{"meta":{"key":"s_de--pass-04","task":"S_DE","title":"SDE Delaware consumer-money custody, trust-account, administrator, and return component","parent_title":"Delaware debt and debt relief law","edition":"pass-04","path":"/research/s_de--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":6,"claims":22,"sources":11,"review_status":"revise","review_complete":true,"sha256":"d042f484d35dcdb57957b08cb7002285f40aa25d80e8d25ced0525c86d8db3c5","headings":["Executive disposition","1. Custody classifications and administrator boundaries","S_DE-P4-C001 — Trust trigger and account definition","S_DE-P4-C002 — Indirect custody and delegated control","S_DE-P4-C003 — Statutory noncustody test","S_DE-P4-C004 — Transferred accounts and administrators","Account and business-model matrix","2. Account institution, ownership, segregation, deadlines, and withdrawals","Account institution and designation — S_DE-P4-C005","Ownership and beneficial interest — S_DE-P4-C006","Segregation and pooled accounting — S_DE-P4-C007","Deposit and creditor-remittance timing — S_DE-P4-C008","Permitted transfers and withdrawals — S_DE-P4-C009","Interest and financial-institution charges — S_DE-P4-C010","Reserves, shortages, reversals, and errors — S_DE-P4-C011","Account relocation — S_DE-P4-C012","3. Ledgers, statements, access, reporting, examinations, and records","Consumer accountings — S_DE-P4-C013","Record retention and account files — S_DE-P4-C014","Regulatory access and examination — S_DE-P4-C015","Public application and renewal materials — S_DE-P4-C016","Renewal reporting and insurance — S_DE-P4-C017","Obsolete overdraft cross-reference — S_DE-P4-C018","4. Cancellation, termination, plan failure, rejection, and cessation","Return-mechanics matrix","S_DE-P4-C019 — Cancellation language does not erase later statutory refunds","S_DE-P4-C020 — No inferred fee deduction","5. Delaware money-transmission and administrator gateway","S_DE-P4-C021 — Separate Chapter 23 analysis may be required","Implementation status is unresolved","Gateway result","6. Conditional federal dedicated-account overlay","S_DE-P4-C022 — State noncustody is not federal dedicated-account clearance","Distinctions preserved","S_DE-P4-E01 — Cleared pooled-trust receipt and termination before final remittance","S_DE-P4-E02 — Reconciliation shortage","S_DE-P4-E03 — Pending ACH is not assumed final","S_DE-P4-E04 — Failed plan and unproven claimed fee","S_DE-P4-E05 — Federal dedicated-account withdrawal","S_DE-P4-E06 — Creditor rejection followed by consumer termination","Freshly read in PASS-04","Reused without rerunning","Not read or not established"],"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_DE/pass-04","facets":{"geography":["us","us-de"],"debt_type":[],"stage":["repossession"],"subject":["client-money"]},"scope":"ExactreviewedP1remainingconsumerfunds/trust/account/administrator/return component, P2/P3fee-qualification/date/currentReg102/provider/broaderholdsretained.","pending_corrections":0},"markdown":"# S_DE PASS-04 — Delaware consumer-money custody, trust-account, administrator, and return component\n\n**Fresh public-source research session:** October 25, 2026, Pacific / October 26, 2026, UTC\n**Relationship to prior work:** Focused continuation of the saved PASS-01 through PASS-03 materials by the same coordinator; **not an independent review**.\n\nAll prior Delaware findings, calculations, examples, corrections, source limitations, and provider-, contract-, fee-, federal-, currentness-, local-, and tribal-specific holds remain unchanged. This pass does not establish a current license for any provider, validate any contract or account structure, or prove that any fee was earned or deductible.\n\n## Executive disposition\n\nDelaware’s consumer-money regime turns on **actual receipt, control, account structure, and purpose**, not on labels such as “independent administrator,” “dedicated account,” “processor,” “client account,” or an out-of-state headquarters.\n\nThe operative framework has three principal branches:\n\n1. **Provider or provider-designee custody.** Money paid to a provider by or for an individual under a plan for creditor distribution is held in trust. It must enter a qualifying trust account, remain segregated from nonparticipant money, be supported by individual ledgers, be reconciled monthly, and be disbursed or returned under statutory and regulatory rules.\n2. **Statutorily deemed noncustodial arrangements.** Under §2422A(j), a provider is deemed not to hold a trust account when the consumer retains the funds at a bank of the consumer’s choosing or uses a provider-designated bank or third-party account satisfying the text’s stated client-name, creditor-claim, or client-control criterion. That deeming does **not** exempt the provider from Chapter 24A licensing, reporting, fee, termination, delegation, or federal requirements.\n3. **Third-party administration.** Using an affiliate, processor, or supposedly independent account administrator does not by itself remove Delaware duties. The statute expressly addresses provider designees and other persons controlling trust accounts, makes providers liable for delegated conduct, and subjects delegates to examination. Regulation 102 also treats a person to whom the account is transferred as a provider, although application of that rule to a particular bank, processor, or account administrator remains fact-specific.\n\nA Delaware state-law noncustody classification also does not establish compliance with the federal Telemarketing Sales Rule’s more specific dedicated-account conditions, and neither state nor federal law was found to equate withdrawal from a debt-relief service with automatic closure of the underlying bank account or revocation of an ACH authorization.\n\n# A. Substantive findings\n\n## 1. Custody classifications and administrator boundaries\n\n### S_DE-P4-C001 — Trust trigger and account definition\n\nA Delaware Chapter 24A “trust account” is an account held by a provider that is:\n\n- established at an **insured bank**;\n- separate from the provider’s or its designee’s other accounts;\n- designated as a trust account or otherwise labeled to show that its money is not the provider’s or designee’s money; and\n- used to hold money of one or more individuals for creditor disbursement.\n\n“All money” paid to a provider by or for an individual under a plan for distribution to creditors is held in trust and must be deposited within two business days after receipt. A single account may therefore contain money of multiple consumers, but it must have individual account records and its cash must equal the sum of those individual balances. §§2402A(20), 2422A(a), (c)(1), (d)–(f). [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe reviewed clauses define “bank” broadly enough to include a regulated commercial bank, savings bank, savings and loan association, credit union, mortgage bank, or trust company. They do not state that the bank must be physically located in Delaware. This pass does not establish that no banking, contract, or other law imposes a separate location requirement. §2402A(4). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### S_DE-P4-C002 — Indirect custody and delegated control\n\nThe statutory definition of “provider” includes a person providing debt-management services “directly or through others.” The trust provisions separately refer to:\n\n- property of the provider **or its designee**;\n- reconciliation where the provider **or its designee** has multiple trust accounts;\n- payment errors caused by the provider **or another person in control of the trust account**; and\n- money received by the provider **or its agent**.\n\nA provider remains liable when it delegates a statutory or agreement duty to another person, including an independent contractor. Providers and persons receiving delegated obligations are subject to Attorney General supervision and examination. §§2402A(15), 2419A(d)(1)(A), 2422A(b), (c)(3), (f), 2431A, 2432A(b). [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nAccordingly, moving the ledger, ACH authority, disbursement authority, or bank interface to an affiliate or processor does not by itself create lawful noncustody. The actual account title, ownership, contractual rights, technical permissions, withdrawal authority, loss allocation, and control over creditor payments must be examined.\n\n### S_DE-P4-C003 — Statutory noncustody test\n\nSection 2422A(j) deems a provider **not to hold a trust account for creditor disbursement** when client funds are either:\n\n1. retained by the client in a bank of the client’s choosing at all times before disbursement to creditors; **or**\n2. deposited by the client in a bank or with a third party designated by the provider, in an account having the listed characteristic that:it is in the client’s name;it is not subject to claims of creditors of a party other than the client; **or**the client exercises full control over all aspects of the account.\n\nThe enacted list uses the disjunctive “or.” This pass does not rewrite the alternatives into an unstated cumulative test. It also does not assume that a marketing description such as “client-owned,” “FDIC-insured,” or “independently administered” proves the facts required by any alternative. §2422A(j). [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe effect of §2422A(j) is narrow: the provider is deemed not to hold a trust account for creditor disbursement. It does not say that the provider is exempt from Chapter 24A, that a third-party administrator is exempt, or that any federal dedicated-account condition has been met.\n\n### S_DE-P4-C004 — Transferred accounts and administrators\n\nRegulation 102 §2.3 states that the person forming the debt-management agreement and “any person to whom the account is then transferred” are providers subject to the Act. The provider also remains liable for a delegate’s violations under §2431A. These provisions prevent an automatic conclusion that a successor, affiliate, or administrator becomes legally invisible merely because the original provider no longer performs every account function. [Delaware Regulations+2](https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml)\n\nThe term “account” in Rule 2.3 must be applied to the actual arrangement. This pass does not conclude that an ordinary depository bank or every payment processor becomes a debt-management provider merely by furnishing banking infrastructure.\n\n## Account and business-model matrix\n\n| Account or payment model | Delaware custody classification | Principal Delaware consequences | Material unresolved facts |\n| --- | --- | --- | --- |\n| **Provider-operated pooled DMP trust account** | Direct statutory trust custody | Insured-bank trust account; separate from provider/designee accounts; individual ledgers; no outside commingling; two-business-day deposit; creditor disbursement rules; monthly reconciliation; return duties | Actual bank, account title, agreements, transaction history, pending items, and fee history |\n| **Affiliate, designee, or processor controls a pooled account** | Cannot be classified as noncustodial merely from the intermediary’s title; §§2422A(b), (c)(3), and (f) expressly address designees and other persons in control | Provider retains delegated-duty liability; administrator/controller may be examined; errors and shortages must be corrected | Legal entity, provider relationship, technical account permissions, beneficial ownership, ACH authority, loss allocation |\n| **Consumer retains funds at a bank of the consumer’s own choosing** | Provider deemed not to hold a trust account under §2422A(j)(1), assuming the funds actually remain there until creditor disbursement | Trust-account custody provisions may not apply to provider as custodian; licensing, reports, fee limits, termination duties, and federal law remain | Whether provider can initiate debits or otherwise exercises control; actual payment and bank agreements |\n| **Provider-designated client-named or client-controlled account** | Potential §2422A(j)(2) noncustody arrangement if the actual account meets an enacted alternative | State noncustody does not itself establish federal dedicated-account compliance or administrator exemption | Account title, creditor-claim protection, full client control, administrator affiliation, referral payments, ACH authority |\n| **“Independent” dedicated-account administrator** | Fact-dependent; administrator label alone is insufficient | Provider may remain liable for delegated conduct; Rule 2.3 may matter if the customer/account relationship is transferred; money-transmission analysis may be separate | Ownership/control affiliations, compensation, written agreements, account control, licensing or exemption, loss allocation |\n| **Consumer directly pays creditors at provider direction** | No provider custody of those directly transmitted funds merely because the payment is reported | Provider must still report consumer-directed creditor disbursements; renewal disclosure extends to distributions even where provider directs consumers to accumulate or pay | Whether provider ever receives, controls, redirects, reverses, or debits funds |\n| **Creditor pays compensation directly to provider** | A creditor-paid service fee is not automatically consumer principal held for creditor distribution | Compensation from a creditor prevents reliance on Chapter 24A’s no-compensation exemption; fee and conflict restrictions still require separate analysis | Actual compensation agreement, fee attribution, indirect consumer charge, settlement-account involvement |\n| **Provider merely supplies instructions while consumer and bank retain full control** | Potential noncustody if actual §2422A(j) conditions are present | Provider remains subject to substantive debt-management duties; federal overlay may be stricter | Whether instructions amount to withdrawal authority, transfer control, or administrator delegation |\n\nThe matrix reflects statutory classification, not approval of any operating model. [Delaware Code+3](https://delcode.delaware.gov/title6/c024a/index.html)\n\n## 2. Account institution, ownership, segregation, deadlines, and withdrawals\n\n### Account institution and designation — S_DE-P4-C005\n\nA statutory trust account must be established at an “insured bank,” separated from the provider’s or designee’s other accounts, and designated to show that the funds do not belong to the provider or designee. The account may hold money of one or more consumers. §§2402A(4), 2402A(20). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe Act does not establish in these clauses:\n\n- the amount of federal deposit insurance available to each participant;\n- FDIC or NCUA pass-through treatment;\n- bankruptcy priority beyond the express statutory property rule;\n- how account insurance applies where a pooled account exceeds insurance limits; or\n- who bears losses under the bank’s deposit or ACH contract.\n\nThose issues remain held. “Insured bank” and the provider’s separate dishonesty insurance must not be treated as the same protection.\n\n### Ownership and beneficial interest — S_DE-P4-C006\n\nMoney held in trust is not property of the provider or its designee and is unavailable to their creditors. A consumer retains a claim to the consumer’s own undistributed balance. The trust account is established for the benefit of individuals receiving debt-management services. §§2422A(a)–(b). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThat statutory property rule is controlling for Chapter 24A purposes, but this pass does not extend it into a categorical federal-bankruptcy priority opinion.\n\n### Segregation and pooled accounting — S_DE-P4-C007\n\nDelaware permits a trust account holding money of one or more individuals, but requires:\n\n- a separate account record for each individual;\n- no commingling with money of other persons;\n- cash at all times equal to the sum of individual account balances; and\n- separate monthly reconciliation of each trust account.\n\nRegulation 102 repeats the individual-record, monthly-reconciliation, exact-balance, and noncommingling requirements. §§2422A(c)(1), (d)–(f); Rules 11.2, 11.3, 11.6. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nPooling among plan participants is therefore distinguishable from commingling provider money, operating funds, or other nonparticipant funds with the trust corpus.\n\n### Deposit and creditor-remittance timing — S_DE-P4-C008\n\nThe statutory and rule timing requirements are:\n\n| Event | Operative requirement |\n| --- | --- |\n| Provider receives final money under a plan for creditor distribution | Deposit into the trust account within **two business days** |\n| Money has been deposited for creditor distribution | Regulation 102 Rule 11.1 requires distribution to creditors within **eight days** |\n| Consumer payment is not final | Provider may delay creditor payment to the extent the payment is not final |\n| Plan provides regular periodic creditor payments | Disbursement must comply with creditor due dates |\n| Provider/controller causes a missed or misdirected payment | Promptly correct it and reimburse the consumer for creditor-imposed costs or fees |\n\nThe eight-day rule is applied together with the statute’s express nonfinal-payment exception and creditor-due-date requirement. This pass does not define “final” for a particular ACH, card, check, chargeback, return-code, or bank contract. §§2422A(a), (c)(2)–(3); Rule 11.1. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### Permitted transfers and withdrawals — S_DE-P4-C009\n\nA provider may not initiate a transfer from an individual’s bank or other account unless it is:\n\n1. a return of money to the individual; or\n2. before termination, properly authorized by both the agreement and Chapter 24A, and for payment to creditors under the plan or payment of a fee.\n\nThus, account access technology does not itself authorize a transfer. Creditor payments and fee withdrawals require independent agreement and statutory authority. After termination, paragraph (B)’s creditor/fee transfer authority is unavailable by its terms; the express permitted transfer is a return to the individual. §2428A(a)(5). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nA fee ceiling, an invoice, a contract entry, or the presence of funds in an account does not prove that a fee is currently payable. All PASS-02 fee-timing and prior-credit qualifications remain controlling.\n\n### Interest and financial-institution charges — S_DE-P4-C010\n\nRegulation 102 Rule 11.6 states that interest payable on a Chapter 24A trust account must be credited to the individual depositors rather than the provider, except that the interest may be used to pay financial-institution fees relating to the trust account. The rule does not authorize using interest for provider service fees or establish an allocation method among consumers. [Delaware Regulations+1](https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm)\n\nFor a federally covered dedicated account, the TSR independently requires the customer to own the funds and receive accrued interest, if any. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### Reserves, shortages, reversals, and errors — S_DE-P4-C011\n\nA consumer accounting must state the amount held in reserve. The statute does not in the reviewed provisions establish a standard reserve percentage or convert a reserve into provider property. §2427A(b)(4). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nA statutory trust account must remain fully matched to individual ledger balances. If provider or controller error causes a missed or misdirected creditor payment, it must be corrected promptly and the consumer must be reimbursed for creditor charges. Suspected embezzlement or unlawful appropriation requires immediate Attorney General notice and, absent a different rule, a remedial-action notice within five days. §§2422A(c)(3), (e)–(g). [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\nNo reviewed clause supplies a universal rule allocating losses caused by:\n\n- bank failure;\n- forged instructions;\n- an ACH return;\n- chargeback;\n- check reversal;\n- administrator insolvency; or\n- a pending item that later fails.\n\nThose issues depend on actual facts, bank and ACH contracts, other law, and potentially later remedies work.\n\n### Account relocation — S_DE-P4-C012\n\nBefore relocating a trust account, the provider must inform the Attorney General of the new bank’s name, business address, and telephone number, then provide the new account number as soon as practicable. Rule 11.5 states that the licensee must notify the Consumer Protection Unit before the account is moved and provide the bank and account information. §§2422A(i); Rule 11.5. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\nNo reviewed clause supplies a complete bank-account closure process, ACH-revocation procedure, or successor-administrator migration protocol.\n\n## 3. Ledgers, statements, access, reporting, examinations, and records\n\n### Consumer accountings — S_DE-P4-C013\n\nA provider must furnish the statutory accounting:\n\n- upon cancellation or termination;\n- at least monthly before cancellation or termination; and\n- within five business days after a consumer request, although no more than one such requested accounting per calendar month is required.\n\nThe accounting must show:\n\n1. money received since the prior report;\n2. creditor disbursement dates and amounts, including payments made directly by the consumer at the provider’s direction;\n3. deductions from consumer receipts;\n4. the amount held in reserve; and\n5. for a new principal-reduction settlement, the settlement amount and terms, debt at enrollment, debt at settlement, and settlement-fee calculation.\n\n§2427A(a)–(b). [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### Record retention and account files — S_DE-P4-C014\n\nConsumer records must be retained for at least five years after the consumer’s final payment and produced to the consumer within a reasonable time after request. Electronic storage is permitted. The Attorney General may require longer retention by rule. §2427A(c)–(e). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nRegulation 102 Rule 12 requires, at minimum:\n\n- a consumer file containing the preliminary analysis, original agreement, income and debt data, monthly creditor payment amounts, and periodic statements;\n- an activity record containing account number, identifying data, agreement date, total debt, dated receipts, charged fees, creditor disbursements and payment dates, estimated term, and collection activity for unpaid fees following cancellation;\n- settlement terms, debt amounts, and settlement-fee calculations; and\n- an alphabetical consumer index.\n\nRules 12.1.1–12.1.4. [Delaware Regulations+1](https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm)\n\n### Regulatory access and examination — S_DE-P4-C015\n\nThe provider’s agreement must authorize the bank holding a provider or agent trust account to disclose trust-account records to the Attorney General. The licensing materials also require identification of trust accounts and irrevocable consent for Attorney General inspection. §§2419A(d)(2), 2405A(b)(3); Rule 4.2.5. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe Attorney General may examine providers and delegates and obtain access to offices, assets, securities, books, records, and papers. Regulation 102 permits an examination of a licensee or affiliate with or without notice during regular business hours. §2432A(b); Rule 12.1. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### Public application and renewal materials — S_DE-P4-C016\n\nThe currently linked Delaware initial application asks for each trust account containing Delaware-resident funds, including account name, location, number, and dollar value, and asks for every person with account access. It requires an irrevocable inspection consent. The PDF itself is internally marked “Revised 2 3 12,” so its current legal sufficiency cannot be inferred merely from its continued presence on the agency website. Initial application, printed page 4 / PDF index 3. [Delaware DOJ+2](https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf)\n\nThe renewal form asks for:\n\n- trust-account name, location, number, and value;\n- 12-month Delaware receipts and creditor disbursements;\n- the highest single-day accumulated balance during the preceding six months;\n- every person with trust-account access;\n- gross money accumulated for Delaware debt-settlement programs;\n- affiliates and agents; and\n- insurance at least equal to the larger of $250,000 or the highest daily trust-account balance holding Delaware-resident funds.\n\nRenewal application, printed pages 2–3 / PDF indices 1–2. [Delaware DOJ+3](https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf)\n\nThe forms support the agency’s operational information demands. They do not establish that an applicant has been approved or that the forms incorporate every current legal requirement.\n\n### Renewal reporting and insurance — S_DE-P4-C017\n\nFor annual renewal:\n\n- insurance must equal the larger of $250,000 or the highest daily trust-account balance during the preceding six months;\n- a custodial provider must disclose Delaware consumer money received under plans and money distributed to their creditors during the preceding 12 months; and\n- the provider must disclose, to the best of its knowledge, gross money accumulated under Delaware plans.\n\nRegulation 102 clarifies that the insurance balance is the Delaware-client-attributable balance and that creditor distributions must be reported regardless of whether the licensee directly receives payments or directs consumers to accumulate an account for debt settlement. §§2411A(b)(5)–(7); Rules 5.3.5–5.3.7. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThis provider misconduct insurance is not a finding of deposit insurance, pass-through insurance, or complete customer-loss protection.\n\n### Obsolete overdraft cross-reference — S_DE-P4-C018\n\nCurrent §2405A(b)(3) still refers to an “overdraft notification agreement required by §2422A.” In 2007, however, 76 Del. Laws ch. 146 §5 deleted former §2422A(j) and (k)—the original overdraft-notification provisions—and redesignated former subsection (l) as current subsection (j). Current Regulation 102 Rule 4.2.5 requires trust-account identification and inspection consent but does not repeat an overdraft-notification requirement. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThis is an orphaned statutory cross-reference, not a basis to invent a current overdraft agreement. Complete current application practice remains a regulator-form question outside this pass.\n\n## 4. Cancellation, termination, plan failure, rejection, and cessation\n\n### Return-mechanics matrix\n\n| Event | Money or accounting consequence | Timing | Qualifications and unresolved points |\n| --- | --- | --- | --- |\n| **Timely three-business-day cancellation** | Statutory notice says provider will refund all money already paid to it; provider must also provide an accounting | No separate numerical refund deadline appears in §2420A | A valid individualized emergency waiver can waive the cancellation right. Treatment of money already lawfully and irreversibly remitted to creditors is not resolved here. |\n| **Extended 30-day cancellation for a deficient agreement or notice** | Same cancellation framework applies | Within the statutory cancellation period | Whether the agreement is deficient is contract-specific and held. |\n| **Consumer terminates at any later time** | Refund all unexpended money received by provider or agent for debt reduction; settlement-plan fee-refund provision also applies; powers of attorney end | Custodial §2426A branch says **immediately** | Actual fee base, unsettled percentage, lawful prior credits, and earning remain held. |\n| **Custodial provider or consumer terminates** | Immediately return all consumer money held in trust, plus 65% of any qualifying setup-fee portion not credited against settlement fees | **Immediately** | No assumption that any setup fee was lawfully charged, earned, retained, or correctly credited |\n| **Noncustodial provider or consumer terminates** | Immediately return 65% of fees associated with the percentage of principal remaining unsettled | **Immediately** | Requires verified principal base, fee association, prior payments, and consistent method; none supplied |\n| **Plan becomes reasonably apparently failed** | Promptly refund all money not paid to creditors, less only fees actually payable under §2423A; Rule 11.4 similarly refers to fees permitted by the Act | **Promptly**; no numerical number of days in the cited clause | “Payable” and “permitted” are predicates, not assumptions; federal timing may bar a state-permitted fee |\n| **Creditor rejects or withdraws from plan** | Provider must identify the creditor and notify consumer of the right to modify or terminate | Within **five days after learning** of the decision | Rejection alone does not automatically terminate the plan or trigger a return; termination or plan failure may |\n| **Consumer misses required payments for 60 days** | Provider may terminate; custodial or noncustodial return rules then apply | Termination available after the 60-day failure | Does not authorize retention of trust principal |\n| **Provider terminates for good cause** | Agreement must state that provider may terminate only upon return of unexpended money | Return obligation accompanies termination | Good-cause facts and contract compliance remain held |\n| **Final renewal denial** | Provider continues servicing until, with Attorney General approval, agreements are transferred to another licensed provider or all unexpended money under provider control is returned | Governed by final decision and Attorney General order; no universal numerical deadline in §2411A(f) | Full receivership, bond, seizure, and priority questions excluded |\n\nThese branches arise from §§2411A(f), 2419A(a)(6)(G), 2419A(d), 2420A, 2422A(h), 2426A, and Rule 11.4. [Delaware Code+5](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### S_DE-P4-C019 — Cancellation language does not erase later statutory refunds\n\nThe mandatory cancellation notice states that a later termination does not require refund of fees already paid. That sentence cannot be read as eliminating the more specific refund rules in §§2419A(d), 2422A(h), and 2426A. Section 2419A(g) makes the statutory termination and cancellation rights effective even when omitted from the agreement and renders contrary provisions void. §§2419A(g), 2420A(b). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe distinction is:\n\n- **principal or unexpended money:** returned under custody and termination rules;\n- **previously paid fees:** subject to the applicable statutory fee-refund branch;\n- **fees currently payable but not yet withdrawn:** deductible only if their legal, contractual, allocation, credit, and timing predicates are established;\n- **completed lawful creditor payments:** no longer part of the present trust balance, although other cancellation or remedy questions can remain.\n\n### S_DE-P4-C020 — No inferred fee deduction\n\nSection 2422A(h) permits deduction only of fees “payable” under §2423A, and Rule 11.4 refers only to fees permitted by the Act. Neither phrase makes a billed, scheduled, accrued, or contractually described amount automatically deductible. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe PASS-02 qualifications remain unchanged:\n\n- §2423A(f) begins with its express subsections (c) and (d) qualification;\n- prior setup and monthly charges are credited only to the extent not already credited against an earlier settlement fee;\n- no universal 18%-earned rate exists;\n- no allocation-method switching is permitted by implication;\n- no arbitrary portfolio front-loading follows from the state ceiling; and\n- independently applicable federal fee timing remains separate.\n\nAccordingly, an unverified proposed fee is held rather than subtracted from consumer principal.\n\n## 5. Delaware money-transmission and administrator gateway\n\n### S_DE-P4-C021 — Separate Chapter 23 analysis may be required\n\nIn July 2026 Delaware enacted a modernized Money Transmission and Virtual Currency Act. The enacted definition includes receiving money for transmission from a person located in Delaware, including electronic or other transmission. The licensing provision generally requires a license unless the person acts as an authorized delegate or within an exemption. §§2303(18), (27), 2304. [Delaware Code+2](https://delcode.delaware.gov/title5/c023/sc01/index.html)\n\nPotential exemptions in the enacted framework include:\n\n- a payment-system operator acting only among licensed or exempt persons;\n- an agent of a payee where a written appointment exists, the payee holds the agent out publicly, and payment to the agent extinguishes the payor’s obligation without payor loss risk;\n- a processing intermediary where the directly obligated entity is licensed or exempt, identifies itself to the sender, and bears sole responsibility for satisfying the transmission obligation; and\n- specified federally insured depository institutions and other institutional actors.\n\nThese are conditional exemptions, not labels. §2305. [Delaware Code+1](https://delcode.delaware.gov/title5/c023/sc02/index.html)\n\nA Chapter 24A provider license, the provider’s own statutory exemption, or a contractual reference to an “independent account administrator” does not automatically confer a Chapter 23 exemption on a separate processor.\n\n### Implementation status is unresolved\n\n85 Del. Laws ch. 338 was approved July 6, 2026. Section 3 says the Act is effective immediately but is to be implemented on the earlier of:\n\n1. one year after enactment; or\n2. publication in the Delaware Register of notice that final implementing regulations have been promulgated.\n\nThe codified transition section separately protects certain existing licensees from conflicting or new requirements until renewal or July 7, 2027, whichever is later. [Delaware General Assembly+1](https://legis.delaware.gov/SessionLaws?chapter=338&volume=85)\n\nNo authenticated implementation notice was located in this focused pass. Search silence is **not** treated as proof that no notice exists. The precise October 25, 2026 operative transition between the legacy and modernized frameworks therefore remains held.\n\nAn official 2026 renewal-exemption form still bears the title “Sale of Checks and Transmission of Money Act,” cites former-style §2304(c) and Regulation 2302, and requests an applicant’s exemption theory and regulatory relationships. That is evidence of an operational legacy form, not conclusive proof of the governing law or any administrator’s exemption. PDF page 1 / index 0. [Delaware State Bank Commissioner+1](https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf)\n\n### Gateway result\n\nNo money-transmitter license or exemption conclusion is made for any provider, administrator, bank, affiliate, or processor. Resolution requires at least:\n\n- the exact legal entity receiving the consumer’s money;\n- where receipt legally occurs;\n- who owes the transmission obligation;\n- whether the consumer’s creditor obligation is extinguished on receipt;\n- written delegate or agent agreements;\n- bank or regulated-institution status;\n- who bears loss if the processor fails;\n- account and ACH authority;\n- the applicable Chapter 23 implementation date; and\n- current license or exemption evidence for the actual entity.\n\n## 6. Conditional federal dedicated-account overlay\n\n### S_DE-P4-C022 — State noncustody is not federal dedicated-account clearance\n\nFor a debt-relief service covered by the federal Telemarketing Sales Rule, requesting the customer to place money in a dedicated account is allowed only when:\n\n1. the account is at an insured financial institution;\n2. the customer owns the money and receives accrued interest, if any;\n3. the account administrator is not owned, controlled by, or affiliated with the debt-relief service;\n4. the administrator and debt-relief service do not exchange compensation for referrals; and\n5. the customer can withdraw from the debt-relief service at any time without penalty and receive all account funds—other than fees earned in compliance with §310.4(a)(5)(i)(A)–(C)—within seven business days after the request.\n\n16 C.F.R. §310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nA debt-relief fee is federally earned only after:\n\n- a debt has been renegotiated, settled, reduced, or otherwise altered under a valid executed agreement;\n- the consumer has made at least one payment under that agreement; and\n- an individually settled debt’s fee follows the rule’s proportional-balance method or a consistent percentage-of-savings method.\n\n16 C.F.R. §310.4(a)(5)(i)(A)–(C). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### Distinctions preserved\n\n- Delaware §2422A(j) noncustody does not prove administrator independence under the TSR.\n- A state fee ceiling or signed agreement does not prove federal fee earning.\n- “Withdraw from the debt-relief service” is not, without more, a rule that the bank must close the account.\n- Return of remaining funds is distinct from revocation of future ACH debits.\n- Account closure, ACH authorization, chargebacks, bank fees, and administrator release remain governed by actual account documents and other law.\n- The seven-business-day federal rule is conditional on actual TSR coverage; coverage is not presumed for every channel or entity.\n\n# B. Bounded ledger examples\n\nThese examples do **not** rerun or modify PASS-01 Examples E01–E06. They illustrate only the funds rules verified in this pass.\n\nUnless expressly stated otherwise, each example assumes:\n\n- exact U.S. dollars with no rounding;\n- no interest;\n- no bank charge;\n- no pending check;\n- no pending ACH;\n- no reversal or chargeback;\n- no unidentified consumer;\n- no fee proven payable;\n- completed creditor remittances were lawful; and\n- no private account or contract facts beyond those stated.\n\n## S_DE-P4-E01 — Cleared pooled-trust receipt and termination before final remittance\n\n**Inputs**\n\n- Cleared consumer receipt for creditor distribution: **$1,200**\n- Completed payment to Creditor A: **$450**\n- Completed payment to Creditor B: **$500**\n- Fee withdrawals: **$0**\n- Snapshot: business day 6 after receipt\n\n**Operator**\n\n$1,200−$450−$500=$250\\$1,200-\\$450-\\$500=\\$250$1,200−$450−$500=$250**Intermediate and result**\n\n- Starting final receipts: **$1,200**\n- Completed creditor remittances: **$950**\n- Current individual trust ledger: **$250**\n- If this is the only consumer in the account, required trust cash: **$250**\n\nIf the consumer terminates at that snapshot, the current trust principal to return is **$250 immediately**, with any fee-refund amount determined separately. If the plan continues, Rule 11.1’s eight-day distribution requirement means the $250 cannot simply remain indefinitely, subject to the statutory finality and creditor-due-date rules. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nNo previously completed creditor payment is subtracted twice.\n\n## S_DE-P4-E02 — Reconciliation shortage\n\n**Individual ledgers**\n\n- Consumer A: **$250**\n- Consumer B: **$400**\n- Consumer C: **$350**\n\n**Required trust cash**\n\n$250+$400+$350=$1,000\\$250+\\$400+\\$350=\\$1,000$250+$400+$350=$1,000**Actual bank cash**\n\n$980\\$980$980**Shortage**\n\n$1,000−$980=$20\\$1,000-\\$980=\\$20$1,000−$980=$20**Result**\n\nThe account is short **$20** against the statutory requirement that trust cash equal the sum of consumer balances. On the stated facts, the statutes and rules do not authorize reducing one or more consumer ledgers to make the reconciliation appear balanced. The cause must be investigated and corrected; if provider or controller error caused creditor charges, the consumer must also be reimbursed for those charges. §§2422A(c)(3), (e)–(f); Rule 11.3. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThis arithmetic does not identify who must fund the correction under a bank, processor, or indemnity contract.\n\n## S_DE-P4-E03 — Pending ACH is not assumed final\n\n**Inputs**\n\n- Existing cleared trust balance: **$300**\n- Newly initiated ACH: **$800**\n- Bank interface displays provisional total: **$1,100**\n- The $800 ACH has not become final\n\n**Operator**\n\nCleared funds=$300\\text{Cleared funds}=\\$300Cleared funds=$300Provisional funds=$800\\text{Provisional funds}=\\$800Provisional funds=$800**Result**\n\nThe provider may delay creditor payment to the extent the consumer payment is not final. The confirmed cleared return base at that moment is **$300**. The $800 cannot be treated simultaneously as final money available for disbursement and as a potential reversal. If the ACH later becomes final after termination, it must be traced under the return rules; if it reverses, it is not available principal. §2422A(c)(2)(A). [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe exact moment of “receipt” and finality under the ACH and bank agreements remains unresolved.\n\n## S_DE-P4-E04 — Failed plan and unproven claimed fee\n\n**Inputs**\n\n- Final consumer receipts: **$2,000**\n- Completed lawful creditor payments: **$1,200**\n- Prior fee withdrawals: **$0**\n- Provider asserts a currently payable fee: **$100**\n- No facts establish that the $100 satisfies state earning, prior-credit, contractual, allocation, or federal timing requirements\n\n**Current held cash**\n\n$2,000−$1,200=$800\\$2,000-\\$1,200=\\$800$2,000−$1,200=$800**Return operator**\n\nReturn=$800−fees actually payable\\text{Return}=\\$800-\\text{fees actually payable}Return=$800−fees actually payableOn the established facts, no fee is proven payable:\n\n$800−$0=$800\\$800-\\$0=\\$800$800−$0=$800**Result**\n\nThe demonstrated principal return is **$800**. The asserted $100 is held and is not deducted merely because it was billed or scheduled. If a separate verified ledger instead showed that a lawful $100 fee had already been withdrawn, current account cash would already reflect that withdrawal; it could not be subtracted a second time. §2422A(h); Rule 11.4. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\n## S_DE-P4-E05 — Federal dedicated-account withdrawal\n\n**Assumptions**\n\n- The provider is deemed noncustodial under an actually satisfied §2422A(j) alternative.\n- The TSR applies to the transaction.\n- The account is at an insured financial institution.\n- The customer owns the funds.\n- The administrator is unaffiliated and has no prohibited referral-compensation arrangement.\n- No fee has been earned under all three federal performance conditions.\n- No interest, bank fee, pending item, or reversal exists.\n\n**Inputs**\n\n- Customer deposits: **$1,000**\n- Completed creditor payment: **$300**\n\n**Account funds remaining**\n\n$1,000−$300=$700\\$1,000-\\$300=\\$700$1,000−$300=$700**Result**\n\nUpon a qualifying request to withdraw from the debt-relief service, the federal return amount is **$700**, due within **seven business days**. The result does not decide whether the underlying bank account must be closed or whether a separate ACH authorization has been revoked. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## S_DE-P4-E06 — Creditor rejection followed by consumer termination\n\n**Inputs**\n\n- Final consumer receipts: **$900**\n- Completed lawful payment to participating creditor: **$600**\n- Money reserved for Creditor X: **$300**\n- Creditor X rejects participation\n- No payable fee established\n\n**Current held principal**\n\n$900−$600=$300\\$900-\\$600=\\$300$900−$600=$300**Sequence**\n\n1. Provider must notify the consumer within five days after learning that Creditor X rejected or withdrew.\n2. The notice must identify Creditor X and explain the right to modify or terminate.\n3. Rejection alone does not establish automatic termination.\n4. If the consumer then terminates, the **$300** current trust balance is returned immediately.\n\n§§2419A(d)(3), 2426A(b). [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n\n# C. Primary-source register\n\nAll “fresh” access entries below refer to the October 25, 2026 Pacific session. No exact per-source fetch timestamps are asserted.\n\n| Source ID | Official source and full literal URL | Exact provisions or pages read | Version/effective status and access classification | Limitations |\n| --- | --- | --- | --- | --- |\n| **S_DE-P4-S001** | Delaware General Assembly, **Title 6, Chapter 24A — Debt-Management Services**. https://delcode.delaware.gov/title6/c024a/index.html | §§2402A(4), (13), (15), (20); 2403A(c); 2405A(b)(3); 2406A(7), (15); 2411A(b)(5)–(7), (f); 2419A(a)(6), (d), (g); 2420A; 2422A; 2426A; 2427A; 2428A(a)(1), (5); 2431A; 2432A(b) | Current official online codification; **freshly read** | Complete amendment-by-amendment history not independently audited; remedies, bond claims, and case law not fully reviewed. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **S_DE-P4-S002** | Delaware General Assembly, **76 Del. Laws ch. 146, HB 164**. https://legis.delaware.gov/SessionLaws/Chapter?id=17741 | §5 deletion of former §2422A(j), (k) and redesignation of former (l); approved July 17, 2007 | Official session law; **freshly read** | Historical amendment authority, not a substitute for current codification. [Delaware General Assembly](https://legis.delaware.gov/SessionLaws?chapter=146&volume=76) |\n| **S_DE-P4-S003** | Delaware Regulations, official readable Administrative Code snapshot, **6 Del. Admin. C. 102**. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml | Rules 2.3; 4.2.5; 5.3.5–5.3.7; 11.1–11.7; 12.1–12.4; 13.1; 13.4 | Official readable code page marked last updated February 11, 2025; **freshly read** | Supports the displayed rule text but is not a separate certification that no change occurred after February 11, 2025. Complete October 2026 Rule 102 history remains held. [Delaware Regulations](https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml) |\n| **S_DE-P4-S004** | Delaware DOJ, **Final Order, 102 Debt Management Services**, 14 DE Reg. 318. https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm | Order and effective date; Rules 2.3, 4.2.5, 5.3.5–5.3.7, 11, 12 | Original final order effective October 11, 2010; **freshly read** | Establishes adopted wording and 2010 effect, not by itself the absence of later amendments. [Delaware Regulations+1](https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm) |\n| **S_DE-P4-S005** | Delaware DOJ, **Debt Management Services Act program page**. https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/ | Links to current public application, renewal, bond, certification, accreditation, and roster resources | Official operational page; **freshly read** | Operational locator only; does not prove legal currency of every linked form or provider authorization. [Delaware DOJ](https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/) |\n| **S_DE-P4-S006** | Delaware DOJ, **Initial Application — Debt-Management Services License**. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf | Printed page 4 / PDF index 3: trust-account name, location, number, value, persons with access, insurance, inspection consent; printed page 5 / index 4: account-access criminal records | Six-page official PDF currently linked by S005; internally marked “Revised 2 3 12”; **parsed and visually inspected** | Current continued linkage does not certify that the 2012 form is complete under all October 2026 law. [Delaware DOJ+1](https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf) |\n| **S_DE-P4-S007** | Delaware DOJ, **Application for Renewal — Debt Management Services License**. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf | Printed pages 2–3 / PDF indices 1–2: trust accounts, receipts, disbursements, highest balance, access persons, gross settlement accumulations, affiliates, agents, insurance | Five-page official PDF currently linked by S005; **parsed and visually inspected** | No provider filing was reviewed; form currency and legal sufficiency are not certified. [Delaware DOJ+2](https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf) |\n| **S_DE-P4-S008** | Electronic Code of Federal Regulations, **16 C.F.R. §310.4**. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E) | Continuously updated eCFR page; **freshly read** | Federal duties are conditional on actual TSR coverage; eCFR describes itself as not the official print legal edition. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_DE-P4-S009** | Delaware General Assembly, **85 Del. Laws ch. 338**. https://legis.delaware.gov/SessionLaws/Chapter?id=42501 | §3 implementation trigger; approved July 6, 2026 | Official session law; **freshly read** | No authenticated implementation notice was established in this pass. [Delaware General Assembly](https://legis.delaware.gov/SessionLaws?chapter=338&volume=85) |\n| **S_DE-P4-S010** | Delaware Code, **Title 5, Chapter 23 — Money Transmission and Virtual Currency**. https://delcode.delaware.gov/title5/c023/sc01/index.html; https://delcode.delaware.gov/title5/c023/sc02/index.html; https://delcode.delaware.gov/title5/c023/sc07/index.html | §§2303(10)–(11), (18), (27); 2304; 2305; 2332 | Current codified enacted framework, each section carrying an application note referring to 85 Del. Laws ch. 338 §3; **freshly read** | Exact October 2026 implementation status and applicable legacy transition remain unresolved. [Delaware Code+2](https://delcode.delaware.gov/title5/c023/sc01/index.html) |\n| **S_DE-P4-S011** | Delaware Office of the State Bank Commissioner, **2026 Renewal Application for Exemption from the Sale of Checks and Transmission of Money Act**. https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf | PDF page/index 0 title and exemption basis; pages 1–3 business plan, regulators, records, federal MSB status, annual expiration and renewal procedure | Official 2026 operational form; **parsed and visually inspected** | Does not establish the governing transition date, approval of any entity, or an exemption for a debt-account administrator. [Delaware State Bank Commissioner+1](https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf) |\n\n# D. Claim-to-evidence register\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, exceptions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_DE-P4-C001** | Plan money received by a provider for creditor distribution is trust money; qualifying account defined by insured bank, separation, designation, and creditor-disbursement purpose | S001 §§2402A(20), 2422A(a)–(b) | High confidence in statutory text; actual receipt and purpose are factual |\n| **S_DE-P4-C002** | Designee or controller involvement does not automatically create noncustody; provider remains liable for delegated violations | S001 §§2402A(15), 2422A(b), (c)(3), (f), 2431A, 2432A(b) | High confidence in duties; classification of an actual processor remains fact-dependent |\n| **S_DE-P4-C003** | §2422A(j) creates two noncustody routes and lists the designated-account characteristics in the disjunctive | S001 §2422A(j) | Text verified; actual application and any judicial interpretation held |\n| **S_DE-P4-C004** | Rule 2.3 subjects the agreement-forming person and person to whom the account is transferred to the Act | S003/S004 Rule 2.3 | Rule text verified; “account” application to particular bank or processor held |\n| **S_DE-P4-C005** | Trust account must be at an insured bank, separated and appropriately designated | S001 §§2402A(4), 2402A(20) | No FDIC/NCUA pass-through or in-state-location conclusion |\n| **S_DE-P4-C006** | Trust money is not provider/designee property and is unavailable to their creditors except the consumer as to the consumer’s undistributed balance | S001 §2422A(b) | High confidence in Chapter 24A property rule; bankruptcy priority beyond text held |\n| **S_DE-P4-C007** | Pooled consumer funds require individual ledgers, no outside commingling, exact aggregate cash, and monthly reconciliation | S001 §2422A(c)(1), (d)–(f); S003/S004 Rules 11.2, 11.3, 11.6 | High confidence in text; actual account compliance untested |\n| **S_DE-P4-C008** | Deposit within two business days; Rule 11.1 distribution within eight days; statutory nonfinal-payment and creditor-due-date qualifications apply | S001 §2422A(a), (c)(2); S003/S004 Rule 11.1 | High confidence in text; exact receipt/finality under payment rails held |\n| **S_DE-P4-C009** | Transfers are limited to returns or pretermination, properly authorized creditor or fee payments | S001 §2428A(a)(5) | Fee transfer still requires independent state and federal permission |\n| **S_DE-P4-C010** | Trust-account interest belongs to depositors, except it may pay financial-institution trust-account fees | S003/S004 Rule 11.6 | High confidence in displayed rule; allocation method not supplied |\n| **S_DE-P4-C011** | Provider/controller errors must be corrected; trust cash must match ledgers; suspected unlawful appropriation triggers immediate and five-day notices | S001 §2422A(c)(3), (e)–(g) | High confidence in text; bank/processor loss allocation held |\n| **S_DE-P4-C012** | Trust-account relocation requires advance bank notification and later or accompanying account-number notice | S001 §2422A(i); S003/S004 Rule 11.5 | Statute/rule wording differs slightly; prudent compliance must satisfy both, but no agency interpretation located |\n| **S_DE-P4-C013** | Monthly, requested, and cancellation/termination accountings must contain receipts, disbursements, deductions, reserves, and settlement details | S001 §2427A(a)–(b) | High confidence; actual statements not reviewed |\n| **S_DE-P4-C014** | Records retained at least five years; Rule 12 specifies consumer files, activity ledgers, settlement calculations, and index | S001 §2427A(c)–(e); S003/S004 Rule 12 | High confidence in displayed text; longer regulator-specific retention not identified |\n| **S_DE-P4-C015** | Attorney General has trust-record consent and examination access over providers, delegates, and relevant records | S001 §§2405A(b)(3), 2419A(d)(2), 2432A(b); S003/S004 Rules 4.2.5, 12 | High confidence in text; no examination of an actual entity |\n| **S_DE-P4-C016** | Current agency-linked forms request account identity, value, access persons, receipts, distributions, balances, gross settlement funds, agents, and affiliates | S005–S007, specified PDF pages | Forms verified as linked; internal form age/current sufficiency held |\n| **S_DE-P4-C017** | Renewal insurance is larger of $250,000 or highest daily trust balance; receipts/distributions and accumulated settlement money must be reported | S001 §2411A(b)(5)–(7); S003/S004 Rules 5.3.5–5.3.7 | Statutory figure verified; actual policy and coverage exclusions held |\n| **S_DE-P4-C018** | Current overdraft-agreement reference is orphaned after 2007 repeal of former §2422A(j), (k) | S001 §2405A(b)(3); S002 §5; S003/S004 Rule 4.2.5 | High confidence in amendment chain for this narrow point; current agency practice held |\n| **S_DE-P4-C019** | Cancellation notice’s later-fee sentence does not erase specific statutory return/refund duties | S001 §§2419A(d), (g), 2420A, 2422A(h), 2426A | High confidence in coexistence of provisions; exact contract application held |\n| **S_DE-P4-C020** | Only actually payable/permitted fees may reduce a return; billing or a ceiling does not prove deductibility | S001 §2422A(h), §2426A; S003/S004 Rule 11.4; preserved PASS-02 predicates | High confidence as negative limit; actual fee history absent |\n| **S_DE-P4-C021** | Separate money-transmission licensing or exemption may apply to an administrator; implementation and entity result unresolved | S009 §3; S010 §§2303–2305, 2332; S011 | Enacted text verified; October 2026 implementation notice and actual entity facts not established |\n| **S_DE-P4-C022** | Federal dedicated account requires insured institution, customer ownership and interest, independent administrator, no referral compensation, and seven-business-day return; earned fees must satisfy all performance conditions | S008 §310.4(a)(5)(i)–(ii) | High confidence in federal text; conditional on actual TSR coverage |\n\n# E. Component coverage and remaining gaps\n\n| Component | PASS-04 status | Claim IDs | Exact missing evidence or next investigation |\n| --- | --- | --- | --- |\n| Trust-account definition and trigger | **Answered at statutory level** | C001, C005, C006 | Apply to actual receipt, purpose, and account documents |\n| Provider direct custody | **Answered at legal level** | C001, C007, C008 | Actual provider ledger and bank account not reviewed |\n| Affiliate/designee/processor control | **Partial** | C002, C004 | Entity chart, contracts, account permissions, ACH authority, loss allocation |\n| Consumer-owned noncustodial account | **Text answered; application partial** | C003 | Verify actual client name, creditor protection, control, and retention of funds |\n| Independent administrator status | **Unresolved for any entity** | C002–C004, C021, C022 | Ownership, affiliation, compensation, delegate agreement, transmission status |\n| Pooled custody and individual ledgers | **Answered** | C007 | Actual reconciliation records remain private and unreviewed |\n| Bank institution and account designation | **Answered within Chapter 24A** | C005 | Actual bank, account agreement, federal deposit insurance treatment |\n| Delaware bank-location requirement | **Not established in reviewed clauses** | C005 | Broader banking law and actual contract, if material |\n| Beneficial ownership/property rule | **Answered within Chapter 24A** | C006 | Bankruptcy and receivership priority excluded |\n| FDIC/NCUA pass-through coverage | **Unresolved** | C005, C022 | Bank account title, insurance rules, depositor records, institutional facts |\n| Segregation and commingling | **Answered** | C007 | Actual account testing |\n| Two-business-day deposit | **Answered** | C008 | Actual receipt timestamp and payment-finality records |\n| Eight-day creditor distribution | **Answered from displayed rule** | C008 | Full October 2026 Rule 102 certification; actual due-date and finality facts |\n| Pending ACH, checks, returns, reversals | **Partial** | C008, C011 | Bank/ACH contracts, return codes, settlement timestamps |\n| Creditor due-date compliance | **Answered at statutory level** | C008 | Actual creditor agreements and due dates |\n| Error correction and creditor charges | **Answered** | C011 | Actual causation and charge records |\n| Interest ownership | **Answered for state trust and conditional TSR account** | C010, C022 | Actual interest, bank fees, and allocation method |\n| Reserve reporting | **Answered; reserve authority partial** | C013 | Actual agreement and whether reserve is consistent with eight-day rule |\n| Trust relocation | **Answered at text level** | C012 | Actual notice, bank move, account number, and agency practice |\n| Account closure and ACH revocation | **Unresolved** | C009, C022 | Bank/administrator contracts and payment authorizations |\n| Monthly statements and request access | **Answered** | C013 | Actual statement form and delivery records |\n| Record retention | **Answered baseline** | C014 | Any longer rule/order-specific period |\n| Examinations and trust consent | **Answered** | C015 | No actual examination or consent reviewed |\n| Initial and renewal forms | **Partial operational evidence** | C016, C017 | Updated internal version, complete current checklist, actual filing |\n| Current Rule 102 trust text | **Substantially supported; complete 2026 currency held** | C004, C007–C018 | Authenticate all post-February-2025 rule changes or official current certification |\n| Overdraft-notification cross-reference | **Narrow amendment question answered** | C018 | Current agency application practice |\n| Timely cancellation funds | **Partial** | C019 | Actual agreement, timing, waiver, remittance history |\n| Custodial termination return | **Answered at statutory level** | C019, C020 | Current ledger and lawful fee history |\n| Noncustodial fee refund | **Answered at statutory level; computation held** | C019, C020 | Verified principal base, fee association, previous credits, earning |\n| Plan failure return | **Answered at statutory level** | C019, C020 | When failure became reasonably apparent; actual balance and payable fees |\n| Creditor rejection/withdrawal | **Answered at statutory level** | C019 | Actual notice and consumer election |\n| Renewal-denial cessation | **Partial** | C019 | Actual Attorney General order, successor provider, transfer and balances |\n| Provider-transfer consequences | **Partial** | C002, C004, C019 | Transfer agreement, recipient status, customer notice and approval |\n| Money-transmission gateway | **Partial/unresolved** | C021 | Implementation notice, legacy/current regime, entity license or exemption facts |\n| Federal dedicated-account overlay | **Answered conditionally** | C022 | Actual TSR coverage, affiliations, referral compensation, account documents |\n| Actual provider authorization | **Unresolved and outside this pass** | — | Current provider-specific agency record |\n| Actual fee earning or deduction | **Unresolved** | C020, C022 | Contract, enrolled debts, settlements, payments, allocation, prior fees |\n| Full agreement enforceability and waivers | **Excluded except necessary return clauses** | — | Separate agreement pass |\n| Bond claims, seizure, receivership, restitution, and remedies | **Excluded** | — | Separate remedies and insolvency pass |\n| Courts and controlling interpretations | **Excluded except statutory reading** | — | Dedicated Delaware and federal case-law pass |\n| Collection, garnishment, limitations, secured debt, sectors, local and tribal law | **Excluded** | — | Separate required Delaware passes |\n| State, parent, A066, operational, or publication acceptance | **Not assessed** | — | No acceptance implication |\n\n# F. Researcher self-check\n\n## Freshly read in PASS-04\n\n- Current official Delaware Code Chapter 24A custody, trust, account, reporting, examination, cancellation, termination, transfer, and cessation provisions.\n- The 2007 official session-law amendment deleting the old overdraft-notification subsections.\n- The materially different, readable official Administrative Code snapshot for Regulation 102, including Rules 2.3, 4.2.5, 5.3, 11, 12, and 13.\n- The original October 2010 final order and its October 11, 2010 effective date.\n- The current Delaware DOJ program page.\n- Initial and renewal application PDFs, including visual inspection of the relevant trust-account pages.\n- The federal TSR dedicated-account and debt-specific fee-earning clauses.\n- Delaware’s 2026 money-transmission modernization session law, codified definitions, licensing/exemption provisions, transition provision, and 2026 legacy-titled exemption-renewal form.\n\n## Reused without rerunning\n\n- PASS-02’s education/counseling qualification.\n- PASS-02’s §2423A(f) opening qualification and prior-fee-credit limitation.\n- PASS-02’s hold on adjusted fee amounts and full Rule 102 currentness.\n- PASS-03’s corrected October 25, 2026 Pacific PASS-02 access date.\n- All six PASS-01 worked fee examples and their numerical review. None was recalculated or modified here.\n- PASS-01 Example E04’s held $300 deduction and E05’s distinction between the $200 timely-cancellation illustration and the separate $260 later-termination branch.\n\n## Not read or not established\n\n- Any private consumer, provider, processor, bank, or ACH account.\n- Any actual provider or administrator contract.\n- Current license or exemption status for a named provider, bank, or administrator.\n- Any actual Attorney General higher-fee authorization.\n- Complete current provider forms or an authenticated October 2026 agency checklist beyond the publicly linked materials.\n- A complete amendment-by-amendment audit of Regulation 102 after the official readable page’s February 11, 2025 update.\n- An authenticated Delaware Register notice implementing the 2026 money-transmission act.\n- Full legacy Chapter 23 currentness during the transition.\n- FDIC or NCUA pass-through coverage, bankruptcy priority, administrator insolvency allocation, or bank failure treatment.\n- Full bond, restitution, seizure, receivership, remedies, contract-waiver, or case-law issues.\n- Local, tribal, secured-sector, collection, litigation, garnishment, and limitations subjects.\n\nNo exact individual source-fetch timestamps were available; only the actual fresh session date is reported. No API route, account action, application, filing, purchase, external contact, private data access, Chrome control, other Chat, local write, site change, or publication action was used.\n\nThis is focused researcher work by the same coordinator, **not an independent review**, operational approval, complete Delaware dossier, or publication-readiness determination.\n\n**END S_DE PASS-04**\n\n","tables":[{"headers":["Account or payment model","Delaware custody classification","Principal Delaware consequences","Material unresolved facts"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Account or payment model","Delaware custody classification","Principal Delaware consequences","Material unresolved facts"],["Provider-operated pooled DMP trust account","Direct statutory trust custody","Insured-bank trust account; separate from provider/designee accounts; individual ledgers; no outside commingling; two-business-day deposit; creditor disbursement rules; monthly reconciliation; return duties","Actual bank, account title, agreements, transaction history, pending items, and fee history"],["Affiliate, designee, or processor controls a pooled account","Cannot be classified as noncustodial merely from the intermediary’s title; §§2422A(b), (c)(3), and (f) expressly address designees and other persons in control","Provider retains delegated-duty liability; administrator/controller may be examined; errors and shortages must be corrected","Legal entity, provider relationship, technical account permissions, beneficial ownership, ACH authority, loss allocation"],["Consumer retains funds at a bank of the consumer’s own choosing","Provider deemed not to hold a trust account under §2422A(j)(1), assuming the funds actually remain there until creditor disbursement","Trust-account custody provisions may not apply to provider as custodian; licensing, reports, fee limits, termination duties, and federal law remain","Whether provider can initiate debits or otherwise exercises control; actual payment and bank agreements"],["Provider-designated client-named or client-controlled account","Potential §2422A(j)(2) noncustody arrangement if the actual account meets an enacted alternative","State noncustody does not itself establish federal dedicated-account compliance or administrator exemption","Account title, creditor-claim protection, full client control, administrator affiliation, referral payments, ACH authority"],["“Independent” dedicated-account administrator","Fact-dependent; administrator label alone is insufficient","Provider may remain liable for delegated conduct; Rule 2.3 may matter if the customer/account relationship is transferred; money-transmission analysis may be separate","Ownership/control affiliations, compensation, written agreements, account control, licensing or exemption, loss allocation"],["Consumer directly pays creditors at provider direction","No provider custody of those directly transmitted funds merely because the payment is reported","Provider must still report consumer-directed creditor disbursements; renewal disclosure extends to distributions even where provider directs consumers to accumulate or pay","Whether provider ever receives, controls, redirects, reverses, or debits funds"],["Creditor pays compensation directly to provider","A creditor-paid service fee is not automatically consumer principal held for creditor distribution","Compensation from a creditor prevents reliance on Chapter 24A’s no-compensation exemption; fee and conflict restrictions still require separate analysis","Actual compensation agreement, fee attribution, indirect consumer charge, settlement-account involvement"],["Provider merely supplies instructions while consumer and bank retain full control","Potential noncustody if actual §2422A(j) conditions are present","Provider remains subject to substantive debt-management duties; federal overlay may be stricter","Whether instructions amount to withdrawal authority, transfer control, or administrator delegation"]]},{"headers":["Event","Operative requirement"],"index":1,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Event","Operative requirement"],["Provider receives final money under a plan for creditor distribution","Deposit into the trust account within two business days"],["Money has been deposited for creditor distribution","Regulation 102 Rule 11.1 requires distribution to creditors within eight days"],["Consumer payment is not final","Provider may delay creditor payment to the extent the payment is not final"],["Plan provides regular periodic creditor payments","Disbursement must comply with creditor due dates"],["Provider/controller causes a missed or misdirected payment","Promptly correct it and reimburse the consumer for creditor-imposed costs or fees"]]},{"headers":["Event","Money or accounting consequence","Timing","Qualifications and unresolved points"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Event","Money or accounting consequence","Timing","Qualifications and unresolved points"],["Timely three-business-day cancellation","Statutory notice says provider will refund all money already paid to it; provider must also provide an accounting","No separate numerical refund deadline appears in §2420A","A valid individualized emergency waiver can waive the cancellation right. Treatment of money already lawfully and irreversibly remitted to creditors is not resolved here."],["Extended 30-day cancellation for a deficient agreement or notice","Same cancellation framework applies","Within the statutory cancellation period","Whether the agreement is deficient is contract-specific and held."],["Consumer terminates at any later time","Refund all unexpended money received by provider or agent for debt reduction; settlement-plan fee-refund provision also applies; powers of attorney end","Custodial §2426A branch says immediately","Actual fee base, unsettled percentage, lawful prior credits, and earning remain held."],["Custodial provider or consumer terminates","Immediately return all consumer money held in trust, plus 65% of any qualifying setup-fee portion not credited against settlement fees","Immediately","No assumption that any setup fee was lawfully charged, earned, retained, or correctly credited"],["Noncustodial provider or consumer terminates","Immediately return 65% of fees associated with the percentage of principal remaining unsettled","Immediately","Requires verified principal base, fee association, prior payments, and consistent method; none supplied"],["Plan becomes reasonably apparently failed","Promptly refund all money not paid to creditors, less only fees actually payable under §2423A; Rule 11.4 similarly refers to fees permitted by the Act","Promptly; no numerical number of days in the cited clause","“Payable” and “permitted” are predicates, not assumptions; federal timing may bar a state-permitted fee"],["Creditor rejects or withdraws from plan","Provider must identify the creditor and notify consumer of the right to modify or terminate","Within five days after learning of the decision","Rejection alone does not automatically terminate the plan or trigger a return; termination or plan failure may"],["Consumer misses required payments for 60 days","Provider may terminate; custodial or noncustodial return rules then apply","Termination available after the 60-day failure","Does not authorize retention of trust principal"],["Provider terminates for good cause","Agreement must state that provider may terminate only upon return of unexpended money","Return obligation accompanies termination","Good-cause facts and contract compliance remain held"],["Final renewal denial","Provider continues servicing until, with Attorney General approval, agreements are transferred to another licensed provider or all unexpended money under provider control is returned","Governed by final decision and Attorney General order; no universal numerical deadline in §2411A(f)","Full receivership, bond, seizure, and priority questions excluded"]]},{"headers":["Source ID","Official source and full literal URL","Exact provisions or pages read","Version/effective status and access classification","Limitations"],"index":3,"links":[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+2"},{"href":"https://legis.delaware.gov/SessionLaws?chapter=146&volume=76","text":"Delaware General Assembly"},{"href":"https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","text":"Delaware Regulations"},{"href":"https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm","text":"Delaware Regulations\n+1"},{"href":"https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/","text":"Delaware DOJ"},{"href":"https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf","text":"Delaware DOJ\n+1"},{"href":"https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf","text":"Delaware DOJ\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://legis.delaware.gov/SessionLaws?chapter=338&volume=85","text":"Delaware General Assembly"},{"href":"https://delcode.delaware.gov/title5/c023/sc01/index.html","text":"Delaware Code\n+2"},{"href":"https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf","text":"Delaware State Bank Commissioner\n+1"}],"row_links":[[],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+2"}],[{"href":"https://legis.delaware.gov/SessionLaws?chapter=146&volume=76","text":"Delaware General Assembly"}],[{"href":"https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","text":"Delaware Regulations"}],[{"href":"https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm","text":"Delaware Regulations\n+1"}],[{"href":"https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/","text":"Delaware DOJ"}],[{"href":"https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf","text":"Delaware DOJ\n+1"}],[{"href":"https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf","text":"Delaware DOJ\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://legis.delaware.gov/SessionLaws?chapter=338&volume=85","text":"Delaware General Assembly"}],[{"href":"https://delcode.delaware.gov/title5/c023/sc01/index.html","text":"Delaware Code\n+2"}],[{"href":"https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf","text":"Delaware State Bank Commissioner\n+1"}]],"rows":[["Source ID","Official source and full literal URL","Exact provisions or pages read","Version/effective status and access classification","Limitations"],["S_DE-P4-S001","Delaware General Assembly, Title 6, Chapter 24A — Debt-Management Services. https://delcode.delaware.gov/title6/c024a/index.html","§§2402A(4), (13), (15), (20); 2403A(c); 2405A(b)(3); 2406A(7), (15); 2411A(b)(5)–(7), (f); 2419A(a)(6), (d), (g); 2420A; 2422A; 2426A; 2427A; 2428A(a)(1), (5); 2431A; 2432A(b)","Current official online codification; freshly read","Complete amendment-by-amendment history not independently audited; remedies, bond claims, and case law not fully reviewed. \nDelaware Code\n+2"],["S_DE-P4-S002","Delaware General Assembly, 76 Del. Laws ch. 146, HB 164. https://legis.delaware.gov/SessionLaws/Chapter?id=17741","§5 deletion of former §2422A(j), (k) and redesignation of former (l); approved July 17, 2007","Official session law; freshly read","Historical amendment authority, not a substitute for current codification. \nDelaware General Assembly"],["S_DE-P4-S003","Delaware Regulations, official readable Administrative Code snapshot, 6 Del. Admin. C. 102. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","Rules 2.3; 4.2.5; 5.3.5–5.3.7; 11.1–11.7; 12.1–12.4; 13.1; 13.4","Official readable code page marked last updated February 11, 2025; freshly read","Supports the displayed rule text but is not a separate certification that no change occurred after February 11, 2025. Complete October 2026 Rule 102 history remains held. \nDelaware Regulations"],["S_DE-P4-S004","Delaware DOJ, Final Order, 102 Debt Management Services, 14 DE Reg. 318. https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm","Order and effective date; Rules 2.3, 4.2.5, 5.3.5–5.3.7, 11, 12","Original final order effective October 11, 2010; freshly read","Establishes adopted wording and 2010 effect, not by itself the absence of later amendments. \nDelaware Regulations\n+1"],["S_DE-P4-S005","Delaware DOJ, Debt Management Services Act program page. https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/","Links to current public application, renewal, bond, certification, accreditation, and roster resources","Official operational page; freshly read","Operational locator only; does not prove legal currency of every linked form or provider authorization. \nDelaware DOJ"],["S_DE-P4-S006","Delaware DOJ, Initial Application — Debt-Management Services License. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf","Printed page 4 / PDF index 3: trust-account name, location, number, value, persons with access, insurance, inspection consent; printed page 5 / index 4: account-access criminal records","Six-page official PDF currently linked by S005; internally marked “Revised 2 3 12”; parsed and visually inspected","Current continued linkage does not certify that the 2012 form is complete under all October 2026 law. \nDelaware DOJ\n+1"],["S_DE-P4-S007","Delaware DOJ, Application for Renewal — Debt Management Services License. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf","Printed pages 2–3 / PDF indices 1–2: trust accounts, receipts, disbursements, highest balance, access persons, gross settlement accumulations, affiliates, agents, insurance","Five-page official PDF currently linked by S005; parsed and visually inspected","No provider filing was reviewed; form currency and legal sufficiency are not certified. \nDelaware DOJ\n+2"],["S_DE-P4-S008","Electronic Code of Federal Regulations, 16 C.F.R. §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§310.4(a)(5)(i)(A)–(C), (ii)(A)–(E)","Continuously updated eCFR page; freshly read","Federal duties are conditional on actual TSR coverage; eCFR describes itself as not the official print legal edition. \neCFR\n+1"],["S_DE-P4-S009","Delaware General Assembly, 85 Del. Laws ch. 338. https://legis.delaware.gov/SessionLaws/Chapter?id=42501","§3 implementation trigger; approved July 6, 2026","Official session law; freshly read","No authenticated implementation notice was established in this pass. \nDelaware General Assembly"],["S_DE-P4-S010","Delaware Code, Title 5, Chapter 23 — Money Transmission and Virtual Currency. https://delcode.delaware.gov/title5/c023/sc01/index.html; https://delcode.delaware.gov/title5/c023/sc02/index.html; https://delcode.delaware.gov/title5/c023/sc07/index.html","§§2303(10)–(11), (18), (27); 2304; 2305; 2332","Current codified enacted framework, each section carrying an application note referring to 85 Del. Laws ch. 338 §3; freshly read","Exact October 2026 implementation status and applicable legacy transition remain unresolved. \nDelaware Code\n+2"],["S_DE-P4-S011","Delaware Office of the State Bank Commissioner, 2026 Renewal Application for Exemption from the Sale of Checks and Transmission of Money Act. https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf","PDF page/index 0 title and exemption basis; pages 1–3 business plan, regulators, records, federal MSB status, annual expiration and renewal procedure","Official 2026 operational form; parsed and visually inspected","Does not establish the governing transition date, approval of any entity, or an exemption for a debt-account administrator. \nDelaware State Bank Commissioner\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, and confidence"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, and confidence"],["S_DE-P4-C001","Plan money received by a provider for creditor distribution is trust money; qualifying account defined by insured bank, separation, designation, and creditor-disbursement purpose","S001 §§2402A(20), 2422A(a)–(b)","High confidence in statutory text; actual receipt and purpose are factual"],["S_DE-P4-C002","Designee or controller involvement does not automatically create noncustody; provider remains liable for delegated violations","S001 §§2402A(15), 2422A(b), (c)(3), (f), 2431A, 2432A(b)","High confidence in duties; classification of an actual processor remains fact-dependent"],["S_DE-P4-C003","§2422A(j) creates two noncustody routes and lists the designated-account characteristics in the disjunctive","S001 §2422A(j)","Text verified; actual application and any judicial interpretation held"],["S_DE-P4-C004","Rule 2.3 subjects the agreement-forming person and person to whom the account is transferred to the Act","S003/S004 Rule 2.3","Rule text verified; “account” application to particular bank or processor held"],["S_DE-P4-C005","Trust account must be at an insured bank, separated and appropriately designated","S001 §§2402A(4), 2402A(20)","No FDIC/NCUA pass-through or in-state-location conclusion"],["S_DE-P4-C006","Trust money is not provider/designee property and is unavailable to their creditors except the consumer as to the consumer’s undistributed balance","S001 §2422A(b)","High confidence in Chapter 24A property rule; bankruptcy priority beyond text held"],["S_DE-P4-C007","Pooled consumer funds require individual ledgers, no outside commingling, exact aggregate cash, and monthly reconciliation","S001 §2422A(c)(1), (d)–(f); S003/S004 Rules 11.2, 11.3, 11.6","High confidence in text; actual account compliance untested"],["S_DE-P4-C008","Deposit within two business days; Rule 11.1 distribution within eight days; statutory nonfinal-payment and creditor-due-date qualifications apply","S001 §2422A(a), (c)(2); S003/S004 Rule 11.1","High confidence in text; exact receipt/finality under payment rails held"],["S_DE-P4-C009","Transfers are limited to returns or pretermination, properly authorized creditor or fee payments","S001 §2428A(a)(5)","Fee transfer still requires independent state and federal permission"],["S_DE-P4-C010","Trust-account interest belongs to depositors, except it may pay financial-institution trust-account fees","S003/S004 Rule 11.6","High confidence in displayed rule; allocation method not supplied"],["S_DE-P4-C011","Provider/controller errors must be corrected; trust cash must match ledgers; suspected unlawful appropriation triggers immediate and five-day notices","S001 §2422A(c)(3), (e)–(g)","High confidence in text; bank/processor loss allocation held"],["S_DE-P4-C012","Trust-account relocation requires advance bank notification and later or accompanying account-number notice","S001 §2422A(i); S003/S004 Rule 11.5","Statute/rule wording differs slightly; prudent compliance must satisfy both, but no agency interpretation located"],["S_DE-P4-C013","Monthly, requested, and cancellation/termination accountings must contain receipts, disbursements, deductions, reserves, and settlement details","S001 §2427A(a)–(b)","High confidence; actual statements not reviewed"],["S_DE-P4-C014","Records retained at least five years; Rule 12 specifies consumer files, activity ledgers, settlement calculations, and index","S001 §2427A(c)–(e); S003/S004 Rule 12","High confidence in displayed text; longer regulator-specific retention not identified"],["S_DE-P4-C015","Attorney General has trust-record consent and examination access over providers, delegates, and relevant records","S001 §§2405A(b)(3), 2419A(d)(2), 2432A(b); S003/S004 Rules 4.2.5, 12","High confidence in text; no examination of an actual entity"],["S_DE-P4-C016","Current agency-linked forms request account identity, value, access persons, receipts, distributions, balances, gross settlement funds, agents, and affiliates","S005–S007, specified PDF pages","Forms verified as linked; internal form age/current sufficiency held"],["S_DE-P4-C017","Renewal insurance is larger of $250,000 or highest daily trust balance; receipts/distributions and accumulated settlement money must be reported","S001 §2411A(b)(5)–(7); S003/S004 Rules 5.3.5–5.3.7","Statutory figure verified; actual policy and coverage exclusions held"],["S_DE-P4-C018","Current overdraft-agreement reference is orphaned after 2007 repeal of former §2422A(j), (k)","S001 §2405A(b)(3); S002 §5; S003/S004 Rule 4.2.5","High confidence in amendment chain for this narrow point; current agency practice held"],["S_DE-P4-C019","Cancellation notice’s later-fee sentence does not erase specific statutory return/refund duties","S001 §§2419A(d), (g), 2420A, 2422A(h), 2426A","High confidence in coexistence of provisions; exact contract application held"],["S_DE-P4-C020","Only actually payable/permitted fees may reduce a return; billing or a ceiling does not prove deductibility","S001 §2422A(h), §2426A; S003/S004 Rule 11.4; preserved PASS-02 predicates","High confidence as negative limit; actual fee history absent"],["S_DE-P4-C021","Separate money-transmission licensing or exemption may apply to an administrator; implementation and entity result unresolved","S009 §3; S010 §§2303–2305, 2332; S011","Enacted text verified; October 2026 implementation notice and actual entity facts not established"],["S_DE-P4-C022","Federal dedicated account requires insured institution, customer ownership and interest, independent administrator, no referral compensation, and seven-business-day return; earned fees must satisfy all performance conditions","S008 §310.4(a)(5)(i)–(ii)","High confidence in federal text; conditional on actual TSR coverage"]]},{"headers":["Component","PASS-04 status","Claim IDs","Exact missing evidence or next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","PASS-04 status","Claim IDs","Exact missing evidence or next investigation"],["Trust-account definition and trigger","Answered at statutory level","C001, C005, C006","Apply to actual receipt, purpose, and account documents"],["Provider direct custody","Answered at legal level","C001, C007, C008","Actual provider ledger and bank account not reviewed"],["Affiliate/designee/processor control","Partial","C002, C004","Entity chart, contracts, account permissions, ACH authority, loss allocation"],["Consumer-owned noncustodial account","Text answered; application partial","C003","Verify actual client name, creditor protection, control, and retention of funds"],["Independent administrator status","Unresolved for any entity","C002–C004, C021, C022","Ownership, affiliation, compensation, delegate agreement, transmission status"],["Pooled custody and individual ledgers","Answered","C007","Actual reconciliation records remain private and unreviewed"],["Bank institution and account designation","Answered within Chapter 24A","C005","Actual bank, account agreement, federal deposit insurance treatment"],["Delaware bank-location requirement","Not established in reviewed clauses","C005","Broader banking law and actual contract, if material"],["Beneficial ownership/property rule","Answered within Chapter 24A","C006","Bankruptcy and receivership priority excluded"],["FDIC/NCUA pass-through coverage","Unresolved","C005, C022","Bank account title, insurance rules, depositor records, institutional facts"],["Segregation and commingling","Answered","C007","Actual account testing"],["Two-business-day deposit","Answered","C008","Actual receipt timestamp and payment-finality records"],["Eight-day creditor distribution","Answered from displayed rule","C008","Full October 2026 Rule 102 certification; actual due-date and finality facts"],["Pending ACH, checks, returns, reversals","Partial","C008, C011","Bank/ACH contracts, return codes, settlement timestamps"],["Creditor due-date compliance","Answered at statutory level","C008","Actual creditor agreements and due dates"],["Error correction and creditor charges","Answered","C011","Actual causation and charge records"],["Interest ownership","Answered for state trust and conditional TSR account","C010, C022","Actual interest, bank fees, and allocation method"],["Reserve reporting","Answered; reserve authority partial","C013","Actual agreement and whether reserve is consistent with eight-day rule"],["Trust relocation","Answered at text level","C012","Actual notice, bank move, account number, and agency practice"],["Account closure and ACH revocation","Unresolved","C009, C022","Bank/administrator contracts and payment authorizations"],["Monthly statements and request access","Answered","C013","Actual statement form and delivery records"],["Record retention","Answered baseline","C014","Any longer rule/order-specific period"],["Examinations and trust consent","Answered","C015","No actual examination or consent reviewed"],["Initial and renewal forms","Partial operational evidence","C016, C017","Updated internal version, complete current checklist, actual filing"],["Current Rule 102 trust text","Substantially supported; complete 2026 currency held","C004, C007–C018","Authenticate all post-February-2025 rule changes or official current certification"],["Overdraft-notification cross-reference","Narrow amendment question answered","C018","Current agency application practice"],["Timely cancellation funds","Partial","C019","Actual agreement, timing, waiver, remittance history"],["Custodial termination return","Answered at statutory level","C019, C020","Current ledger and lawful fee history"],["Noncustodial fee refund","Answered at statutory level; computation held","C019, C020","Verified principal base, fee association, previous credits, earning"],["Plan failure return","Answered at statutory level","C019, C020","When failure became reasonably apparent; actual balance and payable fees"],["Creditor rejection/withdrawal","Answered at statutory level","C019","Actual notice and consumer election"],["Renewal-denial cessation","Partial","C019","Actual Attorney General order, successor provider, transfer and balances"],["Provider-transfer consequences","Partial","C002, C004, C019","Transfer agreement, recipient status, customer notice and approval"],["Money-transmission gateway","Partial/unresolved","C021","Implementation notice, legacy/current regime, entity license or exemption facts"],["Federal dedicated-account overlay","Answered conditionally","C022","Actual TSR coverage, affiliations, referral compensation, account documents"],["Actual provider authorization","Unresolved and outside this pass","—","Current provider-specific agency record"],["Actual fee earning or deduction","Unresolved","C020, C022","Contract, enrolled debts, settlements, payments, allocation, prior fees"],["Full agreement enforceability and waivers","Excluded except necessary return clauses","—","Separate agreement pass"],["Bond claims, seizure, receivership, restitution, and remedies","Excluded","—","Separate remedies and insolvency pass"],["Courts and controlling interpretations","Excluded except statutory reading","—","Dedicated Delaware and federal case-law pass"],["Collection, garnishment, limitations, secured debt, sectors, local and tribal law","Excluded","—","Separate required Delaware passes"],["State, parent, A066, operational, or publication acceptance","Not assessed","—","No acceptance implication"]]}],"claims":[{"claim_id":"S_DE-P4-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C001","Precise assertion":"Plan money received by a provider for creditor distribution is trust money; qualifying account defined by insured bank, separation, designation, and creditor-disbursement purpose","Sources and pinpoints":"S001 §§2402A(20), 2422A(a)–(b)","Conditions, exceptions, currentness, and confidence":"High confidence in statutory text; actual receipt and purpose are factual"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C002","Precise assertion":"Designee or controller involvement does not automatically create noncustody; provider remains liable for delegated violations","Sources and pinpoints":"S001 §§2402A(15), 2422A(b), (c)(3), (f), 2431A, 2432A(b)","Conditions, exceptions, currentness, and confidence":"High confidence in duties; classification of an actual processor remains fact-dependent"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C003","Precise assertion":"§2422A(j) creates two noncustody routes and lists the designated-account characteristics in the disjunctive","Sources and pinpoints":"S001 §2422A(j)","Conditions, exceptions, currentness, and confidence":"Text verified; actual application and any judicial interpretation held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C004","Precise assertion":"Rule 2.3 subjects the agreement-forming person and person to whom the account is transferred to the Act","Sources and pinpoints":"S003/S004 Rule 2.3","Conditions, exceptions, currentness, and confidence":"Rule text verified; “account” application to particular bank or processor held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C005","Precise assertion":"Trust account must be at an insured bank, separated and appropriately designated","Sources and pinpoints":"S001 §§2402A(4), 2402A(20)","Conditions, exceptions, currentness, and confidence":"No FDIC/NCUA pass-through or in-state-location conclusion"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C006","Precise assertion":"Trust money is not provider/designee property and is unavailable to their creditors except the consumer as to the consumer’s undistributed balance","Sources and pinpoints":"S001 §2422A(b)","Conditions, exceptions, currentness, and confidence":"High confidence in Chapter 24A property rule; bankruptcy priority beyond text held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C007","Precise assertion":"Pooled consumer funds require individual ledgers, no outside commingling, exact aggregate cash, and monthly reconciliation","Sources and pinpoints":"S001 §2422A(c)(1), (d)–(f); S003/S004 Rules 11.2, 11.3, 11.6","Conditions, exceptions, currentness, and confidence":"High confidence in text; actual account compliance untested"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C008","Precise assertion":"Deposit within two business days; Rule 11.1 distribution within eight days; statutory nonfinal-payment and creditor-due-date qualifications apply","Sources and pinpoints":"S001 §2422A(a), (c)(2); S003/S004 Rule 11.1","Conditions, exceptions, currentness, and confidence":"High confidence in text; exact receipt/finality under payment rails held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C009","Precise assertion":"Transfers are limited to returns or pretermination, properly authorized creditor or fee payments","Sources and pinpoints":"S001 §2428A(a)(5)","Conditions, exceptions, currentness, and confidence":"Fee transfer still requires independent state and federal permission"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C010","Precise assertion":"Trust-account interest belongs to depositors, except it may pay financial-institution trust-account fees","Sources and pinpoints":"S003/S004 Rule 11.6","Conditions, exceptions, currentness, and confidence":"High confidence in displayed rule; allocation method not supplied"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C011","Precise assertion":"Provider/controller errors must be corrected; trust cash must match ledgers; suspected unlawful appropriation triggers immediate and five-day notices","Sources and pinpoints":"S001 §2422A(c)(3), (e)–(g)","Conditions, exceptions, currentness, and confidence":"High confidence in text; bank/processor loss allocation held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C012","Precise assertion":"Trust-account relocation requires advance bank notification and later or accompanying account-number notice","Sources and pinpoints":"S001 §2422A(i); S003/S004 Rule 11.5","Conditions, exceptions, currentness, and confidence":"Statute/rule wording differs slightly; prudent compliance must satisfy both, but no agency interpretation located"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C013","Precise assertion":"Monthly, requested, and cancellation/termination accountings must contain receipts, disbursements, deductions, reserves, and settlement details","Sources and pinpoints":"S001 §2427A(a)–(b)","Conditions, exceptions, currentness, and confidence":"High confidence; actual statements not reviewed"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C014","Precise assertion":"Records retained at least five years; Rule 12 specifies consumer files, activity ledgers, settlement calculations, and index","Sources and pinpoints":"S001 §2427A(c)–(e); S003/S004 Rule 12","Conditions, exceptions, currentness, and confidence":"High confidence in displayed text; longer regulator-specific retention not identified"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C015","Precise assertion":"Attorney General has trust-record consent and examination access over providers, delegates, and relevant records","Sources and pinpoints":"S001 §§2405A(b)(3), 2419A(d)(2), 2432A(b); S003/S004 Rules 4.2.5, 12","Conditions, exceptions, currentness, and confidence":"High confidence in text; no examination of an actual entity"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C016","Precise assertion":"Current agency-linked forms request account identity, value, access persons, receipts, distributions, balances, gross settlement funds, agents, and affiliates","Sources and pinpoints":"S005–S007, specified PDF pages","Conditions, exceptions, currentness, and confidence":"Forms verified as linked; internal form age/current sufficiency held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C017","Precise assertion":"Renewal insurance is larger of $250,000 or highest daily trust balance; receipts/distributions and accumulated settlement money must be reported","Sources and pinpoints":"S001 §2411A(b)(5)–(7); S003/S004 Rules 5.3.5–5.3.7","Conditions, exceptions, currentness, and confidence":"Statutory figure verified; actual policy and coverage exclusions held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C018","Precise assertion":"Current overdraft-agreement reference is orphaned after 2007 repeal of former §2422A(j), (k)","Sources and pinpoints":"S001 §2405A(b)(3); S002 §5; S003/S004 Rule 4.2.5","Conditions, exceptions, currentness, and confidence":"High confidence in amendment chain for this narrow point; current agency practice held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C019","Precise assertion":"Cancellation notice’s later-fee sentence does not erase specific statutory return/refund duties","Sources and pinpoints":"S001 §§2419A(d), (g), 2420A, 2422A(h), 2426A","Conditions, exceptions, currentness, and confidence":"High confidence in coexistence of provisions; exact contract application held"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C020","Precise assertion":"Only actually payable/permitted fees may reduce a return; billing or a ceiling does not prove deductibility","Sources and pinpoints":"S001 §2422A(h), §2426A; S003/S004 Rule 11.4; preserved PASS-02 predicates","Conditions, exceptions, currentness, and confidence":"High confidence as negative limit; actual fee history absent"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C021","Precise assertion":"Separate money-transmission licensing or exemption may apply to an administrator; implementation and entity result unresolved","Sources and pinpoints":"S009 §3; S010 §§2303–2305, 2332; S011","Conditions, exceptions, currentness, and confidence":"Enacted text verified; October 2026 implementation notice and actual entity facts not established"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"claim_id":"S_DE-P4-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_DE-P4-C022","Precise assertion":"Federal dedicated account requires insured institution, customer ownership and interest, independent administrator, no referral compensation, and seven-business-day return; earned fees must satisfy all performance conditions","Sources and pinpoints":"S008 §310.4(a)(5)(i)–(ii)","Conditions, exceptions, currentness, and confidence":"High confidence in federal text; conditional on actual TSR coverage"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"}],"sources":[{"source_id":"S_DE-P4-S001","urls":["https://delcode.delaware.gov/title6/c024a/index.html"],"researcher_record":{"Source ID":"S_DE-P4-S001","Official source and full literal URL":"Delaware General Assembly, Title 6, Chapter 24A — Debt-Management Services. https://delcode.delaware.gov/title6/c024a/index.html","Exact provisions or pages read":"§§2402A(4), (13), (15), (20); 2403A(c); 2405A(b)(3); 2406A(7), (15); 2411A(b)(5)–(7), (f); 2419A(a)(6), (d), (g); 2420A; 2422A; 2426A; 2427A; 2428A(a)(1), (5); 2431A; 2432A(b)","Version/effective status and access classification":"Current official online codification; freshly read","Limitations":"Complete amendment-by-amendment history not independently audited; remedies, bond claims, and case law not fully reviewed. \nDelaware Code\n+2"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S002","urls":["https://legis.delaware.gov/SessionLaws/Chapter?id=17741","https://legis.delaware.gov/SessionLaws?chapter=146&volume=76"],"researcher_record":{"Source ID":"S_DE-P4-S002","Official source and full literal URL":"Delaware General Assembly, 76 Del. Laws ch. 146, HB 164. https://legis.delaware.gov/SessionLaws/Chapter?id=17741","Exact provisions or pages read":"§5 deletion of former §2422A(j), (k) and redesignation of former (l); approved July 17, 2007","Version/effective status and access classification":"Official session law; freshly read","Limitations":"Historical amendment authority, not a substitute for current codification. \nDelaware General Assembly"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S003","urls":["https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml"],"researcher_record":{"Source ID":"S_DE-P4-S003","Official source and full literal URL":"Delaware Regulations, official readable Administrative Code snapshot, 6 Del. Admin. C. 102. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","Exact provisions or pages read":"Rules 2.3; 4.2.5; 5.3.5–5.3.7; 11.1–11.7; 12.1–12.4; 13.1; 13.4","Version/effective status and access classification":"Official readable code page marked last updated February 11, 2025; freshly read","Limitations":"Supports the displayed rule text but is not a separate certification that no change occurred after February 11, 2025. Complete October 2026 Rule 102 history remains held. \nDelaware Regulations"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S004","urls":["https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm"],"researcher_record":{"Source ID":"S_DE-P4-S004","Official source and full literal URL":"Delaware DOJ, Final Order, 102 Debt Management Services, 14 DE Reg. 318. https://archive.regulations.delaware.gov/register/october2010/final/14%20DE%20Reg%20318%2010-01-10.htm","Exact provisions or pages read":"Order and effective date; Rules 2.3, 4.2.5, 5.3.5–5.3.7, 11, 12","Version/effective status and access classification":"Original final order effective October 11, 2010; freshly read","Limitations":"Establishes adopted wording and 2010 effect, not by itself the absence of later amendments. \nDelaware Regulations\n+1"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S005","urls":["https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/"],"researcher_record":{"Source ID":"S_DE-P4-S005","Official source and full literal URL":"Delaware DOJ, Debt Management Services Act program page. https://attorneygeneral.delaware.gov/fraud/cpu/debtmanadvisory/","Exact provisions or pages read":"Links to current public application, renewal, bond, certification, accreditation, and roster resources","Version/effective status and access classification":"Official operational page; freshly read","Limitations":"Operational locator only; does not prove legal currency of every linked form or provider authorization. \nDelaware DOJ"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S006","urls":["https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf"],"researcher_record":{"Source ID":"S_DE-P4-S006","Official source and full literal URL":"Delaware DOJ, Initial Application — Debt-Management Services License. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Initial-Application.pdf","Exact provisions or pages read":"Printed page 4 / PDF index 3: trust-account name, location, number, value, persons with access, insurance, inspection consent; printed page 5 / index 4: account-access criminal records","Version/effective status and access classification":"Six-page official PDF currently linked by S005; internally marked “Revised 2 3 12”; parsed and visually inspected","Limitations":"Current continued linkage does not certify that the 2012 form is complete under all October 2026 law. \nDelaware DOJ\n+1"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S007","urls":["https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf"],"researcher_record":{"Source ID":"S_DE-P4-S007","Official source and full literal URL":"Delaware DOJ, Application for Renewal — Debt Management Services License. https://attorneygeneral.delaware.gov/wp-content/uploads/sites/50/2019/03/Application-for-Renewal.pdf","Exact provisions or pages read":"Printed pages 2–3 / PDF indices 1–2: trust accounts, receipts, disbursements, highest balance, access persons, gross settlement accumulations, affiliates, agents, insurance","Version/effective status and access classification":"Five-page official PDF currently linked by S005; parsed and visually inspected","Limitations":"No provider filing was reviewed; form currency and legal sufficiency are not certified. \nDelaware DOJ\n+2"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S008","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_DE-P4-S008","Official source and full literal URL":"Electronic Code of Federal Regulations, 16 C.F.R. §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact provisions or pages read":"§310.4(a)(5)(i)(A)–(C), (ii)(A)–(E)","Version/effective status and access classification":"Continuously updated eCFR page; freshly read","Limitations":"Federal duties are conditional on actual TSR coverage; eCFR describes itself as not the official print legal edition. \neCFR\n+1"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S009","urls":["https://legis.delaware.gov/SessionLaws/Chapter?id=42501","https://legis.delaware.gov/SessionLaws?chapter=338&volume=85"],"researcher_record":{"Source ID":"S_DE-P4-S009","Official source and full literal URL":"Delaware General Assembly, 85 Del. Laws ch. 338. https://legis.delaware.gov/SessionLaws/Chapter?id=42501","Exact provisions or pages read":"§3 implementation trigger; approved July 6, 2026","Version/effective status and access classification":"Official session law; freshly read","Limitations":"No authenticated implementation notice was established in this pass. \nDelaware General Assembly"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S010","urls":["https://delcode.delaware.gov/title5/c023/sc01/index.html","https://delcode.delaware.gov/title5/c023/sc02/index.html","https://delcode.delaware.gov/title5/c023/sc07/index.html"],"researcher_record":{"Source ID":"S_DE-P4-S010","Official source and full literal URL":"Delaware Code, Title 5, Chapter 23 — Money Transmission and Virtual Currency. https://delcode.delaware.gov/title5/c023/sc01/index.html; https://delcode.delaware.gov/title5/c023/sc02/index.html; https://delcode.delaware.gov/title5/c023/sc07/index.html","Exact provisions or pages read":"§§2303(10)–(11), (18), (27); 2304; 2305; 2332","Version/effective status and access classification":"Current codified enacted framework, each section carrying an application note referring to 85 Del. Laws ch. 338 §3; freshly read","Limitations":"Exact October 2026 implementation status and applicable legacy transition remain unresolved. \nDelaware Code\n+2"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false},{"source_id":"S_DE-P4-S011","urls":["https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf"],"researcher_record":{"Source ID":"S_DE-P4-S011","Official source and full literal URL":"Delaware Office of the State Bank Commissioner, 2026 Renewal Application for Exemption from the Sale of Checks and Transmission of Money Act. https://banking.delaware.gov/wp-content/uploads/sites/73/2025/08/2026-Renewal-Application-Sale-of-Checks-and-Transmission-of-Money-Act-Exemption.pdf","Exact provisions or pages read":"PDF page/index 0 title and exemption basis; pages 1–3 business plan, regulators, records, federal MSB status, annual expiration and renewal procedure","Version/effective status and access classification":"Official 2026 operational form; parsed and visually inspected","Limitations":"Does not establish the governing transition date, approval of any entity, or an exemption for a debt-account administrator. \nDelaware State Bank Commissioner\n+1"},"coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false}],"coverage":[{"topic":"Trust-account definition and trigger","researcher_record":{"Component":"Trust-account definition and trigger","PASS-04 status":"Answered at statutory level","Claim IDs":"C001, C005, C006","Exact missing evidence or next investigation":"Apply to actual receipt, purpose, and account documents"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Provider direct custody","researcher_record":{"Component":"Provider direct custody","PASS-04 status":"Answered at legal level","Claim IDs":"C001, C007, C008","Exact missing evidence or next investigation":"Actual provider ledger and bank account not reviewed"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Affiliate/designee/processor control","researcher_record":{"Component":"Affiliate/designee/processor control","PASS-04 status":"Partial","Claim IDs":"C002, C004","Exact missing evidence or next investigation":"Entity chart, contracts, account permissions, ACH authority, loss allocation"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Consumer-owned noncustodial account","researcher_record":{"Component":"Consumer-owned noncustodial account","PASS-04 status":"Text answered; application partial","Claim IDs":"C003","Exact missing evidence or next investigation":"Verify actual client name, creditor protection, control, and retention of funds"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Independent administrator status","researcher_record":{"Component":"Independent administrator status","PASS-04 status":"Unresolved for any entity","Claim IDs":"C002–C004, C021, C022","Exact missing evidence or next investigation":"Ownership, affiliation, compensation, delegate agreement, transmission status"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Pooled custody and individual ledgers","researcher_record":{"Component":"Pooled custody and individual ledgers","PASS-04 status":"Answered","Claim IDs":"C007","Exact missing evidence or next investigation":"Actual reconciliation records remain private and unreviewed"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Bank institution and account designation","researcher_record":{"Component":"Bank institution and account designation","PASS-04 status":"Answered within Chapter 24A","Claim IDs":"C005","Exact missing evidence or next investigation":"Actual bank, account agreement, federal deposit insurance treatment"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Delaware bank-location requirement","researcher_record":{"Component":"Delaware bank-location requirement","PASS-04 status":"Not established in reviewed clauses","Claim IDs":"C005","Exact missing evidence or next investigation":"Broader banking law and actual contract, if material"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Beneficial ownership/property rule","researcher_record":{"Component":"Beneficial ownership/property rule","PASS-04 status":"Answered within Chapter 24A","Claim IDs":"C006","Exact missing evidence or next investigation":"Bankruptcy and receivership priority excluded"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"FDIC/NCUA pass-through coverage","researcher_record":{"Component":"FDIC/NCUA pass-through coverage","PASS-04 status":"Unresolved","Claim IDs":"C005, C022","Exact missing evidence or next investigation":"Bank account title, insurance rules, depositor records, institutional facts"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Segregation and commingling","researcher_record":{"Component":"Segregation and commingling","PASS-04 status":"Answered","Claim IDs":"C007","Exact missing evidence or next investigation":"Actual account testing"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Two-business-day deposit","researcher_record":{"Component":"Two-business-day deposit","PASS-04 status":"Answered","Claim IDs":"C008","Exact missing evidence or next investigation":"Actual receipt timestamp and payment-finality records"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Eight-day creditor distribution","researcher_record":{"Component":"Eight-day creditor distribution","PASS-04 status":"Answered from displayed rule","Claim IDs":"C008","Exact missing evidence or next investigation":"Full October 2026 Rule 102 certification; actual due-date and finality facts"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Pending ACH, checks, returns, reversals","researcher_record":{"Component":"Pending ACH, checks, returns, reversals","PASS-04 status":"Partial","Claim IDs":"C008, C011","Exact missing evidence or next investigation":"Bank/ACH contracts, return codes, settlement timestamps"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Creditor due-date compliance","researcher_record":{"Component":"Creditor due-date compliance","PASS-04 status":"Answered at statutory level","Claim IDs":"C008","Exact missing evidence or next investigation":"Actual creditor agreements and due dates"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Error correction and creditor charges","researcher_record":{"Component":"Error correction and creditor charges","PASS-04 status":"Answered","Claim IDs":"C011","Exact missing evidence or next investigation":"Actual causation and charge records"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Interest ownership","researcher_record":{"Component":"Interest ownership","PASS-04 status":"Answered for state trust and conditional TSR account","Claim IDs":"C010, C022","Exact missing evidence or next investigation":"Actual interest, bank fees, and allocation method"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Reserve reporting","researcher_record":{"Component":"Reserve reporting","PASS-04 status":"Answered; reserve authority partial","Claim IDs":"C013","Exact missing evidence or next investigation":"Actual agreement and whether reserve is consistent with eight-day rule"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Trust relocation","researcher_record":{"Component":"Trust relocation","PASS-04 status":"Answered at text level","Claim IDs":"C012","Exact missing evidence or next investigation":"Actual notice, bank move, account number, and agency practice"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Account closure and ACH revocation","researcher_record":{"Component":"Account closure and ACH revocation","PASS-04 status":"Unresolved","Claim IDs":"C009, C022","Exact missing evidence or next investigation":"Bank/administrator contracts and payment authorizations"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Monthly statements and request access","researcher_record":{"Component":"Monthly statements and request access","PASS-04 status":"Answered","Claim IDs":"C013","Exact missing evidence or next investigation":"Actual statement form and delivery records"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Record retention","researcher_record":{"Component":"Record retention","PASS-04 status":"Answered baseline","Claim IDs":"C014","Exact missing evidence or next investigation":"Any longer rule/order-specific period"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Examinations and trust consent","researcher_record":{"Component":"Examinations and trust consent","PASS-04 status":"Answered","Claim IDs":"C015","Exact missing evidence or next investigation":"No actual examination or consent reviewed"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Initial and renewal forms","researcher_record":{"Component":"Initial and renewal forms","PASS-04 status":"Partial operational evidence","Claim IDs":"C016, C017","Exact missing evidence or next investigation":"Updated internal version, complete current checklist, actual filing"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence 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cross-reference","researcher_record":{"Component":"Overdraft-notification cross-reference","PASS-04 status":"Narrow amendment question answered","Claim IDs":"C018","Exact missing evidence or next investigation":"Current agency application practice"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Timely cancellation funds","researcher_record":{"Component":"Timely cancellation funds","PASS-04 status":"Partial","Claim IDs":"C019","Exact missing evidence or next investigation":"Actual agreement, timing, waiver, remittance history"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Custodial termination return","researcher_record":{"Component":"Custodial termination return","PASS-04 status":"Answered at statutory level","Claim IDs":"C019, C020","Exact missing evidence or next investigation":"Current ledger and lawful fee history"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Noncustodial fee refund","researcher_record":{"Component":"Noncustodial fee refund","PASS-04 status":"Answered at statutory level; computation held","Claim IDs":"C019, C020","Exact missing evidence or next investigation":"Verified principal base, fee association, previous credits, earning"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Plan failure return","researcher_record":{"Component":"Plan failure return","PASS-04 status":"Answered at statutory level","Claim IDs":"C019, C020","Exact missing evidence or next investigation":"When failure became reasonably apparent; actual balance and payable fees"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Creditor rejection/withdrawal","researcher_record":{"Component":"Creditor rejection/withdrawal","PASS-04 status":"Answered at statutory level","Claim IDs":"C019","Exact missing evidence or next investigation":"Actual notice and consumer election"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence 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consequences","PASS-04 status":"Partial","Claim IDs":"C002, C004, C019","Exact missing evidence or next investigation":"Transfer agreement, recipient status, customer notice and approval"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Money-transmission gateway","researcher_record":{"Component":"Money-transmission gateway","PASS-04 status":"Partial/unresolved","Claim IDs":"C021","Exact missing evidence or next investigation":"Implementation notice, legacy/current regime, entity license or exemption facts"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Federal dedicated-account overlay","researcher_record":{"Component":"Federal dedicated-account overlay","PASS-04 status":"Answered conditionally","Claim IDs":"C022","Exact missing evidence or next investigation":"Actual TSR coverage, affiliations, referral compensation, account documents"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Actual provider authorization","researcher_record":{"Component":"Actual provider authorization","PASS-04 status":"Unresolved and outside this pass","Claim IDs":"—","Exact missing evidence or next investigation":"Current provider-specific agency record"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Actual fee earning or deduction","researcher_record":{"Component":"Actual fee earning or deduction","PASS-04 status":"Unresolved","Claim IDs":"C020, C022","Exact missing evidence or next investigation":"Contract, enrolled debts, settlements, payments, allocation, prior fees"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Full agreement enforceability and waivers","researcher_record":{"Component":"Full agreement enforceability and waivers","PASS-04 status":"Excluded except necessary return clauses","Claim IDs":"—","Exact missing evidence or next investigation":"Separate agreement pass"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"Bond claims, seizure, receivership, restitution, and remedies","researcher_record":{"Component":"Bond claims, seizure, receivership, restitution, and remedies","PASS-04 status":"Excluded","Claim IDs":"—","Exact missing evidence or next investigation":"Separate remedies and insolvency pass"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence 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law","researcher_record":{"Component":"Collection, garnishment, limitations, secured debt, sectors, local and tribal law","PASS-04 status":"Excluded","Claim IDs":"—","Exact missing evidence or next investigation":"Separate required Delaware passes"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"},{"topic":"State, parent, A066, operational, or publication acceptance","researcher_record":{"Component":"State, parent, A066, operational, or publication acceptance","PASS-04 status":"Not assessed","Claim IDs":"—","Exact missing evidence or next investigation":"No acceptance implication"},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"full_scoped_review_with_bounded_timing_and_predicate_correction_requested","coordinator_review":"[internal evidence reference]","correction_pass":"S_DE/pass-05","parent_assignment_complete":false,"correction_review":"[internal evidence reference]","correction_disposition":"three_requested_precision_groups_resolved_with_limits"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}