{"meta":{"key":"s_dc--pass-01","task":"S_DC","title":"SDC — District of Columbia","parent_title":"District of Columbia debt and debt relief law","edition":"pass-01","path":"/research/s_dc--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":7,"claims":15,"sources":10,"review_status":"revise","review_complete":true,"sha256":"845d3e2eb8a418fff4574a899998a863d75605882d610ee652da3424b58f3efc","headings":["PASS-01: Debt-relief provider market access and consumer fees","Initial controlling findings","A. Substantive findings by scope question","1. Definitions and business-model classification","2. Prohibition, licensing, registration, and exemptions","3. Consumer fees, ceilings, indexing, and refunds","4. Fee timing and performance conditions","5. Regulator permission, applications, and provider lookup","6. Worked fee and boundary examples","Supplemental verified federal finding","B. Source register","C. Claim register","D. Component coverage and gap register","Priority for the next D.C. investigation","E. Researcher self-check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_DC/pass-01","facets":{"geography":["us","us-dc"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh District of Columbiaprovider-access/fees component only; allbroader statecategories required","pending_corrections":0},"markdown":"# S_DC — District of Columbia\n\n## PASS-01: Debt-relief provider market access and consumer fees\n\nSettleADebt.com | Research date: October 24, 2026 (Pacific) | Baseline: October 22, 2026 | Scope: provider classification, legal authorization, fees, and fee timing\n\nResearch status: PARTIALLY VERIFIED — MARKET ACCESS AND FEE AUTHORIZATION HELD\n\nThe most important finding is that the District of Columbia's former criminal debt-adjusting prohibition, D.C. Code § 22-1201, is expressly repealed. That is a significant distinction from jurisdictions retaining a categorical debt-adjusting prohibition.\n\nHowever, repeal alone does not establish that a commercial debt-settlement company may operate in D.C. without a license, charge any particular fee, or collect compensation under any particular schedule.\n\nThe official D.C. Code also contains consumer-debt collection protections that must not be confused with the regulatory requirements governing a consumer's own debt-settlement representative.\n\n### Initial controlling findings\n\n| Question | Finding | Status |\n| --- | --- | --- |\n| Former debt-adjusting prohibition | D.C. Code § 22-1201 is repealed | Verified |\n| Current commercial debt-settlement authorization | Not established by the repeal | Unresolved |\n| Licensing or registration | No applicable authorization conclusively established | Unresolved |\n| Commercial settlement-fee ceiling | No current D.C.-specific amount verified | Unresolved |\n| Advance-fee permission | Not established | Unresolved |\n| Debt-collector settlement rules | Separate D.C. consumer-collection provisions exist | Verified, separate activity |\n| Named provider authorization | No named provider verified | Not investigated |\n\nThe official D.C. Code publication identifies its compilation as current through October 14, 2026, with D.C. Law 26-190 as the last codified permanent law. This is the publisher's stated currency, not a guarantee that every potentially applicable administrative rule or federal provision has been checked. D.C. Law Library+2\n\nOperational consequence: SettleADebt.com should not currently mark D.C. as an approved commercial debt-settlement market, assign it a fee cap, or claim that a license is unnecessary on the basis of this pass.\n\n## A. Substantive findings by scope question\n\n### 1. Definitions and business-model classification\n\nS_DC-P1-C001 — Former debt-adjusting statute repealed.\n\nThe official codification of D.C. Code § 22-1201 states that the provision was repealed, citing D.C. Law 15-154, § 6, effective April 29, 2004. The former title refers to debt adjusting, prohibitions, exceptions, penalties, and prosecutions.\n\nThis verifies the repeal of that provision. It does not establish what replacement or independently applicable laws regulate the same conduct today. D.C. Law Library\n\nS_DC-P1-C002 — Debt collection is separately defined.\n\nD.C. Code § 28-3814(b)(2)–(5) defines consumer debt, debt collection, debt buyers, and debt collectors. Under this provision, consumer debt generally involves a qualifying personal, family, medical, or household obligation more than 30 days overdue, subject to the statutory qualifications and exclusions.\n\nThe definition of debt collection concerns conduct undertaken to collect consumer debt. It does not, by itself, classify a consumer-retained negotiator as a debt collector simply because that negotiator communicates with creditors. D.C. Law Library\n\nS_DC-P1-C003 — Model-specific classifications remain open.\n\n| Business model | Classification established in this pass |\n| --- | --- |\n| For-profit principal-reduction negotiation | Former § 22-1201 prohibition repealed; current affirmative classification held |\n| Noncustodial debt settlement | No separate current D.C. classification verified |\n| Custodial settlement or dedicated-account arrangement | Classification and funds-handling obligations unresolved |\n| Debt management plan with creditor distributions | No current D.C.-specific provider statute conclusively verified |\n| Nonprofit credit counseling without payment handling | No categorical exemption established |\n| Attorney-operated settlement | No categorical exemption established |\n| Original creditor settling its own account | Different underlying activity; no general third-party exemption inferred |\n| Commercial/business-purpose negotiation | Consumer-specific coverage cannot be automatically extended; other laws unresolved |\n| Out-of-District provider serving D.C. residents | Territorial nexus and authorization requirements unresolved |\n\nThe distinction matters: a noncustodial negotiator, an organization distributing monthly payments, and a creditor collecting its own account can perform economically related activities while falling under different legal rules.\n\nNo inference is made from a provider's marketing label, nonprofit status, or attorney affiliation.\n\n### 2. Prohibition, licensing, registration, and exemptions\n\nS_DC-P1-C004 — The historical prohibition is not a current authorization framework.\n\nThe repeal of § 22-1201 eliminates that provision as a current statutory basis for prohibiting debt adjusting. It does not create an affirmative license, establish a fee schedule, or resolve other consumer-protection statutes.\n\nS_DC-P1-C005 — Current provider licensing remains unresolved.\n\nThe reviewed DISB Consumer Services material confirms that the agency handles matters involving financial institutions and professionals regulated in D.C. It does not provide, in the inspected passage, a debt-settlement-specific license category, governing statute, application, or provider registry.\n\nAccordingly, the investigation has not established either that a D.C. debt-settlement license is required or that no such license is required. disb\n\nThe issuing regulator, any separate business-license obligations, institutional exclusions, attorney conditions, nonprofit qualifications, and remote-provider treatment remain open.\n\n### 3. Consumer fees, ceilings, indexing, and refunds\n\nS_DC-P1-C006 — No current D.C. commercial settlement-fee ceiling verified.\n\nNo primary text inspected in this pass establishes a current percentage-of-enrolled-debt cap, percentage-of-savings cap, per-account cap, dollar setup cap, or aggregate commercial debt-settlement fee limit.\n\nThis is a verification failure, not a finding that fees are unlimited.\n\n| Fee category | Current D.C. result |\n| --- | --- |\n| Enrollment/setup | Hold |\n| Monthly maintenance | Hold |\n| Percentage of enrolled balance | Hold |\n| Percentage of savings | Hold |\n| Flat fee per settled debt | Hold |\n| Total aggregate fee | Hold |\n| Minimum-debt exception | Hold |\n| Indexed or adjusted cap | Hold |\n| Cancellation/refund | Hold |\n| Dedicated-account administration | Hold |\n\nNo CPI adjustment, historical fee table, or model-act amount has been substituted for an enacted D.C. requirement.\n\nS_DC-P1-C007 — Debt-collector charges are not provider compensation.\n\nD.C. Code § 28-3814(g)(3)–(4) addresses collection of debt-collector fees and incidental charges, including legal or contractual authorization requirements.\n\nThose provisions must not be treated as permission for a consumer's debt-settlement provider to impose the same charges. D.C. Law Library\n\n### 4. Fee timing and performance conditions\n\nS_DC-P1-C008 — No D.C.-specific settlement-provider fee trigger verified.\n\nThis pass has not established a District-specific rule allowing or prohibiting payment at enrollment, after creditor acceptance, after consumer payment, or after completion of a settlement.\n\nThe independently applicable federal Telemarketing Sales Rule must be analyzed separately. In particular, 16 C.F.R. § 310.4(a)(5) is the relevant federal debt-relief advance-fee provision.\n\nThe controlling federal text was not successfully retrieved in this research pass. Its precise application, including covered telemarketing activity, exceptions, proportional allocation, and performance conditions, therefore remains a primary-source verification hold rather than a fully authenticated legal conclusion.\n\nS_DC-P1-C009 — Creditor-side settlement documentation is a separate issue.\n\nD.C. Code § 28-3814(n), as displayed in the official codification, requires a debt collector entering a qualifying payment schedule or settlement agreement to provide the consumer a written copy within seven days, with additional rules concerning payments before delivery of the agreement.\n\nThis provision regulates the debt-collector-side arrangement; it does not establish when a consumer-retained settlement company earns its service fee. D.C. Law Library\n\n### 5. Regulator permission, applications, and provider lookup\n\nNo current debt-settlement-specific application, license instruction, operative licensing rule, or named-provider registry entry was authenticated.\n\nTwo official operational sources were located:\n\n- [DISB Consumer Services Division](https://disb-migrate.dc.gov/complaints?utm_source=chatgpt.com) — explains financial-services complaint handling and the agency's jurisdictional limits.\n- [D.C. Office of the Attorney General consumer resources](https://oag.dc.gov/consumer-protection/consumer-and-tenant-response?utm_source=chatgpt.com) — identifies consumer assistance and legal representation resources, not commercial debt-settlement authorization.\n\nNeither source is evidence that SettleADebt.com or any other named company is authorized to sell debt-settlement services in D.C.\n\n### 6. Worked fee and boundary examples\n\nBecause no current D.C.-specific lawful commercial fee pathway has been established, the following are classification and arithmetic checks only, not proposed chargeable fees.\n\nExample E01 — Partial settlement with an unverified percentage fee\n\nHypothetical inputs; no established legal fee authority\n\n- Enrolled balance: $10,000.00\n- Settlement amount: $6,000.00\n- Reduction: $10,000.00 − $6,000.00 = $4,000.00\n- Hypothetical 20% enrolled-balance fee: $10,000.00 × 0.20 = $2,000.00\n- Hypothetical 20% savings fee: $4,000.00 × 0.20 = $800.00\n\nThese are mathematically different bases. Neither $2,000 nor $800 is verified as a lawful D.C. fee. Both are held.\n\nExample E02 — Low-balance account\n\n- Enrolled balance: $800.00\n- Proposed settlement: $500.00\n- Savings: $300.00\n- Hypothetical 20% savings fee: $60.00\n- Hypothetical $100 flat fee: $100.00\n\nA flat-fee minimum, low-debt exception, and any aggregate limitation remain unverified. The example does not authorize either charge.\n\nExample E03 — Earlier fees and proportional allocation\n\nAssume three enrolled debts of $5,000.00, $10,000.00, and $15,000.00, totaling $30,000.00, with a hypothetical contracted aggregate fee of $6,000.00.\n\nIf a proportional allocation method is legally applicable and properly contracted, the mathematical allocations would be:\n\n| Debt | Share of balance | Allocated fee |\n| --- | --- | --- |\n| A: $5,000 | 1/6 | $1,000.00 |\n| B: $10,000 | 1/3 | $2,000.00 |\n| C: $15,000 | 1/2 | $3,000.00 |\n| Total | 100% | $6,000.00 |\n\nIf Debt A alone is settled, the calculation does not make all $6,000 earned. Nor does it establish that the $1,000 allocated to A is currently collectible.\n\nEarlier earnings are assumed to be $0.00 for this hypothetical. No previous payment is invented. Any actual earning must independently satisfy applicable state law, contract conditions, and federal timing requirements.\n\nExample E04 — Cancellation before a settlement\n\n- Enrolled balance: $12,000.00\n- Consumer contributions: $1,200.00\n- Settled debts: zero\n- Provider fees previously charged: $0.00\n- Hypothetical cancellation date: day 45\n\nThe $1,200.00 represents consumer contributions, not earned provider compensation.\n\nThe refund, withdrawal, account-ownership, and cancellation requirements cannot be calculated from the D.C. provisions verified here. Those outcomes remain held pending the controlling contract, funds-handling law, and applicable federal provisions.\n\nAll currency calculations above use U.S. dollars and two decimal places. No intermediate rounding affects these results. Numeric accuracy is established; legal collectibility is not.\n\n### Supplemental verified federal finding\n\nThe official eCFR text was successfully opened after the initial federal retrieval attempt. This resolves the earlier federal-text access hold, but not the unresolved D.C. licensing or fee-ceiling questions.\n\nS_DC-P1-C010 — Federal debt-relief performance conditions.\n\nUnder 16 C.F.R. § 310.4(a)(5)(i)(A)–(C), where the Telemarketing Sales Rule applies, the seller or telemarketer cannot request or receive a debt-relief service fee until all three conditions are satisfied:\n\n1. At least one enrolled debt has been renegotiated, settled, reduced, or otherwise altered under a qualifying customer-executed agreement.\n2. The customer has made at least one payment pursuant to that agreement.\n3. For individually resolved debts, the fee follows the prescribed proportional-enrolled-balance allocation or a consistent percentage-of-savings method.\n\nSection 310.4(a)(5)(ii)(A)–(E) separately provides conditions for qualifying customer-controlled accounts, including withdrawal and return of funds within seven business days, excluding properly earned fees.\n\nThese rules are federal performance restrictions, not authorization to charge fees under D.C. law. The eCFR identifies Title 16 as current through October 22, 2026. eCFR\n\nS_DC-P1-C011 — Federal credit-repair representations.\n\nSection 310.4(a)(2) contains a distinct advance-fee restriction for covered services represented as improving or removing derogatory credit information. This may matter when debt-settlement marketing promises credit improvement.\n\nWhether a particular service also falls under CROA, 15 U.S.C. §§ 1679–1679j, requires a separate applicability analysis. The CROA statutory text was not independently verified in this pass. eCFR\n\n## B. Source register\n\nAll source-access dates below are October 24, 2026. \"Read\" means relevant text was actually returned by the public web tool; it does not mean every linked authority or historical version was authenticated.\n\n| Source ID | Issuer, document and literal URL | Pinpoint, version, status and access |\n| --- | --- | --- |\n| S_DC-P1-S001 | D.C. Council, Code publication index. [https://code.dccouncil.gov/us/dc/council/code](https://code.dccouncil.gov/us/dc/council/code?utm_source=chatgpt.com) | Publication information; current through October 14, 2026. Read. Compilation currency only. |\n| S_DC-P1-S002 | D.C. Council, D.C. Code § 22-1201. [https://code.dccouncil.gov/us/dc/council/code/sections/22-1201](https://code.dccouncil.gov/us/dc/council/code/sections/22-1201?utm_source=chatgpt.com) | Entire operative entry; expressly repealed, with 2004 repeal history. Directly opened and read. |\n| S_DC-P1-S003 | D.C. Council, D.C. Code § 28-3814. [https://code.dccouncil.gov/us/dc/council/code/sections/28-3814](https://code.dccouncil.gov/us/dc/council/code/sections/28-3814?utm_source=chatgpt.com) | Subsections (a), (b), (f), (g), (n); current codification, including 2026 amendment history. Directly opened; relevant passages read. Collector-side law. |\n| S_DC-P1-S004 | D.C. Council, § 28-3814 permanent-version entry. [https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29](https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29?utm_source=chatgpt.com) | Subsection (n), permanent-version text. Search-rendered passage read; separate current-versus-permanent reconciliation not completed. |\n| S_DC-P1-S005 | D.C. Council, D.C. Law 24-154. [https://code.dccouncil.gov/us/dc/council/laws/24-154](https://code.dccouncil.gov/us/dc/council/laws/24-154?utm_source=chatgpt.com) | 2022 consumer debt-collection amendments, settlement-document provisions. Relevant search-rendered text read; complete law not separately authenticated. |\n| S_DC-P1-S006 | D.C. Department of Insurance, Securities and Banking, Consumer Services Division. [https://disb-migrate.dc.gov/complaints](https://disb-migrate.dc.gov/complaints?utm_source=chatgpt.com) | Agency complaint jurisdiction and examples. Search-rendered operational text read. No provider-license determination. |\n| S_DC-P1-S007 | D.C. Office of Attorney General, Consumer and Tenant Response. [https://oag.dc.gov/consumer-protection/consumer-and-tenant-response](https://oag.dc.gov/consumer-protection/consumer-and-tenant-response?utm_source=chatgpt.com) | Consumer legal-resource section read. Not licensing authority. |\n| S_DC-P1-S008 | Office of Chief Financial Officer, Central Collection Unit FAQ. [https://cfo.dc.gov/service/ccu-frequently-asked-questions](https://cfo.dc.gov/service/ccu-frequently-asked-questions?utm_source=chatgpt.com) | Questions 1–3, 10–12 read. Government-debt collection, not commercial settlement-provider fees. |\n| S_DC-P1-S009 | D.C. Council, D.C. Code § 1-350.06. [https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06](https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06?utm_source=chatgpt.com) | Subsections (a)–(b), public-debt settlement authority. Search-rendered text read. Different regulated actor. |\n| S_DC-P1-S010 | Federal Trade Commission rule, 16 C.F.R. § 310.4, eCFR. [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com) | (a)(2), (a)(5)(i)–(ii), directly opened and read. Title 16 displayed current through October 22, 2026. Federal context. |\n\nThe search also surfaced Colorado and Maryland debt-management licensing materials. Those were excluded from the D.C. authority register because another jurisdiction's licensing scheme cannot establish District law.\n\nNo D.C. administrative rule, adoption order, current license application, judicial decision, or named-provider registry record was sufficiently authenticated to add as a controlling source.\n\n## C. Claim register\n\n| Claim ID | Precise claim | Sources and pinpoints | Confidence / limitation |\n| --- | --- | --- | --- |\n| C001 | Former § 22-1201 repealed | S002, full entry | High; no affirmative authorization inferred |\n| C002 | § 28-3814 defines consumer debt and debt collection | S003, (a), (b)(1)–(5) | High for that statute; not universal provider classification |\n| C003 | Custodial, noncustodial, DMP and counseling classifications unresolved | S002–S003; no controlling provider text found | Unresolved |\n| C004 | Repeal does not establish commercial licensing or fee permission | S002, repeal entry | High as a limited legal inference |\n| C005 | DISB material does not verify a debt-settlement license | S006, complaint jurisdiction | High about inspected source; underlying licensing status unresolved |\n| C006 | No current D.C. commercial fee ceiling authenticated | S001–S009, reviewed scope | Evidence gap, not proof of no ceiling |\n| C007 | Collector-side incidental-charge rules cannot substitute for provider fees | S003, (g)(3)–(4) | High, subject to actual actor classification |\n| C008 | D.C.-specific provider fee trigger unresolved | S002–S009 | Unresolved; federal trigger separately verified |\n| C009 | Qualifying collector settlement documentation has seven-day requirements | S003–S005, § 28-3814(n) | High for displayed text; not provider compensation |\n| C010 | Covered federal debt-relief fees require performance, payment and proper allocation | S010, (a)(5)(i)(A)–(C) | High for rule text; transaction applicability separate |\n| C011 | Covered credit-improvement representations face a separate federal advance-fee rule | S010, (a)(2) | High for TSR text; CROA overlap unresolved |\n| C012 | Qualifying dedicated accounts have federal ownership, independence and withdrawal conditions | S010, (a)(5)(ii)(A)–(E) | High for text; only where rule applies |\n| C013 | Government debt-settlement authority is not private-provider authorization | S008–S009 | High as a distinction |\n| C014 | No named commercial provider's D.C. authorization was verified | S006; no registry record authenticated | Unresolved |\n| C015 | Hypothetical fee calculations do not establish collectibility | C006, C008, C010 | High methodological conclusion |\n\nThe claim IDs above use the full `S_DC-P1-C###` prefix. No unresolved claim should be promoted to an affirmative legal conclusion merely because a related federal provision was verified.\n\n## D. Component coverage and gap register\n\n| Coverage item | Status | Claim IDs | Missing evidence and exact next investigation |\n| --- | --- | --- | --- |\n| Historical debt-adjusting prohibition | Answered | C001 | Historical repeal text verified; investigate any replacement enactments |\n| Current provider definitions | Partial | C002–C003 | Search complete D.C. Code and operative DCMR titles for debt-adjustment, settlement, management, counseling and negotiation |\n| Principal-reduction model | Unresolved | C003–C005 | Identify controlling current provider statute and administrative interpretation |\n| Custodial/noncustodial distinction | Unresolved | C003 | Obtain operative definitions and funds-handling rules |\n| DMP/distribution model | Unresolved | C003 | Determine separate licensing or exemption pathway |\n| Nonprofit/attorney exemptions | Unresolved | C003–C005 | Read exact statutory and regulatory exemption conditions |\n| Consumer/business and remote nexus | Partial | C002–C003 | Obtain provider-law scope, territorial rules and applicable judicial interpretation |\n| Regulator/issuing authority | Unresolved | C005 | Verify legal delegation and operative licensing category |\n| Current application and lookup | Unresolved | C005, C014 | Obtain regulator-issued instructions and searchable license records |\n| Named-provider authorization | Excluded from verification | C014 | Search named entity only after licensing category is established |\n| Fee bases and ceilings | Unresolved | C006 | Authenticate all operative fee provisions and amendments |\n| CPI/indexed fee amounts | Unresolved | C006 | Find enacted adjustment authority and actual current notice; do not calculate independently |\n| Setup/monthly/per-debt fees | Unresolved | C006 | Obtain controlling fee schedule and exceptions |\n| Refund and cancellation | Partial | C006, C012 | Resolve D.C. contract/funds rules and federal applicability |\n| State-specific earning trigger | Unresolved | C008 | Locate enacted performance and timing provisions |\n| Federal TSR debt-relief timing | Answered as rule text | C010 | Complete applicability and exemption analysis for actual sales model |\n| Federal dedicated-account conditions | Answered as rule text | C012 | Verify applicability and actual account structure |\n| Credit-repair overlap | Partial | C011 | Authenticate CROA text, coverage and any exceptions |\n| Collector-side settlement rules | Partial | C007, C009 | Separate collector obligations from provider obligations; full collection law later |\n| Worked fee examples | Arithmetic answered; legality held | C006, C008, C010, C015 | Supply lawful D.C. fee method and contract before operational use |\n| Controlling judicial interpretations | Unresolved | C003–C008 | Targeted D.C. Court of Appeals and relevant federal court research |\n| DCMR and adoption orders | Unresolved | C003–C008 | Obtain complete operative text, amendments, effective dates and any stays |\n| Agreement, bond, funds and remedies | Excluded except federal intersection | C012 | Required later passes |\n| Litigation, limitations and exemptions | Excluded | — | Required later passes |\n| Secured debt, sector-specific and local rules | Excluded | — | Required later passes |\n| Tribal, contract and full case-law review | Excluded | — | Required later passes |\n\n### Priority for the next D.C. investigation\n\nThe next investigation must first establish the current affirmative legal framework for commercial consumer debt-settlement providers, including whether a separate licensing regime exists. That finding controls the interpretation of nearly every unresolved fee and market-access question.\n\nSecond, the operative DCMR provisions and relevant rulemaking/adoption history must be inspected in full. Third, current licensing instructions and registry procedures must be matched to the actual regulated business model. Only then should the current D.C. fee ceilings, exceptions, adjustments, and refund obligations be calculated.\n\nThe present evidence does not justify an operational D.C. fee schedule.\n\n## E. Researcher self-check\n\nWhat was actually completed\n\nThe investigation used regular Chat public web research on October 24, 2026. It directly opened the official repealed debt-adjusting provision, the current D.C. debt-collection provision, and the federal TSR fee-timing provision. Additional official D.C. materials were inspected through returned search-rendered text.\n\nThe relevant federal TSR text was ultimately obtained, so its performance and dedicated-account provisions are supported by actual retrieved primary text.\n\nWhat was not completed\n\nNo exhaustive D.C. Code or DCMR search, complete administrative-rule review, adoption-order reconstruction, controlling-case-law survey, current provider-license verification, fee-adjustment notice reconciliation, or named-provider lookup was completed.\n\nSearch results that failed to identify a license or fee provision are not proof that no such provision exists. A regulator's complaint page is not a license registry. No full commercial fee pathway was authenticated.\n\nNo external applications, contacts, account changes, Chrome-control operations, other chats, purchases, local writes, or publication actions were performed. This is a single researcher pass, not independent legal review, and it is not publication-ready or an A066 acceptance determination.\n\nFinal disposition: S_DC PASS-01 remains open. The historical repeal, separate collector-side framework, and federal TSR timing text are supported. The decisive D.C. provider-authorization and commercial-fee questions remain unresolved, and all other state-dossier categories remain expressly required.\n\nEND S_DC PASS-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Question","Finding","Status"],["Former debt-adjusting prohibition","D.C. Code § 22-1201 is repealed","Verified"],["Current commercial debt-settlement authorization","Not established by the repeal","Unresolved"],["Licensing or registration","No applicable authorization conclusively established","Unresolved"],["Commercial settlement-fee ceiling","No current D.C.-specific amount verified","Unresolved"],["Advance-fee permission","Not established","Unresolved"],["Debt-collector settlement rules","Separate D.C. consumer-collection provisions exist","Verified, separate activity"],["Named provider authorization","No named provider verified","Not investigated"]]},{"headers":[],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Classification established in this pass"],["For-profit principal-reduction negotiation","Former § 22-1201 prohibition repealed; current affirmative classification held"],["Noncustodial debt settlement","No separate current D.C. classification verified"],["Custodial settlement or dedicated-account arrangement","Classification and funds-handling obligations unresolved"],["Debt management plan with creditor distributions","No current D.C.-specific provider statute conclusively verified"],["Nonprofit credit counseling without payment handling","No categorical exemption established"],["Attorney-operated settlement","No categorical exemption established"],["Original creditor settling its own account","Different underlying activity; no general third-party exemption inferred"],["Commercial/business-purpose negotiation","Consumer-specific coverage cannot be automatically extended; other laws unresolved"],["Out-of-District provider serving D.C. residents","Territorial nexus and authorization requirements unresolved"]]},{"headers":[],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Fee category","Current D.C. result"],["Enrollment/setup","Hold"],["Monthly maintenance","Hold"],["Percentage of enrolled balance","Hold"],["Percentage of savings","Hold"],["Flat fee per settled debt","Hold"],["Total aggregate fee","Hold"],["Minimum-debt exception","Hold"],["Indexed or adjusted cap","Hold"],["Cancellation/refund","Hold"],["Dedicated-account administration","Hold"]]},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Debt","Share of balance","Allocated fee"],["A: $5,000","1/6","$1,000.00"],["B: $10,000","1/3","$2,000.00"],["C: $15,000","1/2","$3,000.00"],["Total","100%","$6,000.00"]]},{"headers":[],"index":4,"links":[{"href":"https://code.dccouncil.gov/us/dc/council/code?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/22-1201?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/22-1201"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29"},{"href":"https://code.dccouncil.gov/us/dc/council/laws/24-154?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/laws/24-154"},{"href":"https://disb-migrate.dc.gov/complaints?utm_source=chatgpt.com","text":"https://disb-migrate.dc.gov/complaints"},{"href":"https://oag.dc.gov/consumer-protection/consumer-and-tenant-response?utm_source=chatgpt.com","text":"https://oag.dc.gov/consumer-protection/consumer-and-tenant-response"},{"href":"https://cfo.dc.gov/service/ccu-frequently-asked-questions?utm_source=chatgpt.com","text":"https://cfo.dc.gov/service/ccu-frequently-asked-questions"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06"},{"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"}],"row_links":[[],[{"href":"https://code.dccouncil.gov/us/dc/council/code?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/22-1201?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/22-1201"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29"}],[{"href":"https://code.dccouncil.gov/us/dc/council/laws/24-154?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/laws/24-154"}],[{"href":"https://disb-migrate.dc.gov/complaints?utm_source=chatgpt.com","text":"https://disb-migrate.dc.gov/complaints"}],[{"href":"https://oag.dc.gov/consumer-protection/consumer-and-tenant-response?utm_source=chatgpt.com","text":"https://oag.dc.gov/consumer-protection/consumer-and-tenant-response"}],[{"href":"https://cfo.dc.gov/service/ccu-frequently-asked-questions?utm_source=chatgpt.com","text":"https://cfo.dc.gov/service/ccu-frequently-asked-questions"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06?utm_source=chatgpt.com","text":"https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06"}],[{"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"}]],"rows":[["Source ID","Issuer, document and literal URL","Pinpoint, version, status and access"],["S_DC-P1-S001","D.C. Council, Code publication index. https://code.dccouncil.gov/us/dc/council/code","Publication information; current through October 14, 2026. Read. Compilation currency only."],["S_DC-P1-S002","D.C. Council, D.C. Code § 22-1201. https://code.dccouncil.gov/us/dc/council/code/sections/22-1201","Entire operative entry; expressly repealed, with 2004 repeal history. Directly opened and read."],["S_DC-P1-S003","D.C. Council, D.C. Code § 28-3814. https://code.dccouncil.gov/us/dc/council/code/sections/28-3814","Subsections (a), (b), (f), (g), (n); current codification, including 2026 amendment history. Directly opened; relevant passages read. Collector-side law."],["S_DC-P1-S004","D.C. Council, § 28-3814 permanent-version entry. https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29","Subsection (n), permanent-version text. Search-rendered passage read; separate current-versus-permanent reconciliation not completed."],["S_DC-P1-S005","D.C. Council, D.C. Law 24-154. https://code.dccouncil.gov/us/dc/council/laws/24-154","2022 consumer debt-collection amendments, settlement-document provisions. Relevant search-rendered text read; complete law not separately authenticated."],["S_DC-P1-S006","D.C. Department of Insurance, Securities and Banking, Consumer Services Division. https://disb-migrate.dc.gov/complaints","Agency complaint jurisdiction and examples. Search-rendered operational text read. No provider-license determination."],["S_DC-P1-S007","D.C. Office of Attorney General, Consumer and Tenant Response. https://oag.dc.gov/consumer-protection/consumer-and-tenant-response","Consumer legal-resource section read. Not licensing authority."],["S_DC-P1-S008","Office of Chief Financial Officer, Central Collection Unit FAQ. https://cfo.dc.gov/service/ccu-frequently-asked-questions","Questions 1–3, 10–12 read. Government-debt collection, not commercial settlement-provider fees."],["S_DC-P1-S009","D.C. Council, D.C. Code § 1-350.06. https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06","Subsections (a)–(b), public-debt settlement authority. Search-rendered text read. Different regulated actor."],["S_DC-P1-S010","Federal Trade Commission rule, 16 C.F.R. § 310.4, eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","(a)(2), (a)(5)(i)–(ii), directly opened and read. Title 16 displayed current through October 22, 2026. Federal context."]]},{"headers":[],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise claim","Sources and pinpoints","Confidence / limitation"],["C001","Former § 22-1201 repealed","S002, full entry","High; no affirmative authorization inferred"],["C002","§ 28-3814 defines consumer debt and debt collection","S003, (a), (b)(1)–(5)","High for that statute; not universal provider classification"],["C003","Custodial, noncustodial, DMP and counseling classifications unresolved","S002–S003; no controlling provider text found","Unresolved"],["C004","Repeal does not establish commercial licensing or fee permission","S002, repeal entry","High as a limited legal inference"],["C005","DISB material does not verify a debt-settlement license","S006, complaint jurisdiction","High about inspected source; underlying licensing status unresolved"],["C006","No current D.C. commercial fee ceiling authenticated","S001–S009, reviewed scope","Evidence gap, not proof of no ceiling"],["C007","Collector-side incidental-charge rules cannot substitute for provider fees","S003, (g)(3)–(4)","High, subject to actual actor classification"],["C008","D.C.-specific provider fee trigger unresolved","S002–S009","Unresolved; federal trigger separately verified"],["C009","Qualifying collector settlement documentation has seven-day requirements","S003–S005, § 28-3814(n)","High for displayed text; not provider compensation"],["C010","Covered federal debt-relief fees require performance, payment and proper allocation","S010, (a)(5)(i)(A)–(C)","High for rule text; transaction applicability separate"],["C011","Covered credit-improvement representations face a separate federal advance-fee rule","S010, (a)(2)","High for TSR text; CROA overlap unresolved"],["C012","Qualifying dedicated accounts have federal ownership, independence and withdrawal conditions","S010, (a)(5)(ii)(A)–(E)","High for text; only where rule applies"],["C013","Government debt-settlement authority is not private-provider authorization","S008–S009","High as a distinction"],["C014","No named commercial provider's D.C. authorization was verified","S006; no registry record authenticated","Unresolved"],["C015","Hypothetical fee calculations do not establish collectibility","C006, C008, C010","High methodological conclusion"]]},{"headers":[],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Coverage item","Status","Claim IDs","Missing evidence and exact next investigation"],["Historical debt-adjusting prohibition","Answered","C001","Historical repeal text verified; investigate any replacement enactments"],["Current provider definitions","Partial","C002–C003","Search complete D.C. Code and operative DCMR titles for debt-adjustment, settlement, management, counseling and negotiation"],["Principal-reduction model","Unresolved","C003–C005","Identify controlling current provider statute and administrative interpretation"],["Custodial/noncustodial distinction","Unresolved","C003","Obtain operative definitions and funds-handling rules"],["DMP/distribution model","Unresolved","C003","Determine separate licensing or exemption pathway"],["Nonprofit/attorney exemptions","Unresolved","C003–C005","Read exact statutory and regulatory exemption conditions"],["Consumer/business and remote nexus","Partial","C002–C003","Obtain provider-law scope, territorial rules and applicable judicial interpretation"],["Regulator/issuing authority","Unresolved","C005","Verify legal delegation and operative licensing category"],["Current application and lookup","Unresolved","C005, C014","Obtain regulator-issued instructions and searchable license records"],["Named-provider authorization","Excluded from verification","C014","Search named entity only after licensing category is established"],["Fee bases and ceilings","Unresolved","C006","Authenticate all operative fee provisions and amendments"],["CPI/indexed fee amounts","Unresolved","C006","Find enacted adjustment authority and actual current notice; do not calculate independently"],["Setup/monthly/per-debt fees","Unresolved","C006","Obtain controlling fee schedule and exceptions"],["Refund and cancellation","Partial","C006, C012","Resolve D.C. contract/funds rules and federal applicability"],["State-specific earning trigger","Unresolved","C008","Locate enacted performance and timing provisions"],["Federal TSR debt-relief timing","Answered as rule text","C010","Complete applicability and exemption analysis for actual sales model"],["Federal dedicated-account conditions","Answered as rule text","C012","Verify applicability and actual account structure"],["Credit-repair overlap","Partial","C011","Authenticate CROA text, coverage and any exceptions"],["Collector-side settlement rules","Partial","C007, C009","Separate collector obligations from provider obligations; full collection law later"],["Worked fee examples","Arithmetic answered; legality held","C006, C008, C010, C015","Supply lawful D.C. fee method and contract before operational use"],["Controlling judicial interpretations","Unresolved","C003–C008","Targeted D.C. Court of Appeals and relevant federal court research"],["DCMR and adoption orders","Unresolved","C003–C008","Obtain complete operative text, amendments, effective dates and any stays"],["Agreement, bond, funds and remedies","Excluded except federal intersection","C012","Required later passes"],["Litigation, limitations and exemptions","Excluded","—","Required later passes"],["Secured debt, sector-specific and local rules","Excluded","—","Required later passes"],["Tribal, contract and full case-law review","Excluded","—","Required later passes"]]}],"claims":[{"claim_id":"S_DC-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C001","Precise claim":"Former § 22-1201 repealed","Sources and pinpoints":"S002, full entry","Confidence / limitation":"High; no affirmative authorization inferred"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise claim":"§ 28-3814 defines consumer debt and debt collection","Sources and pinpoints":"S003, (a), (b)(1)–(5)","Confidence / limitation":"High for that statute; not universal provider classification"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise claim":"Custodial, noncustodial, DMP and counseling classifications unresolved","Sources and pinpoints":"S002–S003; no controlling provider text found","Confidence / limitation":"Unresolved"},"coordinator_verification_status":"held_for_actual_provider_framework_authorization_or_fee_evidence; P2_prepared_not_sent","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise claim":"Repeal does not establish commercial licensing or fee permission","Sources and pinpoints":"S002, repeal entry","Confidence / limitation":"High as a limited legal inference"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise claim":"DISB material does not verify a debt-settlement license","Sources and pinpoints":"S006, complaint jurisdiction","Confidence / limitation":"High about inspected source; underlying licensing status unresolved"},"coordinator_verification_status":"held_for_actual_provider_framework_authorization_or_fee_evidence; P2_prepared_not_sent","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise claim":"No current D.C. commercial fee ceiling authenticated","Sources and pinpoints":"S001–S009, reviewed scope","Confidence / limitation":"Evidence gap, not proof of no ceiling"},"coordinator_verification_status":"held_for_actual_provider_framework_authorization_or_fee_evidence; P2_prepared_not_sent","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise claim":"Collector-side incidental-charge rules cannot substitute for provider fees","Sources and pinpoints":"S003, (g)(3)–(4)","Confidence / limitation":"High, subject to actual actor classification"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise claim":"D.C.-specific provider fee trigger unresolved","Sources and pinpoints":"S002–S009","Confidence / limitation":"Unresolved; federal trigger separately verified"},"coordinator_verification_status":"held_for_actual_provider_framework_authorization_or_fee_evidence; P2_prepared_not_sent","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise claim":"Qualifying collector settlement documentation has seven-day requirements","Sources and pinpoints":"S003–S005, § 28-3814(n)","Confidence / limitation":"High for displayed text; not provider compensation"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise claim":"Covered federal debt-relief fees require performance, payment and proper allocation","Sources and pinpoints":"S010, (a)(5)(i)(A)–(C)","Confidence / limitation":"High for rule text; transaction applicability separate"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise claim":"Covered credit-improvement representations face a separate federal advance-fee rule","Sources and pinpoints":"S010, (a)(2)","Confidence / limitation":"High for TSR text; CROA overlap unresolved"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise claim":"Qualifying dedicated accounts have federal ownership, independence and withdrawal conditions","Sources and pinpoints":"S010, (a)(5)(ii)(A)–(E)","Confidence / limitation":"High for text; only where rule applies"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise claim":"Government debt-settlement authority is not private-provider authorization","Sources and pinpoints":"S008–S009","Confidence / limitation":"High as a distinction"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise claim":"No named commercial provider's D.C. authorization was verified","Sources and pinpoints":"S006; no registry record authenticated","Confidence / limitation":"Unresolved"},"coordinator_verification_status":"held_for_actual_provider_framework_authorization_or_fee_evidence; P2_prepared_not_sent","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"},{"claim_id":"S_DC-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise claim":"Hypothetical fee calculations do not establish collectibility","Sources and pinpoints":"C006, C008, C010","Confidence / limitation":"High methodological conclusion"},"coordinator_verification_status":"scoped_review_completed_with_explicit_source_applicability_and_currentness_limits; not_full_legal_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-25T05:24:31.366074+00:00"}],"sources":[{"source_id":"S_DC-P1-S001","urls":["https://code.dccouncil.gov/us/dc/council/code","https://code.dccouncil.gov/us/dc/council/code?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S001","Issuer, document and literal URL":"D.C. Council, Code publication index. https://code.dccouncil.gov/us/dc/council/code","Pinpoint, version, status and access":"Publication information; current through October 14, 2026. Read. Compilation currency only."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S002","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/22-1201","https://code.dccouncil.gov/us/dc/council/code/sections/22-1201?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S002","Issuer, document and literal URL":"D.C. Council, D.C. Code § 22-1201. https://code.dccouncil.gov/us/dc/council/code/sections/22-1201","Pinpoint, version, status and access":"Entire operative entry; expressly repealed, with 2004 repeal history. Directly opened and read."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S003","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/28-3814","https://code.dccouncil.gov/us/dc/council/code/sections/28-3814?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S003","Issuer, document and literal URL":"D.C. Council, D.C. Code § 28-3814. https://code.dccouncil.gov/us/dc/council/code/sections/28-3814","Pinpoint, version, status and access":"Subsections (a), (b), (f), (g), (n); current codification, including 2026 amendment history. Directly opened; relevant passages read. Collector-side law."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S004","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29","https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S004","Issuer, document and literal URL":"D.C. Council, § 28-3814 permanent-version entry. https://code.dccouncil.gov/us/dc/council/code/sections/28-3814%28Perm%29","Pinpoint, version, status and access":"Subsection (n), permanent-version text. Search-rendered passage read; separate current-versus-permanent reconciliation not completed."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S005","urls":["https://code.dccouncil.gov/us/dc/council/laws/24-154","https://code.dccouncil.gov/us/dc/council/laws/24-154?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S005","Issuer, document and literal URL":"D.C. Council, D.C. Law 24-154. https://code.dccouncil.gov/us/dc/council/laws/24-154","Pinpoint, version, status and access":"2022 consumer debt-collection amendments, settlement-document provisions. Relevant search-rendered text read; complete law not separately authenticated."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S006","urls":["https://disb-migrate.dc.gov/complaints","https://disb-migrate.dc.gov/complaints?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S006","Issuer, document and literal URL":"D.C. Department of Insurance, Securities and Banking, Consumer Services Division. https://disb-migrate.dc.gov/complaints","Pinpoint, version, status and access":"Agency complaint jurisdiction and examples. Search-rendered operational text read. No provider-license determination."},"coordinator_verification_status":"not_verified_coordinator_fetch_timeout; researcher_search_rendered_observation_attributed","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S007","urls":["https://oag.dc.gov/consumer-protection/consumer-and-tenant-response","https://oag.dc.gov/consumer-protection/consumer-and-tenant-response?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S007","Issuer, document and literal URL":"D.C. Office of Attorney General, Consumer and Tenant Response. https://oag.dc.gov/consumer-protection/consumer-and-tenant-response","Pinpoint, version, status and access":"Consumer legal-resource section read. Not licensing authority."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S008","urls":["https://cfo.dc.gov/service/ccu-frequently-asked-questions","https://cfo.dc.gov/service/ccu-frequently-asked-questions?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S008","Issuer, document and literal URL":"Office of Chief Financial Officer, Central Collection Unit FAQ. https://cfo.dc.gov/service/ccu-frequently-asked-questions","Pinpoint, version, status and access":"Questions 1–3, 10–12 read. Government-debt collection, not commercial settlement-provider fees."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S009","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06","https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S009","Issuer, document and literal URL":"D.C. Council, D.C. Code § 1-350.06. https://code.dccouncil.gov/us/dc/council/code/sections/1-350.06","Pinpoint, version, status and access":"Subsections (a)–(b), public-debt settlement authority. Search-rendered text read. Different regulated actor."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P1-S010","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_DC-P1-S010","Issuer, document and literal URL":"Federal Trade Commission rule, 16 C.F.R. § 310.4, eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Pinpoint, version, status and access":"(a)(2), (a)(5)(i)–(ii), directly opened and read. Title 16 displayed current through October 22, 2026. Federal context."},"coordinator_verification_status":"see_scoped_document_read_or_reuse_or_failed_status_in_coordinator_source_checks; no_blanket_source_verification","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Historical debt-adjusting prohibition","researcher_record":{"Coverage item":"Historical debt-adjusting prohibition","Status":"Answered","Claim IDs":"C001","Missing evidence and exact next investigation":"Historical repeal text verified; investigate any replacement enactments"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current provider definitions","researcher_record":{"Coverage item":"Current provider definitions","Status":"Partial","Claim IDs":"C002–C003","Missing evidence and exact next investigation":"Search complete D.C. Code and operative DCMR titles for debt-adjustment, settlement, management, counseling and negotiation"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Principal-reduction model","researcher_record":{"Coverage item":"Principal-reduction model","Status":"Unresolved","Claim IDs":"C003–C005","Missing evidence and exact next investigation":"Identify controlling current provider statute and administrative interpretation"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial/noncustodial distinction","researcher_record":{"Coverage item":"Custodial/noncustodial distinction","Status":"Unresolved","Claim IDs":"C003","Missing evidence and exact next investigation":"Obtain operative definitions and funds-handling rules"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP/distribution model","researcher_record":{"Coverage item":"DMP/distribution model","Status":"Unresolved","Claim IDs":"C003","Missing evidence and exact next investigation":"Determine separate licensing or exemption pathway"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit/attorney exemptions","researcher_record":{"Coverage item":"Nonprofit/attorney exemptions","Status":"Unresolved","Claim IDs":"C003–C005","Missing evidence and exact next investigation":"Read exact statutory and regulatory exemption conditions"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business and remote nexus","researcher_record":{"Coverage item":"Consumer/business and remote nexus","Status":"Partial","Claim IDs":"C002–C003","Missing evidence and exact next investigation":"Obtain provider-law scope, territorial rules and applicable judicial interpretation"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Regulator/issuing authority","researcher_record":{"Coverage item":"Regulator/issuing authority","Status":"Unresolved","Claim IDs":"C005","Missing evidence and exact next investigation":"Verify legal delegation and operative licensing category"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current application and lookup","researcher_record":{"Coverage item":"Current application and lookup","Status":"Unresolved","Claim IDs":"C005, C014","Missing evidence and exact next investigation":"Obtain regulator-issued instructions and searchable license records"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider authorization","researcher_record":{"Coverage item":"Named-provider authorization","Status":"Excluded from verification","Claim IDs":"C014","Missing evidence and exact next investigation":"Search named entity only after licensing category is established"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Fee bases and ceilings","researcher_record":{"Coverage item":"Fee bases and ceilings","Status":"Unresolved","Claim IDs":"C006","Missing evidence and exact next investigation":"Authenticate all operative fee provisions and amendments"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"CPI/indexed fee amounts","researcher_record":{"Coverage item":"CPI/indexed fee amounts","Status":"Unresolved","Claim IDs":"C006","Missing evidence and exact next investigation":"Find enacted adjustment authority and actual current notice; do not calculate independently"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Setup/monthly/per-debt fees","researcher_record":{"Coverage item":"Setup/monthly/per-debt fees","Status":"Unresolved","Claim IDs":"C006","Missing evidence and exact next investigation":"Obtain controlling fee schedule and exceptions"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Refund and cancellation","researcher_record":{"Coverage item":"Refund and cancellation","Status":"Partial","Claim IDs":"C006, C012","Missing evidence and exact next investigation":"Resolve D.C. contract/funds rules and federal applicability"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State-specific earning trigger","researcher_record":{"Coverage item":"State-specific earning trigger","Status":"Unresolved","Claim IDs":"C008","Missing evidence and exact next investigation":"Locate enacted performance and timing provisions"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR debt-relief timing","researcher_record":{"Coverage item":"Federal TSR debt-relief timing","Status":"Answered as rule text","Claim IDs":"C010","Missing evidence and exact next investigation":"Complete applicability and exemption analysis for actual sales model"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal dedicated-account conditions","researcher_record":{"Coverage item":"Federal dedicated-account conditions","Status":"Answered as rule text","Claim IDs":"C012","Missing evidence and exact next investigation":"Verify applicability and actual account structure"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-repair overlap","researcher_record":{"Coverage item":"Credit-repair overlap","Status":"Partial","Claim IDs":"C011","Missing evidence and exact next investigation":"Authenticate CROA text, coverage and any exceptions"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collector-side settlement rules","researcher_record":{"Coverage item":"Collector-side settlement rules","Status":"Partial","Claim IDs":"C007, C009","Missing evidence and exact next investigation":"Separate collector obligations from provider obligations; full collection law later"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Worked fee examples","researcher_record":{"Coverage item":"Worked fee examples","Status":"Arithmetic answered; legality held","Claim IDs":"C006, C008, C010, C015","Missing evidence and exact next investigation":"Supply lawful D.C. fee method and contract before operational use"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling judicial interpretations","researcher_record":{"Coverage item":"Controlling judicial interpretations","Status":"Unresolved","Claim IDs":"C003–C008","Missing evidence and exact next investigation":"Targeted D.C. Court of Appeals and relevant federal court research"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DCMR and adoption orders","researcher_record":{"Coverage item":"DCMR and adoption orders","Status":"Unresolved","Claim IDs":"C003–C008","Missing evidence and exact next investigation":"Obtain complete operative text, amendments, effective dates and any stays"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement, bond, funds and remedies","researcher_record":{"Coverage item":"Agreement, bond, funds and remedies","Status":"Excluded except federal intersection","Claim IDs":"C012","Missing evidence and exact next investigation":"Required later passes"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Litigation, limitations and exemptions","researcher_record":{"Coverage item":"Litigation, limitations and exemptions","Status":"Excluded","Claim IDs":"—","Missing evidence and exact next investigation":"Required later passes"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt, sector-specific and local rules","researcher_record":{"Coverage item":"Secured debt, sector-specific and local rules","Status":"Excluded","Claim IDs":"—","Missing evidence and exact next investigation":"Required later passes"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Tribal, contract and full case-law review","researcher_record":{"Coverage item":"Tribal, contract and full case-law review","Status":"Excluded","Claim IDs":"—","Missing evidence and exact next investigation":"Required later passes"},"coordinator_acceptance":"reviewed_with_partial_evidence_and_remaining_holds; no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}