 Rule 4(a)(1); S005 purpose; S001 §223(d)(2)(C) | **Partial.** Full official adopted text S006 unread; federal formula verification does not substitute for it. |\n| **S_CO-P1-C023** | Separate education/counseling fees after assent are generally prohibited, with administrator authorization and §228(d) exceptions. | S001 §§223(c), 228(d) | **Verified.** No provider-specific authorization or amount verified. |\n| **S_CO-P1-C024** | The reproduced standalone $100/administrator-approved-larger-fee and 90-day refund provisions cannot yet be treated as cleared current charging authority. | S003 §5; S007 Rule 4(b), (b)(1); S006 | **Held.** Statutory repeal and stale reproduced cross-reference require official-text comparison. |\n| **S_CO-P1-C025** | DMP and settlement fee families cannot both be imposed or received. | S001 §223(d)(3) | **Verified.** Mixed-service labeling does not authorize stacking. |\n| **S_CO-P1-C026** | Dishonor charge must be reasonable and ≤ min($25, other-law limit). | S001 §223(f) | **Verified formula**; specific charge held until other law and facts are checked. |\n| **S_CO-P1-C027** | Contributions cannot be solicited; accepted amounts remain within permitted aggregate through 30 days after completion/termination. | S001 §224 | **Verified.** No donation-based evasion. |\n| **S_CO-P1-C028** | No added expense for settlement-fee deferral; unrelated-product, specified referral/credit-arrangement compensation, and unfairness restrictions remain. | S001 §228(a)(7), (15), (b)(3), (7), (d) | **Verified.** Government-program exception in (d) preserved. |\n| **S_CO-P1-C029** | Three-business-day cancellation entails the specified all-money refund; specified defects extend cancellation to 30 days; emergency waiver is narrow. | S001 §220(a)–(c) | **Verified.** No standard-form emergency waiver. |\n| **S_CO-P1-C030** | Later termination is without penalty; unexpended/trust funds return under §§219, 222, 226; only properly payable/earned fees may be retained under applicable provisions. | S001 §§202(20)(B)(v), 219(d), 222(h), 226(b), 228(a)(4) | **Verified framework.** No blanket refund or retention conclusion for later-failed installment settlements. |\n| **S_CO-P1-C031** | Unauthorized charges and absence of required registration can make the agreement voidable. | S001 §225(a)–(c) | **Verified narrow consequence.** Full remedies pass remains open. |\n| **S_CO-P1-C032** | Historical CPI mechanism cannot justify an invented current adjustment; official records show 2011 repeal of former inflation provisions. | S001 §§223, 232; S014 former §12-14.5-232(f)–(g); S015 pp. 134–135; S017 items 1(c), 3 | **Strong corroboration/current statutory text.** Original 2011 act route failed; no higher current notice verified. |\n| **S_CO-P1-C033** | Former 18% aggregate/4% setup figures are historical, not current verified settlement caps. | S020 p. 1 n.4; S015 pp. 134–135; S001 §223 | **Historical agency evidence.** Report read by parallel agent; synthesis retry failed. |\n| **S_CO-P1-C034** | Statutory fee changes took effect March 1, 2025; rule is officially listed effective March 30; 2026 annual expiration was postponed. | S003 §§5–6; S004–S005; S008 §1(1)(i) | **Verified dates/status metadata.** Transition period and full adopted wording held; no exhaustive stay/vacatur certification. |\n| **S_CO-P1-C035** | TSR coverage can include settlement, interest/fee concessions, and qualifying inbound advertising responses; attorney/nonprofit labels do not resolve coverage. | S018 §§310.2(o), (ii), 310.6(b)(5)(i), (6)(i); S019 coverage section | **Verified federal framework**, conditional on jurisdiction, transaction, and applicable exemptions. |\n| **S_CO-P1-C036** | Covered TSR fees require executed debt alteration plus one payment and prescribed allocation for individually resolved debts. | S018 §310.4(a)(5)(i)(A)–(C) | **Verified.** Applies independently of Colorado’s ceiling or registration. |\n| **S_CO-P1-C037** | Qualifying dedicated accounts preserve consumer ownership and withdrawal rights; funding is not fee collection. | S001 §202(20)(B); S018 §310.4(a)(5)(ii)(A)–(E) | **Verified.** Colorado immediate-return requirement is not relaxed by federal seven-business-day provision. |\n\n## D. Worked examples and coverage\n\n### D.1 Bounded plain-text examples\n\nAll figures are hypothetical U.S. dollars. Each calculation is exact to whole dollars; **no rounding is required**. A numerical result does not establish registration, plan suitability, consumer assent, service performance, or other required conditions.\n\n#### Example 1 — Lower-debt DMP\n\nInputs: $1,000 enrolled debt; two creditors remain when the monthly fee is assessed.\n\nBase: remaining creditors, not debt dollars.\n\nOperator: minimum of ($10 × 2) and $50.\n\nIntermediate: $10 × 2 = $20.\n\nResult: statutory monthly ceiling = **$20**. Setup ceiling = **$50**, separately.\n\nConditions: applicable §223(d)(1) plan, suitable payment obligations, compliant agreement, lawful services, and any federal timing satisfied. This does not mean a $50 setup fee is automatically payable at signup. **[C017–C019, C036]**\n\n#### Example 2 — DMP creditor count changes\n\nInputs: six creditors remain in month 1; three remain in month 2.\n\nMonth 1: min($10 × 6, $50) = min($60, $50) = **$50**.\n\nMonth 2: min($10 × 3, $50) = min($30, $50) = **$30**.\n\nThe original six-creditor count cannot support another $50 monthly assessment after only three remain. Counting six accounts held by three creditors would also require the statutory creditor measure, not automatic account multiplication. **[C019]**\n\n#### Example 3 — Partial settlement under the verified federal proportional method\n\nAssumptions: TSR applies; enrolled debts total $20,000; the hypothetical contract’s total fee is 20% of enrolled debt. **20% is an example rate, not a Colorado ceiling.**\n\nInputs: debt A = $5,000; debt B = $15,000.\n\nTotal contract fee: $20,000 × 0.20 = $4,000.\n\nA’s proportion: $5,000 ÷ $20,000 = 0.25.\n\nA’s allocated fee: $4,000 × 0.25 = **$1,000**.\n\nIf A has the required executed settlement and creditor payment but B remains unresolved, the first resolution does not support collecting the entire $4,000. If $500 of A’s fee has already been lawfully collected, the remaining A allocation is $1,000 − $500 = **$500**.\n\nThis verifies the federal arithmetic and performance boundary. **Colorado Rule 4’s official-text comparison remains a hold before approving the fee schedule. [C020–C022, C036]**\n\n#### Example 4 — Savings fee uses the correct base\n\nAssumptions: TSR applies; a hypothetical 25% savings rate; the debt has been fully satisfied, so the actual satisfaction amount is known.\n\nInputs: enrollment debt = $5,000; later displayed balance = $5,800; actual amount paid to satisfy debt = $3,000.\n\nSavings base: $5,000 − $3,000 = $2,000.\n\nFee arithmetic: $2,000 × 0.25 = **$500**.\n\nUsing the later $5,800 balance would produce $700 and would use the wrong federal base. Using only a first installment of the $3,000 settlement as the satisfaction amount would also overstate savings. The same percentage must apply from debt to debt under this method.\n\nAgain, the percentage is hypothetical and Colorado’s full-rule verification remains held. Full payoff is assumed to make this example’s base certain; it is not substituted for the statute’s first-payment trigger. **[C020, C022, C036]**\n\n#### Example 5 — Completed-plan aggregate cap with previous fees\n\nInputs: agreement-date principal = $20,000; aggregate settlement offers obtained = $17,000; all consumer obligations completed; $1,000 of fees already paid.\n\nTotal fee headroom: $20,000 − $17,000 = **$3,000**.\n\nRemaining headroom: $3,000 − $1,000 = **$2,000**.\n\nA contract demanding another $3,000 would exceed this aggregate protection by $1,000. The $2,000 figure is an outer constraint, not independent authorization to collect it; all other fee and timing rules still apply. **[C021]**\n\n#### Example 6 — Low debt defeats a larger percentage-based demand\n\nInputs: agreement-date principal = $1,000; settlement offer = $800; all consumer obligations completed; hypothetical fee = 25% of $1,000.\n\nProposed fee: $1,000 × 0.25 = $250.\n\nCombined amount: $800 + $250 = $1,050.\n\nExcess: $1,050 − $1,000 = **$50**.\n\nMaximum aggregate headroom: $1,000 − $800 = **$200**.\n\nThe proposed $250 fee fails the verified state aggregate condition. This example establishes neither a lawful 25% rate nor automatic permission to collect $200. **[C021–C022]**\n\n#### Example 7 — Cancellation before any settlement performance\n\nInputs: $1,500 in consumer funds; no executed creditor settlement; no payment under a creditor settlement; no other properly earned fee.\n\nSettlement fee satisfying the verified state trigger: **$0**.\n\nReturn calculation: $1,500 − $0 = **$1,500**.\n\nAn enrollment charge cannot become earned merely because the consumer accumulated settlement funds. No cancellation penalty is added. **[C020, C030, C037]**\n\n#### Example 8 — Three-business-day DMP cancellation\n\nAssumptions: no valid emergency waiver; no creditor disbursement; timely cancellation.\n\nInputs: $50 setup fee paid; $200 deposited for debt payments.\n\nRefund: $50 + $200 = **$250**.\n\nThis is the statutory early-cancellation example. Later termination requires a different analysis and does not automatically unwind every fee lawfully earned and paid. **[C029–C030]**\n\n#### Example 9 — Standalone education: hold rather than presumed permission\n\nInputs: proposed $80 standalone counseling charge; consumer later signs a plan 60 days after counseling ends.\n\nBoundary arithmetic: 60 days < 90 days; the reproduced Rule 4 would indicate an **$80 refund**.\n\nResult for this investigation: **hold the charging pathway and refund implementation** pending the official adopted text and cross-reference comparison. Do not recharacterize the reproduced refund as an optional $80 account credit. **[C024]**\n\n#### Example 10 — Noncustodial and nonprofit boundary failures\n\nNoncustodial inputs: an out-of-state company offers to negotiate personal credit-card principal reductions for a Colorado resident; the consumer pays creditors directly.\n\nClassification: intermediary concession services remain potentially covered. Without verified registration, genuine agency under a registered provider, or an applicable exclusion, **no lawful fee scenario is established for that company**. **[C002–C003, C012–C013]**\n\nNonprofit inputs: consumer pays $0; creditor pays provider $50 for the services.\n\nCompensation received: $0 + $50 = **$50**.\n\nResult: the no-compensation exclusion does not apply merely because the consumer’s charge is zero. **[C009]**\n\n#### Example 11 — Own-creditor boundary\n\nInputs: creditor owns its own $6,000 receivable and directly accepts $4,000 from its debtor; no separate intermediary is involved.\n\nDifference: $6,000 − $4,000 = **$2,000**.\n\nClassification: the $4,000 is debt satisfaction and the $2,000 is a concession—not, on these assumed facts, a provider settlement fee. The definition-based conclusion does not clear collection, servicing, lending, tax, or assignment issues. **[C005]**\n\n#### Example 12 — Dishonor charge cannot be finalized from $25 alone\n\nInputs: proposed charge $25; reasonable charge on the facts assumed to be $18; other-law limit not yet verified.\n\nOperator: minimum of $18, $25, and the applicable other-law limit.\n\nResult: **no more than $18, but exact permissible charge held** until the other-law limit is established. **[C026]**\n\n### D.2 Component coverage and exact next investigations\n\n| Scope component | Status | Claims | Exact missing evidence or next investigation |\n| --- | --- | --- | --- |\n| Core intermediary/concession classification | **Answered** | C001–C002 | Apply definition to actual contracts, advertisements, and service roles before a provider-specific conclusion. |\n| Principal reduction versus finance-charge/fee concession DMP | **Answered** | C002, C019–C021 | For a mixed plan, establish which statutory fee family applies; do not stack both. |\n| Custodial/noncustodial and remote-provider nexus | **Answered** | C003, C012, C037 | Provider-specific custody, agency, residence knowledge, and account facts remain necessary. |\n| Consumer/business and mixed-purpose boundaries | **Partial** | C004 | Determine debt purpose, debtor identity, guarantees, and provider’s relevant business segment; research controlling interpretations if facts are mixed. |\n| Pure education, bill payment, own-creditor boundary | **Partial** | C005–C006 | Verify whether intermediation or an offer through others exists; inspect applicable alternative regimes. |\n| Nonprofit and institutional exclusions | **Answered as legal tests** | C009–C010 | Actual compensation, governance, charter, banking supervision, control, and incidental-activity evidence needed for an entity claim. |\n| Attorney/CPA/enrolled-agent exclusions | **Answered as legal tests; individual application open** | C007–C008 | Verify professional status, actual services, client relationship, employment/supervision; establish current Rule 205.1 eligibility if relevant. |\n| Statutory registration pathway | **Answered** | C001, C012–C014, C017 | Provider-specific issuance and continuing compliance are separate. |\n| Current application and renewal route | **Answered operationally** | C015 | Recheck linked instructions at actual filing time; no filing authorized or performed here. |\n| Named-provider public status | **Unresolved** | C016 | Retry the ordinary public report interface; match legal entity/DBA, registration number, activity, status, renewal evidence, and any restrictions. Failed route: S012 loading/CSS error. |\n| Current provider administrative fee authority chain | **Partial** | C015 | Retrieve the dated administrative fee schedule/order establishing $1,500/$5,000 and reconcile it with historical Rule 1. |\n| DMP statutory amounts and assessment base | **Answered** | C018–C019, C025 | No higher adjusted amount verified; do not apply CPI independently. |\n| Settlement state performance trigger and completed-plan aggregate | **Answered** | C020–C021 | Actual consumer execution, creditor payment, agreement-date principal, settlement offers, completion, and previous fees must be documented. |\n| Full current 4 CCR 902-2 and adoption materials | **Unresolved primary-text comparison** | C022, C024, C034 | Obtain readable official current PDF/adopted DOCX and final basis/adoption materials; compare all operative provisions, including Rules 1–4, against the reproduction. Failed routes: S006 and unusable current PDF retrieval. |\n| Standalone education $100/larger approved fee and 90-day refund | **Held** | C023–C024 | Confirm official final wording, scope, stale cross-reference, and any public interpretation or applicable provider authorization. |\n| Historical CPI and retired percentage figures | **Answered for nonreliance; historical act comparison partial** | C032–C033 | Retrieve original HB11-1206 through another ordinary public document route if a complete historical chain is required. No invented indexed amount. |\n| March 1–29, 2025 transition | **Excluded from current-baseline conclusion; open historically** | C034 | Compare effective clauses, final adoption materials, and any transition interpretation for conduct during those dates. |\n| Federal TSR timing/allocation common context | **Answered conditionally** | C035–C037 | Provider-specific telemarketing, jurisdiction, nonprofit, and transaction-exemption analysis remains necessary. |\n| Cancellation and earned/unearned fee boundary | **Answered in part** | C029–C031 | Research contract/case treatment of later-failed installment settlements, disputed earned fees, and incomplete-plan charges. |\n| Dishonor and third-party account charges | **Partial** | C026, C037 | Identify applicable other-law dishonor ceiling and any independently lawful third-party charge; no extra provider fee assumed. |\n| Rule litigation/status | **Partial** | C008, C034 | Targeted searches did not establish a stay/vacatur, but full citator and docket treatment remains required for comprehensive case-law coverage. |\n| Agreements, funds, bond, remedies | **Later required passes remain open** | Narrow intersections: C013, C017–C018, C029–C031, C037 | Full agreement/e-signature/disclosure review; trust operations and reconciliations; bond/substitute requirements; enforcement and remedy analysis. |\n| Collection, litigation, limitations, execution exemptions | **Excluded from this component; open** | — | Separate controlling statutes, rules, procedures, limitations/revival, garnishment and property-exemption investigations. |\n| Secured debt/foreclosure, sector, local, tribal, contracts, full case law | **Excluded from this component; open** | C011 only identifies a boundary | Separate investigations of each applicable regime. No clearance inferred from Part 2 exclusion. |\n| Full Colorado dossier / A066 acceptance | **Not established** | — | Complete remaining components and resolve material holds before any acceptance decision. |\n\n## E. Researcher self-check\n\n**Actual reading.** The research retrieved the relevant 2026 statutory passages, enacted HB24-1380 and SB26-083 provisions, official SOS version and docket records, actual current application instructions, AG operational materials, relevant *Coffman* passages, official historical legislative materials, and the exact federal TSR provisions materially used. These were not treated as search-snippet evidence.\n\n**Material documents not read successfully.** The official final 2025 rule attachment and final basis attachment did not yield readable content. The Cornell Rule 4 reproduction was read and expressly identified as secondary. The original 2011 act route failed. The 2011 annual report was read by a parallel research agent, while subsequent synthesis retrieval attempts timed out. No named-provider registry record was obtained.\n\n**Version discipline.** Current statutes, official current-rule metadata, a secondary rule reproduction, proposed materials, archived rules, historical agency statements, and future repeal dates are separated. Webpage updates and filenames were not used as legal effective dates. The 2026 rule extension was checked without treating it as proof of substantive validity.\n\n**Calculation discipline.** Examples use explicit bases and operators, preserve the distinction between agreement-date principal and enrollment-date debt, account for previous fees, and show partial-settlement and cancellation boundaries. Hypothetical percentages are not represented as Colorado statutory caps. No CPI adjustment was calculated.\n\n**Research mode and action limits.** The requested chatgpt.com model selector was not available to verify or change in this session. Research proceeded in the available ordinary-chat environment with parallel task agents within this conversation. No DeepResearch or separate Chat conversations were opened. No application was filed, person contacted, purchase made, account changed, or publication performed.\n\n**Component conclusion:** The statutory market-access pathway and principal statutory fee constraints are established. The exact current-rule comparison, administrative fee-setting instrument, and provider-specific authorization remain explicit holds. All later Colorado passes remain open.\n\nEND S_CO PASS-01\n\n","tables":[{"headers":["Actual activity or relationship","Classification and boundary"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Actual activity or relationship","Classification and boundary"],["Negotiating acceptance of less than the statutory principal amount","Principal-reduction settlement under §223(d)(2). The statutory definition of principal uses the debt amount at the time of the provider agreement, not necessarily the original loan principal."],["Obtaining reduced interest, finance charges, late fees, default fees, or delinquency fees while arranging repayment","Concession-based services; the fee structure in §223(d)(1) applies to plans contemplating those concessions."],["Receiving one payment and distributing it among creditors while obtaining concessions","Covered intermediary activity. Custody creates additional obligations; it is not the element that creates coverage."],["Negotiating concessions while consumers pay creditors themselves","Potentially covered on the same definition. No custody requirement appears in §202(8)."],["Arranging an independent dedicated account","Does not remove the provider from coverage. The current application expressly accommodates noncustodial providers that suggest or arrange third-party accounts."],["Financial education without offering or performing intermediary concession services","May fall outside the core definition. A provider offering subsequent negotiation cannot establish exclusion merely by calling the first service “education.”"],["Bill payment without concession activity","May fall outside the definition; §203(c)(4) also supplies a specific incidental-services exclusion, discussed below."],["A creditor negotiating only its own receivable directly with its debtor","Definition-based inference: ordinarily there is no intermediary between the debtor and another creditor. This is not an express general “self-creditor exemption,” and it does not automatically resolve collectors, servicers, affiliates, or debt purchasers."],["Credit repair combined with negotiation or a DMP","§5-19-114 requires compliance with Part 2 when a credit services organization also performs debt-management services; Part 2 controls a conflict between the two parts."]]},{"headers":["Exclusion or special situation","Required conditions and failure cases"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Exclusion or special situation","Required conditions and failure cases"],["Attorney legal services","Actual legal services in an attorney-client relationship, provided by an attorney licensed to practice in Colorado. A lawyer’s ownership, referral, retainer label, or nominal affiliation is insufficient. The professional exclusion does not extend to a nonemployee merely providing services on the professional’s behalf."],["Out-of-state attorney","Coffman v. Williamson recognizes that qualifying limited Colorado authorization under C.R.C.P. 205.1 can satisfy the licensing element. It also holds that attorney status alone does not establish the other elements. A particular practice’s current eligibility under the admission rules remains to be verified."],["CPA","Accounting services in an accountant-client relationship by a CPA certified or authorized by Colorado’s accountancy board. The nonemployee restriction also applies."],["Enrolled agent","Treasury-authorized, good-standing enrolled agent; tax representation before the IRS, Colorado Department of Revenue, or Colorado Department of Labor and Employment; enrolled-agent/client relationship; no other debt-management services."],["No-compensation provider","No compensation for the services from or on behalf of the individuals or from their creditors. “Free to the consumer” fails this exclusion if the creditor compensates the provider."],["Nonprofit","No general nonprofit exclusion. Applicants must substantiate applicable status, and §209 imposes board-independence conditions. A nonprofit or tax-exempt label alone is insufficient."],["Bank","Must meet §202(4)’s charter, banking-business, and banking-regulation definition. The definition lists several institutional forms; their names alone are not the complete test."],["Bank affiliate","The relevant control relationship must exist, and the affiliate itself must be regulated by a federal or state banking regulatory authority."],["Judicial or ordered activity","Judicial officer, person acting under court or administrative-agency order, or assignee for benefit of creditors, acting within the specified regular-course condition."],["Incidental bill payment","Title insurer, escrow company, or other bill-paying person, where debt-management services are incidental to bill-paying services, within the regular-course condition."],["Foreclosure-protection activity","Section 203(b)(4) excludes a provider subject to the Colorado Foreclosure Protection Act. This allocates activity to another legal regime; it does not establish a settlement-fee permission under that other regime."],["Employee or agent of registered provider","Section 204(b) removes the separate §204(a) registration requirement. This provision includes agents and is distinct from the professional exclusion’s nonemployee restriction."],["Registration elsewhere","Section 212 permits substitute application documentation under conditions. It does not make another state’s license automatic Colorado authorization."]]},{"headers":["Fee or charge","Verified statutory treatment","Conditions or limitation"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Fee or charge","Verified statutory treatment","Conditions or limitation"],["DMP setup","Up to $50 for consultation, obtaining a credit report, and setting up an account.","§223(d)(1)(A); applicable concession-based plan and compliant signed agreement."],["DMP monthly service","Up to $10 × creditors remaining in the plan when assessed, capped at $50 in any month.","The statutory unit is creditors, not accounts, original enrolled debts, or original creditor count."],["DMP lifetime or debt-percentage cap","Section 223(d)(1) supplies setup and monthly limits, not a separate debt-percentage or plan-lifetime ceiling.","This does not remove suitability, unfairness, agreement, or other-law constraints."],["Principal-reduction settlement fee","No payment request or receipt before the state performance conditions in §223(d)(2)(A).","Any fee or consideration is covered; relabeling a charge as enrollment or setup does not bypass the condition."],["Completed settlement plan aggregate","Fees plus the aggregate settlement offers obtained may not exceed agreement-date principal when the individual completes all obligations under the agreement.","§223(d)(2)(B). Preserve the completion condition and the statutory “offers of settlement” measure."],["Fixed numerical settlement percentage","No current fixed percentage ceiling was established from the verified current primary text.","Do not use 18%, 20%, 25%, or another commercial rate as a verified Colorado cap. Full current Rule 4 remains a primary-text hold."],["Education/counseling after assent to a provider agreement","Generally no separate charge. The administrator may authorize a fee based on the nature and extent of the services; §228(d) also matters.","No particular provider’s authorization or approved amount was verified."],["DMP plus settlement fee stacking","Fees may not be imposed or received under both §223(d)(1) and §223(d)(2).","§223(d)(3)."],["Dishonored consumer payment","Reasonable charge no greater than the lesser of $25 and the amount permitted by other law.","$25 is not automatic authorization; the other-law ceiling and reasonableness must also be satisfied."],["“Voluntary” contribution","May not be solicited from the individual or affiliate. Accepted contributions count toward the permitted aggregate through 30 days after plan completion or termination.","§224 prevents using contributions to exceed ordinary limits during that period."],["Settlement-fee financing","Deferral is permitted only at no additional expense to the individual.","§228(b)(3)."],["Unrelated products and referral compensation","Restrictions cover unrelated insurance, clubs, coupons, computer access, and specified compensation for arranging credit or other services.","§§228(b)(7), 228(d); the latter includes a government-program education/counseling exception."]]},{"headers":["Historical material","Reconciliation with this baseline"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Historical material","Reconciliation with this baseline"],["Former 18% aggregate / 4% setup settlement structure described in the AG’s 2011 annual report","Historical, not a current fee schedule. The official 2011 legislative digest describes removal of the former statutory settlement fee cap effective July 1, 2011."],["Archived Rule 2 CPI mechanism","Cannot support a newly calculated 2026 amount. The official Red Book records repeal of former §12-14.5-232(f)–(g), effective July 1, 2011."],["AG’s 2013 regulatory agenda","Calls the CPI rule outdated and proposes repeal. This is evidence of historical agency treatment, not proof that the proposed rule repeal was completed."],["Current §223 and current AG consumer guidance","Support the $50 setup and $10-per-remaining-creditor/$50-monthly statutory structure. No higher current adjusted amount was verified."],["HB24-1380","Replaced the former statutory settlement allocation language with a rule-compliance requirement and repealed the standalone education/refund subsections effective March 1, 2025."],["March 30, 2025 rule","Its listed effective date is later than the March 1 statutory changes. This pass does not resolve the historical March 1–29 transition period."],["SB26-083","Postponed the annual expiration of covered Department of Law rules adopted in the relevant 2024–2025 window. This supports continued listed status; it does not cure substantive defects or prove absence of a judicial restriction."]]},{"headers":["Provider activity","Current registration/renewal amount displayed by AG"],"index":4,"links":[],"row_links":[[],[],[],[]],"rows":[["Provider activity","Current registration/renewal amount displayed by AG"],["Credit counseling","$1,500"],["Debt settlement","$5,000"],["Both","$5,000"]]},{"headers":["Source ID","Document / issuer and direct literal URL","Exact pinpoint, version, legal status, and access limitation"],"index":5,"links":[{"href":"https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com","text":"https://olls.info/crs/crs2026-title-05.htm"},{"href":"https://olls.info/crs/crs2026-title-05.pdf?utm_source=chatgpt.com","text":"https://olls.info/crs/crs2026-title-05.pdf"},{"href":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download?utm_source=chatgpt.com","text":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download"},{"href":"https://leg.colorado.gov/bill_files/44318/download?utm_source=chatgpt.com","text":"https://leg.colorado.gov/bill_files/44318/download"},{"href":"https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980&utm_source=chatgpt.com","text":"https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980"},{"href":"https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603&utm_source=chatgpt.com","text":"https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603"},{"href":"https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx","text":"https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx"},{"href":"https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc","text":"https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc"},{"href":"https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4"},{"href":"https://leg.colorado.gov/laws/session-laws/SB26-083/106/download?utm_source=chatgpt.com","text":"https://leg.colorado.gov/laws/session-laws/SB26-083/106/download"},{"href":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/?utm_source=chatgpt.com","text":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/"},{"href":"https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf?utm_source=chatgpt.com","text":"https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf"},{"href":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/?utm_source=chatgpt.com","text":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/"},{"href":"https://licensing.coag.gov/s/public-reports?utm_source=chatgpt.com","text":"https://licensing.coag.gov/s/public-reports"},{"href":"https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf?utm_source=chatgpt.com","text":"https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf"},{"href":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011?utm_source=chatgpt.com","text":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011"},{"href":"https://leg.colorado.gov/sites/default/files/digest2011.pdf?utm_source=chatgpt.com","text":"https://leg.colorado.gov/sites/default/files/digest2011.pdf"},{"href":"https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291&utm_source=chatgpt.com","text":"https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291"},{"href":"https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf?utm_source=chatgpt.com","text":"https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf"},{"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-310.4?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-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"},{"href":"https://www.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://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf","text":"https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf"},{"href":"https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf?utm_source=chatgpt.com","text":"https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf"},{"href":"https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf?utm_source=chatgpt.com","text":"https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf"},{"href":"https://scholar.law.colorado.edu/session-laws-2001-2050/4873/","text":"https://scholar.law.colorado.edu/session-laws-2001-2050/4873/"},{"href":"https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050","text":"https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050"}],"row_links":[[],[{"href":"https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com","text":"https://olls.info/crs/crs2026-title-05.htm"},{"href":"https://olls.info/crs/crs2026-title-05.pdf?utm_source=chatgpt.com","text":"https://olls.info/crs/crs2026-title-05.pdf"}],[{"href":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download?utm_source=chatgpt.com","text":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download"}],[{"href":"https://leg.colorado.gov/bill_files/44318/download?utm_source=chatgpt.com","text":"https://leg.colorado.gov/bill_files/44318/download"}],[{"href":"https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980&utm_source=chatgpt.com","text":"https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980"}],[{"href":"https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603&utm_source=chatgpt.com","text":"https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603"}],[{"href":"https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx","text":"https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx"},{"href":"https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc","text":"https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc"}],[{"href":"https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4"}],[{"href":"https://leg.colorado.gov/laws/session-laws/SB26-083/106/download?utm_source=chatgpt.com","text":"https://leg.colorado.gov/laws/session-laws/SB26-083/106/download"}],[{"href":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/?utm_source=chatgpt.com","text":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/"}],[{"href":"https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf?utm_source=chatgpt.com","text":"https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf"}],[{"href":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/?utm_source=chatgpt.com","text":"https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/"}],[{"href":"https://licensing.coag.gov/s/public-reports?utm_source=chatgpt.com","text":"https://licensing.coag.gov/s/public-reports"}],[{"href":"https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf?utm_source=chatgpt.com","text":"https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf"}],[{"href":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011?utm_source=chatgpt.com","text":"https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011"}],[{"href":"https://leg.colorado.gov/sites/default/files/digest2011.pdf?utm_source=chatgpt.com","text":"https://leg.colorado.gov/sites/default/files/digest2011.pdf"}],[{"href":"https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291&utm_source=chatgpt.com","text":"https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291"}],[{"href":"https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf?utm_source=chatgpt.com","text":"https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf"}],[{"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-310.4?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-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"}],[{"href":"https://www.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://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf","text":"https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf"}],[{"href":"https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf?utm_source=chatgpt.com","text":"https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf"}],[{"href":"https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf?utm_source=chatgpt.com","text":"https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf"}],[{"href":"https://scholar.law.colorado.edu/session-laws-2001-2050/4873/","text":"https://scholar.law.colorado.edu/session-laws-2001-2050/4873/"},{"href":"https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050","text":"https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050"}]],"rows":[["Source ID","Document / issuer and direct literal URL","Exact pinpoint, version, legal status, and access limitation"],["S_CO-P1-S001","Colorado Revised Statutes 2026, Title 5, OLLS. https://olls.info/crs/crs2026-title-05.htm ; https://olls.info/crs/crs2026-title-05.pdf","A—read relevant operative passages. §§5-19-114; 202–212; 217; 219–228; 231–232; 242. Current 2026 compilation. One document ID reused across sections and formats. Colorado substantive law; selected relevant provisions, not every page of Title 5."],["S_CO-P1-S002","2026 CRS Titles Download, Colorado General Assembly/OLLS. https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download","A—read. Official publication route linking the 2026 title files. Establishes provenance/current compilation, not a substitute for statutory text."],["S_CO-P1-S003","HB24-1380, signed act, Colorado General Assembly. https://leg.colorado.gov/bill_files/44318/download","A—read. §5, pp. 4–6; §6 effective-date provisions. Rule authority effective August 7, 2024; specified fee amendment/repeals effective March 1, 2025. Enacted law, not proposed bill text."],["S_CO-P1-S004","4 CCR 902-2 official version index, Colorado Secretary of State. https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980","A—read. “Current version” row: adopted February 7, 2025; published March 10; effective March 30. Also identifies archived versions. Metadata verified; full current rule text not retrieved from this index."],["S_CO-P1-S005","eDocket 2024-00603, Colorado Secretary of State. https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603","A—read. Purpose/objective, adopted-rule section, dates and attachment links. Confirms permanent filing and stated intent to retain former fee structure. Its statutory-authority field contains a subsection-reference inconsistency; enacted §223(d)(2)(C) controls."],["S_CO-P1-S006","Official adopted rule attachment, Department of Law/SOS. https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx","A—attempted, not read. Unsupported-document/HTTP retrieval failures. Full operative wording remains held. Related basis attachment also failed: https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc. No inference that either document is legally absent."],["S_CO-P1-S007","4 CCR 902-2, Rule 4 reproduction, Cornell LII. https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4","A—full reproduced Rule 4 read. Clauses (a)(1), (b), (b)(1); note reports March 30, 2025 effectiveness. Secondary transcription, not primary adoption verification. Refund cross-reference problem preserved."],["S_CO-P1-S008","SB26-083, chapter 106, Administrative Rule Review, Colorado General Assembly. https://leg.colorado.gov/laws/session-laws/SB26-083/106/download","A—full two-page act read. §1(1), especially (i), printed pp. 433–434; §2; approved May 5, 2026. Postpones annual expiration of covered Department of Law rules. Does not establish substantive validity or lack of injunction."],["S_CO-P1-S009","Debt Management Registration, Colorado AG. https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/","A—read. Opening coverage description; application link; renewal dates; administrative fees; pending-renewal note. Current operational evidence, not independent legal authority for consumer charges."],["S_CO-P1-S010","Debt Management Services Provider Application & Instructions, Colorado Department of Law. https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf","A—relevant instructions/checklist and model fields read. p. 1 submission and fees; pp. 2–7 requirements; p. 9 custody/third-party-account categories. Current linked 33-page application. Filename is not a legal effective date. “Notification” heading and erroneous rule-number reference do not supersede the statute."],["S_CO-P1-S011","Debt Management: Consumers, Colorado AG. https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/","A—read. Consumer fee and cancellation explanations; lookup route. Agency summary. Its “debts” wording does not replace §223(d)(1)(B)’s “creditors” measure."],["S_CO-P1-S012","Public Reports, Colorado AG licensing system. https://licensing.coag.gov/s/public-reports","A—attempted; error page read. Loading/CSS failure. No provider record or search result verified."],["S_CO-P1-S013","Coffman v. Williamson, 2015 CO 35, 348 P.3d 929, Colorado Supreme Court. https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf","A—relevant opinion passages read. ¶¶21, 31–42, 48–55; footnote 4. Colorado Supreme Court construction of professional exclusion and constitutional issues. Original-statute analysis distinguished from amended law. No exhaustive subsequent-history certification."],["S_CO-P1-S014","Red Book 2011, Colorado General Assembly/OLLS. https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011","A—relevant entries read. Former §12-14.5-232(f), (g): repeal by HB11-1206, ch. 113, §17, July 1, 2011. Official legislative disposition table; historical evidence."],["S_CO-P1-S015","2011 Digest of Bills, Colorado General Assembly. https://leg.colorado.gov/sites/default/files/digest2011.pdf","A—HB11-1206 entry read. Printed pp. 134–135. Describes repeal of settlement cap and inflation-adjustment mandate; effective July 1, 2011. Official legislative summary, not the enacted act itself."],["S_CO-P1-S016","Archived 4 CCR 902-2, SOS, ruleVersionId 7291. https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291","A—two-page document read. Rules 1–3: $1,000 administrative fee, CPI mechanism, insurance notice. Archived September 21, 2017 correction of older rules. Does not contain current Rule 4 and is not treated as the full current regulation."],["S_CO-P1-S017","Department of Law Regulatory Agenda for Calendar Year 2013, Colorado AG. https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf","A—full page read. Items 1(c), 3, 4. Describes outdated CPI/insurance rules and contemplated repeal. Historical proposed agenda, not an adoption order."],["S_CO-P1-S018","16 CFR Part 310, eCFR/Federal Register system. 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-310.4 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","A—operative provisions read. §§310.2(o), (ii); 310.4(a)(5)(i)–(ii); 310.6(b)(5)(i), (6)(i). eCFR displayed up to date October 21, 2026. One Part 310 source ID reused. Federal coverage conditional; eCFR is authoritative but unofficial."],["S_CO-P1-S019","Debt Relief Services & the TSR: A Guide for Business, FTC. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","A—relevant sections read. “Who’s Covered,” nonprofit/attorney explanations, collecting fees and dedicated accounts. Agency staff guidance, expressly nonbinding; current regulation controls."],["S_CO-P1-S020","2011 Annual Report—Colorado Debt-Management Services Providers, Department of Law, state-library copy. https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf","A—read by parallel research agent; synthesis retrieval retries timed out. p. 1, footnote 4, former 18%/4% structure and 2010/2011 timing changes. Historical agency report; not a current fee authorization."],["S_CO-P1-S021","Rules Governing Admission to Practice Law in Colorado, hosted by Colorado attorney-regulation office. https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf","A—Rule 205.1, printed p. 26, read. Corroborates limited-practice framework. Compilation’s current amendment status was not established; not used to clear a particular attorney’s present eligibility."],["S_CO-P1-S022","Proposed Statement of Basis and Purpose—DMSA Fees, Colorado AG. https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf","A—read. December 2024 rulemaking material. Proposed, not a substitute for the unread final adopted attachment."],["S_CO-P1-S023","HB11-1206 original session-law retrieval route, CU Law repository. https://scholar.law.colorado.edu/session-laws-2001-2050/4873/ ; https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050","A—metadata/discovery and failed full-text route. Full act retrieval returned access failure; not treated as freshly read enacted text. Current conclusions instead rest on S001 and the identified official historical corroboration."]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, confidence limits"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, confidence limits"],["S_CO-P1-C001","Part 2 establishes Colorado’s debt-management registration regime, administered by the designated AG official; current §242 schedules repeal September 1, 2035.","S001 §§202(1), 204–212, 242; S002","Verified current statutory framework. Future repeal is not current expiration."],["S_CO-P1-C002","Coverage turns on intermediary concession services for a natural person; providers include offers and services through others; statutory principal is agreement-date debt.","S001 §202(6), (8), (11), (14), (15), (17)","Verified. Marketing labels and original-loan principal are not substitutes for these definitions."],["S_CO-P1-C003","Custody is not a coverage prerequisite; Colorado-resident agreement nexus can reach remote providers.","S001 §§202(8), 203(a)–(b)(1), 204(a), 206(3), 206.7; S010 p. 9","Verified, subject to knowledge standard and exclusions. Remote employee permission has separate safeguards."],["S_CO-P1-C004","Natural-person focus and the business-debt exclusion limit scope; mixed-purpose facts cannot be resolved by a business label.","S001 §§202(11)–(12), 203(b)(3)","Text verified; mixed-purpose/guarantor application unresolved."],["S_CO-P1-C005","Pure education or bill payment may lack intermediary concession activity; direct own-creditor negotiation may likewise fall outside the definition.","S001 §§202(8), (15), 203(c)(4)","Qualified inference, not a general exemption or clearance under other laws."],["S_CO-P1-C006","A credit services organization also performing debt-management services must comply with Part 2; Part 2 controls a conflict.","S001 §114","Verified. Full credit-repair analysis remains outside this pass."],["S_CO-P1-C007","Attorney, CPA, and enrolled-agent exclusions require the specified professional services, relationships, and qualifications; nonemployee service providers do not inherit them.","S001 §202(8)(A)–(B)","Verified. Enrolled-agent exclusion additionally excludes other debt-management services."],["S_CO-P1-C008","Attorney status or affiliation alone is insufficient; Coffman requires real qualifying services and recognizes qualifying limited Colorado authorization.","S013 ¶¶31–42, 53; footnote 4; S001 §202(8)","Verified holding, with original/amended statute distinction. Current individual Rule 205.1 eligibility and exhaustive subsequent history not certified."],["S_CO-P1-C009","Nonprofit status alone does not exempt a provider; no-compensation exclusion includes creditor compensation; nonprofit applicants face independence requirements.","S001 §§203(b)(2), 205(b)(5), 209(c)–(d)","Verified. More than one-fourth of board members within the specified relationships defeats statutory independence."],["S_CO-P1-C010","Institutional and ordered-activity exclusions apply only to specified persons, relationships, regulation, incidental services, and regular-course activity.","S001 §§202(4), 203(c)","Verified. Bank affiliation alone is insufficient."],["S_CO-P1-C011","Foreclosure-protection exclusion does not establish a DMSA fee permission for that excluded activity.","S001 §203(b)(4)","Exclusion verified; alternative statute’s requirements open."],["S_CO-P1-C012","Employees/agents of registered providers need not separately register under §204(a); another-state registration only supports substitute application documentation.","S001 §§204(b), 212","Verified. Does not establish factual agency or automatically authorize Colorado operation."],["S_CO-P1-C013","Issuance requires statutory application compliance; denial standards apply; limited temporary approval requires regulator action; delay does not create deemed approval.","S001 §§205–206, 209–210","Verified. Temporary criminal-check approval limited to statutory conditions and no more than 120 days."],["S_CO-P1-C014","Annual July 1 renewal requires a complete application and fee; timely pending renewal can preserve status.","S001 §211(d)–(f); S009 renewal sections","Verified. Late/incomplete filing and stale displayed dates cannot be treated as proof of continuation."],["S_CO-P1-C015","Current instructions request $1,500 for counseling, $5,000 settlement, $5,000 both; initial PDF application and portal renewal routes are available.","S009 fee/renewal sections; S010 p. 1; S001 §§205(b)(1), 232(e)","Operationally verified. Dated fee-setting instrument held; no consumer pass-through authorization established."],["S_CO-P1-C016","No named provider’s registration status was verified.","S012 actual retrieval; S009 lookup context","Access finding. Loading/CSS failure is not a no-match search result."],["S_CO-P1-C017","Education and financial analysis precede contracting; periodic-payment plans also require suitability, ability-to-pay, and creditor-acceptance determinations.","S001 §217(a)–(c)","Verified. Registration and numerical fee compliance alone do not satisfy these conditions."],["S_CO-P1-C018","Direct/indirect fees must be authorized; charges/payment require a compliant agreement signed by both parties.","S001 §223(a)–(b); §§217(a), 219(a)(6)(B)","Verified. Required fee disclosure is distinct from a payment demand."],["S_CO-P1-C019","Applicable DMP setup cap is $50; monthly cap is min($10 × remaining creditors, $50).","S001 §223(d)(1)(A)–(B); S011","Verified statutory figures. Federal timing and other legal constraints remain separate."],["S_CO-P1-C020","Principal-reduction fees cannot be requested/received until an executed settlement, at least one creditor/collector payment, and applicable-rule compliance.","S001 §223(d)(2)(A)(i)–(iii); §228(a)(2)","Verified state trigger. A savings deposit or provider payment alone does not meet it."],["S_CO-P1-C021","For a consumer completing all agreement obligations, fees plus aggregate settlement offers obtained cannot exceed agreement-date principal.","S001 §§202(14), 223(d)(2)(B)","Verified. Do not erase completion condition or replace statutory offer measure with an unsupported measure."],["S_CO-P1-C022","Rule 4 reproduction reports proportional enrollment-debt or invariant savings-percentage methods; no numerical settlement percentage is cleared by this pass.","S007 Rule 4(a)(1); S005 purpose; S001 §223(d)(2)(C)","Partial. Full official adopted text S006 unread; federal formula verification does not substitute for it."],["S_CO-P1-C023","Separate education/counseling fees after assent are generally prohibited, with administrator authorization and §228(d) exceptions.","S001 §§223(c), 228(d)","Verified. No provider-specific authorization or amount verified."],["S_CO-P1-C024","The reproduced standalone $100/administrator-approved-larger-fee and 90-day refund provisions cannot yet be treated as cleared current charging authority.","S003 §5; S007 Rule 4(b), (b)(1); S006","Held. Statutory repeal and stale reproduced cross-reference require official-text comparison."],["S_CO-P1-C025","DMP and settlement fee families cannot both be imposed or received.","S001 §223(d)(3)","Verified. Mixed-service labeling does not authorize stacking."],["S_CO-P1-C026","Dishonor charge must be reasonable and ≤ min($25, other-law limit).","S001 §223(f)","Verified formula; specific charge held until other law and facts are checked."],["S_CO-P1-C027","Contributions cannot be solicited; accepted amounts remain within permitted aggregate through 30 days after completion/termination.","S001 §224","Verified. No donation-based evasion."],["S_CO-P1-C028","No added expense for settlement-fee deferral; unrelated-product, specified referral/credit-arrangement compensation, and unfairness restrictions remain.","S001 §228(a)(7), (15), (b)(3), (7), (d)","Verified. Government-program exception in (d) preserved."],["S_CO-P1-C029","Three-business-day cancellation entails the specified all-money refund; specified defects extend cancellation to 30 days; emergency waiver is narrow.","S001 §220(a)–(c)","Verified. No standard-form emergency waiver."],["S_CO-P1-C030","Later termination is without penalty; unexpended/trust funds return under §§219, 222, 226; only properly payable/earned fees may be retained under applicable provisions.","S001 §§202(20)(B)(v), 219(d), 222(h), 226(b), 228(a)(4)","Verified framework. No blanket refund or retention conclusion for later-failed installment settlements."],["S_CO-P1-C031","Unauthorized charges and absence of required registration can make the agreement voidable.","S001 §225(a)–(c)","Verified narrow consequence. Full remedies pass remains open."],["S_CO-P1-C032","Historical CPI mechanism cannot justify an invented current adjustment; official records show 2011 repeal of former inflation provisions.","S001 §§223, 232; S014 former §12-14.5-232(f)–(g); S015 pp. 134–135; S017 items 1(c), 3","Strong corroboration/current statutory text. Original 2011 act route failed; no higher current notice verified."],["S_CO-P1-C033","Former 18% aggregate/4% setup figures are historical, not current verified settlement caps.","S020 p. 1 n.4; S015 pp. 134–135; S001 §223","Historical agency evidence. Report read by parallel agent; synthesis retry failed."],["S_CO-P1-C034","Statutory fee changes took effect March 1, 2025; rule is officially listed effective March 30; 2026 annual expiration was postponed.","S003 §§5–6; S004–S005; S008 §1(1)(i)","Verified dates/status metadata. Transition period and full adopted wording held; no exhaustive stay/vacatur certification."],["S_CO-P1-C035","TSR coverage can include settlement, interest/fee concessions, and qualifying inbound advertising responses; attorney/nonprofit labels do not resolve coverage.","S018 §§310.2(o), (ii), 310.6(b)(5)(i), (6)(i); S019 coverage section","Verified federal framework, conditional on jurisdiction, transaction, and applicable exemptions."],["S_CO-P1-C036","Covered TSR fees require executed debt alteration plus one payment and prescribed allocation for individually resolved debts.","S018 §310.4(a)(5)(i)(A)–(C)","Verified. Applies independently of Colorado’s ceiling or registration."],["S_CO-P1-C037","Qualifying dedicated accounts preserve consumer ownership and withdrawal rights; funding is not fee collection.","S001 §202(20)(B); S018 §310.4(a)(5)(ii)(A)–(E)","Verified. Colorado immediate-return requirement is not relaxed by federal seven-business-day provision."]]},{"headers":["Scope component","Status","Claims","Exact missing evidence or next investigation"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Scope component","Status","Claims","Exact missing evidence or next investigation"],["Core intermediary/concession classification","Answered","C001–C002","Apply definition to actual contracts, advertisements, and service roles before a provider-specific conclusion."],["Principal reduction versus finance-charge/fee concession DMP","Answered","C002, C019–C021","For a mixed plan, establish which statutory fee family applies; do not stack both."],["Custodial/noncustodial and remote-provider nexus","Answered","C003, C012, C037","Provider-specific custody, agency, residence knowledge, and account facts remain necessary."],["Consumer/business and mixed-purpose boundaries","Partial","C004","Determine debt purpose, debtor identity, guarantees, and provider’s relevant business segment; research controlling interpretations if facts are mixed."],["Pure education, bill payment, own-creditor boundary","Partial","C005–C006","Verify whether intermediation or an offer through others exists; inspect applicable alternative regimes."],["Nonprofit and institutional exclusions","Answered as legal tests","C009–C010","Actual compensation, governance, charter, banking supervision, control, and incidental-activity evidence needed for an entity claim."],["Attorney/CPA/enrolled-agent exclusions","Answered as legal tests; individual application open","C007–C008","Verify professional status, actual services, client relationship, employment/supervision; establish current Rule 205.1 eligibility if relevant."],["Statutory registration pathway","Answered","C001, C012–C014, C017","Provider-specific issuance and continuing compliance are separate."],["Current application and renewal route","Answered operationally","C015","Recheck linked instructions at actual filing time; no filing authorized or performed here."],["Named-provider public status","Unresolved","C016","Retry the ordinary public report interface; match legal entity/DBA, registration number, activity, status, renewal evidence, and any restrictions. Failed route: S012 loading/CSS error."],["Current provider administrative fee authority chain","Partial","C015","Retrieve the dated administrative fee schedule/order establishing $1,500/$5,000 and reconcile it with historical Rule 1."],["DMP statutory amounts and assessment base","Answered","C018–C019, C025","No higher adjusted amount verified; do not apply CPI independently."],["Settlement state performance trigger and completed-plan aggregate","Answered","C020–C021","Actual consumer execution, creditor payment, agreement-date principal, settlement offers, completion, and previous fees must be documented."],["Full current 4 CCR 902-2 and adoption materials","Unresolved primary-text comparison","C022, C024, C034","Obtain readable official current PDF/adopted DOCX and final basis/adoption materials; compare all operative provisions, including Rules 1–4, against the reproduction. Failed routes: S006 and unusable current PDF retrieval."],["Standalone education $100/larger approved fee and 90-day refund","Held","C023–C024","Confirm official final wording, scope, stale cross-reference, and any public interpretation or applicable provider authorization."],["Historical CPI and retired percentage figures","Answered for nonreliance; historical act comparison partial","C032–C033","Retrieve original HB11-1206 through another ordinary public document route if a complete historical chain is required. No invented indexed amount."],["March 1–29, 2025 transition","Excluded from current-baseline conclusion; open historically","C034","Compare effective clauses, final adoption materials, and any transition interpretation for conduct during those dates."],["Federal TSR timing/allocation common context","Answered conditionally","C035–C037","Provider-specific telemarketing, jurisdiction, nonprofit, and transaction-exemption analysis remains necessary."],["Cancellation and earned/unearned fee boundary","Answered in part","C029–C031","Research contract/case treatment of later-failed installment settlements, disputed earned fees, and incomplete-plan charges."],["Dishonor and third-party account charges","Partial","C026, C037","Identify applicable other-law dishonor ceiling and any independently lawful third-party charge; no extra provider fee assumed."],["Rule litigation/status","Partial","C008, C034","Targeted searches did not establish a stay/vacatur, but full citator and docket treatment remains required for comprehensive case-law coverage."],["Agreements, funds, bond, remedies","Later required passes remain open","Narrow intersections: C013, C017–C018, C029–C031, C037","Full agreement/e-signature/disclosure review; trust operations and reconciliations; bond/substitute requirements; enforcement and remedy analysis."],["Collection, litigation, limitations, execution exemptions","Excluded from this component; open","—","Separate controlling statutes, rules, procedures, limitations/revival, garnishment and property-exemption investigations."],["Secured debt/foreclosure, sector, local, tribal, contracts, full case law","Excluded from this component; open","C011 only identifies a boundary","Separate investigations of each applicable regime. No clearance inferred from Part 2 exclusion."],["Full Colorado dossier / A066 acceptance","Not established","—","Complete remaining components and resolve material holds before any acceptance decision."]]}],"claims":[{"claim_id":"S_CO-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C001","Precise assertion":"Part 2 establishes Colorado’s debt-management registration regime, administered by the designated AG official; current §242 schedules repeal September 1, 2035.","Sources and pinpoints":"S001 §§202(1), 204–212, 242; S002","Conditions, currentness, confidence limits":"Verified current statutory framework. Future repeal is not current expiration."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C002","Precise assertion":"Coverage turns on intermediary concession services for a natural person; providers include offers and services through others; statutory principal is agreement-date debt.","Sources and pinpoints":"S001 §202(6), (8), (11), (14), (15), (17)","Conditions, currentness, confidence limits":"Verified. Marketing labels and original-loan principal are not substitutes for these definitions."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C003","Precise assertion":"Custody is not a coverage prerequisite; Colorado-resident agreement nexus can reach remote providers.","Sources and pinpoints":"S001 §§202(8), 203(a)–(b)(1), 204(a), 206(3), 206.7; S010 p. 9","Conditions, currentness, confidence limits":"Verified, subject to knowledge standard and exclusions. Remote employee permission has separate safeguards."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C004","Precise assertion":"Natural-person focus and the business-debt exclusion limit scope; mixed-purpose facts cannot be resolved by a business label.","Sources and pinpoints":"S001 §§202(11)–(12), 203(b)(3)","Conditions, currentness, confidence limits":"Text verified; mixed-purpose/guarantor application unresolved."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C005","Precise assertion":"Pure education or bill payment may lack intermediary concession activity; direct own-creditor negotiation may likewise fall outside the definition.","Sources and pinpoints":"S001 §§202(8), (15), 203(c)(4)","Conditions, currentness, confidence limits":"Qualified inference, not a general exemption or clearance under other laws."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C006","Precise assertion":"A credit services organization also performing debt-management services must comply with Part 2; Part 2 controls a conflict.","Sources and pinpoints":"S001 §114","Conditions, currentness, confidence limits":"Verified. Full credit-repair analysis remains outside this pass."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C007","Precise assertion":"Attorney, CPA, and enrolled-agent exclusions require the specified professional services, relationships, and qualifications; nonemployee service providers do not inherit them.","Sources and pinpoints":"S001 §202(8)(A)–(B)","Conditions, currentness, confidence limits":"Verified. Enrolled-agent exclusion additionally excludes other debt-management services."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C008","Precise assertion":"Attorney status or affiliation alone is insufficient; Coffman requires real qualifying services and recognizes qualifying limited Colorado authorization.","Sources and pinpoints":"S013 ¶¶31–42, 53; footnote 4; S001 §202(8)","Conditions, currentness, confidence limits":"Verified holding, with original/amended statute distinction. Current individual Rule 205.1 eligibility and exhaustive subsequent history not certified."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C009","Precise assertion":"Nonprofit status alone does not exempt a provider; no-compensation exclusion includes creditor compensation; nonprofit applicants face independence requirements.","Sources and pinpoints":"S001 §§203(b)(2), 205(b)(5), 209(c)–(d)","Conditions, currentness, confidence limits":"Verified. More than one-fourth of board members within the specified relationships defeats statutory independence."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C010","Precise assertion":"Institutional and ordered-activity exclusions apply only to specified persons, relationships, regulation, incidental services, and regular-course activity.","Sources and pinpoints":"S001 §§202(4), 203(c)","Conditions, currentness, confidence limits":"Verified. Bank affiliation alone is insufficient."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C011","Precise assertion":"Foreclosure-protection exclusion does not establish a DMSA fee permission for that excluded activity.","Sources and pinpoints":"S001 §203(b)(4)","Conditions, currentness, confidence limits":"Exclusion verified; alternative statute’s requirements open."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C012","Precise assertion":"Employees/agents of registered providers need not separately register under §204(a); another-state registration only supports substitute application documentation.","Sources and pinpoints":"S001 §§204(b), 212","Conditions, currentness, confidence limits":"Verified. Does not establish factual agency or automatically authorize Colorado operation."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C013","Precise assertion":"Issuance requires statutory application compliance; denial standards apply; limited temporary approval requires regulator action; delay does not create deemed approval.","Sources and pinpoints":"S001 §§205–206, 209–210","Conditions, currentness, confidence limits":"Verified. Temporary criminal-check approval limited to statutory conditions and no more than 120 days."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C014","Precise assertion":"Annual July 1 renewal requires a complete application and fee; timely pending renewal can preserve status.","Sources and pinpoints":"S001 §211(d)–(f); S009 renewal sections","Conditions, currentness, confidence limits":"Verified. Late/incomplete filing and stale displayed dates cannot be treated as proof of continuation."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C015","Precise assertion":"Current instructions request $1,500 for counseling, $5,000 settlement, $5,000 both; initial PDF application and portal renewal routes are available.","Sources and pinpoints":"S009 fee/renewal sections; S010 p. 1; S001 §§205(b)(1), 232(e)","Conditions, currentness, confidence limits":"Operationally verified. Dated fee-setting instrument held; no consumer pass-through authorization established."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C016","Precise assertion":"No named provider’s registration status was verified.","Sources and pinpoints":"S012 actual retrieval; S009 lookup context","Conditions, currentness, confidence limits":"Access finding. Loading/CSS failure is not a no-match search result."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C017","Precise assertion":"Education and financial analysis precede contracting; periodic-payment plans also require suitability, ability-to-pay, and creditor-acceptance determinations.","Sources and pinpoints":"S001 §217(a)–(c)","Conditions, currentness, confidence limits":"Verified. Registration and numerical fee compliance alone do not satisfy these conditions."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C018","Precise assertion":"Direct/indirect fees must be authorized; charges/payment require a compliant agreement signed by both parties.","Sources and pinpoints":"S001 §223(a)–(b); §§217(a), 219(a)(6)(B)","Conditions, currentness, confidence limits":"Verified. Required fee disclosure is distinct from a payment demand."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C019","Precise assertion":"Applicable DMP setup cap is $50; monthly cap is min($10 × remaining creditors, $50).","Sources and pinpoints":"S001 §223(d)(1)(A)–(B); S011","Conditions, currentness, confidence limits":"Verified statutory figures. Federal timing and other legal constraints remain separate."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C020","Precise assertion":"Principal-reduction fees cannot be requested/received until an executed settlement, at least one creditor/collector payment, and applicable-rule compliance.","Sources and pinpoints":"S001 §223(d)(2)(A)(i)–(iii); §228(a)(2)","Conditions, currentness, confidence limits":"Verified state trigger. A savings deposit or provider payment alone does not meet it."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C021","Precise assertion":"For a consumer completing all agreement obligations, fees plus aggregate settlement offers obtained cannot exceed agreement-date principal.","Sources and pinpoints":"S001 §§202(14), 223(d)(2)(B)","Conditions, currentness, confidence limits":"Verified. Do not erase completion condition or replace statutory offer measure with an unsupported measure."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C022","Precise assertion":"Rule 4 reproduction reports proportional enrollment-debt or invariant savings-percentage methods; no numerical settlement percentage is cleared by this pass.","Sources and pinpoints":"S007 Rule 4(a)(1); S005 purpose; S001 §223(d)(2)(C)","Conditions, currentness, confidence limits":"Partial. Full official adopted text S006 unread; federal formula verification does not substitute for it."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C023","Precise assertion":"Separate education/counseling fees after assent are generally prohibited, with administrator authorization and §228(d) exceptions.","Sources and pinpoints":"S001 §§223(c), 228(d)","Conditions, currentness, confidence limits":"Verified. No provider-specific authorization or amount verified."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C024","Precise assertion":"The reproduced standalone $100/administrator-approved-larger-fee and 90-day refund provisions cannot yet be treated as cleared current charging authority.","Sources and pinpoints":"S003 §5; S007 Rule 4(b), (b)(1); S006","Conditions, currentness, confidence limits":"Held. Statutory repeal and stale reproduced cross-reference require official-text comparison."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C025","Precise assertion":"DMP and settlement fee families cannot both be imposed or received.","Sources and pinpoints":"S001 §223(d)(3)","Conditions, currentness, confidence limits":"Verified. Mixed-service labeling does not authorize stacking."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C026","Precise assertion":"Dishonor charge must be reasonable and ≤ min($25, other-law limit).","Sources and pinpoints":"S001 §223(f)","Conditions, currentness, confidence limits":"Verified formula; specific charge held until other law and facts are checked."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C027","Precise assertion":"Contributions cannot be solicited; accepted amounts remain within permitted aggregate through 30 days after completion/termination.","Sources and pinpoints":"S001 §224","Conditions, currentness, confidence limits":"Verified. No donation-based evasion."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C028","Precise assertion":"No added expense for settlement-fee deferral; unrelated-product, specified referral/credit-arrangement compensation, and unfairness restrictions remain.","Sources and pinpoints":"S001 §228(a)(7), (15), (b)(3), (7), (d)","Conditions, currentness, confidence limits":"Verified. Government-program exception in (d) preserved."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C029","Precise assertion":"Three-business-day cancellation entails the specified all-money refund; specified defects extend cancellation to 30 days; emergency waiver is narrow.","Sources and pinpoints":"S001 §220(a)–(c)","Conditions, currentness, confidence limits":"Verified. No standard-form emergency waiver."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C030","Precise assertion":"Later termination is without penalty; unexpended/trust funds return under §§219, 222, 226; only properly payable/earned fees may be retained under applicable provisions.","Sources and pinpoints":"S001 §§202(20)(B)(v), 219(d), 222(h), 226(b), 228(a)(4)","Conditions, currentness, confidence limits":"Verified framework. No blanket refund or retention conclusion for later-failed installment settlements."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C031","Precise assertion":"Unauthorized charges and absence of required registration can make the agreement voidable.","Sources and pinpoints":"S001 §225(a)–(c)","Conditions, currentness, confidence limits":"Verified narrow consequence. Full remedies pass remains open."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C032","Precise assertion":"Historical CPI mechanism cannot justify an invented current adjustment; official records show 2011 repeal of former inflation provisions.","Sources and pinpoints":"S001 §§223, 232; S014 former §12-14.5-232(f)–(g); S015 pp. 134–135; S017 items 1(c), 3","Conditions, currentness, confidence limits":"Strong corroboration/current statutory text. Original 2011 act route failed; no higher current notice verified."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C033","Precise assertion":"Former 18% aggregate/4% setup figures are historical, not current verified settlement caps.","Sources and pinpoints":"S020 p. 1 n.4; S015 pp. 134–135; S001 §223","Conditions, currentness, confidence limits":"Historical agency evidence. Report read by parallel agent; synthesis retry failed."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C034","Precise assertion":"Statutory fee changes took effect March 1, 2025; rule is officially listed effective March 30; 2026 annual expiration was postponed.","Sources and pinpoints":"S003 §§5–6; S004–S005; S008 §1(1)(i)","Conditions, currentness, confidence limits":"Verified dates/status metadata. Transition period and full adopted wording held; no exhaustive stay/vacatur certification."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C035","Precise assertion":"TSR coverage can include settlement, interest/fee concessions, and qualifying inbound advertising responses; attorney/nonprofit labels do not resolve coverage.","Sources and pinpoints":"S018 §§310.2(o), (ii), 310.6(b)(5)(i), (6)(i); S019 coverage section","Conditions, currentness, confidence limits":"Verified federal framework, conditional on jurisdiction, transaction, and applicable exemptions."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C036","Precise assertion":"Covered TSR fees require executed debt alteration plus one payment and prescribed allocation for individually resolved debts.","Sources and pinpoints":"S018 §310.4(a)(5)(i)(A)–(C)","Conditions, currentness, confidence limits":"Verified. Applies independently of Colorado’s ceiling or registration."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_CO-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_CO-P1-C037","Precise assertion":"Qualifying dedicated accounts preserve consumer ownership and withdrawal rights; funding is not fee collection.","Sources and pinpoints":"S001 §202(20)(B); S018 §310.4(a)(5)(ii)(A)–(E)","Conditions, currentness, confidence limits":"Verified. Colorado immediate-return requirement is not relaxed by federal seven-business-day provision."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_CO-P1-S001","urls":["https://olls.info/crs/crs2026-title-05.htm","https://olls.info/crs/crs2026-title-05.pdf","https://olls.info/crs/crs2026-title-05.htm?utm_source=chatgpt.com","https://olls.info/crs/crs2026-title-05.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S001","Document / issuer and direct literal URL":"Colorado Revised Statutes 2026, Title 5, OLLS. https://olls.info/crs/crs2026-title-05.htm ; https://olls.info/crs/crs2026-title-05.pdf","Exact pinpoint, version, legal status, and access limitation":"A—read relevant operative passages. §§5-19-114; 202–212; 217; 219–228; 231–232; 242. Current 2026 compilation. One document ID reused across sections and formats. Colorado substantive law; selected relevant provisions, not every page of Title 5."},"coordinator_verification_status":"selected_passages_checked_only_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_CO-P1-S002","urls":["https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download","https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S002","Document / issuer and direct literal URL":"2026 CRS Titles Download, Colorado General Assembly/OLLS. https://content.leg.colorado.gov/agencies/office-legislative-legal-services/2026-crs-titles-download","Exact pinpoint, version, legal status, and access limitation":"A—read. Official publication route linking the 2026 title files. Establishes provenance/current compilation, not a substitute for statutory text."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S003","urls":["https://leg.colorado.gov/bill_files/44318/download","https://leg.colorado.gov/bill_files/44318/download?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S003","Document / issuer and direct literal URL":"HB24-1380, signed act, Colorado General Assembly. https://leg.colorado.gov/bill_files/44318/download","Exact pinpoint, version, legal status, and access limitation":"A—read. §5, pp. 4–6; §6 effective-date provisions. Rule authority effective August 7, 2024; specified fee amendment/repeals effective March 1, 2025. Enacted law, not proposed bill text."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S004","urls":["https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980","https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S004","Document / issuer and direct literal URL":"4 CCR 902-2 official version index, Colorado Secretary of State. https://www.sos.state.co.us/CCR/DisplayRule.do?action=ruleinfo&ruleId=2980","Exact pinpoint, version, legal status, and access limitation":"A—read. “Current version” row: adopted February 7, 2025; published March 10; effective March 30. Also identifies archived versions. Metadata verified; full current rule text not retrieved from this index."},"coordinator_verification_status":"selected_passages_checked_only_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_CO-P1-S005","urls":["https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603","https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S005","Document / issuer and direct literal URL":"eDocket 2024-00603, Colorado Secretary of State. https://www.sos.state.co.us/CCR/eDocketDetails.do?trackingNum=2024-00603","Exact pinpoint, version, legal status, and access limitation":"A—read. Purpose/objective, adopted-rule section, dates and attachment links. Confirms permanent filing and stated intent to retain former fee structure. Its statutory-authority field contains a subsection-reference inconsistency; enacted §223(d)(2)(C) controls."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S006","urls":["https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx","https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc"],"researcher_record":{"Source ID":"S_CO-P1-S006","Document / issuer and direct literal URL":"Official adopted rule attachment, Department of Law/SOS. https://www.sos.state.co.us/CCR/Upload/AGORequest/AdoptedRules02024-00603.docx","Exact pinpoint, version, legal status, and access limitation":"A—attempted, not read. Unsupported-document/HTTP retrieval failures. Full operative wording remains held. Related basis attachment also failed: https://www.sos.state.co.us/CCR/Upload/AGORequest/BasisAndPurposeAttachment2024-00603.doc. No inference that either document is legally absent."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S007","urls":["https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4","https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S007","Document / issuer and direct literal URL":"4 CCR 902-2, Rule 4 reproduction, Cornell LII. https://www.law.cornell.edu/regulations/colorado/4-CCR-902-2-4","Exact pinpoint, version, legal status, and access limitation":"A—full reproduced Rule 4 read. Clauses (a)(1), (b), (b)(1); note reports March 30, 2025 effectiveness. Secondary transcription, not primary adoption verification. Refund cross-reference problem preserved."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S008","urls":["https://leg.colorado.gov/laws/session-laws/SB26-083/106/download","https://leg.colorado.gov/laws/session-laws/SB26-083/106/download?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S008","Document / issuer and direct literal URL":"SB26-083, chapter 106, Administrative Rule Review, Colorado General Assembly. https://leg.colorado.gov/laws/session-laws/SB26-083/106/download","Exact pinpoint, version, legal status, and access limitation":"A—full two-page act read. §1(1), especially (i), printed pp. 433–434; §2; approved May 5, 2026. Postpones annual expiration of covered Department of Law rules. Does not establish substantive validity or lack of injunction."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S009","urls":["https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/","https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S009","Document / issuer and direct literal URL":"Debt Management Registration, Colorado AG. https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/registration/","Exact pinpoint, version, legal status, and access limitation":"A—read. Opening coverage description; application link; renewal dates; administrative fees; pending-renewal note. Current operational evidence, not independent legal authority for consumer charges."},"coordinator_verification_status":"selected_passages_checked_only_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_CO-P1-S010","urls":["https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf","https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S010","Document / issuer and direct literal URL":"Debt Management Services Provider Application & Instructions, Colorado Department of Law. https://coag.gov/app/uploads/2026/09/DM-Full-Application-10.26.pdf","Exact pinpoint, version, legal status, and access limitation":"A—relevant instructions/checklist and model fields read. p. 1 submission and fees; pp. 2–7 requirements; p. 9 custody/third-party-account categories. Current linked 33-page application. Filename is not a legal effective date. “Notification” heading and erroneous rule-number reference do not supersede the statute."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S011","urls":["https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/","https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S011","Document / issuer and direct literal URL":"Debt Management: Consumers, Colorado AG. https://coag.gov/office-sections/consumer-protection/consumer-credit-unit/debt-management/consumers/","Exact pinpoint, version, legal status, and access limitation":"A—read. Consumer fee and cancellation explanations; lookup route. Agency summary. Its “debts” wording does not replace §223(d)(1)(B)’s “creditors” measure."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S012","urls":["https://licensing.coag.gov/s/public-reports","https://licensing.coag.gov/s/public-reports?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S012","Document / issuer and direct literal URL":"Public Reports, Colorado AG licensing system. https://licensing.coag.gov/s/public-reports","Exact pinpoint, version, legal status, and access limitation":"A—attempted; error page read. Loading/CSS failure. No provider record or search result verified."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S013","urls":["https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf","https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S013","Document / issuer and direct literal URL":"Coffman v. Williamson, 2015 CO 35, 348 P.3d 929, Colorado Supreme Court. https://www.coloradojudicial.gov/sites/default/files/2024-05/14SA249.pdf","Exact pinpoint, version, legal status, and access limitation":"A—relevant opinion passages read. ¶¶21, 31–42, 48–55; footnote 4. Colorado Supreme Court construction of professional exclusion and constitutional issues. Original-statute analysis distinguished from amended law. No exhaustive subsequent-history certification."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S014","urls":["https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011","https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S014","Document / issuer and direct literal URL":"Red Book 2011, Colorado General Assembly/OLLS. https://content.leg.colorado.gov/agencies/office-legislative-legal-services/red-book-2011","Exact pinpoint, version, legal status, and access limitation":"A—relevant entries read. Former §12-14.5-232(f), (g): repeal by HB11-1206, ch. 113, §17, July 1, 2011. Official legislative disposition table; historical evidence."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S015","urls":["https://leg.colorado.gov/sites/default/files/digest2011.pdf","https://leg.colorado.gov/sites/default/files/digest2011.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S015","Document / issuer and direct literal URL":"2011 Digest of Bills, Colorado General Assembly. https://leg.colorado.gov/sites/default/files/digest2011.pdf","Exact pinpoint, version, legal status, and access limitation":"A—HB11-1206 entry read. Printed pp. 134–135. Describes repeal of settlement cap and inflation-adjustment mandate; effective July 1, 2011. Official legislative summary, not the enacted act itself."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S016","urls":["https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291","https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S016","Document / issuer and direct literal URL":"Archived 4 CCR 902-2, SOS, ruleVersionId 7291. https://www.coloradosos.gov/CCR/GenerateRulePdf.do?fileName=4+CCR+902-2&ruleVersionId=7291","Exact pinpoint, version, legal status, and access limitation":"A—two-page document read. Rules 1–3: $1,000 administrative fee, CPI mechanism, insurance notice. Archived September 21, 2017 correction of older rules. Does not contain current Rule 4 and is not treated as the full current regulation."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S017","urls":["https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf","https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S017","Document / issuer and direct literal URL":"Department of Law Regulatory Agenda for Calendar Year 2013, Colorado AG. https://www.coloradosos.gov/pubs/CCR/annualAgendas/Agenda2013/Law.pdf","Exact pinpoint, version, legal status, and access limitation":"A—full page read. Items 1(c), 3, 4. Describes outdated CPI/insurance rules and contemplated repeal. Historical proposed agenda, not an adoption order."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-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-310.4","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-310.2?utm_source=chatgpt.com","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","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_CO-P1-S018","Document / issuer and direct literal URL":"16 CFR Part 310, eCFR/Federal Register system. 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-310.4 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Exact pinpoint, version, legal status, and access limitation":"A—operative provisions read. §§310.2(o), (ii); 310.4(a)(5)(i)–(ii); 310.6(b)(5)(i), (6)(i). eCFR displayed up to date October 21, 2026. One Part 310 source ID reused. Federal coverage conditional; eCFR is authoritative but unofficial."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S019","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_CO-P1-S019","Document / issuer and direct literal URL":"Debt Relief Services & the TSR: A Guide for Business, FTC. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact pinpoint, version, legal status, and access limitation":"A—relevant sections read. “Who’s Covered,” nonprofit/attorney explanations, collecting fees and dedicated accounts. Agency staff guidance, expressly nonbinding; current regulation controls."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S020","urls":["https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf"],"researcher_record":{"Source ID":"S_CO-P1-S020","Document / issuer and direct literal URL":"2011 Annual Report—Colorado Debt-Management Services Providers, Department of Law, state-library copy. https://spl.cde.state.co.us/artemis/lawserials/law610internet/law6102011internet.pdf","Exact pinpoint, version, legal status, and access limitation":"A—read by parallel research agent; synthesis retrieval retries timed out. p. 1, footnote 4, former 18%/4% structure and 2010/2011 timing changes. Historical agency report; not a current fee authorization."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S021","urls":["https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf","https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S021","Document / issuer and direct literal URL":"Rules Governing Admission to Practice Law in Colorado, hosted by Colorado attorney-regulation office. https://www.coloradolegalregulation.com/wp-content/uploads/PDF/BLE/Rules%20Governing%20Admission%20to%20Practice%20Law%20in%20Colorado.pdf","Exact pinpoint, version, legal status, and access limitation":"A—Rule 205.1, printed p. 26, read. Corroborates limited-practice framework. Compilation’s current amendment status was not established; not used to clear a particular attorney’s present eligibility."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S022","urls":["https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf","https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_CO-P1-S022","Document / issuer and direct literal URL":"Proposed Statement of Basis and Purpose—DMSA Fees, Colorado AG. https://coag.gov/app/uploads/2024/12/Statement-of-Basis-and-Purpose-DMSA-Fees.pdf","Exact pinpoint, version, legal status, and access limitation":"A—read. December 2024 rulemaking material. Proposed, not a substitute for the unread final adopted attachment."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_CO-P1-S023","urls":["https://scholar.law.colorado.edu/session-laws-2001-2050/4873/","https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050"],"researcher_record":{"Source ID":"S_CO-P1-S023","Document / issuer and direct literal URL":"HB11-1206 original session-law retrieval route, CU Law repository. https://scholar.law.colorado.edu/session-laws-2001-2050/4873/ ; https://scholar.law.colorado.edu/cgi/viewcontent.cgi?article=5872&context=session-laws-2001-2050","Exact pinpoint, version, legal status, and access limitation":"A—metadata/discovery and failed full-text route. Full act retrieval returned access failure; not treated as freshly read enacted text. Current conclusions instead rest on S001 and the identified official historical corroboration."},"coordinator_verification_status":"unverified_in_current_scoped_review"}],"coverage":[{"topic":"Core intermediary/concession classification","researcher_record":{"Scope component":"Core intermediary/concession classification","Status":"Answered","Claims":"C001–C002","Exact missing evidence or next investigation":"Apply definition to actual contracts, advertisements, and service roles before a provider-specific conclusion."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Principal reduction versus finance-charge/fee concession DMP","researcher_record":{"Scope component":"Principal reduction versus finance-charge/fee concession DMP","Status":"Answered","Claims":"C002, C019–C021","Exact missing evidence or next investigation":"For a mixed plan, establish which statutory fee family applies; do not stack both."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial/noncustodial and remote-provider nexus","researcher_record":{"Scope component":"Custodial/noncustodial and remote-provider nexus","Status":"Answered","Claims":"C003, C012, C037","Exact missing evidence or next investigation":"Provider-specific custody, agency, residence knowledge, and account facts remain necessary."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business and mixed-purpose boundaries","researcher_record":{"Scope component":"Consumer/business and mixed-purpose boundaries","Status":"Partial","Claims":"C004","Exact missing evidence or next investigation":"Determine debt purpose, debtor identity, guarantees, and provider’s relevant business segment; research controlling interpretations if facts are mixed."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Pure education, bill payment, own-creditor boundary","researcher_record":{"Scope component":"Pure education, bill payment, own-creditor boundary","Status":"Partial","Claims":"C005–C006","Exact missing evidence or next investigation":"Verify whether intermediation or an offer through others exists; inspect applicable alternative regimes."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit and institutional exclusions","researcher_record":{"Scope component":"Nonprofit and institutional exclusions","Status":"Answered as legal tests","Claims":"C009–C010","Exact missing evidence or next investigation":"Actual compensation, governance, charter, banking supervision, control, and incidental-activity evidence needed for an entity claim."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney/CPA/enrolled-agent exclusions","researcher_record":{"Scope component":"Attorney/CPA/enrolled-agent exclusions","Status":"Answered as legal tests; individual application open","Claims":"C007–C008","Exact missing evidence or next investigation":"Verify professional status, actual services, client relationship, employment/supervision; establish current Rule 205.1 eligibility if relevant."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory registration pathway","researcher_record":{"Scope component":"Statutory registration pathway","Status":"Answered","Claims":"C001, C012–C014, C017","Exact missing evidence or next investigation":"Provider-specific issuance and continuing compliance are separate."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Current application and renewal route","researcher_record":{"Scope component":"Current application and renewal route","Status":"Answered operationally","Claims":"C015","Exact missing evidence or next investigation":"Recheck linked instructions at actual filing time; no filing authorized or performed here."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider public status","researcher_record":{"Scope component":"Named-provider public status","Status":"Unresolved","Claims":"C016","Exact missing evidence or next investigation":"Retry the ordinary public report interface; match legal entity/DBA, registration number, activity, status, renewal evidence, and any restrictions. Failed route: S012 loading/CSS error."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Current provider administrative fee authority chain","researcher_record":{"Scope component":"Current provider administrative fee authority chain","Status":"Partial","Claims":"C015","Exact missing evidence or next investigation":"Retrieve the dated administrative fee schedule/order establishing $1,500/$5,000 and reconcile it with historical Rule 1."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"DMP statutory amounts and assessment base","researcher_record":{"Scope component":"DMP statutory amounts and assessment base","Status":"Answered","Claims":"C018–C019, C025","Exact missing evidence or next investigation":"No higher adjusted amount verified; do not apply CPI independently."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement state performance trigger and completed-plan aggregate","researcher_record":{"Scope component":"Settlement state performance trigger and completed-plan aggregate","Status":"Answered","Claims":"C020–C021","Exact missing evidence or next investigation":"Actual consumer execution, creditor payment, agreement-date principal, settlement offers, completion, and previous fees must be documented."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Full current 4 CCR 902-2 and adoption materials","researcher_record":{"Scope component":"Full current 4 CCR 902-2 and adoption materials","Status":"Unresolved primary-text comparison","Claims":"C022, C024, C034","Exact missing evidence or next investigation":"Obtain readable official current PDF/adopted DOCX and final basis/adoption materials; compare all operative provisions, including Rules 1–4, against the reproduction. Failed routes: S006 and unusable current PDF retrieval."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Standalone education $100/larger approved fee and 90-day refund","researcher_record":{"Scope component":"Standalone education $100/larger approved fee and 90-day refund","Status":"Held","Claims":"C023–C024","Exact missing evidence or next investigation":"Confirm official final wording, scope, stale cross-reference, and any public interpretation or applicable provider authorization."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Historical CPI and retired percentage figures","researcher_record":{"Scope component":"Historical CPI and retired percentage figures","Status":"Answered for nonreliance; historical act comparison partial","Claims":"C032–C033","Exact missing evidence or next investigation":"Retrieve original HB11-1206 through another ordinary public document route if a complete historical chain is required. No invented indexed amount."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"March 1–29, 2025 transition","researcher_record":{"Scope component":"March 1–29, 2025 transition","Status":"Excluded from current-baseline conclusion; open historically","Claims":"C034","Exact missing evidence or next investigation":"Compare effective clauses, final adoption materials, and any transition interpretation for conduct during those dates."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR timing/allocation common context","researcher_record":{"Scope component":"Federal TSR timing/allocation common context","Status":"Answered conditionally","Claims":"C035–C037","Exact missing evidence or next investigation":"Provider-specific telemarketing, jurisdiction, nonprofit, and transaction-exemption analysis remains necessary."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation and earned/unearned fee boundary","researcher_record":{"Scope component":"Cancellation and earned/unearned fee boundary","Status":"Answered in part","Claims":"C029–C031","Exact missing evidence or next investigation":"Research contract/case treatment of later-failed installment settlements, disputed earned fees, and incomplete-plan charges."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Dishonor and third-party account charges","researcher_record":{"Scope component":"Dishonor and third-party account charges","Status":"Partial","Claims":"C026, C037","Exact missing evidence or next investigation":"Identify applicable other-law dishonor ceiling and any independently lawful third-party charge; no extra provider fee assumed."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Rule litigation/status","researcher_record":{"Scope component":"Rule litigation/status","Status":"Partial","Claims":"C008, C034","Exact missing evidence or next investigation":"Targeted searches did not establish a stay/vacatur, but full citator and docket treatment remains required for comprehensive case-law coverage."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Agreements, funds, bond, remedies","researcher_record":{"Scope component":"Agreements, funds, bond, remedies","Status":"Later required passes remain open","Claims":"Narrow intersections: C013, C017–C018, C029–C031, C037","Exact missing evidence or next investigation":"Full agreement/e-signature/disclosure review; trust operations and reconciliations; bond/substitute requirements; enforcement and remedy analysis."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, litigation, limitations, execution exemptions","researcher_record":{"Scope component":"Collection, litigation, limitations, execution exemptions","Status":"Excluded from this component; open","Claims":"—","Exact missing evidence or next investigation":"Separate controlling statutes, rules, procedures, limitations/revival, garnishment and property-exemption investigations."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt/foreclosure, sector, local, tribal, contracts, full case law","researcher_record":{"Scope component":"Secured debt/foreclosure, sector, local, tribal, contracts, full case law","Status":"Excluded from this component; open","Claims":"C011 only identifies a boundary","Exact missing evidence or next investigation":"Separate investigations of each applicable regime. No clearance inferred from Part 2 exclusion."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Full Colorado dossier / A066 acceptance","researcher_record":{"Scope component":"Full Colorado dossier / A066 acceptance","Status":"Not established","Claims":"—","Exact missing evidence or next investigation":"Complete remaining components and resolve material holds before any acceptance decision."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}