{"meta":{"key":"s_dc--pass-02","task":"S_DC","title":"SDC — District of Columbia","parent_title":"District of Columbia debt and debt relief law","edition":"pass-02","path":"/research/s_dc--pass-02/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":33,"sources":23,"review_status":"scoped_review_complete_requires_bounded_correction","review_complete":true,"sha256":"7007976291cbb549b2a9584a353f35a0e1939cf111679d37afeb18bc14d21969","headings":["PASS-02: Focused provider-market-access follow-up","1.1 The affirmative provider framework exists","1.2 Commercial debt settlement is strongly, but not finally judicially, within that framework","1.3 DISB is the current administering regulator","1.4 The legal duty is verified; the current filing mechanics are not","1.5 Consumer fee amount limits remain on hold","4.1 Issuing and administering authority","4.2 Application route","4.3 Public lookup","4.4 DCMR implementation layer","5.1 Money transmission","5.2 Basic Business License","5.3 Foreign-entity registration","S_DC-P2-S001 — D.C. Code, Title 28, Chapter 46, Consumer Credit Service Organizations","S_DC-P2-S002 — D.C. Law 8-236","S_DC-P2-S003 — D.C. Code publication information","S_DC-P2-S004 — D.C. Code § 26-551.03","S_DC-P2-S005 — D.C. Code §§ 31-101 and 31-103","S_DC-P2-S006 — DISB Banking Bureau","S_DC-P2-S007 — DISB Divisions","S_DC-P2-S008 — DISB Compliance Requirements: Banking","S_DC-P2-S009 — DISB non-depository public verification page","S_DC-P2-S010 — DISB Licensing and Registration Requirements","S_DC-P2-S011 — D.C. Municipal Regulations, Title 16","S_DC-P2-S012 — OAG Student Aid Center release","S_DC-P2-S013 — District v. Student Aid Center complaint","S_DC-P2-S014 — OAG Burlington release","S_DC-P2-S015 — Burlington consent judgment","S_DC-P2-S016 — YF Solution Assurance of Voluntary Compliance","S_DC-P2-S017 — Chen v. Bell-Smith","S_DC-P2-S018 — D.C. Money Transmitters Act provisions","S_DC-P2-S019 — Basic Business License provisions","S_DC-P2-S020 — DLCP Business Licensing Division","S_DC-P2-S021 — Foreign-entity provisions","S_DC-P2-S022 — Historical DISB initial non-depository instructions","S_DC-P2-S023 — DISB FY 2017–2018 Biennial Report","P1 authority aliases, not new P2 sources","Actually freshly read or visually inspected","Reused rather than re-researched","Not established or not completely read","Final provider-market-access result"],"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-02","facets":{"geography":["us","us-dc"],"debt_type":[],"stage":[],"subject":["provider-licensing"]},"scope":"Reviewed remaining affirmativeproviderframework/operativeDCMR/authorizationcategory/instructions and minimalP1federal-accesssupersession;feecomputationheldpendingpath","pending_corrections":0},"markdown":"# S_DC — District of Columbia\n\n## PASS-02: Focused provider-market-access follow-up\n\n**Research access date:** October 24, 2026, Pacific\n**Official D.C. Code publication status:** Current through October 22, 2026; last codified permanent law D.C. Law 26-190, effective October 14, 2026; last codified emergency law D.C. Act 26-784, effective October 22, 2026. Publication currency does not establish that every administrative rule, order, or operational form has been located. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code)\n**Mode/model:** Regular Chat; GPT-5.6 Sol Pro; no Deep Research, Work, Chrome control, API use, contacts, applications, or named-provider investigation.\n**Scope:** Current affirmative legal framework for a commercial, consumer-retained debt-settlement or negotiation provider serving District residents.\n**Disposition:** **PARTIAL — governing statute, regulator, and registration obligation established; current public filing instructions and CCSO-specific lookup pathway remain unresolved.**\n\nThis is a focused patch to PASS-01. It does not replace or expand the remaining D.C. state, local, tribal, contract, litigation, remedies, limitations, secured-debt, or sector-specific passes.\n\n# 1. Bottom-line findings\n\n## 1.1 The affirmative provider framework exists\n\nThe current affirmative framework is **D.C. Code Title 28, Chapter 46, Consumer Credit Service Organizations**, not the repealed debt-adjusting provision discussed in PASS-01.\n\nChapter 46 defines a “consumer credit service organization” broadly enough to include a compensated person who provides advice or assistance concerning a consumer’s personal, household, or family credit. A covered organization that “operates in the District” must register, file the Mayor-prescribed registration statement, pay a **$300 initial registration fee**, and pay a **$200 annual fee**. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46)\n\n## 1.2 Commercial debt settlement is strongly, but not finally judicially, within that framework\n\nChapter 46 does not use the labels “debt settlement,” “debt negotiation,” or “debt relief.” The strongest textual hook is § 28-4601(2)(A)(iii), covering compensated advice or assistance concerning personal, household, or family credit.\n\nThat textual reading is reinforced by official D.C. enforcement records:\n\n- OAG alleged that a Florida student-loan debt-relief provider serving District consumers was a CCSO, had failed to register, and had charged advance fees without the statutory bond or trust.\n- OAG used the CCSOA against a Maryland company offering services to validate, dispute, resolve, or reduce consumer debts.\n- A separate assurance concerning a debt-relief provider alleged CCSOA bond, disclosure, agreement, cancellation, and advance-fee violations.\n\nThose materials establish the District’s enforcement position. The complaint, consent judgment, and assurance are not controlling appellate decisions, and the Burlington defendants expressly denied liability. [DC Attorney General+9](https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc)\n\n**Qualified conclusion:** A for-profit provider paid to negotiate, validate, dispute, resolve, or reduce a District consumer’s personal debts should be treated as a covered CCSO unless it can establish a precise statutory exclusion. This is a strong statutory and enforcement conclusion, not a holding from the D.C. Court of Appeals.\n\n## 1.3 DISB is the current administering regulator\n\nImplementation authority over Chapter 46 was transferred from DCRA to the financial-services regulator. Current statutes place administration of the D.C. Banking Code with the Department of Insurance, Securities, and Banking, acting through its Securities and Banking Bureau.\n\nDISB’s current Banking Bureau and Divisions pages expressly state that its Licensing Division reviews applications for **consumer credit service organizations** and maintains the non-depository licensing database, identified on the Divisions page as NMLS. The statute calls the Chapter 46 authorization a **registration**; DISB’s operational pages use the broader phrase “license applications.” The agency terminology should not silently change the statutory authorization type. [D.C. Law Library+5](https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03)\n\n## 1.4 The legal duty is verified; the current filing mechanics are not\n\nThe following are established:\n\n- Covered CCSOs must register.\n- DISB is the administering agency.\n- DISB’s Licensing Division handles CCSO applications.\n- The statute specifies the initial and annual government fees.\n\nThe following were **not** authenticated from current public materials:\n\n- A current CCSO-specific application or checklist.\n- The exact electronic or paper submission route.\n- A current D.C.-specific NMLS CCSO license or registration checklist.\n- A public lookup result category clearly identifying CCSO registrations.\n- An operative CCSO-specific DCMR rule or adoption order supplying the missing application details.\n\nDISB’s current general NMLS compliance list and public verification page enumerate multiple non-depository categories but omit CCSOs. Its general licensing-and-registration forms page likewise does not surface a CCSO application. This omission is not proof that the registration program is inactive; it means the public operational route was not fully verified. [Disb+2](https://disb.dc.gov/page/compliance-requirements-banking)\n\n**Market-access disposition:** D.C. should not be coded as “no license required.” It should be coded as:\n\n**Covered commercial debt-relief providers: Chapter 46 registration required; DISB administrator established; current public application and lookup completion pathway unresolved. Launch remains HOLD pending operational verification.**\n\n## 1.5 Consumer fee amount limits remain on hold\n\nChapter 46 establishes:\n\n- Provider-to-government registration fees.\n- A state condition governing money received before completion.\n- A $25,000 bond or trust requirement for that state-law advance-payment branch.\n- Written disclosures and contract requirements.\n- A five-calendar-day cancellation right.\n- Reimbursement within ten days after receipt of a cancellation notice.\n\nChapter 46 does **not itself state a percentage-of-debt, percentage-of-savings, per-account, monthly, setup, or aggregate consumer-service fee ceiling**. No separate current D.C. amount cap was authenticated in this pass. That does not establish unlimited fees.\n\nThe independently applicable federal TSR conditions previously verified in PASS-01 remain separate. The earlier P1 federal-text retrieval hold was superseded by P1’s supplemental federal finding and is not an open PASS-02 issue.\n\n# 2. Section-by-section governing-framework matrix\n\n| Authority and pinpoint | Operative rule and covered conduct | Authorization, exemption, or condition | Version/effectiveness and limits | Claims |\n| --- | --- | --- | --- | --- |\n| **D.C. Code § 28-4601(1)** | “Consumer” is a person solicited to purchase or purchasing CCSO services. Consumer awareness and purchase or solicitation matter. | Establishes the protected customer relationship; it does not require that every payment come directly from the consumer. | Enacted effective March 8, 1991. No separate amendment shown for subsection (1). Chen applied this definition narrowly on unusual facts involving no consumer solicitation or awareness. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C002, C022 |\n| **§ 28-4601(2)(A)(i)** | Paid services represented as improving a consumer’s credit record, history, or rating are directly covered. | Covered unless an exact subsection (D) exclusion applies. | Section last amended May 6, 2020. CROA applicability remains outside this pass. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C002, C016 |\n| **§ 28-4601(2)(A)(ii)** | Paid assistance obtaining an extension of credit for a consumer is covered. | Same exclusions. | “Extension of credit by others” limits the definition; Chen rejected coverage where the defendants obtained funds in their own names and then extended their own alleged credit. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C002, C022 |\n| **§ 28-4601(2)(A)(iii)** | Paid advice or assistance concerning any matter related to personal, household, or family credit is covered. | Principal-reduction negotiation, debt validation, dispute assistance, DMP counseling, and similar services have a strong textual fit, subject to actual facts and exclusions. | The section does not say “debt settlement.” OAG’s debt-relief actions supply official enforcement support rather than binding appellate construction. [D.C. Law Library+4](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C003, C004, C011, C012 |\n| **§ 28-4601(2)(B)–(C)** | Salespersons, agents, representatives, and independent agents who sell or attempt to sell CCSO services are included. | A seller cannot avoid coverage merely by being labeled an agent or independent marketer. | Pure lead generation that stops before selling, attempting to sell, advising, or assisting remains fact-dependent. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C015 |\n| **§ 28-4601(2)(D)(i)–(viii)** | Express exclusions cover specified regulated lenders, insured banks and certain subsidiaries, qualifying credit unions, § 501(c)(3) organizations, collection agencies operating under D.C. law, D.C.-licensed attorneys acting within their practice, broker-dealers acting within applicable federal law, and FCRA consumer reporting agencies. | Each exclusion is actor- and conduct-specific. Nonprofit branding, an attorney relationship, or institutional affiliation alone is insufficient. | The claimant bears the burden of proving an exception or exemption under § 28-4606(b). [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C017–C019 |\n| **§ 28-4601(3)** | “Extension of credit” concerns deferred debt primarily for personal, family, or household purposes. | Purely business-purpose credit falls outside this Chapter 46 definition. | Mixed-purpose, guarantor, sole-proprietor, and personally liable business-card facts require separate analysis. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | C020 |\n| **§ 28-4602(a)–(c)** | A covered CCSO operating in D.C. must file the prescribed registration statement, pay $300 initially and $200 annually, report information changes within ten days, and supply additional requested information before acceptance. | Registration is mandatory; it is not created by the repealed § 22-1201. | Last amended October 3, 2001. “Operates in the District” is not defined in Chapter 46. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4602) | C005, C006 |\n| **§ 28-4603(1)** | A CCSO may not charge or receive consideration before completion unless it has the § 28-4604 bond or trust. | This is a state-law exception to the state prohibition, not federal TSR authorization. | “Completion” is not defined in the Chapter 46 definitions. No authenticated DCMR interpretation was located. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4603) | C025, C028 |\n| **§ 28-4603(2)** | Prohibits charging solely for certain referrals to a retail seller where substantially similar credit is available to the public. | This is a narrow referral prohibition, not a general authorization for all compensated referrals. | Does not resolve pure lead generation, creditor-referral compensation, or affiliate marketing outside its terms. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4603) | C015 |\n| **§ 28-4603(3)–(7)** | Prohibits specified false or misleading credit statements, deceptive omissions or methods, misleading use of “repair,” waiver attempts, and noncompliance with the chapter or rules. | Applies independently of registration and fee timing. | Current codified section traces its latest listed amendment to April 9, 1997. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4603) | C016, C029 |\n| **§ 28-4604(a)–(b)** | A provider receiving money before completion must maintain a $25,000 surety bond or a $25,000 minimum trust at a qualifying District institution. Security may support cancellation refunds, assessed damages, and complaint settlements. | The trust is provider financial security. It is not the consumer’s dedicated settlement account. | Enacted effective March 8, 1991. No indexed adjustment language appears in the section. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4604) | C014, C025 |\n| **§ 28-4605(a)–(c)** | Requires pre-contract or pre-payment disclosures, retention of signed disclosures, a detailed description of services and total charges, and a written signed contract containing all payment terms, including payments to the provider or another person. | Applies to covered CCSOs regardless of whether money is paid directly to the provider. | Drafting contains substantial credit-report-repair terminology; application to debt settlement is supported by OAG enforcement but has not been comprehensively construed by an appellate court. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4605) | C026, C029 |\n| **§ 28-4605(d)–(e)** | Contract must include a five-calendar-day cancellation right; reimbursement is due within ten days after receipt of the cancellation notice; required documents must be given to the consumer. | Exact treatment of already completed services, third-party charges, or consumer account funds is not comprehensively specified in the text reviewed. | Enacted effective March 8, 1991. No separate current rule was authenticated. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4605) | C026 |\n| **§ 28-4606** | Registrations receive APA hearing protection; the person claiming an exemption carries the burden; rights under other D.C. and federal law remain enforceable. | A claimed nonprofit, attorney, lender, or other exclusion must be proved by the claimant. The chapter does not displace the federal TSR. | Enacted effective March 8, 1991. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4606) | C017–C019, C025 |\n| **§ 28-4607** | Provides criminal, civil, and private remedies for Chapter 46 violations. | Confirms the registration and conduct rules are enforceable, not merely advisory. | Last listed amendment June 11, 2013. Full remedies analysis remains for a later pass. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4607) | C001, C029 |\n| **§ 28-4608** | Directs the Mayor to issue implementing rules covering registration, sample disclosures, contract and cancellation forms, and civil fines. | The statute contemplates an implementation layer beyond the Code text. | No current operative CCSO-specific rule or adoption order was authenticated in this pass. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4608) | C009, C033 |\n| **D.C. Code § 26-551.03; §§ 31-101, 31-103** | Transfers and assigns Chapter 46 financial-regulation functions to the banking regulator now operating within DISB. | DISB, through its banking organization, is the administering regulator. | § 26-551.03’s editor’s note expressly identifies Title 28, Chapter 46 in the transferred functions. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03) | C007 |\n| **Current DISB Banking Bureau/Divisions pages** | Licensing Division reviews CCSO applications and maintains the non-depository licensing database/NMLS. | Operationally confirms the active regulatory category. | Webpage statements as accessed October 24, 2026; not statutory effective dates and not a CCSO-specific filing checklist. [Disb+1](https://disb.dc.gov/page/banking-bureau) | C008–C010 |\n\n# 3. Conduct and business-model matrix\n\n| Model or status | Chapter 46 result | Other possible category | Authorization or exemption result | Remaining condition or failure case |\n| --- | --- | --- | --- | --- |\n| **For-profit, noncustodial principal-reduction negotiation** | **Answered, qualified:** strong CCSO coverage under § 28-4601(2)(A)(iii). OAG has applied the CCSOA to services intended to resolve or reduce consumer debts. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) | No separate debt-settlement license chapter was authenticated. | Chapter 46 registration required if the provider operates in D.C. and lacks an exclusion. | No controlling D.C. appellate debt-settlement decision located; current filing mechanics unresolved. |\n| **Student-loan debt relief or repayment-plan assistance for compensation** | **Answered, qualified:** official OAG complaint treated such a provider as a CCSO. [DC Attorney General+3](https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc) | Student-loan-servicer licensing could be separate if the company actually services loans; not analyzed here. | CCSO registration and Chapter 46 conditions apply under OAG’s pleaded theory. | The Student Aid document is a complaint, not a merits judgment. |\n| **Paid DMP or credit counseling without custody** | **Partial:** paid advice or assistance concerning personal credit fits § 28-4601(2)(A)(iii). | No separate D.C. DMP statute or current DCMR category was authenticated. | Registration unless an exact exclusion, particularly § 501(c)(3), applies. | Creditor concessions, payment administration, and provider compensation facts may affect classification. |\n| **Genuinely free counseling with no direct or indirect valuable consideration** | **Partial, likely outside Chapter 46:** the definition requires money or other valuable consideration. | Other consumer-protection laws could still apply. | No Chapter 46 registration on the stated no-consideration facts. | Referral payments, affiliate revenue, creditor funding, data monetization, or bundled charges may constitute consideration. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Custodial DMP receiving consumer money and paying creditors** | **Partial:** counseling or assistance remains CCSO conduct. | **Possible money-transmitter licensing** because D.C. defines money transmission to include receiving money for transmission and requires a license absent an exemption. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001) | Chapter 46 registration plus any independently applicable money-transmitter authorization. | Exact funds flow, ownership, agency, bank relationship, and receipt/control must be established. No debt-relief or agent-of-payee exemption appears in the inspected §§ 26-1001–1003, but a complete interpretive pass remains open. |\n| **Independent consumer-controlled dedicated account** | **Partial:** using a dedicated account does not remove the provider’s advice or negotiation from Chapter 46. | Money-transmission treatment depends on whether the provider or affiliate receives, controls, or transmits the funds. | CCSO registration still required if otherwise covered. | Account agreement, payment instructions, provider access, affiliate status, and withdrawal control are essential. |\n| **Provider- or affiliate-controlled dedicated account** | **Partial, elevated money-transmission risk:** receipt or transmission by the provider or affiliate may fit § 26-1001(10). | Money transmitter. | Separate authorization potentially required. | No conclusion without actual account and funds-flow documents. |\n| **§ 28-4604 provider trust account** | **Answered:** this is $25,000 provider security supporting refunds and liabilities. | Not a money-transmission classification by itself. | Necessary for the Chapter 46 state-law pre-completion-payment branch. | Must not be mislabeled as the consumer’s settlement savings account. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4604) |\n| **Sales agent or independent closer selling the program** | **Answered:** expressly included as a CCSO. | Individual licensing was not separately found. | Covered through the organization definition. | Outsourcing sales does not remove Chapter 46 coverage. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Pure compensated lead generator or referral source** | **Unresolved:** inclusion depends on whether it sells or attempts to sell CCSO services, advises the consumer, or otherwise acts as an agent or representative. | CPPA, advertising, telemarketing, and referral rules may separately apply. | No blanket broker exemption established. | Need scripts, compensation, handoff, representations, and degree of participation. |\n| **Credit-repair promises or representations** | **Answered:** directly covered by § 28-4601(2)(A)(i), subject to exclusions. | Conditional federal TSR credit-repair rule and CROA may overlap. | Chapter 46 registration if covered. | CROA applicability remains held as directed; no universal federal or state exemption inferred. |\n| **Organization actually exempt under IRC § 501(c)(3)** | **Answered:** expressly excluded from the CCSO definition. | Other laws may remain applicable. | No Chapter 46 registration if the entity actually satisfies the exact exemption. | “Nonprofit” branding, state incorporation, or pending tax status is not enough; claimant bears the burden. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Other nonprofit organization** | **Answered:** no categorical exclusion merely because the entity is nonprofit. | Same analysis as commercial provider unless another exclusion applies. | Registration required if covered. | Must establish actual § 501(c)(3) status or another precise exclusion. |\n| **D.C.-licensed attorney performing services within the practice of law** | **Answered:** expressly excluded. | Attorney ethics, fee, trust-account, and unauthorized-practice rules remain separate. | No Chapter 46 registration on facts satisfying both elements. | Lawyer must be licensed in D.C.; services must be within the course and scope of practice. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Attorney-owned, attorney-affiliated, or out-of-state attorney business** | **Partial:** no automatic exclusion. | Corporate, unauthorized-practice, fee-sharing, and attorney-regulation issues remain open. | Chapter 46 registration required unless the exact attorney exclusion is proved. | Marketing through a lawyer or retaining counsel does not transform nonlegal commercial services into the exclusion. |\n| **Banks, supervised lenders, credit unions, collection agencies, broker-dealers, and CRAs** | **Answered only to the statutory categories and scope.** | Their own regulatory laws continue to apply. | Excluded only when the actor and conduct satisfy § 28-4601(2)(D). | Institutional affiliation or an affiliate relationship not described by the text is not enough. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Original creditor negotiating its own debt** | **Partial, likely outside ordinary CCSO coverage:** the service is not ordinarily sold to the consumer concerning credit “by others,” and the creditor is acting on its own account. | Collection and consumer-protection law may apply. | No affirmative Chapter 46 authorization needed on ordinary self-creditor facts. | Avoid universal conclusion where an affiliate separately sells paid advisory or negotiation services. Chen supports a narrow own-credit boundary on its facts. [GovInfo+1](https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf) |\n| **Pure business-purpose debt negotiation** | **Answered for Chapter 46:** outside the definition to the extent the underlying credit is not primarily personal, family, or household. | Commercial-law and professional-regulation issues remain open. | No Chapter 46 registration on pure business-credit facts. | Mixed-purpose cards, personally guaranteed business debts, and sole-proprietor obligations require purpose-specific analysis. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4601) |\n| **Remote out-of-District provider soliciting and serving D.C. residents** | **Partial but high enforcement risk:** “operates in the District” is undefined, yet OAG applied the statute to Florida and Maryland entities marketing or selling debt-relief services to District consumers. [DC Attorney General+3](https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf) | Foreign-entity registration and BBL may be separate. | Treat District-facing sales and service as triggering Chapter 46 unless a contrary controlling authority is established. | No controlling appellate territorial test located. Marketing, solicitation, contracting, consumer residence, and performance facts matter. |\n| **Consumer unaware of provider or third-party payer** | **Partial:** Chen found no CCSO relationship where the consumers were not solicited, did not understand themselves to be purchasing the service, and payment came from another person without their awareness. | Fact-specific. | Potentially outside Chapter 46 on comparable facts. | Chen is a 2011 federal trial-court decision, not a controlling D.C. Court of Appeals decision. [GovInfo](https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf) |\n\n# 4. Regulator, application, and public-lookup findings\n\n## 4.1 Issuing and administering authority\n\nThe statutory registration is filed with the Mayor. The relevant functions were transferred to the D.C. banking regulator and are now administered by DISB. Current DISB materials place CCSO applications in the Banking Licensing Division. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/28-4602)\n\n**Legal category:** Consumer Credit Service Organization registration under D.C. Code § 28-4602.\n\n**Current administering agency:** District of Columbia Department of Insurance, Securities, and Banking, Banking Bureau, Licensing Division.\n\n**Statutory government charges:**\n\n- Initial Chapter 46 registration: **$300**\n- Annual Chapter 46 fee: **$200**, due before April 2 or another regulatory date\n\nThese are government registration charges, not consumer service-fee limits. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/28-4602)\n\n## 4.2 Application route\n\nThe statute requires a form prescribed by the Mayor. DISB says its Licensing Division reviews CCSO applications and maintains NMLS. However:\n\n- DISB’s current banking-compliance page lists NMLS requirements for several categories but not CCSOs.\n- Its public non-depository verification page lists several NMLS categories but not CCSOs.\n- Its general licensing-and-registration page does not provide a CCSO form or checklist.\n- No current CCSO-specific NMLS state checklist or public submission instruction was located.\n\nThe evidence supports an inference that NMLS may be involved in the back-end or broader non-depository database, but it does not establish the complete current CCSO submission route. [Disb+3](https://disb.dc.gov/page/divisions-1)\n\nA historical DISB biennial report stated that DISB had moved to a coordinated NMLS process for non-depository licensees and registrants. Its specific list of NMLS-managed categories did not expressly name CCSOs, and its statistics table likewise omitted them. Because that document covers fiscal years 2017–2018, it is operational history, not sufficient current application instructions. [Disb+1](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf)\n\n## 4.3 Public lookup\n\nDISB directs consumers to NMLS Consumer Access for listed non-depository entities. The page does not expressly list CCSOs among those categories. The direct NMLS Consumer Access route could not be opened through the research tool in this pass, and no CCSO-specific public record was tested.\n\nTherefore:\n\n- The existence of a general DISB/NMLS lookup route is verified.\n- Its ability to confirm a Chapter 46 CCSO registration is **not verified**.\n- No named provider was searched.\n- PASS-01 C014 must not be converted into an adverse provider-status claim. [Disb](https://disb.dc.gov/page/non-depository-institutions-operating-dc)\n\n## 4.4 DCMR implementation layer\n\nSection 28-4608 directs rulemaking for registration requirements, disclosures, contracts, cancellation forms, and fines. Title 16’s current index displays Chapter 1, Consumer Retail Credit, and Chapter 37, DISB Infractions. The visible Chapter 1 sections concern retail sellers, finance companies, and related consumer-credit topics; no CCSO-specific heading appears in the displayed list.\n\nThe displayed 1/1/1900 Chapter 1 dates were not treated as reliable promulgation or legal effective dates. The direct Chapter 37 section-list route failed in the web tool. Exact official-domain searches did not surface a current CCSO-specific rule or adoption order.\n\nThis supports only an **unresolved-rule finding**, not a conclusion that no implementing rules were ever adopted. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/28-4608)\n\n# 5. Parallel authorization categories\n\n## 5.1 Money transmission\n\nD.C. defines money transmission to include engaging in the business of receiving money for transmission or transmitting money by any means. A person engaging in that business must obtain a money-transmitter license unless an exemption applies.\n\nThe inspected statutory exemptions cover governments, specified regulated financial institutions, government-benefit transfers, and authorized delegates of a licensed transmitter. They do not expressly mention debt settlement, DMPs, credit counseling, dedicated accounts, or an agent-of-payee exclusion. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001)\n\nAccordingly:\n\n- A provider that only negotiates and never receives, controls, or transmits consumer money is not classified as a money transmitter merely because it negotiates debt.\n- A provider or affiliate that receives consumer funds for onward transmission to creditors presents a separate money-transmission question.\n- Use of an independent consumer-controlled account does not resolve the question without examining account control, withdrawal rights, payment instructions, and the provider’s ability to direct or possess funds.\n- No money-transmitter exemption should be inferred from Chapter 46 registration.\n- The Chapter 46 $25,000 trust is not a consumer payment account.\n\nMoney-transmitter application, bond, fees, and dedicated-account interpretations remain later-pass issues.\n\n## 5.2 Basic Business License\n\nCurrent D.C. law broadly requires a person doing business in the District to maintain a Basic Business License. “Business” includes compensated services offered in D.C.; “general sales and services” is the residual category for services not covered by another BBL category. DLCP currently directs applicants to BOSS and offers a BBL verification route. [D.C. Law Library+5](https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01)\n\nA covered CCSO with a D.C. business location likely has a parallel BBL obligation, probably under the general-business residual category unless DLCP assigns another endorsement. However:\n\n- The BBL definition refers to operating from a D.C. location.\n- The precise treatment of a remote provider with no District premises was not resolved.\n- The Code pages contain conflicting implementation notes concerning the 2023 licensing amendments, one saying implementation occurred October 1, 2025 and another retaining the earlier not-implemented note.\n- A BBL does not replace the DISB Chapter 46 registration.\n- DISB retains the legal determination for its own regulated category. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01)\n\nIf applicable, the current statutory BBL fee text lists $49 for six months, $99 for two years, and $198 for four years, with specified low-revenue fee relief. Those are government charges, not consumer debt-relief fees. Because remote-provider BBL applicability and the conflicting applicability notes were not fully reconciled, the amounts should not yet be incorporated into a final D.C. launch-cost model. [D.C. Law Library+2](https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.04)\n\n## 5.3 Foreign-entity registration\n\nA foreign filing entity doing business in D.C. generally must register under Title 29. Title 29 excludes certain activities from its own “doing business” test, including some interstate-commerce activity and orders accepted outside D.C.\n\nCrucially, § 29-105.05(b) states that those exclusions do not determine whether the entity is subject to regulation under other D.C. law. A company therefore cannot use a Title 29 foreign-qualification exclusion as a Chapter 46 CCSO exemption. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02)\n\nForeign qualification remains a separate entity-law issue requiring the provider’s actual solicitation, contracting, office, employee, and performance facts.\n\n# 6. Limited fee, timing, contract, and cancellation patch\n\n| Issue | Verified D.C. result | Limit |\n| --- | --- | --- |\n| Chapter 46 initial government fee | **$300** | Provider-to-government registration fee. |\n| Chapter 46 annual government fee | **$200** before April 2 or regulatory date | No current alternative regulatory date authenticated. |\n| Consumer service-fee amount cap | **HOLD** | No percentage, flat-dollar, monthly, per-debt, savings, or aggregate ceiling authenticated. Absence from Chapter 46 is not proof of unlimited fees. |\n| Money before completion | Prohibited unless the provider has the § 28-4604 security | Applicable federal TSR restrictions remain independently controlling where covered. |\n| Bond | **$25,000** | Surety must be legally permitted to do business in D.C. |\n| Provider trust alternative | **$25,000 minimum** | Must be at a federally insured bank or savings and loan association located in D.C.; this is provider security. |\n| “Completion” | **Undefined in authenticated Chapter 46 text** | DCMR interpretation or case law remains unresolved. |\n| Total-charge disclosure | Required before contract or payment | Disclosure must include detailed services and total amount charged. |\n| Written agreement | Required | Must state all payment terms, including payments to the provider or another person, services, refund promises, timing, and business/agent information. |\n| Cancellation | Five calendar days after signing | Exact interaction with completed services or third-party charges remains unresolved. |\n| Reimbursement after cancellation | Within ten days after receipt of cancellation notice | Scope and calculation were not further defined in authenticated rules. |\n| Consumer funds in dedicated account | No D.C.-specific Chapter 46 account formula established | Federal dedicated-account requirements were already handled in P1; D.C. money-transmission treatment depends on actual control and receipt. |\n\nThe statutory support for this table is §§ 28-4602 through 28-4605. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/28-4602)\n\nNo fee example is supplied because no current D.C. consumer-service fee formula or amount ceiling was established.\n\n# 7. Minimal PASS-01 supersession and coverage patch\n\n| P1 cell | PASS-02 treatment | Result |\n| --- | --- | --- |\n| **S_DC-P1-C003** — custodial, noncustodial, DMP, and counseling classifications unresolved | Superseded in part by P2 C001–C022. Chapter 46 is the governing affirmative framework; noncustodial principal-reduction and paid counseling have strong CCSO coverage. Custody, money transmission, dedicated-account control, and some DMP conditions remain partial. | **Partial → substantially answered, with enumerated sub-gaps** |\n| **S_DC-P1-C004** — repeal does not establish licensing or fee permission | Preserved. Chapter 46, not repeal, supplies the current affirmative registration framework. | **Confirmed and supplemented** |\n| **S_DC-P1-C005** — DISB complaint material did not verify a debt-settlement license | Replaced in part. DISB is the current CCSO administrator, and registration is required under § 28-4602. Current prescribed form, submission route, and CCSO-specific public lookup remain unresolved. | **Partial → regulator and legal category answered; procedure held** |\n| **S_DC-P1-C006** — no current D.C. commercial consumer-fee ceiling authenticated | Preserved. P2 establishes registration fees, state pre-completion security, contract disclosures, cancellation, and reimbursement; it does not establish a consumer-service fee amount cap. | **Still HOLD** |\n| **S_DC-P1-C008** — D.C.-specific provider fee trigger unresolved | Partially superseded. Chapter 46 prohibits pre-completion receipt absent bond/trust, but “completion” and any finer D.C. earning milestones remain unresolved. | **Partial** |\n| **P1 early § 4 federal-text retrieval hold** | Superseded by P1’s later supplemental federal finding and final self-check. | **Closed before P2; not a current gap** |\n| **S_DC-P1-C014** — no named provider authorization verified | Preserved only as “not investigated.” No named provider was checked in P2, and no adverse status inference is permitted. | **Not investigated** |\n\n# 8. PASS-02 source register\n\n## S_DC-P2-S001 — D.C. Code, Title 28, Chapter 46, Consumer Credit Service Organizations\n\n**Issuer:** Council of the District of Columbia, D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4601\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4602\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4603\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4604\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4605\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4606\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4607\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4608\n\n**Pinpoints:** §§ 28-4601(1)–(4), 28-4602(a)–(c), 28-4603(1)–(7), 28-4604(a)–(b), 28-4605(a)–(e), 28-4606(a)–(c), 28-4607, 28-4608.\n**Status/version:** Current codification read October 24, 2026. Individual section histories range from the 1991 enactment through the May 6, 2020 amendment to § 28-4601.\n**Actual check:** All operative sections directly opened and read.\n**Limit:** Does not itself supply a current public application form, detailed territorial definition, definition of “completion,” or consumer fee amount cap. [D.C. Law Library+8](https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46)\n\n## S_DC-P2-S002 — D.C. Law 8-236\n\n**Issuer:** Council of the District of Columbia\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/laws/8-236\n**Pinpoint:** Enacting law for the CCSOA; effective March 8, 1991, 38 DCR 306, as reflected in the codified section histories.\n**Actual check:** Law metadata and codification links identified; complete session-law HTML was not relied upon as independently read text.\n**Limit:** Current operative analysis is based on S001’s codified text.\n\n## S_DC-P2-S003 — D.C. Code publication information\n\n**Issuer:** D.C. Law Library\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/code\n**Pinpoint:** Publication-information block.\n**Status:** Current through October 22, 2026; last codified permanent and emergency measures identified above.\n**Actual check:** Directly opened and read.\n**Limit:** Publisher currency is not proof that every administrative rule or noncodified order was found. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code)\n\n## S_DC-P2-S004 — D.C. Code § 26-551.03\n\n**Issuer:** D.C. Law Library\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03\n**Pinpoints:** Subsections (b), (g); editor’s note quoting D.C. Law 14-28 § 802.\n**Status:** Current codification.\n**Actual check:** Directly read.\n**Use:** Administration of Banking Code; transfer of Title 28, Chapter 46 functions to the banking regulator. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03)\n\n## S_DC-P2-S005 — D.C. Code §§ 31-101 and 31-103\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/31-101\n- https://code.dccouncil.gov/us/dc/council/code/sections/31-103\n\n**Pinpoints:** § 31-101(2), (3), (5); § 31-103(a)(3).\n**Actual check:** Directly read.\n**Use:** Identifies DISB, the Commissioner, and administration through the Securities and Banking Bureau. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/31-101)\n\n## S_DC-P2-S006 — DISB Banking Bureau\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/banking-bureau\n**Pinpoints:** Licensing Division description, especially the bullets naming CCSOs and the non-depository licensing database.\n**Actual check:** Current page directly read October 24, 2026.\n**Limit:** Says “license applications” but does not supply the Chapter 46 form or identify the precise registration submission route. [Disb](https://disb.dc.gov/page/banking-bureau)\n\n## S_DC-P2-S007 — DISB Divisions\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/divisions-1\n**Pinpoints:** Banking Division, Licensing Division bullets.\n**Actual check:** Directly read.\n**Use:** Names CCSOs among reviewed applications and identifies NMLS as the maintained non-depository database.\n**Limit:** Does not expressly state that the Chapter 46 CCSO registration is currently filed through a particular NMLS license type. [Disb](https://disb.dc.gov/page/divisions-1)\n\n## S_DC-P2-S008 — DISB Compliance Requirements: Banking\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/compliance-requirements-banking\n**Pinpoints:** Non-depository licensing list and forms section.\n**Actual check:** Directly read.\n**Limit:** Current list omits CCSOs; omission is evidence of an operational gap, not statutory noncoverage. [Disb](https://disb.dc.gov/page/compliance-requirements-banking)\n\n## S_DC-P2-S009 — DISB non-depository public verification page\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/non-depository-institutions-operating-dc\n**Pinpoints:** Lines directing users to NMLS Consumer Access and enumerating categories.\n**Actual check:** Directly read.\n**Limit:** CCSOs are not expressly included in the page’s enumeration. No named provider was checked. [Disb](https://disb.dc.gov/page/non-depository-institutions-operating-dc)\n\n## S_DC-P2-S010 — DISB Licensing and Registration Requirements\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/licensing-and-registration-requirements\n**Pinpoint:** Forms and application listing.\n**Actual check:** Directly read.\n**Limit:** No current CCSO form or checklist surfaced. [Disb](https://disb.dc.gov/page/licensing-and-registration-requirements)\n\n## S_DC-P2-S011 — D.C. Municipal Regulations, Title 16\n\n**Issuer:** Office of Documents and Administrative Issuances\n**Literal URLs:**\n\n- https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16\n- https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1\n- Attempted: https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37\n\n**Pinpoints:** Title 16 chapter list; Chapter 1 section list.\n**Actual check:** Title index and Chapter 1 list directly read; Chapter 37 route failed.\n**Limit:** No CCSO-specific operative rule or adoption order authenticated. The displayed 1/1/1900 dates were not accepted as actual rule effective dates. [DCRegs+2](https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16)\n\n## S_DC-P2-S012 — OAG Student Aid Center release\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc\n**Date:** May 25, 2016.\n**Pinpoints:** Description of Florida provider, District marketing, debt-relief services, and CCSOA advance-fee allegations.\n**Actual check:** Directly read.\n**Limit:** Press release summarizing allegations. [DC Attorney General](https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc)\n\n## S_DC-P2-S013 — District v. Student Aid Center complaint\n\n**Issuer:** D.C. Office of Attorney General / D.C. Superior Court filing\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf\n**Pinpoints:** Complaint ¶¶ 3, 24, 29, 37–47; printed pages 2, 7–8, 11–12.\n**Actual check:** Parsed text read and printed pages 11–12 visually inspected.\n**Limit:** Allegations, not adjudicated findings. [DC Attorney General+2](https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf)\n\n## S_DC-P2-S014 — OAG Burlington release\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against\n**Date:** May 23, 2017.\n**Pinpoints:** Maryland provider, District consumers, debt validation/reduction services, settlement terms.\n**Actual check:** Directly read.\n**Limit:** Agency summary of a consent resolution. [DC Attorney General](https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against)\n\n## S_DC-P2-S015 — Burlington consent judgment\n\n**Issuer:** D.C. Superior Court / D.C. OAG\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf\n**Pinpoints:** Printed pages 2–4, especially ¶¶ 2, 4, 6–8, 11, 18, and 22–23.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Party-specific consent judgment; defendants denied the alleged violations. [DC Attorney General+2](https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf)\n\n## S_DC-P2-S016 — YF Solution Assurance of Voluntary Compliance\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf\n**Pinpoints:** Printed pages 3–4, ¶¶ 8–14 and 18.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Assurance and stipulations, not a controlling judicial interpretation. [DC Attorney General+1](https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf)\n\n## S_DC-P2-S017 — Chen v. Bell-Smith\n\n**Issuer:** U.S. District Court for the District of Columbia\n**Literal URL:** https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf\n**Citation/date:** Civil Action No. 08-0999 (JDB), memorandum opinion filed March 8, 2011.\n**Pinpoints:** Printed pages 39–40.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Federal trial-court decision; unusual own-credit and consumer-awareness facts; not controlling D.C. appellate authority. [GovInfo+1](https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf)\n\n## S_DC-P2-S018 — D.C. Money Transmitters Act provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1001\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1002\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1003\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1004\n\n**Pinpoints:** §§ 26-1001(10), 26-1002(a), 26-1003(a)–(b), 26-1004.\n**Actual check:** Directly read.\n**Limit:** Full application, bonding, fees, interpretive decisions, and all funds-flow exceptions were not completed. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001)\n\n## S_DC-P2-S019 — Basic Business License provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.02\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.03\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.04\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.07\n\n**Pinpoints:** Definitions, license requirement, general-sales-and-services category, statutory fees, and retention of regulator eligibility judgments.\n**Actual check:** Directly read.\n**Limit:** Conflicting implementation notes and remote-provider/location application remain unresolved. [D.C. Law Library+5](https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01)\n\n## S_DC-P2-S020 — DLCP Business Licensing Division\n\n**Issuer:** Department of Licensing and Consumer Protection\n**Literal URL:** https://dlcp.dc.gov/service/business-licensing-division\n**Pinpoints:** Business definition, requirement, BOSS application route, General Business category, and BBL verification.\n**Actual check:** Directly read.\n**Limit:** Does not decide the DISB CCSO registration or remote/no-location application. [DCRA+2](https://dlcp.dc.gov/service/business-licensing-division)\n\n## S_DC-P2-S021 — Foreign-entity provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02\n- https://code.dccouncil.gov/us/dc/council/code/sections/29-105.05\n\n**Pinpoints:** Registration duty; activities not constituting business under Title 29; savings clause for regulation under other D.C. law.\n**Actual check:** Directly read. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02)\n\n## S_DC-P2-S022 — Historical DISB initial non-depository instructions\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf\n**Version:** May 2014.\n**Actual check:** Text read and page 1 visually inspected.\n**Limit:** Historical; does not list CCSOs among the covered application categories; contains superseded addresses and paper-submission instructions; not used as current CCSO procedure. [Disb+1](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf)\n\n## S_DC-P2-S023 — DISB FY 2017–2018 Biennial Report\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20(1).pdf\n**Pinpoint:** Printed page 14, licensing-system discussion.\n**Actual check:** Text read and page visually inspected.\n**Limit:** Historical operational context; not current filing instructions. [Disb+1](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf)\n\n### P1 authority aliases, not new P2 sources\n\n- **P1-S002:** D.C. Code § 22-1201 repeal entry — preserved solely for the narrow repeal finding.\n- **P1-S010:** 16 C.F.R. § 310.4 — previously verified in P1; early retrieval hold superseded.\n- No duplicate P2 source IDs were assigned to those already-reviewed authorities.\n\n# 9. PASS-02 claim register\n\n| Claim ID | Precise assertion | Sources/pinpoints | Conditions and confidence limit |\n| --- | --- | --- | --- |\n| **S_DC-P2-C001** | D.C. Code Title 28, Chapter 46 is the current affirmative consumer-credit-service-organization framework. | S001, Chapter heading and §§ 4601–4608 | High; does not by itself resolve every debt-relief fact pattern. |\n| **C002** | Paid advice or assistance concerning personal, household, or family credit is within the CCSO definition. | S001, § 28-4601(2)(A)(iii) | High as statutory text. |\n| **C003** | A paid noncustodial provider negotiating reduction or resolution of personal debts has a strong textual fit under § 28-4601(2)(A)(iii). | S001; S013; S015; S016 | Strong qualified conclusion; statute does not use the words “debt settlement.” |\n| **C004** | D.C. OAG has applied the CCSOA to student-debt relief and services intended to validate, dispute, resolve, or reduce consumer debts. | S012–S016 | High as enforcement position; complaints and settlements are not controlling appellate holdings. |\n| **C005** | A covered CCSO operating in D.C. must register and pay $300 initially and $200 annually. | S001, § 28-4602(a) | High. |\n| **C006** | Chapter 46 does not define “operates in the District”; OAG has pursued out-of-state entities serving District consumers. | S001, § 28-4602; S013, complaint ¶ 3; S015, pp. 2–3 | High for text and enforcement facts; controlling territorial test unresolved. |\n| **C007** | DISB is the current administering regulator for Chapter 46. | S004–S007 | High. |\n| **C008** | DISB’s Licensing Division currently identifies CCSOs as an application category and maintains the non-depository/NMLS database. | S006–S007 | High as agency operational statement. |\n| **C009** | No current CCSO-specific prescribed form, checklist, or complete submission route was authenticated. | S008–S011; S022–S023 | Research-result limitation, not proof that no form exists. |\n| **C010** | A CCSO-specific public-registration lookup pathway was not verified. | S009; failed NMLS route | No named provider was checked. |\n| **C011** | Noncustodial debt negotiation does not require custody to fit the CCSO advice/assistance definition. | S001, § 28-4601(2)(A)(iii) | Strong textual conclusion. |\n| **C012** | Paid DMP or credit counseling can fit Chapter 46 even without principal reduction. | S001, § 28-4601(2)(A)(iii) | Actual services and consideration matter. |\n| **C013** | A provider or affiliate receiving consumer money for onward transmission may separately require a money-transmitter license. | S018, §§ 26-1001(10), 26-1002, 26-1003 | Conditional; actual funds flow and interpretations unresolved. |\n| **C014** | The § 28-4604 trust is provider security and is not the consumer’s dedicated settlement account. | S001, § 28-4604 | High. |\n| **C015** | Agents and independent persons who sell or attempt to sell CCSO services are included; pure lead generation remains fact-dependent. | S001, § 28-4601(2)(B)–(C) | High for sellers; unresolved for passive referrals. |\n| **C016** | Paid credit-repair representations are directly within § 28-4601(2)(A)(i). | S001 | High; CROA overlap held. |\n| **C017** | Only an actual § 501(c)(3) organization receives the listed nonprofit exclusion. | S001, § 28-4601(2)(D)(iv); § 28-4606(b) | High; claimant bears burden. |\n| **C018** | Attorney exclusion requires D.C. licensure and services within the course and scope of practice. | S001, § 28-4601(2)(D)(vi); § 28-4606(b) | High; affiliation alone insufficient. |\n| **C019** | Other institutional exclusions are actor- and conduct-specific and do not create a general affiliate exemption. | S001, § 28-4601(2)(D) | High as limited reading. |\n| **C020** | Pure business-purpose debt is outside Chapter 46’s consumer-credit definition. | S001, § 28-4601(3) | High; mixed-purpose treatment unresolved. |\n| **C021** | A genuinely free service with no valuable consideration is outside the CCSO definition. | S001, § 28-4601(2)(A) | Qualified; indirect compensation may alter result. |\n| **C022** | Own-credit and consumer-unaware transactions can fall outside Chapter 46; Chen supports this only on its facts. | S017, pp. 39–40 | Moderate; federal trial-court authority only. |\n| **C023** | A parallel BBL likely applies to a CCSO doing business from a D.C. location; remote/no-location treatment is unresolved. | S019–S020 | Partial due statutory location language and applicability-note conflict. |\n| **C024** | Title 29 foreign-entity exclusions do not determine Chapter 46 regulatory coverage. | S021, § 29-105.05(b) | High. |\n| **C025** | Chapter 46 bars pre-completion receipt absent the $25,000 bond or trust. | S001, §§ 28-4603(1), 28-4604 | High as state rule; no federal authorization inferred. |\n| **C026** | Chapter 46 requires pre-contract disclosures, a written contract, five-day cancellation, and reimbursement within ten days. | S001, § 28-4605 | High as statutory text. |\n| **C027** | No current D.C. consumer-service fee amount ceiling was authenticated. | Complete S001 review; S011 rule search | Evidence gap, not proof of no cap or unlimited fees. |\n| **C028** | “Completion” is not defined in authenticated Chapter 46 text. | S001, §§ 28-4601–4608 | High for the chapter; rule or case interpretation unresolved. |\n| **C029** | OAG pleadings and resolutions support coverage but do not replace controlling judicial construction. | S012–S016 | High methodological qualification. |\n| **C030** | No named provider’s registration or authorization was checked. | Scope limitation | Not an adverse status finding. |\n| **C031** | Public-source evidence is insufficient to mark D.C. operationally launch-ready because the current filing and lookup mechanics remain incomplete. | C005, C007–C010 | Operational conclusion, not denial of legal registration availability. |\n| **C032** | P1’s early federal-text hold was superseded by P1’s later verified TSR finding. | P1 internal record supplied in prompt | Closed P1 issue; federal overview not repeated. |\n| **C033** | No current operative CCSO-specific DCMR rule or adoption order was authenticated. | S001 § 28-4608; S011 | Search limitation, not exhaustive absence claim. |\n\n# 10. Component coverage and exact next investigations\n\n| Model or legal category | Status | Claims | Exact missing evidence and next investigation |\n| --- | --- | --- | --- |\n| Affirmative governing statute | **Answered** | C001–C005 | Preserve Chapter 46 as controlling starting point. |\n| For-profit noncustodial principal reduction | **Answered, qualified** | C003–C004, C011 | Target controlling D.C. appellate authority or a final administrative decision directly construing debt settlement. |\n| Remote provider nexus | **Partial** | C006 | Search D.C. Court of Appeals, Superior Court orders, DISB decisions, and rulemaking for “operates in the District”; test solicitation, contracting, and performance factors. |\n| Issuing regulator | **Answered** | C007–C008 | None for agency identity. |\n| Current application form/checklist | **Unresolved** | C009 | Locate the current Mayor/DISB-prescribed CCSO registration statement, state checklist, renewal form, and submission method from DISB, NMLS state-resource materials, D.C. Register notices, or archived agency rulemaking. |\n| Current public lookup | **Unresolved** | C010 | Establish whether CCSOs appear in NMLS Consumer Access, a separate DISB database, or another public roster; do not test a named provider until the category is identified. |\n| Operative DCMR registration rules | **Unresolved** | C033 | Retrieve complete Chapter 37 text, search D.C. Register rulemaking history, and locate any final Chapter 46 registration/disclosure/cancellation rules and Council review records. |\n| Noncustodial DMP or credit counseling | **Partial** | C012 | Obtain D.C. administrative or judicial classification and review actual compensation and services. |\n| Custodial DMP | **Partial** | C013 | Map funds from consumer through each account and entity; complete money-transmission licensing and exemption pass. |\n| Consumer-controlled dedicated account | **Partial** | C013–C014 | Review account contract, consumer ownership, provider access, payment direction, withdrawal, and affiliate roles. |\n| Provider- or affiliate-controlled account | **Partial** | C013 | Complete money-transmitter authorization, delegate, bond, permissible-investment, and application review. |\n| Provider § 28-4604 trust | **Answered** | C014, C025 | Later pass should confirm approved trust form, depository evidence, and regulator filing treatment. |\n| Compensated sales agents | **Answered** | C015 | Later pass may inspect individual liability and registration practices. |\n| Passive lead generators and referrals | **Unresolved** | C015 | Review scripts, handoff, sale attempts, compensation, branding, data transfer, and creditor/referral relationships. |\n| Credit-repair representations | **Answered for D.C.; federal overlap partial** | C016 | Complete conditional CROA applicability and any separate D.C. credit-reporting interpretations. |\n| § 501(c)(3) exclusion | **Answered** | C017 | Verify actual IRS status and operating entity identity for any provider claiming it. |\n| Attorney exclusion | **Answered in text; factual use partial** | C018 | Verify D.C. bar status, engagement structure, legal work, nonlawyer affiliate conduct, fee sharing, and scope of practice. |\n| Institutional exclusions | **Answered in text** | C019 | Match actual entity and conduct to each clause; do not extend exclusions by analogy. |\n| Business-purpose obligations | **Answered for pure business debt** | C020 | Develop mixed-purpose and sole-proprietor allocation rules if needed. |\n| Free counseling | **Partial** | C021 | Investigate indirect or third-party consideration. |\n| Original creditor/self-creditor | **Partial** | C022 | Search controlling D.C. authority; distinguish self-creditor activity from separately sold advisory services. |\n| Money transmission | **Partial** | C013 | Complete full statute, DCMR, DISB checklist, exemptions, interpretive orders, and account-flow analysis. |\n| BBL | **Partial** | C023 | Reconcile conflicting implementation notes and determine remote/no-premises treatment and correct endorsement. |\n| Foreign-entity qualification | **Partial** | C024 | Apply Title 29 to actual solicitation, contracting, employees, offices, and transaction pattern. |\n| State pre-completion rule | **Answered in text** | C025, C028 | Locate any rule or case defining completion; keep federal TSR independent. |\n| Consumer fee amount cap | **Unresolved** | C027 | Search final Chapter 46 regulations, DISB orders, D.C. Register, fee bulletins, and controlling cases. No CPI or borrowed model-act calculation. |\n| Contract, cancellation, reimbursement | **Answered at statutory level; implementation partial** | C026 | Obtain any mandatory forms or implementing rules and later analyze cancellation calculations. |\n| Named provider authorization | **Not investigated** | C030 | Only after the correct registry/category and lookup methodology are verified. |\n| Market launch readiness | **HOLD** | C031 | Verify current registration filing pathway and public or official confirmation mechanism before operational approval. |\n| Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law | **Outside P2 except intersections above** | — | Preserve for later passes; no acceptance by implication. |\n\n# 11. Actual search, read, and failure log\n\n| Log ID | Route or query checked | Result | Evidentiary treatment |\n| --- | --- | --- | --- |\n| **F001** | Full official Chapter 46 section sequence, §§ 28-4601–4608 | All sections opened and read | Primary controlling text |\n| **F002** | Official D.C. Code searches for debt settlement, debt management, credit counseling, and debt adjusting | No separate current provider chapter surfaced beyond Chapter 46 and unrelated provisions | Documented search coverage only; not proof of absence |\n| **F003** | https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16 | Title 16 index read; Chapters 1 and 37 identified | Primary index |\n| **F004** | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1 | Consumer Retail Credit section list read; no CCSO heading displayed | Does not establish absence from other chapters or register notices |\n| **F005** | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37 | Web tool returned non-retryable open failure | Chapter 37 operative text remains unread |\n| **F006** | Official-domain D.C. Register searches for “consumer credit service organization,” “debt settlement,” “debt management,” “credit counseling,” and “28-4608” | No matching current CCSO implementation rule was authenticated | Search limitation; no exhaustive absence claim |\n| **F007** | Current DISB Banking Bureau and Divisions pages | CCSO application category and Licensing Division established | Current operational support |\n| **F008** | Current DISB banking compliance, verification, and forms pages | CCSO-specific checklist/form/category not displayed | Public procedure remains unresolved |\n| **F009** | https://www.nmlsconsumeraccess.org through the research tool | Direct route could not be opened | No provider or category lookup performed |\n| **F010** | Current NMLS/official-domain searches for a D.C. CCSO state checklist | No current D.C. CCSO-specific checklist authenticated | Does not establish that NMLS cannot process the category |\n| **F011** | May 2014 DISB initial non-depository instructions | Document read and visually inspected; categories omitted CCSO and instructions are historical | Excluded as current procedure |\n| **F012** | DISB FY 2017–2018 report | Historical NMLS transition discussion read and visually inspected | Historical context only |\n| **F013** | Student Aid Center complaint PDF | Parsed text read; relevant pages visually inspected | Allegations, not adjudication |\n| **F014** | Burlington consent judgment PDF | Relevant pages visually inspected | Party-specific consent; defendants denied violations |\n| **F015** | YF assurance PDF | Relevant pages visually inspected | Assurance and stipulations, not precedent |\n| **F016** | Chen opinion PDF | Relevant pages visually inspected | Federal trial-court boundary authority |\n| **F017** | Targeted D.C. and federal case searches for CCSOA and debt-relief construction | Chen located; no controlling D.C. Court of Appeals debt-settlement decision located | Targeted result only, not exhaustive case-law absence finding |\n| **F018** | Money-transmission §§ 26-1001–1004 | Directly read | Preliminary parallel-category analysis only |\n| **F019** | BBL and foreign-entity provisions | Directly read | Parallel-category analysis; remote application unresolved |\n| **F020** | Named provider lookup | Deliberately not performed | No provider-status claim |\n\n# 12. Researcher self-check and final disposition\n\n## Actually freshly read or visually inspected\n\n- Complete current D.C. Code Chapter 46 operative sections.\n- Current D.C. Code publication information.\n- Financial-regulator transfer and administration provisions.\n- Current DISB Banking Bureau, Divisions, compliance, verification, and licensing pages.\n- DCMR Title 16 index and Chapter 1 listing.\n- OAG Student Aid Center release and complaint, including relevant complaint-page images.\n- Burlington release and relevant consent-judgment pages.\n- Relevant YF Solution assurance pages.\n- Chen v. Bell-Smith pages 39–40.\n- Preliminary money-transmission, BBL, and foreign-entity provisions.\n- Historical 2014 DISB instructions and FY 2017–2018 biennial report, with page inspection.\n\n## Reused rather than re-researched\n\n- PASS-01 § 22-1201 repeal finding.\n- PASS-01 current federal TSR text and timing findings.\n- PASS-01 debt-collector and government-debt distinctions.\n\n## Not established or not completely read\n\n- A current CCSO-specific registration form, checklist, renewal form, or submission instruction.\n- A verified CCSO-specific public registry or NMLS lookup category.\n- Complete operative Chapter 37 DISB-infraction text.\n- Full D.C. Register rulemaking and adoption history under § 28-4608.\n- A controlling D.C. Court of Appeals debt-settlement classification decision.\n- Complete money-transmitter application, funds-flow, exemption, bond, fee, and interpretive framework.\n- CROA applicability.\n- Named-provider authorization.\n- Full BBL remote-provider application.\n- Remaining state, local, tribal, contract, remedies, limitations, secured-debt, sector, and comprehensive case-law categories.\n\n## Final provider-market-access result\n\nThe decisive PASS-01 gap is partly closed:\n\n1. **The District has an affirmative current provider framework:** D.C. Code Title 28, Chapter 46.\n2. **A compensated commercial debt-settlement or negotiation provider serving District consumers has a strong, officially enforced fit within the CCSO definition.**\n3. **A covered CCSO must register.**\n4. **DISB’s Banking Licensing Division is the administering authority.**\n5. **The current public application/checklist and CCSO-specific lookup process remain unverified.**\n6. **The D.C. consumer-service fee amount ceiling remains unresolved.**\n7. **The Chapter 46 state advance-payment branch, bond/trust amount, contract duties, cancellation period, and reimbursement timing are verified.**\n8. **D.C. is not presently supportable as “no registration required” or as operationally launch-ready.**\n\nThis is a focused same-coordinator follow-up, not independent review, qualified legal approval, publication readiness, state acceptance, or A066 acceptance.\n\n**PASS-02 status: AFFIRMATIVE FRAMEWORK ESTABLISHED; OPERATIONAL REGISTRATION PATH AND CONSUMER FEE AMOUNTS REMAIN PARTIAL/HOLD.**\n\nEND S_DC PASS-02.\n\n","tables":[{"headers":["Authority and pinpoint","Operative rule and covered conduct","Authorization, exemption, or condition","Version/effectiveness and limits","Claims"],"index":0,"links":[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. 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Law Library\n+3"}],[{"href":"https://disb.dc.gov/page/banking-bureau","text":"Disb\n+1"}]],"rows":[["Authority and pinpoint","Operative rule and covered conduct","Authorization, exemption, or condition","Version/effectiveness and limits","Claims"],["D.C. Code § 28-4601(1)","“Consumer” is a person solicited to purchase or purchasing CCSO services. Consumer awareness and purchase or solicitation matter.","Establishes the protected customer relationship; it does not require that every payment come directly from the consumer.","Enacted effective March 8, 1991. No separate amendment shown for subsection (1). Chen applied this definition narrowly on unusual facts involving no consumer solicitation or awareness. \nD.C. Law Library\n+1","C002, C022"],["§ 28-4601(2)(A)(i)","Paid services represented as improving a consumer’s credit record, history, or rating are directly covered.","Covered unless an exact subsection (D) exclusion applies.","Section last amended May 6, 2020. CROA applicability remains outside this pass. \nD.C. Law Library","C002, C016"],["§ 28-4601(2)(A)(ii)","Paid assistance obtaining an extension of credit for a consumer is covered.","Same exclusions.","“Extension of credit by others” limits the definition; Chen rejected coverage where the defendants obtained funds in their own names and then extended their own alleged credit. \nD.C. Law Library\n+2","C002, C022"],["§ 28-4601(2)(A)(iii)","Paid advice or assistance concerning any matter related to personal, household, or family credit is covered.","Principal-reduction negotiation, debt validation, dispute assistance, DMP counseling, and similar services have a strong textual fit, subject to actual facts and exclusions.","The section does not say “debt settlement.” OAG’s debt-relief actions supply official enforcement support rather than binding appellate construction. \nD.C. Law Library\n+4","C003, C004, C011, C012"],["§ 28-4601(2)(B)–(C)","Salespersons, agents, representatives, and independent agents who sell or attempt to sell CCSO services are included.","A seller cannot avoid coverage merely by being labeled an agent or independent marketer.","Pure lead generation that stops before selling, attempting to sell, advising, or assisting remains fact-dependent. \nD.C. Law Library","C015"],["§ 28-4601(2)(D)(i)–(viii)","Express exclusions cover specified regulated lenders, insured banks and certain subsidiaries, qualifying credit unions, § 501(c)(3) organizations, collection agencies operating under D.C. law, D.C.-licensed attorneys acting within their practice, broker-dealers acting within applicable federal law, and FCRA consumer reporting agencies.","Each exclusion is actor- and conduct-specific. Nonprofit branding, an attorney relationship, or institutional affiliation alone is insufficient.","The claimant bears the burden of proving an exception or exemption under § 28-4606(b). \nD.C. Law Library\n+1","C017–C019"],["§ 28-4601(3)","“Extension of credit” concerns deferred debt primarily for personal, family, or household purposes.","Purely business-purpose credit falls outside this Chapter 46 definition.","Mixed-purpose, guarantor, sole-proprietor, and personally liable business-card facts require separate analysis. \nD.C. Law Library","C020"],["§ 28-4602(a)–(c)","A covered CCSO operating in D.C. must file the prescribed registration statement, pay $300 initially and $200 annually, report information changes within ten days, and supply additional requested information before acceptance.","Registration is mandatory; it is not created by the repealed § 22-1201.","Last amended October 3, 2001. “Operates in the District” is not defined in Chapter 46. \nD.C. Law Library","C005, C006"],["§ 28-4603(1)","A CCSO may not charge or receive consideration before completion unless it has the § 28-4604 bond or trust.","This is a state-law exception to the state prohibition, not federal TSR authorization.","“Completion” is not defined in the Chapter 46 definitions. No authenticated DCMR interpretation was located. \nD.C. Law Library\n+1","C025, C028"],["§ 28-4603(2)","Prohibits charging solely for certain referrals to a retail seller where substantially similar credit is available to the public.","This is a narrow referral prohibition, not a general authorization for all compensated referrals.","Does not resolve pure lead generation, creditor-referral compensation, or affiliate marketing outside its terms. \nD.C. Law Library","C015"],["§ 28-4603(3)–(7)","Prohibits specified false or misleading credit statements, deceptive omissions or methods, misleading use of “repair,” waiver attempts, and noncompliance with the chapter or rules.","Applies independently of registration and fee timing.","Current codified section traces its latest listed amendment to April 9, 1997. \nD.C. Law Library","C016, C029"],["§ 28-4604(a)–(b)","A provider receiving money before completion must maintain a $25,000 surety bond or a $25,000 minimum trust at a qualifying District institution. Security may support cancellation refunds, assessed damages, and complaint settlements.","The trust is provider financial security. It is not the consumer’s dedicated settlement account.","Enacted effective March 8, 1991. No indexed adjustment language appears in the section. \nD.C. Law Library","C014, C025"],["§ 28-4605(a)–(c)","Requires pre-contract or pre-payment disclosures, retention of signed disclosures, a detailed description of services and total charges, and a written signed contract containing all payment terms, including payments to the provider or another person.","Applies to covered CCSOs regardless of whether money is paid directly to the provider.","Drafting contains substantial credit-report-repair terminology; application to debt settlement is supported by OAG enforcement but has not been comprehensively construed by an appellate court. \nD.C. Law Library\n+1","C026, C029"],["§ 28-4605(d)–(e)","Contract must include a five-calendar-day cancellation right; reimbursement is due within ten days after receipt of the cancellation notice; required documents must be given to the consumer.","Exact treatment of already completed services, third-party charges, or consumer account funds is not comprehensively specified in the text reviewed.","Enacted effective March 8, 1991. No separate current rule was authenticated. \nD.C. Law Library","C026"],["§ 28-4606","Registrations receive APA hearing protection; the person claiming an exemption carries the burden; rights under other D.C. and federal law remain enforceable.","A claimed nonprofit, attorney, lender, or other exclusion must be proved by the claimant. The chapter does not displace the federal TSR.","Enacted effective March 8, 1991. \nD.C. Law Library","C017–C019, C025"],["§ 28-4607","Provides criminal, civil, and private remedies for Chapter 46 violations.","Confirms the registration and conduct rules are enforceable, not merely advisory.","Last listed amendment June 11, 2013. Full remedies analysis remains for a later pass. \nD.C. Law Library","C001, C029"],["§ 28-4608","Directs the Mayor to issue implementing rules covering registration, sample disclosures, contract and cancellation forms, and civil fines.","The statute contemplates an implementation layer beyond the Code text.","No current operative CCSO-specific rule or adoption order was authenticated in this pass. \nD.C. Law Library","C009, C033"],["D.C. Code § 26-551.03; §§ 31-101, 31-103","Transfers and assigns Chapter 46 financial-regulation functions to the banking regulator now operating within DISB.","DISB, through its banking organization, is the administering regulator.","§ 26-551.03’s editor’s note expressly identifies Title 28, Chapter 46 in the transferred functions. \nD.C. Law Library\n+3","C007"],["Current DISB Banking Bureau/Divisions pages","Licensing Division reviews CCSO applications and maintains the non-depository licensing database/NMLS.","Operationally confirms the active regulatory category.","Webpage statements as accessed October 24, 2026; not statutory effective dates and not a CCSO-specific filing checklist. \nDisb\n+1","C008–C010"]]},{"headers":["Model or status","Chapter 46 result","Other possible category","Authorization or exemption result","Remaining condition or failure case"],"index":1,"links":[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+3"},{"href":"https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc","text":"DC Attorney General\n+3"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/26-1001","text":"D.C. Law Library\n+2"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4604","text":"D.C. Law Library"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+1"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+1"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"},{"href":"https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf","text":"GovInfo\n+1"},{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"},{"href":"https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf","text":"DC Attorney General\n+3"},{"href":"https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf","text":"GovInfo"}],"row_links":[[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+3"}],[{"href":"https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc","text":"DC Attorney General\n+3"}],[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/26-1001","text":"D.C. Law Library\n+2"}],[],[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4604","text":"D.C. Law Library"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"}],[],[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+1"}],[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library\n+1"}],[],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"}],[{"href":"https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf","text":"GovInfo\n+1"}],[{"href":"https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","text":"D.C. Law Library"}],[{"href":"https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf","text":"DC Attorney General\n+3"}],[{"href":"https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf","text":"GovInfo"}]],"rows":[["Model or status","Chapter 46 result","Other possible category","Authorization or exemption result","Remaining condition or failure case"],["For-profit, noncustodial principal-reduction negotiation","Answered, qualified: strong CCSO coverage under § 28-4601(2)(A)(iii). OAG has applied the CCSOA to services intended to resolve or reduce consumer debts. \nD.C. Law Library\n+3","No separate debt-settlement license chapter was authenticated.","Chapter 46 registration required if the provider operates in D.C. and lacks an exclusion.","No controlling D.C. appellate debt-settlement decision located; current filing mechanics unresolved."],["Student-loan debt relief or repayment-plan assistance for compensation","Answered, qualified: official OAG complaint treated such a provider as a CCSO. \nDC Attorney General\n+3","Student-loan-servicer licensing could be separate if the company actually services loans; not analyzed here.","CCSO registration and Chapter 46 conditions apply under OAG’s pleaded theory.","The Student Aid document is a complaint, not a merits judgment."],["Paid DMP or credit counseling without custody","Partial: paid advice or assistance concerning personal credit fits § 28-4601(2)(A)(iii).","No separate D.C. DMP statute or current DCMR category was authenticated.","Registration unless an exact exclusion, particularly § 501(c)(3), applies.","Creditor concessions, payment administration, and provider compensation facts may affect classification."],["Genuinely free counseling with no direct or indirect valuable consideration","Partial, likely outside Chapter 46: the definition requires money or other valuable consideration.","Other consumer-protection laws could still apply.","No Chapter 46 registration on the stated no-consideration facts.","Referral payments, affiliate revenue, creditor funding, data monetization, or bundled charges may constitute consideration. \nD.C. Law Library"],["Custodial DMP receiving consumer money and paying creditors","Partial: counseling or assistance remains CCSO conduct.","Possible money-transmitter licensing because D.C. defines money transmission to include receiving money for transmission and requires a license absent an exemption. \nD.C. Law Library\n+2","Chapter 46 registration plus any independently applicable money-transmitter authorization.","Exact funds flow, ownership, agency, bank relationship, and receipt/control must be established. No debt-relief or agent-of-payee exemption appears in the inspected §§ 26-1001–1003, but a complete interpretive pass remains open."],["Independent consumer-controlled dedicated account","Partial: using a dedicated account does not remove the provider’s advice or negotiation from Chapter 46.","Money-transmission treatment depends on whether the provider or affiliate receives, controls, or transmits the funds.","CCSO registration still required if otherwise covered.","Account agreement, payment instructions, provider access, affiliate status, and withdrawal control are essential."],["Provider- or affiliate-controlled dedicated account","Partial, elevated money-transmission risk: receipt or transmission by the provider or affiliate may fit § 26-1001(10).","Money transmitter.","Separate authorization potentially required.","No conclusion without actual account and funds-flow documents."],["§ 28-4604 provider trust account","Answered: this is $25,000 provider security supporting refunds and liabilities.","Not a money-transmission classification by itself.","Necessary for the Chapter 46 state-law pre-completion-payment branch.","Must not be mislabeled as the consumer’s settlement savings account. \nD.C. Law Library"],["Sales agent or independent closer selling the program","Answered: expressly included as a CCSO.","Individual licensing was not separately found.","Covered through the organization definition.","Outsourcing sales does not remove Chapter 46 coverage. \nD.C. Law Library"],["Pure compensated lead generator or referral source","Unresolved: inclusion depends on whether it sells or attempts to sell CCSO services, advises the consumer, or otherwise acts as an agent or representative.","CPPA, advertising, telemarketing, and referral rules may separately apply.","No blanket broker exemption established.","Need scripts, compensation, handoff, representations, and degree of participation."],["Credit-repair promises or representations","Answered: directly covered by § 28-4601(2)(A)(i), subject to exclusions.","Conditional federal TSR credit-repair rule and CROA may overlap.","Chapter 46 registration if covered.","CROA applicability remains held as directed; no universal federal or state exemption inferred."],["Organization actually exempt under IRC § 501(c)(3)","Answered: expressly excluded from the CCSO definition.","Other laws may remain applicable.","No Chapter 46 registration if the entity actually satisfies the exact exemption.","“Nonprofit” branding, state incorporation, or pending tax status is not enough; claimant bears the burden. \nD.C. Law Library\n+1"],["Other nonprofit organization","Answered: no categorical exclusion merely because the entity is nonprofit.","Same analysis as commercial provider unless another exclusion applies.","Registration required if covered.","Must establish actual § 501(c)(3) status or another precise exclusion."],["D.C.-licensed attorney performing services within the practice of law","Answered: expressly excluded.","Attorney ethics, fee, trust-account, and unauthorized-practice rules remain separate.","No Chapter 46 registration on facts satisfying both elements.","Lawyer must be licensed in D.C.; services must be within the course and scope of practice. \nD.C. Law Library\n+1"],["Attorney-owned, attorney-affiliated, or out-of-state attorney business","Partial: no automatic exclusion.","Corporate, unauthorized-practice, fee-sharing, and attorney-regulation issues remain open.","Chapter 46 registration required unless the exact attorney exclusion is proved.","Marketing through a lawyer or retaining counsel does not transform nonlegal commercial services into the exclusion."],["Banks, supervised lenders, credit unions, collection agencies, broker-dealers, and CRAs","Answered only to the statutory categories and scope.","Their own regulatory laws continue to apply.","Excluded only when the actor and conduct satisfy § 28-4601(2)(D).","Institutional affiliation or an affiliate relationship not described by the text is not enough. \nD.C. Law Library"],["Original creditor negotiating its own debt","Partial, likely outside ordinary CCSO coverage: the service is not ordinarily sold to the consumer concerning credit “by others,” and the creditor is acting on its own account.","Collection and consumer-protection law may apply.","No affirmative Chapter 46 authorization needed on ordinary self-creditor facts.","Avoid universal conclusion where an affiliate separately sells paid advisory or negotiation services. Chen supports a narrow own-credit boundary on its facts. \nGovInfo\n+1"],["Pure business-purpose debt negotiation","Answered for Chapter 46: outside the definition to the extent the underlying credit is not primarily personal, family, or household.","Commercial-law and professional-regulation issues remain open.","No Chapter 46 registration on pure business-credit facts.","Mixed-purpose cards, personally guaranteed business debts, and sole-proprietor obligations require purpose-specific analysis. \nD.C. Law Library"],["Remote out-of-District provider soliciting and serving D.C. residents","Partial but high enforcement risk: “operates in the District” is undefined, yet OAG applied the statute to Florida and Maryland entities marketing or selling debt-relief services to District consumers. \nDC Attorney General\n+3","Foreign-entity registration and BBL may be separate.","Treat District-facing sales and service as triggering Chapter 46 unless a contrary controlling authority is established.","No controlling appellate territorial test located. Marketing, solicitation, contracting, consumer residence, and performance facts matter."],["Consumer unaware of provider or third-party payer","Partial: Chen found no CCSO relationship where the consumers were not solicited, did not understand themselves to be purchasing the service, and payment came from another person without their awareness.","Fact-specific.","Potentially outside Chapter 46 on comparable facts.","Chen is a 2011 federal trial-court decision, not a controlling D.C. Court of Appeals decision. \nGovInfo"]]},{"headers":["Issue","Verified D.C. result","Limit"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Issue","Verified D.C. result","Limit"],["Chapter 46 initial government fee","$300","Provider-to-government registration fee."],["Chapter 46 annual government fee","$200 before April 2 or regulatory date","No current alternative regulatory date authenticated."],["Consumer service-fee amount cap","HOLD","No percentage, flat-dollar, monthly, per-debt, savings, or aggregate ceiling authenticated. Absence from Chapter 46 is not proof of unlimited fees."],["Money before completion","Prohibited unless the provider has the § 28-4604 security","Applicable federal TSR restrictions remain independently controlling where covered."],["Bond","$25,000","Surety must be legally permitted to do business in D.C."],["Provider trust alternative","$25,000 minimum","Must be at a federally insured bank or savings and loan association located in D.C.; this is provider security."],["“Completion”","Undefined in authenticated Chapter 46 text","DCMR interpretation or case law remains unresolved."],["Total-charge disclosure","Required before contract or payment","Disclosure must include detailed services and total amount charged."],["Written agreement","Required","Must state all payment terms, including payments to the provider or another person, services, refund promises, timing, and business/agent information."],["Cancellation","Five calendar days after signing","Exact interaction with completed services or third-party charges remains unresolved."],["Reimbursement after cancellation","Within ten days after receipt of cancellation notice","Scope and calculation were not further defined in authenticated rules."],["Consumer funds in dedicated account","No D.C.-specific Chapter 46 account formula established","Federal dedicated-account requirements were already handled in P1; D.C. money-transmission treatment depends on actual control and receipt."]]},{"headers":["P1 cell","PASS-02 treatment","Result"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["P1 cell","PASS-02 treatment","Result"],["S_DC-P1-C003 — custodial, noncustodial, DMP, and counseling classifications unresolved","Superseded in part by P2 C001–C022. Chapter 46 is the governing affirmative framework; noncustodial principal-reduction and paid counseling have strong CCSO coverage. Custody, money transmission, dedicated-account control, and some DMP conditions remain partial.","Partial → substantially answered, with enumerated sub-gaps"],["S_DC-P1-C004 — repeal does not establish licensing or fee permission","Preserved. Chapter 46, not repeal, supplies the current affirmative registration framework.","Confirmed and supplemented"],["S_DC-P1-C005 — DISB complaint material did not verify a debt-settlement license","Replaced in part. DISB is the current CCSO administrator, and registration is required under § 28-4602. Current prescribed form, submission route, and CCSO-specific public lookup remain unresolved.","Partial → regulator and legal category answered; procedure held"],["S_DC-P1-C006 — no current D.C. commercial consumer-fee ceiling authenticated","Preserved. P2 establishes registration fees, state pre-completion security, contract disclosures, cancellation, and reimbursement; it does not establish a consumer-service fee amount cap.","Still HOLD"],["S_DC-P1-C008 — D.C.-specific provider fee trigger unresolved","Partially superseded. Chapter 46 prohibits pre-completion receipt absent bond/trust, but “completion” and any finer D.C. earning milestones remain unresolved.","Partial"],["P1 early § 4 federal-text retrieval hold","Superseded by P1’s later supplemental federal finding and final self-check.","Closed before P2; not a current gap"],["S_DC-P1-C014 — no named provider authorization verified","Preserved only as “not investigated.” No named provider was checked in P2, and no adverse status inference is permitted.","Not investigated"]]},{"headers":["Claim ID","Precise assertion","Sources/pinpoints","Conditions and confidence limit"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources/pinpoints","Conditions and confidence limit"],["S_DC-P2-C001","D.C. Code Title 28, Chapter 46 is the current affirmative consumer-credit-service-organization framework.","S001, Chapter heading and §§ 4601–4608","High; does not by itself resolve every debt-relief fact pattern."],["C002","Paid advice or assistance concerning personal, household, or family credit is within the CCSO definition.","S001, § 28-4601(2)(A)(iii)","High as statutory text."],["C003","A paid noncustodial provider negotiating reduction or resolution of personal debts has a strong textual fit under § 28-4601(2)(A)(iii).","S001; S013; S015; S016","Strong qualified conclusion; statute does not use the words “debt settlement.”"],["C004","D.C. OAG has applied the CCSOA to student-debt relief and services intended to validate, dispute, resolve, or reduce consumer debts.","S012–S016","High as enforcement position; complaints and settlements are not controlling appellate holdings."],["C005","A covered CCSO operating in D.C. must register and pay $300 initially and $200 annually.","S001, § 28-4602(a)","High."],["C006","Chapter 46 does not define “operates in the District”; OAG has pursued out-of-state entities serving District consumers.","S001, § 28-4602; S013, complaint ¶ 3; S015, pp. 2–3","High for text and enforcement facts; controlling territorial test unresolved."],["C007","DISB is the current administering regulator for Chapter 46.","S004–S007","High."],["C008","DISB’s Licensing Division currently identifies CCSOs as an application category and maintains the non-depository/NMLS database.","S006–S007","High as agency operational statement."],["C009","No current CCSO-specific prescribed form, checklist, or complete submission route was authenticated.","S008–S011; S022–S023","Research-result limitation, not proof that no form exists."],["C010","A CCSO-specific public-registration lookup pathway was not verified.","S009; failed NMLS route","No named provider was checked."],["C011","Noncustodial debt negotiation does not require custody to fit the CCSO advice/assistance definition.","S001, § 28-4601(2)(A)(iii)","Strong textual conclusion."],["C012","Paid DMP or credit counseling can fit Chapter 46 even without principal reduction.","S001, § 28-4601(2)(A)(iii)","Actual services and consideration matter."],["C013","A provider or affiliate receiving consumer money for onward transmission may separately require a money-transmitter license.","S018, §§ 26-1001(10), 26-1002, 26-1003","Conditional; actual funds flow and interpretations unresolved."],["C014","The § 28-4604 trust is provider security and is not the consumer’s dedicated settlement account.","S001, § 28-4604","High."],["C015","Agents and independent persons who sell or attempt to sell CCSO services are included; pure lead generation remains fact-dependent.","S001, § 28-4601(2)(B)–(C)","High for sellers; unresolved for passive referrals."],["C016","Paid credit-repair representations are directly within § 28-4601(2)(A)(i).","S001","High; CROA overlap held."],["C017","Only an actual § 501(c)(3) organization receives the listed nonprofit exclusion.","S001, § 28-4601(2)(D)(iv); § 28-4606(b)","High; claimant bears burden."],["C018","Attorney exclusion requires D.C. licensure and services within the course and scope of practice.","S001, § 28-4601(2)(D)(vi); § 28-4606(b)","High; affiliation alone insufficient."],["C019","Other institutional exclusions are actor- and conduct-specific and do not create a general affiliate exemption.","S001, § 28-4601(2)(D)","High as limited reading."],["C020","Pure business-purpose debt is outside Chapter 46’s consumer-credit definition.","S001, § 28-4601(3)","High; mixed-purpose treatment unresolved."],["C021","A genuinely free service with no valuable consideration is outside the CCSO definition.","S001, § 28-4601(2)(A)","Qualified; indirect compensation may alter result."],["C022","Own-credit and consumer-unaware transactions can fall outside Chapter 46; Chen supports this only on its facts.","S017, pp. 39–40","Moderate; federal trial-court authority only."],["C023","A parallel BBL likely applies to a CCSO doing business from a D.C. location; remote/no-location treatment is unresolved.","S019–S020","Partial due statutory location language and applicability-note conflict."],["C024","Title 29 foreign-entity exclusions do not determine Chapter 46 regulatory coverage.","S021, § 29-105.05(b)","High."],["C025","Chapter 46 bars pre-completion receipt absent the $25,000 bond or trust.","S001, §§ 28-4603(1), 28-4604","High as state rule; no federal authorization inferred."],["C026","Chapter 46 requires pre-contract disclosures, a written contract, five-day cancellation, and reimbursement within ten days.","S001, § 28-4605","High as statutory text."],["C027","No current D.C. consumer-service fee amount ceiling was authenticated.","Complete S001 review; S011 rule search","Evidence gap, not proof of no cap or unlimited fees."],["C028","“Completion” is not defined in authenticated Chapter 46 text.","S001, §§ 28-4601–4608","High for the chapter; rule or case interpretation unresolved."],["C029","OAG pleadings and resolutions support coverage but do not replace controlling judicial construction.","S012–S016","High methodological qualification."],["C030","No named provider’s registration or authorization was checked.","Scope limitation","Not an adverse status finding."],["C031","Public-source evidence is insufficient to mark D.C. operationally launch-ready because the current filing and lookup mechanics remain incomplete.","C005, C007–C010","Operational conclusion, not denial of legal registration availability."],["C032","P1’s early federal-text hold was superseded by P1’s later verified TSR finding.","P1 internal record supplied in prompt","Closed P1 issue; federal overview not repeated."],["C033","No current operative CCSO-specific DCMR rule or adoption order was authenticated.","S001 § 28-4608; S011","Search limitation, not exhaustive absence claim."]]},{"headers":["Model or legal category","Status","Claims","Exact missing evidence and next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or legal category","Status","Claims","Exact missing evidence and next investigation"],["Affirmative governing statute","Answered","C001–C005","Preserve Chapter 46 as controlling starting point."],["For-profit noncustodial principal reduction","Answered, qualified","C003–C004, C011","Target controlling D.C. appellate authority or a final administrative decision directly construing debt settlement."],["Remote provider nexus","Partial","C006","Search D.C. Court of Appeals, Superior Court orders, DISB decisions, and rulemaking for “operates in the District”; test solicitation, contracting, and performance factors."],["Issuing regulator","Answered","C007–C008","None for agency identity."],["Current application form/checklist","Unresolved","C009","Locate the current Mayor/DISB-prescribed CCSO registration statement, state checklist, renewal form, and submission method from DISB, NMLS state-resource materials, D.C. Register notices, or archived agency rulemaking."],["Current public lookup","Unresolved","C010","Establish whether CCSOs appear in NMLS Consumer Access, a separate DISB database, or another public roster; do not test a named provider until the category is identified."],["Operative DCMR registration rules","Unresolved","C033","Retrieve complete Chapter 37 text, search D.C. Register rulemaking history, and locate any final Chapter 46 registration/disclosure/cancellation rules and Council review records."],["Noncustodial DMP or credit counseling","Partial","C012","Obtain D.C. administrative or judicial classification and review actual compensation and services."],["Custodial DMP","Partial","C013","Map funds from consumer through each account and entity; complete money-transmission licensing and exemption pass."],["Consumer-controlled dedicated account","Partial","C013–C014","Review account contract, consumer ownership, provider access, payment direction, withdrawal, and affiliate roles."],["Provider- or affiliate-controlled account","Partial","C013","Complete money-transmitter authorization, delegate, bond, permissible-investment, and application review."],["Provider § 28-4604 trust","Answered","C014, C025","Later pass should confirm approved trust form, depository evidence, and regulator filing treatment."],["Compensated sales agents","Answered","C015","Later pass may inspect individual liability and registration practices."],["Passive lead generators and referrals","Unresolved","C015","Review scripts, handoff, sale attempts, compensation, branding, data transfer, and creditor/referral relationships."],["Credit-repair representations","Answered for D.C.; federal overlap partial","C016","Complete conditional CROA applicability and any separate D.C. credit-reporting interpretations."],["§ 501(c)(3) exclusion","Answered","C017","Verify actual IRS status and operating entity identity for any provider claiming it."],["Attorney exclusion","Answered in text; factual use partial","C018","Verify D.C. bar status, engagement structure, legal work, nonlawyer affiliate conduct, fee sharing, and scope of practice."],["Institutional exclusions","Answered in text","C019","Match actual entity and conduct to each clause; do not extend exclusions by analogy."],["Business-purpose obligations","Answered for pure business debt","C020","Develop mixed-purpose and sole-proprietor allocation rules if needed."],["Free counseling","Partial","C021","Investigate indirect or third-party consideration."],["Original creditor/self-creditor","Partial","C022","Search controlling D.C. authority; distinguish self-creditor activity from separately sold advisory services."],["Money transmission","Partial","C013","Complete full statute, DCMR, DISB checklist, exemptions, interpretive orders, and account-flow analysis."],["BBL","Partial","C023","Reconcile conflicting implementation notes and determine remote/no-premises treatment and correct endorsement."],["Foreign-entity qualification","Partial","C024","Apply Title 29 to actual solicitation, contracting, employees, offices, and transaction pattern."],["State pre-completion rule","Answered in text","C025, C028","Locate any rule or case defining completion; keep federal TSR independent."],["Consumer fee amount cap","Unresolved","C027","Search final Chapter 46 regulations, DISB orders, D.C. Register, fee bulletins, and controlling cases. No CPI or borrowed model-act calculation."],["Contract, cancellation, reimbursement","Answered at statutory level; implementation partial","C026","Obtain any mandatory forms or implementing rules and later analyze cancellation calculations."],["Named provider authorization","Not investigated","C030","Only after the correct registry/category and lookup methodology are verified."],["Market launch readiness","HOLD","C031","Verify current registration filing pathway and public or official confirmation mechanism before operational approval."],["Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law","Outside P2 except intersections above","—","Preserve for later passes; no acceptance by implication."]]},{"headers":["Log ID","Route or query checked","Result","Evidentiary treatment"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Log ID","Route or query checked","Result","Evidentiary treatment"],["F001","Full official Chapter 46 section sequence, §§ 28-4601–4608","All sections opened and read","Primary controlling text"],["F002","Official D.C. Code searches for debt settlement, debt management, credit counseling, and debt adjusting","No separate current provider chapter surfaced beyond Chapter 46 and unrelated provisions","Documented search coverage only; not proof of absence"],["F003","https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16","Title 16 index read; Chapters 1 and 37 identified","Primary index"],["F004","https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1","Consumer Retail Credit section list read; no CCSO heading displayed","Does not establish absence from other chapters or register notices"],["F005","https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37","Web tool returned non-retryable open failure","Chapter 37 operative text remains unread"],["F006","Official-domain D.C. Register searches for “consumer credit service organization,” “debt settlement,” “debt management,” “credit counseling,” and “28-4608”","No matching current CCSO implementation rule was authenticated","Search limitation; no exhaustive absence claim"],["F007","Current DISB Banking Bureau and Divisions pages","CCSO application category and Licensing Division established","Current operational support"],["F008","Current DISB banking compliance, verification, and forms pages","CCSO-specific checklist/form/category not displayed","Public procedure remains unresolved"],["F009","https://www.nmlsconsumeraccess.org through the research tool","Direct route could not be opened","No provider or category lookup performed"],["F010","Current NMLS/official-domain searches for a D.C. CCSO state checklist","No current D.C. CCSO-specific checklist authenticated","Does not establish that NMLS cannot process the category"],["F011","May 2014 DISB initial non-depository instructions","Document read and visually inspected; categories omitted CCSO and instructions are historical","Excluded as current procedure"],["F012","DISB FY 2017–2018 report","Historical NMLS transition discussion read and visually inspected","Historical context only"],["F013","Student Aid Center complaint PDF","Parsed text read; relevant pages visually inspected","Allegations, not adjudication"],["F014","Burlington consent judgment PDF","Relevant pages visually inspected","Party-specific consent; defendants denied violations"],["F015","YF assurance PDF","Relevant pages visually inspected","Assurance and stipulations, not precedent"],["F016","Chen opinion PDF","Relevant pages visually inspected","Federal trial-court boundary authority"],["F017","Targeted D.C. and federal case searches for CCSOA and debt-relief construction","Chen located; no controlling D.C. Court of Appeals debt-settlement decision located","Targeted result only, not exhaustive case-law absence finding"],["F018","Money-transmission §§ 26-1001–1004","Directly read","Preliminary parallel-category analysis only"],["F019","BBL and foreign-entity provisions","Directly read","Parallel-category analysis; remote application unresolved"],["F020","Named provider lookup","Deliberately not performed","No provider-status claim"]]}],"claims":[{"claim_id":"S_DC-P2-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DC-P2-C001","Precise assertion":"D.C. Code Title 28, Chapter 46 is the current affirmative consumer-credit-service-organization framework.","Sources/pinpoints":"S001, Chapter heading and §§ 4601–4608","Conditions and confidence limit":"High; does not by itself resolve every debt-relief fact pattern."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-P2-C001","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged."},{"claim_id":"S_DC-P2-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"Paid advice or assistance concerning personal, household, or family credit is within the CCSO definition.","Sources/pinpoints":"S001, § 28-4601(2)(A)(iii)","Conditions and confidence limit":"High as statutory text."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C002"},{"claim_id":"S_DC-P2-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"A paid noncustodial provider negotiating reduction or resolution of personal debts has a strong textual fit under § 28-4601(2)(A)(iii).","Sources/pinpoints":"S001; S013; S015; S016","Conditions and confidence limit":"Strong qualified conclusion; statute does not use the words “debt settlement.”"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C003"},{"claim_id":"S_DC-P2-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"D.C. OAG has applied the CCSOA to student-debt relief and services intended to validate, dispute, resolve, or reduce consumer debts.","Sources/pinpoints":"S012–S016","Conditions and confidence limit":"High as enforcement position; complaints and settlements are not controlling appellate holdings."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C004"},{"claim_id":"S_DC-P2-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"A covered CCSO operating in D.C. must register and pay $300 initially and $200 annually.","Sources/pinpoints":"S001, § 28-4602(a)","Conditions and confidence limit":"High."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C005"},{"claim_id":"S_DC-P2-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Chapter 46 does not define “operates in the District”; OAG has pursued out-of-state entities serving District consumers.","Sources/pinpoints":"S001, § 28-4602; S013, complaint ¶ 3; S015, pp. 2–3","Conditions and confidence limit":"High for text and enforcement facts; controlling territorial test unresolved."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C006"},{"claim_id":"S_DC-P2-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"DISB is the current administering regulator for Chapter 46.","Sources/pinpoints":"S004–S007","Conditions and confidence limit":"High."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C007"},{"claim_id":"S_DC-P2-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"DISB’s Licensing Division currently identifies CCSOs as an application category and maintains the non-depository/NMLS database.","Sources/pinpoints":"S006–S007","Conditions and confidence limit":"High as agency operational statement."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C008"},{"claim_id":"S_DC-P2-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"No current CCSO-specific prescribed form, checklist, or complete submission route was authenticated.","Sources/pinpoints":"S008–S011; S022–S023","Conditions and confidence limit":"Research-result limitation, not proof that no form exists."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C009"},{"claim_id":"S_DC-P2-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"A CCSO-specific public-registration lookup pathway was not verified.","Sources/pinpoints":"S009; failed NMLS route","Conditions and confidence limit":"No named provider was checked."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C010"},{"claim_id":"S_DC-P2-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"Noncustodial debt negotiation does not require custody to fit the CCSO advice/assistance definition.","Sources/pinpoints":"S001, § 28-4601(2)(A)(iii)","Conditions and confidence limit":"Strong textual conclusion."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C011"},{"claim_id":"S_DC-P2-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"Paid DMP or credit counseling can fit Chapter 46 even without principal reduction.","Sources/pinpoints":"S001, § 28-4601(2)(A)(iii)","Conditions and confidence limit":"Actual services and consideration matter."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C012"},{"claim_id":"S_DC-P2-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"A provider or affiliate receiving consumer money for onward transmission may separately require a money-transmitter license.","Sources/pinpoints":"S018, §§ 26-1001(10), 26-1002, 26-1003","Conditions and confidence limit":"Conditional; actual funds flow and interpretations unresolved."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C013"},{"claim_id":"S_DC-P2-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"The § 28-4604 trust is provider security and is not the consumer’s dedicated settlement account.","Sources/pinpoints":"S001, § 28-4604","Conditions and confidence limit":"High."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C014"},{"claim_id":"S_DC-P2-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Agents and independent persons who sell or attempt to sell CCSO services are included; pure lead generation remains fact-dependent.","Sources/pinpoints":"S001, § 28-4601(2)(B)–(C)","Conditions and confidence limit":"High for sellers; unresolved for passive referrals."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C015"},{"claim_id":"S_DC-P2-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"Paid credit-repair representations are directly within § 28-4601(2)(A)(i).","Sources/pinpoints":"S001","Conditions and confidence limit":"High; CROA overlap held."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C016"},{"claim_id":"S_DC-P2-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"Only an actual § 501(c)(3) organization receives the listed nonprofit exclusion.","Sources/pinpoints":"S001, § 28-4601(2)(D)(iv); § 28-4606(b)","Conditions and confidence limit":"High; claimant bears burden."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C017"},{"claim_id":"S_DC-P2-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"Attorney exclusion requires D.C. licensure and services within the course and scope of practice.","Sources/pinpoints":"S001, § 28-4601(2)(D)(vi); § 28-4606(b)","Conditions and confidence limit":"High; affiliation alone insufficient."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C018"},{"claim_id":"S_DC-P2-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"Other institutional exclusions are actor- and conduct-specific and do not create a general affiliate exemption.","Sources/pinpoints":"S001, § 28-4601(2)(D)","Conditions and confidence limit":"High as limited reading."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C019"},{"claim_id":"S_DC-P2-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"Pure business-purpose debt is outside Chapter 46’s consumer-credit definition.","Sources/pinpoints":"S001, § 28-4601(3)","Conditions and confidence limit":"High; mixed-purpose treatment unresolved."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C020"},{"claim_id":"S_DC-P2-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"A genuinely free service with no valuable consideration is outside the CCSO definition.","Sources/pinpoints":"S001, § 28-4601(2)(A)","Conditions and confidence limit":"Qualified; indirect compensation may alter result."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C021"},{"claim_id":"S_DC-P2-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"Own-credit and consumer-unaware transactions can fall outside Chapter 46; Chen supports this only on its facts.","Sources/pinpoints":"S017, pp. 39–40","Conditions and confidence limit":"Moderate; federal trial-court authority only."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C022"},{"claim_id":"S_DC-P2-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"A parallel BBL likely applies to a CCSO doing business from a D.C. location; remote/no-location treatment is unresolved.","Sources/pinpoints":"S019–S020","Conditions and confidence limit":"Partial due statutory location language and applicability-note conflict."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C023"},{"claim_id":"S_DC-P2-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"Title 29 foreign-entity exclusions do not determine Chapter 46 regulatory coverage.","Sources/pinpoints":"S021, § 29-105.05(b)","Conditions and confidence limit":"High."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C024"},{"claim_id":"S_DC-P2-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"Chapter 46 bars pre-completion receipt absent the $25,000 bond or trust.","Sources/pinpoints":"S001, §§ 28-4603(1), 28-4604","Conditions and confidence limit":"High as state rule; no federal authorization inferred."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C025"},{"claim_id":"S_DC-P2-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise assertion":"Chapter 46 requires pre-contract disclosures, a written contract, five-day cancellation, and reimbursement within ten days.","Sources/pinpoints":"S001, § 28-4605","Conditions and confidence limit":"High as statutory text."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C026"},{"claim_id":"S_DC-P2-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise assertion":"No current D.C. consumer-service fee amount ceiling was authenticated.","Sources/pinpoints":"Complete S001 review; S011 rule search","Conditions and confidence limit":"Evidence gap, not proof of no cap or unlimited fees."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C027"},{"claim_id":"S_DC-P2-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise assertion":"“Completion” is not defined in authenticated Chapter 46 text.","Sources/pinpoints":"S001, §§ 28-4601–4608","Conditions and confidence limit":"High for the chapter; rule or case interpretation unresolved."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C028"},{"claim_id":"S_DC-P2-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise assertion":"OAG pleadings and resolutions support coverage but do not replace controlling judicial construction.","Sources/pinpoints":"S012–S016","Conditions and confidence limit":"High methodological qualification."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C029"},{"claim_id":"S_DC-P2-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise assertion":"No named provider’s registration or authorization was checked.","Sources/pinpoints":"Scope limitation","Conditions and confidence limit":"Not an adverse status finding."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C030"},{"claim_id":"S_DC-P2-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C031","Precise assertion":"Public-source evidence is insufficient to mark D.C. operationally launch-ready because the current filing and lookup mechanics remain incomplete.","Sources/pinpoints":"C005, C007–C010","Conditions and confidence limit":"Operational conclusion, not denial of legal registration availability."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C031"},{"claim_id":"S_DC-P2-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C032","Precise assertion":"P1’s early federal-text hold was superseded by P1’s later verified TSR finding.","Sources/pinpoints":"P1 internal record supplied in prompt","Conditions and confidence limit":"Closed P1 issue; federal overview not repeated."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C032"},{"claim_id":"S_DC-P2-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C033","Precise assertion":"No current operative CCSO-specific DCMR rule or adoption order was authenticated.","Sources/pinpoints":"S001 § 28-4608; S011","Conditions and confidence limit":"Search limitation, not exhaustive absence claim."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","id_normalization":"Pass-qualified namespace; literal researcher cell unchanged.","coordinator_review":"[internal evidence reference]","prior_mechanical_claim_id":"S_DC-C033"}],"sources":[{"source_id":"S_DC-P2-S001","urls":["https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46","https://code.dccouncil.gov/us/dc/council/code/sections/28-4601","https://code.dccouncil.gov/us/dc/council/code/sections/28-4602","https://code.dccouncil.gov/us/dc/council/code/sections/28-4603","https://code.dccouncil.gov/us/dc/council/code/sections/28-4604","https://code.dccouncil.gov/us/dc/council/code/sections/28-4605","https://code.dccouncil.gov/us/dc/council/code/sections/28-4606","https://code.dccouncil.gov/us/dc/council/code/sections/28-4607","https://code.dccouncil.gov/us/dc/council/code/sections/28-4608"],"researcher_record":{"Source heading":"## S_DC-P2-S001 — D.C. Code, Title 28, Chapter 46, Consumer Credit Service Organizations","Verbatim visible source entry":"## S_DC-P2-S001 — D.C. Code, Title 28, Chapter 46, Consumer Credit Service Organizations\n\n**Issuer:** Council of the District of Columbia, D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4601\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4602\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4603\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4604\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4605\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4606\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4607\n- https://code.dccouncil.gov/us/dc/council/code/sections/28-4608\n\n**Pinpoints:** §§ 28-4601(1)–(4), 28-4602(a)–(c), 28-4603(1)–(7), 28-4604(a)–(b), 28-4605(a)–(e), 28-4606(a)–(c), 28-4607, 28-4608.\n**Status/version:** Current codification read October 24, 2026. Individual section histories range from the 1991 enactment through the May 6, 2020 amendment to § 28-4601.\n**Actual check:** All operative sections directly opened and read.\n**Limit:** Does not itself supply a current public application form, detailed territorial definition, definition of “completion,” or consumer fee amount cap. [D.C. Law Library+8](https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S002","urls":["https://code.dccouncil.gov/us/dc/council/laws/8-236"],"researcher_record":{"Source heading":"## S_DC-P2-S002 — D.C. Law 8-236","Verbatim visible source entry":"## S_DC-P2-S002 — D.C. Law 8-236\n\n**Issuer:** Council of the District of Columbia\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/laws/8-236\n**Pinpoint:** Enacting law for the CCSOA; effective March 8, 1991, 38 DCR 306, as reflected in the codified section histories.\n**Actual check:** Law metadata and codification links identified; complete session-law HTML was not relied upon as independently read text.\n**Limit:** Current operative analysis is based on S001’s codified text."},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S003","urls":["https://code.dccouncil.gov/us/dc/council/code"],"researcher_record":{"Source heading":"## S_DC-P2-S003 — D.C. Code publication information","Verbatim visible source entry":"## S_DC-P2-S003 — D.C. Code publication information\n\n**Issuer:** D.C. Law Library\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/code\n**Pinpoint:** Publication-information block.\n**Status:** Current through October 22, 2026; last codified permanent and emergency measures identified above.\n**Actual check:** Directly opened and read.\n**Limit:** Publisher currency is not proof that every administrative rule or noncodified order was found. [D.C. Law Library](https://code.dccouncil.gov/us/dc/council/code)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S004","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03"],"researcher_record":{"Source heading":"## S_DC-P2-S004 — D.C. Code § 26-551.03","Verbatim visible source entry":"## S_DC-P2-S004 — D.C. Code § 26-551.03\n\n**Issuer:** D.C. Law Library\n**Literal URL:** https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03\n**Pinpoints:** Subsections (b), (g); editor’s note quoting D.C. Law 14-28 § 802.\n**Status:** Current codification.\n**Actual check:** Directly read.\n**Use:** Administration of Banking Code; transfer of Title 28, Chapter 46 functions to the banking regulator. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S005","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/31-101","https://code.dccouncil.gov/us/dc/council/code/sections/31-103"],"researcher_record":{"Source heading":"## S_DC-P2-S005 — D.C. Code §§ 31-101 and 31-103","Verbatim visible source entry":"## S_DC-P2-S005 — D.C. Code §§ 31-101 and 31-103\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/31-101\n- https://code.dccouncil.gov/us/dc/council/code/sections/31-103\n\n**Pinpoints:** § 31-101(2), (3), (5); § 31-103(a)(3).\n**Actual check:** Directly read.\n**Use:** Identifies DISB, the Commissioner, and administration through the Securities and Banking Bureau. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/31-101)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S006","urls":["https://disb.dc.gov/page/banking-bureau"],"researcher_record":{"Source heading":"## S_DC-P2-S006 — DISB Banking Bureau","Verbatim visible source entry":"## S_DC-P2-S006 — DISB Banking Bureau\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/banking-bureau\n**Pinpoints:** Licensing Division description, especially the bullets naming CCSOs and the non-depository licensing database.\n**Actual check:** Current page directly read October 24, 2026.\n**Limit:** Says “license applications” but does not supply the Chapter 46 form or identify the precise registration submission route. [Disb](https://disb.dc.gov/page/banking-bureau)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S007","urls":["https://disb.dc.gov/page/divisions-1"],"researcher_record":{"Source heading":"## S_DC-P2-S007 — DISB Divisions","Verbatim visible source entry":"## S_DC-P2-S007 — DISB Divisions\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/divisions-1\n**Pinpoints:** Banking Division, Licensing Division bullets.\n**Actual check:** Directly read.\n**Use:** Names CCSOs among reviewed applications and identifies NMLS as the maintained non-depository database.\n**Limit:** Does not expressly state that the Chapter 46 CCSO registration is currently filed through a particular NMLS license type. [Disb](https://disb.dc.gov/page/divisions-1)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S008","urls":["https://disb.dc.gov/page/compliance-requirements-banking"],"researcher_record":{"Source heading":"## S_DC-P2-S008 — DISB Compliance Requirements: Banking","Verbatim visible source entry":"## S_DC-P2-S008 — DISB Compliance Requirements: Banking\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/compliance-requirements-banking\n**Pinpoints:** Non-depository licensing list and forms section.\n**Actual check:** Directly read.\n**Limit:** Current list omits CCSOs; omission is evidence of an operational gap, not statutory noncoverage. [Disb](https://disb.dc.gov/page/compliance-requirements-banking)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S009","urls":["https://disb.dc.gov/page/non-depository-institutions-operating-dc"],"researcher_record":{"Source heading":"## S_DC-P2-S009 — DISB non-depository public verification page","Verbatim visible source entry":"## S_DC-P2-S009 — DISB non-depository public verification page\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/non-depository-institutions-operating-dc\n**Pinpoints:** Lines directing users to NMLS Consumer Access and enumerating categories.\n**Actual check:** Directly read.\n**Limit:** CCSOs are not expressly included in the page’s enumeration. No named provider was checked. [Disb](https://disb.dc.gov/page/non-depository-institutions-operating-dc)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S010","urls":["https://disb.dc.gov/page/licensing-and-registration-requirements"],"researcher_record":{"Source heading":"## S_DC-P2-S010 — DISB Licensing and Registration Requirements","Verbatim visible source entry":"## S_DC-P2-S010 — DISB Licensing and Registration Requirements\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/page/licensing-and-registration-requirements\n**Pinpoint:** Forms and application listing.\n**Actual check:** Directly read.\n**Limit:** No current CCSO form or checklist surfaced. [Disb](https://disb.dc.gov/page/licensing-and-registration-requirements)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S011","urls":["https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16","https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1","https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37"],"researcher_record":{"Source heading":"## S_DC-P2-S011 — D.C. Municipal Regulations, Title 16","Verbatim visible source entry":"## S_DC-P2-S011 — D.C. Municipal Regulations, Title 16\n\n**Issuer:** Office of Documents and Administrative Issuances\n**Literal URLs:**\n\n- https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16\n- https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1\n- Attempted: https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37\n\n**Pinpoints:** Title 16 chapter list; Chapter 1 section list.\n**Actual check:** Title index and Chapter 1 list directly read; Chapter 37 route failed.\n**Limit:** No CCSO-specific operative rule or adoption order authenticated. The displayed 1/1/1900 dates were not accepted as actual rule effective dates. [DCRegs+2](https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S012","urls":["https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc"],"researcher_record":{"Source heading":"## S_DC-P2-S012 — OAG Student Aid Center release","Verbatim visible source entry":"## S_DC-P2-S012 — OAG Student Aid Center release\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc\n**Date:** May 25, 2016.\n**Pinpoints:** Description of Florida provider, District marketing, debt-relief services, and CCSOA advance-fee allegations.\n**Actual check:** Directly read.\n**Limit:** Press release summarizing allegations. [DC Attorney General](https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S013","urls":["https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S013 — District v. Student Aid Center complaint","Verbatim visible source entry":"## S_DC-P2-S013 — District v. Student Aid Center complaint\n\n**Issuer:** D.C. Office of Attorney General / D.C. Superior Court filing\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf\n**Pinpoints:** Complaint ¶¶ 3, 24, 29, 37–47; printed pages 2, 7–8, 11–12.\n**Actual check:** Parsed text read and printed pages 11–12 visually inspected.\n**Limit:** Allegations, not adjudicated findings. [DC Attorney General+2](https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S014","urls":["https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against"],"researcher_record":{"Source heading":"## S_DC-P2-S014 — OAG Burlington release","Verbatim visible source entry":"## S_DC-P2-S014 — OAG Burlington release\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against\n**Date:** May 23, 2017.\n**Pinpoints:** Maryland provider, District consumers, debt validation/reduction services, settlement terms.\n**Actual check:** Directly read.\n**Limit:** Agency summary of a consent resolution. [DC Attorney General](https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S015","urls":["https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S015 — Burlington consent judgment","Verbatim visible source entry":"## S_DC-P2-S015 — Burlington consent judgment\n\n**Issuer:** D.C. Superior Court / D.C. OAG\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf\n**Pinpoints:** Printed pages 2–4, especially ¶¶ 2, 4, 6–8, 11, 18, and 22–23.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Party-specific consent judgment; defendants denied the alleged violations. [DC Attorney General+2](https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S016","urls":["https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S016 — YF Solution Assurance of Voluntary Compliance","Verbatim visible source entry":"## S_DC-P2-S016 — YF Solution Assurance of Voluntary Compliance\n\n**Issuer:** D.C. Office of Attorney General\n**Literal URL:** https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf\n**Pinpoints:** Printed pages 3–4, ¶¶ 8–14 and 18.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Assurance and stipulations, not a controlling judicial interpretation. [DC Attorney General+1](https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S017","urls":["https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S017 — Chen v. Bell-Smith","Verbatim visible source entry":"## S_DC-P2-S017 — Chen v. Bell-Smith\n\n**Issuer:** U.S. District Court for the District of Columbia\n**Literal URL:** https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf\n**Citation/date:** Civil Action No. 08-0999 (JDB), memorandum opinion filed March 8, 2011.\n**Pinpoints:** Printed pages 39–40.\n**Actual check:** Relevant pages visually inspected.\n**Limit:** Federal trial-court decision; unusual own-credit and consumer-awareness facts; not controlling D.C. appellate authority. [GovInfo+1](https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S018","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/26-1001","https://code.dccouncil.gov/us/dc/council/code/sections/26-1002","https://code.dccouncil.gov/us/dc/council/code/sections/26-1003","https://code.dccouncil.gov/us/dc/council/code/sections/26-1004"],"researcher_record":{"Source heading":"## S_DC-P2-S018 — D.C. Money Transmitters Act provisions","Verbatim visible source entry":"## S_DC-P2-S018 — D.C. Money Transmitters Act provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1001\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1002\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1003\n- https://code.dccouncil.gov/us/dc/council/code/sections/26-1004\n\n**Pinpoints:** §§ 26-1001(10), 26-1002(a), 26-1003(a)–(b), 26-1004.\n**Actual check:** Directly read.\n**Limit:** Full application, bonding, fees, interpretive decisions, and all funds-flow exceptions were not completed. [D.C. Law Library+3](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S019","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01","https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.02","https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.03","https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.04","https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.07"],"researcher_record":{"Source heading":"## S_DC-P2-S019 — Basic Business License provisions","Verbatim visible source entry":"## S_DC-P2-S019 — Basic Business License provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.02\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.03\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.04\n- https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.07\n\n**Pinpoints:** Definitions, license requirement, general-sales-and-services category, statutory fees, and retention of regulator eligibility judgments.\n**Actual check:** Directly read.\n**Limit:** Conflicting implementation notes and remote-provider/location application remain unresolved. [D.C. Law Library+5](https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S020","urls":["https://dlcp.dc.gov/service/business-licensing-division"],"researcher_record":{"Source heading":"## S_DC-P2-S020 — DLCP Business Licensing Division","Verbatim visible source entry":"## S_DC-P2-S020 — DLCP Business Licensing Division\n\n**Issuer:** Department of Licensing and Consumer Protection\n**Literal URL:** https://dlcp.dc.gov/service/business-licensing-division\n**Pinpoints:** Business definition, requirement, BOSS application route, General Business category, and BBL verification.\n**Actual check:** Directly read.\n**Limit:** Does not decide the DISB CCSO registration or remote/no-location application. [DCRA+2](https://dlcp.dc.gov/service/business-licensing-division)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S021","urls":["https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02","https://code.dccouncil.gov/us/dc/council/code/sections/29-105.05"],"researcher_record":{"Source heading":"## S_DC-P2-S021 — Foreign-entity provisions","Verbatim visible source entry":"## S_DC-P2-S021 — Foreign-entity provisions\n\n**Issuer:** D.C. Law Library\n**Literal URLs:**\n\n- https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02\n- https://code.dccouncil.gov/us/dc/council/code/sections/29-105.05\n\n**Pinpoints:** Registration duty; activities not constituting business under Title 29; savings clause for regulation under other D.C. law.\n**Actual check:** Directly read. [D.C. Law Library+1](https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S022","urls":["https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S022 — Historical DISB initial non-depository instructions","Verbatim visible source entry":"## S_DC-P2-S022 — Historical DISB initial non-depository instructions\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf\n**Version:** May 2014.\n**Actual check:** Text read and page 1 visually inspected.\n**Limit:** Historical; does not list CCSOs among the covered application categories; contains superseded addresses and paper-submission instructions; not used as current CCSO procedure. [Disb+1](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]"},{"source_id":"S_DC-P2-S023","urls":["https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf"],"researcher_record":{"Source heading":"## S_DC-P2-S023 — DISB FY 2017–2018 Biennial Report","Verbatim visible source entry":"## S_DC-P2-S023 — DISB FY 2017–2018 Biennial Report\n\n**Issuer:** DISB\n**Literal URL:** https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20(1).pdf\n**Pinpoint:** Printed page 14, licensing-system discussion.\n**Actual check:** Text read and page visually inspected.\n**Limit:** Historical operational context; not current filing instructions. [Disb+1](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf)"},"coordinator_verification_status":"scoped_review_complete_with_limits_and_bounded_correction_required","classification":"Verbatim individually headed visible source entry; original answer did not render a source table.","coordinator_review":"[internal evidence reference]","literal_import_urls_preserved":["https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20(1","https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf"],"coordinator_locator_reconciliation":{"at":"2026-10-27T20:03:21.640676+00:00","review":"[internal evidence reference]","method":"Correct only parser-truncated duplicate URL fragment; complete encoded URL was already present in original citation and preserved P03 table.","body_reopened":false,"historical_access_claim_not_newly_verified":true}}],"coverage":[{"topic":"Affirmative governing statute","researcher_record":{"Model or legal category":"Affirmative governing statute","Status":"Answered","Claims":"C001–C005","Exact missing evidence and next investigation":"Preserve Chapter 46 as controlling starting point."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"For-profit noncustodial principal reduction","researcher_record":{"Model or legal category":"For-profit noncustodial principal reduction","Status":"Answered, qualified","Claims":"C003–C004, C011","Exact missing evidence and next investigation":"Target controlling D.C. appellate authority or a final administrative decision directly construing debt settlement."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Remote provider nexus","researcher_record":{"Model or legal category":"Remote provider nexus","Status":"Partial","Claims":"C006","Exact missing evidence and next investigation":"Search D.C. Court of Appeals, Superior Court orders, DISB decisions, and rulemaking for “operates in the District”; test solicitation, contracting, and performance factors."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Issuing regulator","researcher_record":{"Model or legal category":"Issuing regulator","Status":"Answered","Claims":"C007–C008","Exact missing evidence and next investigation":"None for agency identity."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Current application form/checklist","researcher_record":{"Model or legal category":"Current application form/checklist","Status":"Unresolved","Claims":"C009","Exact missing evidence and next investigation":"Locate the current Mayor/DISB-prescribed CCSO registration statement, state checklist, renewal form, and submission method from DISB, NMLS state-resource materials, D.C. Register notices, or archived agency rulemaking."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Current public lookup","researcher_record":{"Model or legal category":"Current public lookup","Status":"Unresolved","Claims":"C010","Exact missing evidence and next investigation":"Establish whether CCSOs appear in NMLS Consumer Access, a separate DISB database, or another public roster; do not test a named provider until the category is identified."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Operative DCMR registration rules","researcher_record":{"Model or legal category":"Operative DCMR registration rules","Status":"Unresolved","Claims":"C033","Exact missing evidence and next investigation":"Retrieve complete Chapter 37 text, search D.C. Register rulemaking history, and locate any final Chapter 46 registration/disclosure/cancellation rules and Council review records."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial DMP or credit counseling","researcher_record":{"Model or legal category":"Noncustodial DMP or credit counseling","Status":"Partial","Claims":"C012","Exact missing evidence and next investigation":"Obtain D.C. administrative or judicial classification and review actual compensation and services."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial DMP","researcher_record":{"Model or legal category":"Custodial DMP","Status":"Partial","Claims":"C013","Exact missing evidence and next investigation":"Map funds from consumer through each account and entity; complete money-transmission licensing and exemption pass."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer-controlled dedicated account","researcher_record":{"Model or legal category":"Consumer-controlled dedicated account","Status":"Partial","Claims":"C013–C014","Exact missing evidence and next investigation":"Review account contract, consumer ownership, provider access, payment direction, withdrawal, and affiliate roles."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Provider- or affiliate-controlled account","researcher_record":{"Model or legal category":"Provider- or affiliate-controlled account","Status":"Partial","Claims":"C013","Exact missing evidence and next investigation":"Complete money-transmitter authorization, delegate, bond, permissible-investment, and application review."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Provider § 28-4604 trust","researcher_record":{"Model or legal category":"Provider § 28-4604 trust","Status":"Answered","Claims":"C014, C025","Exact missing evidence and next investigation":"Later pass should confirm approved trust form, depository evidence, and regulator filing treatment."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Compensated sales agents","researcher_record":{"Model or legal category":"Compensated sales agents","Status":"Answered","Claims":"C015","Exact missing evidence and next investigation":"Later pass may inspect individual liability and registration practices."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Passive lead generators and referrals","researcher_record":{"Model or legal category":"Passive lead generators and referrals","Status":"Unresolved","Claims":"C015","Exact missing evidence and next investigation":"Review scripts, handoff, sale attempts, compensation, branding, data transfer, and creditor/referral relationships."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-repair representations","researcher_record":{"Model or legal category":"Credit-repair representations","Status":"Answered for D.C.; federal overlap partial","Claims":"C016","Exact missing evidence and next investigation":"Complete conditional CROA applicability and any separate D.C. credit-reporting interpretations."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"§ 501(c)(3) exclusion","researcher_record":{"Model or legal category":"§ 501(c)(3) exclusion","Status":"Answered","Claims":"C017","Exact missing evidence and next investigation":"Verify actual IRS status and operating entity identity for any provider claiming it."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exclusion","researcher_record":{"Model or legal category":"Attorney exclusion","Status":"Answered in text; factual use partial","Claims":"C018","Exact missing evidence and next investigation":"Verify D.C. bar status, engagement structure, legal work, nonlawyer affiliate conduct, fee sharing, and scope of practice."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Institutional exclusions","researcher_record":{"Model or legal category":"Institutional exclusions","Status":"Answered in text","Claims":"C019","Exact missing evidence and next investigation":"Match actual entity and conduct to each clause; do not extend exclusions by analogy."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Business-purpose obligations","researcher_record":{"Model or legal category":"Business-purpose obligations","Status":"Answered for pure business debt","Claims":"C020","Exact missing evidence and next investigation":"Develop mixed-purpose and sole-proprietor allocation rules if needed."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Free counseling","researcher_record":{"Model or legal category":"Free counseling","Status":"Partial","Claims":"C021","Exact missing evidence and next investigation":"Investigate indirect or third-party consideration."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Original creditor/self-creditor","researcher_record":{"Model or legal category":"Original creditor/self-creditor","Status":"Partial","Claims":"C022","Exact missing evidence and next investigation":"Search controlling D.C. authority; distinguish self-creditor activity from separately sold advisory services."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Money transmission","researcher_record":{"Model or legal category":"Money transmission","Status":"Partial","Claims":"C013","Exact missing evidence and next investigation":"Complete full statute, DCMR, DISB checklist, exemptions, interpretive orders, and account-flow analysis."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"BBL","researcher_record":{"Model or legal category":"BBL","Status":"Partial","Claims":"C023","Exact missing evidence and next investigation":"Reconcile conflicting implementation notes and determine remote/no-premises treatment and correct endorsement."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Foreign-entity qualification","researcher_record":{"Model or legal category":"Foreign-entity qualification","Status":"Partial","Claims":"C024","Exact missing evidence and next investigation":"Apply Title 29 to actual solicitation, contracting, employees, offices, and transaction pattern."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"State pre-completion rule","researcher_record":{"Model or legal category":"State pre-completion rule","Status":"Answered in text","Claims":"C025, C028","Exact missing evidence and next investigation":"Locate any rule or case defining completion; keep federal TSR independent."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer fee amount cap","researcher_record":{"Model or legal category":"Consumer fee amount cap","Status":"Unresolved","Claims":"C027","Exact missing evidence and next investigation":"Search final Chapter 46 regulations, DISB orders, D.C. Register, fee bulletins, and controlling cases. No CPI or borrowed model-act calculation."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Contract, cancellation, reimbursement","researcher_record":{"Model or legal category":"Contract, cancellation, reimbursement","Status":"Answered at statutory level; implementation partial","Claims":"C026","Exact missing evidence and next investigation":"Obtain any mandatory forms or implementing rules and later analyze cancellation calculations."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Model or legal category":"Named provider authorization","Status":"Not investigated","Claims":"C030","Exact missing evidence and next investigation":"Only after the correct registry/category and lookup methodology are verified."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Market launch readiness","researcher_record":{"Model or legal category":"Market launch readiness","Status":"HOLD","Claims":"C031","Exact missing evidence and next investigation":"Verify current registration filing pathway and public or official confirmation mechanism before operational approval."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law","researcher_record":{"Model or legal category":"Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law","Status":"Outside P2 except intersections above","Claims":"—","Exact missing evidence and next investigation":"Preserve for later passes; no acceptance by implication."},"coordinator_acceptance":"scoped_review_complete_with_limits_and_bounded_correction_required","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T19:10:16.091130+00:00","review":"[internal evidence reference]","disposition":"revise_bounded_audit_trail_and_source_table","raw_originals_unchanged":true,"first_scoped_review_complete":true,"material_correction_required":false,"correction_items":["Provenance/access-dateerratumwithoutinventedindividualsourcedates","Completevisible23sourcegroupstablewithliteralURLs/readbounds"],"public_procedure_and_rule_gaps_remain":true,"historical_enforcement_records_not_freshly_verified":true,"no_actual_status_query_authorization":true,"no_component_acceptance":true,"bounded_repairs_addressed_at":"2026-10-27T20:03:21.640676+00:00","bounded_repairs_review":"[internal evidence reference]","requested_provenance_and_source_table_repairs_addressed":true,"original_disposition_preserved":true,"remaining_public_procedure_rule_gaps":true},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_DC-P02-provenance-source-table-and-public-procedure-holds-20261027","status":"requested_provenance_and_table_repairs_addressed_with_limits","at":"2026-10-27T19:10:16.091130+00:00"}]}