{"meta":{"key":"s_de--pass-05","task":"S_DE","title":"SDE bounded timing and predicate correction","parent_title":"Delaware debt and debt relief law","edition":"pass-05","path":"/research/s_de--pass-05/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":5,"sources":3,"review_status":"accepted_with_limits","review_complete":true,"sha256":"a7f8c780a9eac34ddb7422594c7be1c6b2799a175a39d9275b363b9f775d025d","headings":["1. Exact replacement table","2. Corrected substantive findings","A. Deposit and creditor-disbursement clocks","Corrected event-matrix cells","Effect on the saved examples","B. Thirty-day cancellation right versus refund timing","Corrected return-matrix cell","C. Federal summary precision","Corrected account/model-matrix cell","3. Corrective claim table","4. Corrected source/version usage cells","5. Focused coverage patch","6. Preserved examples and holds","7. Researcher self-check","Freshly read","Reused without rerunning","Not read or not performed in PASS-05"],"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-05","facets":{"geography":["us","us-de"],"debt_type":[],"stage":[],"subject":[]},"scope":"P4depositfinality/eightdayclock,extendedcancellationwindow-versusrefunddeadline,andcompletefederalpredicateparaphrase precisiononly; corefunds/broaderholdsretained.","pending_corrections":0},"markdown":"# S_DE PASS-05 — bounded timing and predicate correction\n\n**Fresh access session:** October 25, 2026, Pacific / October 26, 2026, UTC. No individual source-fetch timestamps are asserted. \n\n**Review relationship:** Same-coordinator correction to the saved complete PASS-04; **not an independent review**.\n\nOnly the three specified precision groups are corrected. All PASS-04 examples, arithmetic, account classifications, money-transmission findings, source limitations, and provider-, contract-, bank/ACH-, fee-, federal-coverage-, currentness-, local-, tribal-, and parent-level holds remain preserved.\n\n## 1. Exact replacement table\n\n| P4 location / stable ID | Old PASS-04 wording | Precise replacement | Authority and limitation |\n| --- | --- | --- | --- |\n| **A.2 event matrix, first row; S_DE-P4-C008** | “Provider receives final money under a plan for creditor distribution” followed by deposit within two business days | **All money paid to a provider by or on behalf of an individual pursuant to a plan for distribution to creditors is held in trust, and the provider must deposit that money within two business days after receipt.** Neither §2422A(a) nor Rule 102 §11.1 makes “final money” an express prerequisite to the deposit duty. The nonfinal-payment exception appears instead in §2422A(c)(2)(A) and permits delay of **payment to creditors** to the extent the individual’s payment is not final. The actual moment of “receipt” for a provisional ACH, check, card payment, return, or reversal remains fact- and contract-dependent. | 6 Del. C. §2422A(a), (c)(2)(A); Rule 102 §11.1. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **A.2 event matrix, second row; S_DE-P4-C008** | “Money has been deposited for creditor distribution” followed by distribution within eight days | **Rule 102 §11.1 states that the money must be distributed to creditors within eight days, but it does not state that a new eight-day period begins after deposit.** The text therefore does not support an automatic “two business days plus eight more days” construction. The only expressly stated event in the sentence is receipt, but because the phrase “within eight days” does not repeat its anchor and no controlling interpretation was established, the precise start and interaction of the eight-day period remain held. Rule 13.1 supplies computation rules once the triggering act or event is identified; it does not itself identify that trigger. | Rule 102 §§1.1, 11.1, 13.1; 6 Del. C. §2402A(8). No calendar or holiday computation is made. [Delaware Code+3](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **A.4 return-mechanics matrix, extended-cancellation row; S_DE-P4-C019** | Timing: “Within the statutory cancellation period” | **The consumer may exercise the extended cancellation right within 30 days after assent when the agreement fails to comply with §2420A(b), §2419A, or §2428A. The 30 days is a cancellation-notice window, not an express refund deadline.** Section 2420A does not state a numerical deadline for completing the resulting refund. Section 2427A(a)(1) separately requires an accounting upon cancellation. Any immediate or prompt return duty under §§2426A or 2422A(h) applies only when that provision’s separate termination or plan-failure predicate is met. | 6 Del. C. §§2419A(d), (g), 2420A(a)–(c), 2422A(h), 2426A, 2427A(a)(1). No actual agreement, waiver, notice, or completed creditor payment is adjudicated. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **A.6 federal fee-trigger narrative; S_DE-P4-C022** | “Valid executed agreement” and “consumer has made at least one payment under that agreement” | **For a covered debt-relief service, §310.4(a)(5)(i)(A) requires a qualifying settlement agreement, debt-management plan, or other valid contractual agreement executed by the customer. Subparagraph (B) requires the customer to make at least one payment pursuant to that agreement between the customer and the creditor or debt collector.** These are distinct predicates and must both be satisfied. | 16 C.F.R. §310.4(a)(5)(i)(A)–(B). Actual TSR coverage, execution, creditor assent, and payment remain unverified. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **A.6 federal allocation narrative; S_DE-P4-C022** | General reference to proportional allocation or a consistent savings method | **For debts altered individually, subparagraph (C) requires either:** (1) the same proportional relationship between the individual-debt fee and total program fee as the individual debt amount bears to the entire debt amount, using amounts owed when enrolled; **or** (2) a percentage of savings that does not change from one individual debt to another, with savings measured as the enrolled amount minus the amount actually paid to satisfy that debt. | 16 C.F.R. §310.4(a)(5)(i)(C)(1)–(2). No actual fee, enrolled balance, satisfaction payment, or allocation is validated. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **A.6 dedicated-account item 4 and affected administrator matrix cell; S_DE-P4-C022** | “The administrator and debt-relief service do not exchange compensation for referrals” | **The account administrator must not give or accept any money or other compensation in exchange for referrals of business involving the debt-relief service.** This is not limited to a direct exchange between the administrator and the debt-relief provider. | 16 C.F.R. §310.4(a)(5)(ii)(D). Actual ownership, control, affiliation, referral, and compensation relationships remain held. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n## 2. Corrected substantive findings\n\n### A. Deposit and creditor-disbursement clocks\n\nThe corrected sequence is:\n\n1. **Deposit obligation:** Section 2422A(a) reaches all money paid to the provider by or for the consumer pursuant to a creditor-distribution plan. The provider must deposit it within two business days after receipt. “Final money” is removed as a blanket deposit predicate. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html)\n2. **Creditor-disbursement obligation:** Section 2422A(c)(2) requires disbursement as disclosed in the agreement. The provider may delay creditor payment to the extent the consumer’s payment is not final, and regular periodic payments must comply with creditor due dates. [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n3. **Rule 102 eight-day language:** Rule 11.1 separately says money must be distributed to creditors within eight days. It does not say “within eight days after deposit.” PASS-04 therefore may not construct a fresh eight-day clock beginning when the deposit occurs or an automatic maximum of two business days plus eight days. [Delaware Regulations](https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml)\n4. **Time computation:** Section 2402A(8) defines “day” as a calendar day, and Rule 102 §1.1 imports that definition. Rule 13.1 excludes the triggering act or event from the count and extends the final day when it falls on a Saturday, Sunday, or Delaware legal holiday. Because the eight-day trigger has not been conclusively fixed, no calendar calculation is made. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe text’s syntax may support treating receipt as the shared event for both Rule 11.1 periods, but that interpretation is **held rather than presented as a controlling judicial or agency construction**. What is established is narrower: the rule supplies no after-deposit anchor and no automatic 2-plus-8 calculation.\n\n### Corrected event-matrix cells\n\n| Event | Operative requirement | Exact timing treatment | Conditions and unresolved facts |\n| --- | --- | --- | --- |\n| **Provider receives money paid by or for the consumer pursuant to a plan for creditor distribution** | Deposit the money in the statutory trust account | **Within two business days after receipt** | Finality is not an express deposit prerequisite. The legal/factual moment of receipt for an ACH, check, card payment, provisional credit, reversal, or return remains held. |\n| **Rule 102 creditor-distribution requirement** | Money governed by Rule 11.1 must be distributed to creditors within eight days; §2422A(c)(2) also requires agreement-consistent disbursement | **No new eight-day clock after deposit is established.** Exact eight-day trigger and interaction remain held; Rule 13.1 governs computation only after the trigger is identified | Creditor payment may be delayed to the extent the consumer payment is not final. Regular periodic disbursements must meet creditor due dates. No holiday or calendar application is performed. |\n\nThese replacements are supported by §§2402A(8), 2422A(a), (c)(2), and Rules 1.1, 11.1, and 13.1. [Delaware Code+4](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### Effect on the saved examples\n\nPASS-04 Examples E01 and E03 remain numerically and conditionally unchanged:\n\n- **E01:** The $250 current balance calculation remains valid under its stated cleared-receipt and completed-remittance assumptions. A snapshot on “business day 6” does not, standing alone, prove that any creditor payment was late because this correction does not establish the eight-day trigger or perform a calendar calculation.\n- **E03:** The distinction between $300 cleared and $800 provisional remains valid. Section 2422A(c)(2)(A) expressly bears on delaying creditor disbursement for a nonfinal payment; PASS-05 does not decide when the provisional $800 was legally “received” for the separate deposit obligation.\n\nNo arithmetic was rerun.\n\n### B. Thirty-day cancellation right versus refund timing\n\nSection 2420A(a) creates:\n\n- an ordinary cancellation right before midnight of the third business day after assent; and\n- an extended right to cancel within 30 days after assent if the agreement fails to comply with §2420A(b), §2419A, or §2428A.\n\nThe 30-day period specifies **when cancellation may be exercised**. It does not state that the provider has 30 days to refund money, nor does it state that the refund must be completed within the same 30-day period. [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\nThe mandatory form says that cancellation during the ordinary three-day period results in refund of all money already paid to the provider, but that clause likewise supplies no separate numerical refund deadline. Section 2427A(a)(1) requires an accounting upon cancellation or termination. Sections 2422A(h) and 2426A contain “promptly” and “immediately” return duties, respectively, but only when their separate termination or plan-failure conditions are present. [Delaware Code+2](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### Corrected return-matrix cell\n\n| Event | Money or accounting consequence | Corrected timing | Conditions and unresolved points |\n| --- | --- | --- | --- |\n| **Extended cancellation for an agreement that fails §2420A(b), §2419A, or §2428A** | Section 2420A(a) extends the cancellation right; §2427A(a)(1) requires an accounting upon cancellation. Any principal return or fee refund under another clause depends on that clause’s independent predicates | **Cancellation notice may be given within 30 days after assent. Section 2420A does not state a numerical refund deadline for this branch** | No automatic application of §2426A’s immediate termination return or §2422A(h)’s prompt termination/failed-plan refund unless the corresponding predicate is separately satisfied. No blanket clawback of completed lawful creditor remittances is inferred. Actual agreement compliance, notice, waiver, funds status, and fee history remain held. |\n\nThe emergency-waiver conditions remain unchanged: a personal financial emergency must necessitate creditor disbursement before expiration of the three-day period; the consumer must send or deliver a signed, dated statement in the consumer’s own words describing the circumstances and explicitly waiving cancellation; a standard-form waiver is void. No conclusion is made about any actual waiver or its effect on a separately arising extended right for a deficient agreement. [Delaware Code](https://delcode.delaware.gov/title6/c024a/index.html)\n\n### C. Federal summary precision\n\nFor an actually covered debt-relief service, the corrected federal sequence is:\n\n1. The seller or telemarketer must have renegotiated, settled, reduced, or otherwise altered at least one debt pursuant to a settlement agreement, debt-management plan, or other valid contractual agreement **executed by the customer**.\n2. The customer must have made at least one payment pursuant to that agreement **between the customer and the creditor or debt collector**.\n3. For debts altered individually, the fee must use either:the enrolled-balance proportional method; ora savings percentage that remains constant from debt to debt, with savings calculated from the enrolled amount and the amount actually paid to satisfy the debt. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe saved C022 reference to compliance with all §310.4(a)(5)(i)(A)–(C) conditions was not false; the PASS-04 narrative shorthand is replaced with the more exact predicates above.\n\nFor a dedicated account, the affected referral condition is:\n\nThe administrator does not give or accept money or other compensation in exchange for referrals of business involving the debt-relief service.\n\nIt is not limited to reciprocal or direct payments between the administrator and the provider. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### Corrected account/model-matrix cell\n\n| Account or administrator model | State classification retained | Corrected conditional federal overlay | Material unresolved facts |\n| --- | --- | --- | --- |\n| **Purportedly independent dedicated-account administrator** | The label “independent” does not establish Delaware noncustody, administrator exemption, or lawful account control | If the TSR applies, the administrator must not be owned or controlled by, or affiliated in any way with, the debt-relief service; it also must not **give or accept any money or other compensation in exchange for referrals of business involving the debt-relief service** | Actual ownership, control, affiliates, compensation recipients and payors, referral arrangements, account documents, ACH powers, and TSR coverage |\n\nThe other dedicated-account conditions—insured financial institution, customer ownership and interest, withdrawal without penalty, and seven-business-day return of funds other than properly earned fees—remain unchanged. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nPASS-04 Example E05 remains exactly conditional: no fee is assumed earned, no interest or pending item exists, and the stated remaining $700 is returned within seven business days if all applicable federal conditions and coverage predicates are satisfied. No calculation was rerun.\n\n## 3. Corrective claim table\n\n| New corrective claim ID | Stable P4 claim affected | Precise corrected assertion | Source pinpoints | Conditions and confidence limits |\n| --- | --- | --- | --- | --- |\n| **S_DE-P5-C001** | **S_DE-P4-C008** | Section 2422A(a) and Rule 11.1 require deposit within two business days after receipt of plan money; neither makes payment finality an express deposit prerequisite. The nonfinal-payment exception is a creditor-disbursement exception under §2422A(c)(2)(A). | S_DE-P4-S001, §§2422A(a), (c)(2)(A); S_DE-P4-S003, Rule 11.1 | Statutory and rule text verified. Exact “receipt” for a particular payment rail remains unresolved. [Delaware Code+1](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **S_DE-P5-C002** | **S_DE-P4-C008** | Rule 11.1 requires distribution within eight days but does not create an eight-day period beginning after deposit. No automatic two-business-day-plus-eight-day period is established. The exact eight-day trigger is held. | S_DE-P4-S003, Rules 1.1, 11.1, 13.1; S_DE-P4-S001, §2402A(8) | Text verified; no controlling judicial or formal agency interpretation of the anchor was established. No calendar computation performed. [Delaware Code+3](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **S_DE-P5-C003** | **S_DE-P4-C019** | The 30-day language in §2420A(a) is the period to exercise an extended cancellation right for a deficient agreement, not an express refund deadline. Cancellation requires an accounting; separate immediate or prompt return duties apply only if their own predicates are satisfied. | S_DE-P4-S001, §§2419A(d), 2420A(a)–(c), 2422A(h), 2426A, 2427A(a)(1) | Text verified. No actual contract, waiver, cancellation notice, termination, plan failure, remittance, or fee is assessed. [Delaware Code+3](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **S_DE-P5-C004** | **S_DE-P4-C022** | Federal fee earning requires a qualifying agreement executed by the customer, at least one customer payment under that agreement between the customer and creditor or debt collector, and the applicable enrolled-balance proportional or consistent-savings allocation predicate. | S_DE-P4-S008, §310.4(a)(5)(i)(A)–(C) | Federal text verified; actual TSR coverage and transaction facts remain held. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_DE-P5-C005** | **S_DE-P4-C022** | A dedicated-account administrator may not give or accept money or other compensation in exchange for referrals of business involving the debt-relief service; the restriction is not confined to direct administrator-provider exchanges. | S_DE-P4-S008, §310.4(a)(5)(ii)(D) | Federal text verified; actual affiliation, compensation, referral, and administrator facts remain held. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n## 4. Corrected source/version usage cells\n\nNo new source document was required, so no duplicative **S_DE-P5-S001+** source IDs are created. The existing PASS-04 document IDs are reused.\n\n| Existing source ID | Title, issuer, and exact literal URL | Exact P5 provisions read | Version/effective and actual-access status | Limits |\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(8); 2419A(d), (g); 2420A(a)–(c); 2422A(a), (c)(2), (h); 2426A; 2427A(a) | Official current online codification; **freshly read in PASS-05 on October 25, 2026 Pacific / October 26 UTC** | Complete amendment-chain audit remains held. No actual contract, payment, cancellation, termination, or account facts were reviewed. [Delaware Code+4](https://delcode.delaware.gov/title6/c024a/index.html) |\n| **S_DE-P4-S003** | Delaware Regulations, readable official Administrative Code snapshot, **6 Del. Admin. C. 102**. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml | Rules 1.1, 11.1, and 13.1 | Official readable page marked **Last Updated February 11, 2025**; **freshly read in PASS-05** | Full 2026 Rule 102 amendment history and current certification remain held. The previously failed current-rule endpoints are not retroactively treated as successful. Rule 13.1 does not resolve which event begins the Rule 11.1 eight-day period. [Delaware Regulations+2](https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml) |\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)(C)–(E) | eCFR displayed Title 16 as up to date through **October 22, 2026**; **freshly read in PASS-05** | eCFR is authoritative but unofficial. Actual TSR coverage, customer execution, creditor agreement, payment, administrator independence, referral compensation, and fee earning remain unresolved. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n**S_DE-P4-S004**, the 2010 final order, was not needed or freshly reread for these corrections. Its historical status remains unchanged: it is not treated as proof that every displayed Rule 102 clause was first adopted in 2010 or that no later amendment exists.\n\n## 5. Focused coverage patch\n\n| Affected PASS-04 component | Corrected status | Corrective claims | Remaining exact evidence or next action |\n| --- | --- | --- | --- |\n| **Two-business-day deposit** | **Answered at text level with corrected trigger** | P5-C001 | Determine actual receipt under the bank, ACH, check, card, processor, and account contracts. No finality prerequisite is imported from §2422A(c)(2)(A). |\n| **Eight-day creditor distribution** | **Partial / anchor unresolved** | P5-C002 | Locate controlling court authority, formal Attorney General interpretation, or complete rulemaking explanation fixing the eight-day trigger and interaction. No after-deposit clock or automatic 2+8 construction is used. |\n| **Rule 13.1 computation** | **Answered only as general method** | P5-C002 | Apply only after the triggering act or event is established. No actual calendar, weekend, holiday, or mailing computation performed. |\n| **Pending ACH, check, or reversal** | **Partial; prior hold preserved** | P5-C001, P5-C002 | Distinguish statutory receipt from creditor-payment finality using actual payment-rail and bank documents. PASS-04 E03 remains conditional. |\n| **Thirty-day deficient-agreement cancellation** | **Cancellation window answered; refund deadline unresolved under §2420A itself** | P5-C003 | Review actual agreement defect, assent date, notice, delivery, waiver, cancellation, termination, and account facts. Apply §§2422A(h) or 2426A only when their separate predicates exist. |\n| **Cancellation accounting** | **Answered at statutory level** | P5-C003 | Actual accounting contents and delivery remain unreviewed. |\n| **Completed creditor remittances following cancellation** | **No blanket clawback established** | P5-C003 | Trace actual completed lawful payments, current trust balance, pending items, and any separately available remedy. Full remedies remain excluded. |\n| **Federal debt-specific fee predicates** | **Exact wording corrected; operational application unresolved** | P5-C004 | Establish actual TSR coverage, customer execution, customer-creditor/debt-collector agreement, first payment, enrolled balances, actual satisfaction payments, and one consistent allocation method. |\n| **Federal administrator referral restriction** | **Exact wording corrected; entity application unresolved** | P5-C005 | Obtain ownership/control/affiliate data and every compensation or referral arrangement involving the administrator and debt-relief-service business. |\n| **Federal seven-business-day return example** | **Unchanged and conditional** | P5-C004, P5-C005 | PASS-04 E05’s $700 result remains under its express assumptions; no fee, interest, pending item, coverage, or account fact is newly established. |\n\n## 6. Preserved examples and holds\n\nAll six PASS-04 ledger examples remain numerically unchanged:\n\n- **E01:** $250 current balance; prior creditor payments are not subtracted twice.\n- **E02:** $20 reconciliation shortage; no consumer-ledger write-down authorization.\n- **E03:** $300 cleared and $800 provisional; receipt and finality remain unresolved.\n- **E04:** unproven $100 fee is not deducted; $800 conditional return remains.\n- **E05:** conditional $700 federal dedicated-account return within seven business days.\n- **E06:** five-day creditor-rejection notice does not itself terminate the agreement; $300 return follows only upon the assumed termination.\n\nNo PASS-01 fee example, PASS-04 ledger arithmetic, proportional allocation, lawful fee, interest amount, pending item, deadline calendar, insurance result, priority rule, or remitted-creditor clawback was recalculated or invented.\n\nThe following remain expressly open:\n\n- complete 2026 Regulation 102 history and certification;\n- indexed fee amounts and Attorney General approvals;\n- provider and administrator authorization;\n- actual account, bank, ACH, processor, and referral contracts;\n- actual receipt, finality, fee earning, prior credits, and fee deductibility;\n- insurance and federal deposit-insurance treatment;\n- bankruptcy and receivership priority;\n- complete agreements, waivers, bonds, remedies, collections, courts, limitations, and secured-sector law;\n- money-transmission implementation, existing-licensee, delegate, and transition questions;\n- local, tribal, country, and seven parent-dimension work.\n\nNothing in PASS-05 constitutes component, Delaware-state, parent, A066, operational, or publication acceptance.\n\n## 7. Researcher self-check\n\n### Freshly read\n\n- Current Chapter 24A definitions and the complete relevant deposit, disbursement, cancellation, waiver, termination, accounting, and return paragraphs at the literal Delaware Code URL.\n- Rule 102 §§1.1, 11.1, and 13.1 at the materially different readable official route.\n- The complete relevant federal §310.4(a)(5)(i)(A)–(C) and (ii)(C)–(E) clauses.\n\n### Reused without rerunning\n\n- Every PASS-04 account classification, unaffected source, money-transmission finding, ledger example, numerical result, and coverage hold.\n- The historical 2007 deletion and 2006 enactment work concerning the orphaned overdraft cross-reference.\n- PASS-02’s fee, prior-credit, counseling, and adjustment qualifications.\n- PASS-03’s provenance correction.\n\n### Not read or not performed in PASS-05\n\n- The historical 2010 final order was not freshly reread and is not claimed to be the first adoption of every Rule 102 clause.\n- Previously failed Rule 102 endpoints were not retried or recharacterized.\n- No new Chapter 23 money-transmission research or implementation-notice conclusion was performed.\n- No provider, administrator, contract, consumer account, bank record, ACH record, court case, private data, application, filing, or fee history was reviewed.\n- No exact individual source-fetch timestamp is claimed.\n- No Deep Research, Work mode, Codex research generation, API, Chrome control, new tab, other Chat, purchase, account change, filing, contact, site change, local write, or publication action was used.\n\nThis is a bounded same-coordinator precision correction, **not independent review** or publication readiness.\n\n**END S_DE PASS-05**\n\n","tables":[{"headers":["P4 location / stable ID","Old PASS-04 wording","Precise replacement","Authority and limitation"],"index":0,"links":[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+1"},{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"},{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],"row_links":[[],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+1"}],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"}],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}]],"rows":[["P4 location / stable ID","Old PASS-04 wording","Precise replacement","Authority and limitation"],["A.2 event matrix, first row; S_DE-P4-C008","“Provider receives final money under a plan for creditor distribution” followed by deposit within two business days","All money paid to a provider by or on behalf of an individual pursuant to a plan for distribution to creditors is held in trust, and the provider must deposit that money within two business days after receipt. Neither §2422A(a) nor Rule 102 §11.1 makes “final money” an express prerequisite to the deposit duty. The nonfinal-payment exception appears instead in §2422A(c)(2)(A) and permits delay of payment to creditors to the extent the individual’s payment is not final. The actual moment of “receipt” for a provisional ACH, check, card payment, return, or reversal remains fact- and contract-dependent.","6 Del. C. §2422A(a), (c)(2)(A); Rule 102 §11.1. \nDelaware Code\n+1"],["A.2 event matrix, second row; S_DE-P4-C008","“Money has been deposited for creditor distribution” followed by distribution within eight days","Rule 102 §11.1 states that the money must be distributed to creditors within eight days, but it does not state that a new eight-day period begins after deposit. The text therefore does not support an automatic “two business days plus eight more days” construction. The only expressly stated event in the sentence is receipt, but because the phrase “within eight days” does not repeat its anchor and no controlling interpretation was established, the precise start and interaction of the eight-day period remain held. Rule 13.1 supplies computation rules once the triggering act or event is identified; it does not itself identify that trigger.","Rule 102 §§1.1, 11.1, 13.1; 6 Del. C. §2402A(8). No calendar or holiday computation is made. \nDelaware Code\n+3"],["A.4 return-mechanics matrix, extended-cancellation row; S_DE-P4-C019","Timing: “Within the statutory cancellation period”","The consumer may exercise the extended cancellation right within 30 days after assent when the agreement fails to comply with §2420A(b), §2419A, or §2428A. The 30 days is a cancellation-notice window, not an express refund deadline. Section 2420A does not state a numerical deadline for completing the resulting refund. Section 2427A(a)(1) separately requires an accounting upon cancellation. Any immediate or prompt return duty under §§2426A or 2422A(h) applies only when that provision’s separate termination or plan-failure predicate is met.","6 Del. C. §§2419A(d), (g), 2420A(a)–(c), 2422A(h), 2426A, 2427A(a)(1). No actual agreement, waiver, notice, or completed creditor payment is adjudicated. \nDelaware Code\n+2"],["A.6 federal fee-trigger narrative; S_DE-P4-C022","“Valid executed agreement” and “consumer has made at least one payment under that agreement”","For a covered debt-relief service, §310.4(a)(5)(i)(A) requires a qualifying settlement agreement, debt-management plan, or other valid contractual agreement executed by the customer. Subparagraph (B) requires the customer to make at least one payment pursuant to that agreement between the customer and the creditor or debt collector. These are distinct predicates and must both be satisfied.","16 C.F.R. §310.4(a)(5)(i)(A)–(B). Actual TSR coverage, execution, creditor assent, and payment remain unverified. \neCFR"],["A.6 federal allocation narrative; S_DE-P4-C022","General reference to proportional allocation or a consistent savings method","For debts altered individually, subparagraph (C) requires either: (1) the same proportional relationship between the individual-debt fee and total program fee as the individual debt amount bears to the entire debt amount, using amounts owed when enrolled; or (2) a percentage of savings that does not change from one individual debt to another, with savings measured as the enrolled amount minus the amount actually paid to satisfy that debt.","16 C.F.R. §310.4(a)(5)(i)(C)(1)–(2). No actual fee, enrolled balance, satisfaction payment, or allocation is validated. \neCFR"],["A.6 dedicated-account item 4 and affected administrator matrix cell; S_DE-P4-C022","“The administrator and debt-relief service do not exchange compensation for referrals”","The account administrator must not give or accept any money or other compensation in exchange for referrals of business involving the debt-relief service. This is not limited to a direct exchange between the administrator and the debt-relief provider.","16 C.F.R. §310.4(a)(5)(ii)(D). Actual ownership, control, affiliation, referral, and compensation relationships remain held. \neCFR"]]},{"headers":["Event","Operative requirement","Exact timing treatment","Conditions and unresolved facts"],"index":1,"links":[],"row_links":[[],[],[]],"rows":[["Event","Operative requirement","Exact timing treatment","Conditions and unresolved facts"],["Provider receives money paid by or for the consumer pursuant to a plan for creditor distribution","Deposit the money in the statutory trust account","Within two business days after receipt","Finality is not an express deposit prerequisite. The legal/factual moment of receipt for an ACH, check, card payment, provisional credit, reversal, or return remains held."],["Rule 102 creditor-distribution requirement","Money governed by Rule 11.1 must be distributed to creditors within eight days; §2422A(c)(2) also requires agreement-consistent disbursement","No new eight-day clock after deposit is established. Exact eight-day trigger and interaction remain held; Rule 13.1 governs computation only after the trigger is identified","Creditor payment may be delayed to the extent the consumer payment is not final. Regular periodic disbursements must meet creditor due dates. No holiday or calendar application is performed."]]},{"headers":["Event","Money or accounting consequence","Corrected timing","Conditions and unresolved points"],"index":2,"links":[],"row_links":[[],[]],"rows":[["Event","Money or accounting consequence","Corrected timing","Conditions and unresolved points"],["Extended cancellation for an agreement that fails §2420A(b), §2419A, or §2428A","Section 2420A(a) extends the cancellation right; §2427A(a)(1) requires an accounting upon cancellation. Any principal return or fee refund under another clause depends on that clause’s independent predicates","Cancellation notice may be given within 30 days after assent. Section 2420A does not state a numerical refund deadline for this branch","No automatic application of §2426A’s immediate termination return or §2422A(h)’s prompt termination/failed-plan refund unless the corresponding predicate is separately satisfied. No blanket clawback of completed lawful creditor remittances is inferred. Actual agreement compliance, notice, waiver, funds status, and fee history remain held."]]},{"headers":["Account or administrator model","State classification retained","Corrected conditional federal overlay","Material unresolved facts"],"index":3,"links":[],"row_links":[[],[]],"rows":[["Account or administrator model","State classification retained","Corrected conditional federal overlay","Material unresolved facts"],["Purportedly independent dedicated-account administrator","The label “independent” does not establish Delaware noncustody, administrator exemption, or lawful account control","If the TSR applies, the administrator must not be owned or controlled by, or affiliated in any way with, the debt-relief service; it also must not give or accept any money or other compensation in exchange for referrals of business involving the debt-relief service","Actual ownership, control, affiliates, compensation recipients and payors, referral arrangements, account documents, ACH powers, and TSR coverage"]]},{"headers":["New corrective claim ID","Stable P4 claim affected","Precise corrected assertion","Source pinpoints","Conditions and confidence limits"],"index":4,"links":[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+1"},{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"},{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],"row_links":[[],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+1"}],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"}],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+3"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}]],"rows":[["New corrective claim ID","Stable P4 claim affected","Precise corrected assertion","Source pinpoints","Conditions and confidence limits"],["S_DE-P5-C001","S_DE-P4-C008","Section 2422A(a) and Rule 11.1 require deposit within two business days after receipt of plan money; neither makes payment finality an express deposit prerequisite. The nonfinal-payment exception is a creditor-disbursement exception under §2422A(c)(2)(A).","S_DE-P4-S001, §§2422A(a), (c)(2)(A); S_DE-P4-S003, Rule 11.1","Statutory and rule text verified. Exact “receipt” for a particular payment rail remains unresolved. \nDelaware Code\n+1"],["S_DE-P5-C002","S_DE-P4-C008","Rule 11.1 requires distribution within eight days but does not create an eight-day period beginning after deposit. No automatic two-business-day-plus-eight-day period is established. The exact eight-day trigger is held.","S_DE-P4-S003, Rules 1.1, 11.1, 13.1; S_DE-P4-S001, §2402A(8)","Text verified; no controlling judicial or formal agency interpretation of the anchor was established. No calendar computation performed. \nDelaware Code\n+3"],["S_DE-P5-C003","S_DE-P4-C019","The 30-day language in §2420A(a) is the period to exercise an extended cancellation right for a deficient agreement, not an express refund deadline. Cancellation requires an accounting; separate immediate or prompt return duties apply only if their own predicates are satisfied.","S_DE-P4-S001, §§2419A(d), 2420A(a)–(c), 2422A(h), 2426A, 2427A(a)(1)","Text verified. No actual contract, waiver, cancellation notice, termination, plan failure, remittance, or fee is assessed. \nDelaware Code\n+3"],["S_DE-P5-C004","S_DE-P4-C022","Federal fee earning requires a qualifying agreement executed by the customer, at least one customer payment under that agreement between the customer and creditor or debt collector, and the applicable enrolled-balance proportional or consistent-savings allocation predicate.","S_DE-P4-S008, §310.4(a)(5)(i)(A)–(C)","Federal text verified; actual TSR coverage and transaction facts remain held. \neCFR"],["S_DE-P5-C005","S_DE-P4-C022","A dedicated-account administrator may not give or accept money or other compensation in exchange for referrals of business involving the debt-relief service; the restriction is not confined to direct administrator-provider exchanges.","S_DE-P4-S008, §310.4(a)(5)(ii)(D)","Federal text verified; actual affiliation, compensation, referral, and administrator facts remain held. \neCFR"]]},{"headers":["Existing source ID","Title, issuer, and exact literal URL","Exact P5 provisions read","Version/effective and actual-access status","Limits"],"index":5,"links":[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+4"},{"href":"https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","text":"Delaware Regulations\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],"row_links":[[],[{"href":"https://delcode.delaware.gov/title6/c024a/index.html","text":"Delaware Code\n+4"}],[{"href":"https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","text":"Delaware Regulations\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}]],"rows":[["Existing source ID","Title, issuer, and exact literal URL","Exact P5 provisions read","Version/effective and actual-access status","Limits"],["S_DE-P4-S001","Delaware General Assembly, Title 6, Chapter 24A — Debt-Management Services. https://delcode.delaware.gov/title6/c024a/index.html","§§2402A(8); 2419A(d), (g); 2420A(a)–(c); 2422A(a), (c)(2), (h); 2426A; 2427A(a)","Official current online codification; freshly read in PASS-05 on October 25, 2026 Pacific / October 26 UTC","Complete amendment-chain audit remains held. No actual contract, payment, cancellation, termination, or account facts were reviewed. \nDelaware Code\n+4"],["S_DE-P4-S003","Delaware Regulations, readable official Administrative Code snapshot, 6 Del. Admin. C. 102. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","Rules 1.1, 11.1, and 13.1","Official readable page marked Last Updated February 11, 2025; freshly read in PASS-05","Full 2026 Rule 102 amendment history and current certification remain held. The previously failed current-rule endpoints are not retroactively treated as successful. Rule 13.1 does not resolve which event begins the Rule 11.1 eight-day period. \nDelaware Regulations\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)(C)–(E)","eCFR displayed Title 16 as up to date through October 22, 2026; freshly read in PASS-05","eCFR is authoritative but unofficial. Actual TSR coverage, customer execution, creditor agreement, payment, administrator independence, referral compensation, and fee earning remain unresolved. \neCFR\n+1"]]},{"headers":["Affected PASS-04 component","Corrected status","Corrective claims","Remaining exact evidence or next action"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Affected PASS-04 component","Corrected status","Corrective claims","Remaining exact evidence or next action"],["Two-business-day deposit","Answered at text level with corrected trigger","P5-C001","Determine actual receipt under the bank, ACH, check, card, processor, and account contracts. No finality prerequisite is imported from §2422A(c)(2)(A)."],["Eight-day creditor distribution","Partial / anchor unresolved","P5-C002","Locate controlling court authority, formal Attorney General interpretation, or complete rulemaking explanation fixing the eight-day trigger and interaction. No after-deposit clock or automatic 2+8 construction is used."],["Rule 13.1 computation","Answered only as general method","P5-C002","Apply only after the triggering act or event is established. No actual calendar, weekend, holiday, or mailing computation performed."],["Pending ACH, check, or reversal","Partial; prior hold preserved","P5-C001, P5-C002","Distinguish statutory receipt from creditor-payment finality using actual payment-rail and bank documents. PASS-04 E03 remains conditional."],["Thirty-day deficient-agreement cancellation","Cancellation window answered; refund deadline unresolved under §2420A itself","P5-C003","Review actual agreement defect, assent date, notice, delivery, waiver, cancellation, termination, and account facts. Apply §§2422A(h) or 2426A only when their separate predicates exist."],["Cancellation accounting","Answered at statutory level","P5-C003","Actual accounting contents and delivery remain unreviewed."],["Completed creditor remittances following cancellation","No blanket clawback established","P5-C003","Trace actual completed lawful payments, current trust balance, pending items, and any separately available remedy. Full remedies remain excluded."],["Federal debt-specific fee predicates","Exact wording corrected; operational application unresolved","P5-C004","Establish actual TSR coverage, customer execution, customer-creditor/debt-collector agreement, first payment, enrolled balances, actual satisfaction payments, and one consistent allocation method."],["Federal administrator referral restriction","Exact wording corrected; entity application unresolved","P5-C005","Obtain ownership/control/affiliate data and every compensation or referral arrangement involving the administrator and debt-relief-service business."],["Federal seven-business-day return example","Unchanged and conditional","P5-C004, P5-C005","PASS-04 E05’s $700 result remains under its express assumptions; no fee, interest, pending item, coverage, or account fact is newly established."]]}],"claims":[{"claim_id":"S_DE-P5-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"New corrective claim ID":"S_DE-P5-C001","Stable P4 claim affected":"S_DE-P4-C008","Precise corrected assertion":"Section 2422A(a) and Rule 11.1 require deposit within two business days after receipt of plan money; neither makes payment finality an express deposit prerequisite. The nonfinal-payment exception is a creditor-disbursement exception under §2422A(c)(2)(A).","Source pinpoints":"S_DE-P4-S001, §§2422A(a), (c)(2)(A); S_DE-P4-S003, Rule 11.1","Conditions and confidence limits":"Statutory and rule text verified. Exact “receipt” for a particular payment rail remains unresolved. \nDelaware Code\n+1"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_DE-P5-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"New corrective claim ID":"S_DE-P5-C002","Stable P4 claim affected":"S_DE-P4-C008","Precise corrected assertion":"Rule 11.1 requires distribution within eight days but does not create an eight-day period beginning after deposit. No automatic two-business-day-plus-eight-day period is established. The exact eight-day trigger is held.","Source pinpoints":"S_DE-P4-S003, Rules 1.1, 11.1, 13.1; S_DE-P4-S001, §2402A(8)","Conditions and confidence limits":"Text verified; no controlling judicial or formal agency interpretation of the anchor was established. No calendar computation performed. \nDelaware Code\n+3"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_DE-P5-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"New corrective claim ID":"S_DE-P5-C003","Stable P4 claim affected":"S_DE-P4-C019","Precise corrected assertion":"The 30-day language in §2420A(a) is the period to exercise an extended cancellation right for a deficient agreement, not an express refund deadline. Cancellation requires an accounting; separate immediate or prompt return duties apply only if their own predicates are satisfied.","Source pinpoints":"S_DE-P4-S001, §§2419A(d), 2420A(a)–(c), 2422A(h), 2426A, 2427A(a)(1)","Conditions and confidence limits":"Text verified. No actual contract, waiver, cancellation notice, termination, plan failure, remittance, or fee is assessed. \nDelaware Code\n+3"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_DE-P5-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"New corrective claim ID":"S_DE-P5-C004","Stable P4 claim affected":"S_DE-P4-C022","Precise corrected assertion":"Federal fee earning requires a qualifying agreement executed by the customer, at least one customer payment under that agreement between the customer and creditor or debt collector, and the applicable enrolled-balance proportional or consistent-savings allocation predicate.","Source pinpoints":"S_DE-P4-S008, §310.4(a)(5)(i)(A)–(C)","Conditions and confidence limits":"Federal text verified; actual TSR coverage and transaction facts remain held. \neCFR"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_DE-P5-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"New corrective claim ID":"S_DE-P5-C005","Stable P4 claim affected":"S_DE-P4-C022","Precise corrected assertion":"A dedicated-account administrator may not give or accept money or other compensation in exchange for referrals of business involving the debt-relief service; the restriction is not confined to direct administrator-provider exchanges.","Source pinpoints":"S_DE-P4-S008, §310.4(a)(5)(ii)(D)","Conditions and confidence limits":"Federal text verified; actual affiliation, compensation, referral, and administrator facts remain held. \neCFR"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"sources":[{"source_id":"S_DE-P4-S001","urls":["https://delcode.delaware.gov/title6/c024a/index.html"],"researcher_record":{"Existing source ID":"S_DE-P4-S001","Title, issuer, and exact literal URL":"Delaware General Assembly, Title 6, Chapter 24A — Debt-Management Services. https://delcode.delaware.gov/title6/c024a/index.html","Exact P5 provisions read":"§§2402A(8); 2419A(d), (g); 2420A(a)–(c); 2422A(a), (c)(2), (h); 2426A; 2427A(a)","Version/effective and actual-access status":"Official current online codification; freshly read in PASS-05 on October 25, 2026 Pacific / October 26 UTC","Limits":"Complete amendment-chain audit remains held. No actual contract, payment, cancellation, termination, or account facts were reviewed. \nDelaware Code\n+4"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_DE-P4-S003","urls":["https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml"],"researcher_record":{"Existing source ID":"S_DE-P4-S003","Title, issuer, and exact literal URL":"Delaware Regulations, readable official Administrative Code snapshot, 6 Del. Admin. C. 102. https://archive.regulations.delaware.gov/AdminCode/title6/Fraud/100/102.shtml","Exact P5 provisions read":"Rules 1.1, 11.1, and 13.1","Version/effective and actual-access status":"Official readable page marked Last Updated February 11, 2025; freshly read in PASS-05","Limits":"Full 2026 Rule 102 amendment history and current certification remain held. The previously failed current-rule endpoints are not retroactively treated as successful. Rule 13.1 does not resolve which event begins the Rule 11.1 eight-day period. \nDelaware Regulations\n+2"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","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":{"Existing source ID":"S_DE-P4-S008","Title, issuer, and exact 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 P5 provisions read":"§310.4(a)(5)(i)(A)–(C), (ii)(C)–(E)","Version/effective and actual-access status":"eCFR displayed Title 16 as up to date through October 22, 2026; freshly read in PASS-05","Limits":"eCFR is authoritative but unofficial. Actual TSR coverage, customer execution, creditor agreement, payment, administrator independence, referral compensation, and fee earning remain unresolved. \neCFR\n+1"},"coordinator_verification_status":"checked_against_explicitly_reused_actual_DE4_primary_passages","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"coverage":[{"topic":"Two-business-day deposit","researcher_record":{"Affected PASS-04 component":"Two-business-day deposit","Corrected status":"Answered at text level with corrected trigger","Corrective claims":"P5-C001","Remaining exact evidence or next action":"Determine actual receipt under the bank, ACH, check, card, processor, and account contracts. No finality prerequisite is imported from §2422A(c)(2)(A)."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Eight-day creditor distribution","researcher_record":{"Affected PASS-04 component":"Eight-day creditor distribution","Corrected status":"Partial / anchor unresolved","Corrective claims":"P5-C002","Remaining exact evidence or next action":"Locate controlling court authority, formal Attorney General interpretation, or complete rulemaking explanation fixing the eight-day trigger and interaction. No after-deposit clock or automatic 2+8 construction is used."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Rule 13.1 computation","researcher_record":{"Affected PASS-04 component":"Rule 13.1 computation","Corrected status":"Answered only as general method","Corrective claims":"P5-C002","Remaining exact evidence or next action":"Apply only after the triggering act or event is established. No actual calendar, weekend, holiday, or mailing computation performed."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Pending ACH, check, or reversal","researcher_record":{"Affected PASS-04 component":"Pending ACH, check, or reversal","Corrected status":"Partial; prior hold preserved","Corrective claims":"P5-C001, P5-C002","Remaining exact evidence or next action":"Distinguish statutory receipt from creditor-payment finality using actual payment-rail and bank documents. PASS-04 E03 remains conditional."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Thirty-day deficient-agreement cancellation","researcher_record":{"Affected PASS-04 component":"Thirty-day deficient-agreement cancellation","Corrected status":"Cancellation window answered; refund deadline unresolved under §2420A itself","Corrective claims":"P5-C003","Remaining exact evidence or next action":"Review actual agreement defect, assent date, notice, delivery, waiver, cancellation, termination, and account facts. Apply §§2422A(h) or 2426A only when their separate predicates exist."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Cancellation accounting","researcher_record":{"Affected PASS-04 component":"Cancellation accounting","Corrected status":"Answered at statutory level","Corrective claims":"P5-C003","Remaining exact evidence or next action":"Actual accounting contents and delivery remain unreviewed."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Completed creditor remittances following cancellation","researcher_record":{"Affected PASS-04 component":"Completed creditor remittances following cancellation","Corrected status":"No blanket clawback established","Corrective claims":"P5-C003","Remaining exact evidence or next action":"Trace actual completed lawful payments, current trust balance, pending items, and any separately available remedy. Full remedies remain excluded."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Federal debt-specific fee predicates","researcher_record":{"Affected PASS-04 component":"Federal debt-specific fee predicates","Corrected status":"Exact wording corrected; operational application unresolved","Corrective claims":"P5-C004","Remaining exact evidence or next action":"Establish actual TSR coverage, customer execution, customer-creditor/debt-collector agreement, first payment, enrolled balances, actual satisfaction payments, and one consistent allocation method."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Federal administrator referral restriction","researcher_record":{"Affected PASS-04 component":"Federal administrator referral restriction","Corrected status":"Exact wording corrected; entity application unresolved","Corrective claims":"P5-C005","Remaining exact evidence or next action":"Obtain ownership/control/affiliate data and every compensation or referral arrangement involving the administrator and debt-relief-service business."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Federal seven-business-day return example","researcher_record":{"Affected PASS-04 component":"Federal seven-business-day return example","Corrected status":"Unchanged and conditional","Corrective claims":"P5-C004, P5-C005","Remaining exact evidence or next action":"PASS-04 E05’s $700 result remains under its express assumptions; no fee, interest, pending item, coverage, or account fact is newly established."},"coordinator_acceptance":"accepted_with_limits_for_exact_bounded_correction_only","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}