{"meta":{"key":"s_ia--pass-01","task":"S_IA","title":"SIA — Iowa Debt Management, Debt Settlement & Consumer Fees","parent_title":"Iowa debt and debt relief law","edition":"pass-01","path":"/research/s_ia--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":7,"claims":25,"sources":10,"review_status":"revise","review_complete":true,"sha256":"cdc4c3768849c767f1f8022c4c64e8b9a2358226985292740241fc0ad9dc2648","headings":["1. Executive findings","Preliminary business-model classification","2. Substantive findings: classification and market access","2.1 What constitutes debt management?","2.2 Licensing and exemptions","2.3 Program obligations relevant to fee permission","3. Iowa consumer fee architecture","3.1 Statutory fee matrix","3.2 Cancellation and refund provisions","3.3 Currentness and indexing","4. Fee collection timing: state versus federal","5. Regulatory access, licensing procedure and rulemaking","5.1 Actual public licensing route","5.2 Important 2026 administrative-rule development","5.3 Market-access determination","6. Bounded worked fee examples","Example IA-E01 — Custodial DMP, amounts applied","Example IA-E02 — Noncustodial, low enrolled debt","Example IA-E03 — Percent-of-total-debt, completed partial portfolio","Example IA-E04 — Percent-of-savings, one completed settlement","Example IA-E05 — Savings-based method with prior monthly collections","Example IA-E06 — Cancellation within first 12 months","Example IA-E07 — Cancellation after a completed settlement","7. Source register — S_IA-P1-S001+","8. Claim register — S_IA-P1-C001+","Additional material boundary findings","9. Full PASS-01 component coverage and gaps","10. Exact next investigations","11. Researcher self-check","12. PASS-01 disposition"],"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_IA/pass-01","facets":{"geography":["us","us-ia"],"debt_type":[],"stage":["settlement"],"subject":["counseling-dmp","settlement-negotiation","fees-outcomes"]},"scope":"Fresh Iowaprovider-access/fees component only;allbroader statecategoriesrequired","pending_corrections":0},"markdown":"# S_IA — Iowa Debt Management, Debt Settlement & Consumer Fees\n\nPASS-01 | SettleADebt.com | Provider market access and consumer fees\n\nResearch access date: October 24, 2026, Pacific\nBaseline: October 22, 2026\nJurisdiction: Iowa\nResearch method: Regular Chat, public web browsing, primary statutory sources, administrative materials and federal regulatory text. No Deep Research, Work, Chrome control, external actions or publication.\n\n## 1. Executive findings\n\nIowa has an express licensing framework for debt settlement and other compensated debt-management services. Unlike states that broadly prohibit commercial debt adjusting, Iowa Code chapter 533A provides a licensing route for qualifying providers.\n\nThe important distinction is that Iowa's fee permissions differ substantially depending on whether the provider's program involves receiving and distributing consumer funds. Iowa also has special fee collection, settlement-completion and cancellation provisions that must be reconciled with federal advance-fee restrictions.\n\nPRIMARY STATUTORY FINDINGS — 2026 IOWA CODE\n\nOne-time initiation fee\n\n# $50\n\nMaximum under §533A.9(2)Custodial/distribution model\n\n# 15%\n\nOf amounts actually applied to creditor accounts, plus initiation feeNoncustodial model\n\n# 18%\n\nAggregate additional-fee ceiling based on enrolled debtSavings-based method\n\n# 30%\n\nMaximum contracted savings percentage, subject to the 18% aggregate ceilingThese are state statutory ceilings, not blanket permission to collect fees before providing services. Federal law may independently prohibit advance collection.\n\nThe controlling statute was opened and read in the Iowa Legislature's 2026 chapter PDF and its separately published 2026 §533A.9 PDF. Iowa Legislature+1\n\n### Preliminary business-model classification\n\n| Business model | Iowa treatment | Operational conclusion |\n| --- | --- | --- |\n| For-profit debt settlement/negotiation | Expressly included in debt management | Chapter 533A license generally required |\n| Noncustodial debt settlement | Expressly contemplated | License route; special 18% aggregate ceiling and collection methods |\n| Custodial debt-management plan | Expressly contemplated | License route; 15% applied-funds ceiling |\n| Fee-based credit counseling negotiating concessions | Potentially covered | Activity, not marketing label, controls |\n| Gratuitous nonprofit religious/fraternal/cooperative service | Express conditional exemption | No general nonprofit exemption established |\n| Iowa attorney providing incidental legal services | Express conditional exemption | Iowa admission and incident-to-practice conditions required |\n| Pure education without debt-management activity | Fact-dependent | Classification held |\n| Educational-loan modification services | Expressly included | Additional §533A.8A requirements require separate analysis |\n\nCritical conclusion: The statute establishes a licensing pathway, but does not establish that any particular debt settlement company is currently licensed, that its specific contract is compliant, or that its proposed collection schedule is federally permissible.\n\n## 2. Substantive findings: classification and market access\n\n### 2.1 What constitutes debt management?\n\nS_IA-P1-C001 — Broad, activity-based definition\n\nIowa Code §533A.1(2) defines compensated debt management through five alternative activities:\n\n1. Arranging, negotiating or attempting to negotiate debt amounts or terms.\n2. Receiving money from debtors for distribution to creditors.\n3. Acting as an intermediary to obtain creditor concessions.\n4. Engaging in debt settlement.\n5. Acting as an intermediary to seek modifications of educational-loan terms.\n\nSection 533A.1(3) specifically defines debt settlement by the objective of reducing the amount owed.\n\nThese categories are alternatives, not cumulative requirements. A company does not escape classification simply because it never takes custody of settlement funds.\n\nEvidence: S001, §533A.1(2)–(3), PDF page 1, lines 37–49. Iowa Legislature\n\nS_IA-P1-C002 — Covered debtor and geographic nexus\n\nThe statutory debtor is a natural person, and §533A.2(1) reaches a person soliciting or contracting to provide debt management to an Iowa resident.\n\nAccordingly, an out-of-state call center or website that solicits Iowa residents for compensated debt settlement can fall within the Iowa licensing requirement. A physical Iowa office is not a necessary condition for that statutory nexus.\n\nBusiness-entity debtors are outside the chapter's express natural-person definition, but that does not establish exemption from every other Iowa or federal law.\n\nEvidence: S001, §§533A.1(4), 533A.2(1), pages 1–2, lines 48–50 and 79–84. Iowa Legislature\n\n### 2.2 Licensing and exemptions\n\nS_IA-P1-C003 — Licensing is mandatory absent an exemption\n\nSection 533A.2(1) establishes the licensing requirement. The issuing authority is Iowa's Superintendent of Banking, operating through the Iowa Division of Banking.\n\nSection 533A.13 separately makes unlicensed operation unlawful and provides criminal consequences for knowing or willful violations.\n\nThe existence of an application process is not authorization to operate while an application is pending.\n\nS_IA-P1-C004 — Statutory exemptions are conditional\n\nThe following exemptions appear in §533A.2(2):\n\n| Category | Conditions or limitations |\n| --- | --- |\n| Attorneys | Licensed and admitted in Iowa; debt management solely incidental to practicing law |\n| Banks and specified financial institutions | Statutorily identified entities conducting covered activity in their regular principal business or an escrow function |\n| Abstract companies | Performing an escrow function |\n| Employees of licensees | Acting for their licensed employer |\n| Judicial officers and others | Acting under court orders |\n| Nonprofit religious, fraternal or cooperative organizations | Offering gratuitous debt-management services |\n| First-mortgage originators | Principal business is originating first mortgages for portfolio retention or sale to institutional investors |\n| Licensed or exempt money transmitters | Acting within the specified money-transmission activity |\n\nThe money-transmitter exception does not automatically authorize an independent debt-negotiation business. Likewise, incorporating a for-profit debt settlement company with an attorney relationship does not itself satisfy the attorney exemption.\n\nA standalone commercial nonprofit charging consumers for negotiations has no demonstrated general nonprofit exemption under this list.\n\nEvidence: S001, §533A.2(1)–(2), PDF page 2, lines 79–105. Iowa Legislature\n\n### 2.3 Program obligations relevant to fee permission\n\nS_IA-P1-C005 — Contract and pre-enrollment conditions\n\nUnder §533A.8, a licensee must assess the consumer's debts and budget, determine program suitability, provide specified verbal and written disclosures, and deliver a written contract before collecting fees.\n\nThe contract cannot exceed 60 months. Debt settlement contracts must identify the enrolled debts and estimated settlement funding requirements.\n\nThe consumer must be told about potential credit damage, collection activity, litigation exposure and the inability to guarantee results.\n\nThese are relevant conditions for a legally operated program, not optional consumer-education features. Iowa Legislature\n\nS_IA-P1-C006 — Student-loan modification is a distinct branch\n\nFor licensees primarily engaged in educational-loan debt management, §533A.8A(2) prohibits requesting or receiving compensation until all contracted or represented services have been fully performed.\n\nSection 533A.8A(3) additionally provides a three-business-day cancellation right, subject to the statutory mechanics.\n\nThe general $50 initiation-fee provision must not be used to bypass this more specific performance prerequisite.\n\nEvidence: S001, §533A.8A(1)–(4), PDF pages 7–9. Iowa Legislature\n\n## 3. Iowa consumer fee architecture\n\n### 3.1 Statutory fee matrix\n\n| Fee or method | Statutory calculation | Key restriction |\n| --- | --- | --- |\n| Initiation | Maximum $50, once | §533A.9(2); other law may restrict timing |\n| Custodial/distribution | Maximum 15% × funds actually applied to creditor accounts | §533A.9(3) |\n| Noncustodial aggregate | Maximum 18% × original enrolled debt | §533A.9(4)(b) |\n| Percent of total debt | Contracted additional fee collected in equal installments over first two-thirds of contract | Cancellation and settlement-completion rules |\n| Percent of savings | Contracted savings percentage, maximum 30% × savings on settled debt | $50 monthly collection/credit method; aggregate 18% ceiling |\n| Third-party lead generation or sales | Provider bears cost | No separate required consumer payment to obtain the licensee's services |\n\nSource: S002, Iowa Code 2026, §533A.9(1)–(5), pages 1–2. Iowa Legislature\n\nS_IA-P1-C007 — Custodial model\n\nThe 15% base is the amount actually applied to creditor accounts, not the original enrolled balance, estimated settlements, money deposited into an account or the face amount of an agreement.\n\nThe statute does not support converting the 15% limit into a 15%-of-enrolled-debt fee.\n\nS_IA-P1-C008 — Noncustodial model\n\nThe aggregate additional-fee ceiling is 18% of original enrolled debt, excluding the separately authorized initiation fee.\n\nThe statute expressly limits the additional-fee collection method to its percent-of-total-debt and percent-of-savings alternatives.\n\nThis is not a general authorization for arbitrary per-debt, monthly, subscription or flat-rate fee schedules.\n\nS_IA-P1-C009 — Percent-of-total-debt method\n\nThe contracted additional fee is ordinarily scheduled in equal monthly installments during the first two-thirds of the contract term.\n\nUpon completion of an individual settlement, §533A.9(4)(b)(1) separately permits a proportional calculation:\n\nFi=Fcontract×DiDenrolledF_i=F_{\\text{contract}}\\times\\frac{D_i}{D_{\\text{enrolled}}}Fi​=Fcontract​×Denrolled​Di​​Here, DiD_iDi​ is the original enrolled balance of the settled debt, not the reduced settlement payment.\n\nAmounts already lawfully earned or collected must be reconciled against the same contracted total; the formula does not authorize double recovery.\n\nS_IA-P1-C010 — Percent-of-savings method\n\nThe statute specifies $50 monthly installments credited against fees earned from settlements.\n\nFor a completed settlement:\n\nFi=p×(Di−Si)F_i=p\\times(D_i-S_i)Fi​=p×(Di​−Si​)Where ppp is the contracted savings percentage (no more than 30%), DiD_iDi​ is the original enrolled balance and SiS_iSi​ is the settlement amount.\n\nThe overall additional fee remains subject to 18% of total enrolled debt.\n\nThe statute does not authorize a new, higher savings percentage for a different creditor.\n\n### 3.2 Cancellation and refund provisions\n\nS_IA-P1-C011 — Cancellation during the first 12 months\n\nFor the two noncustodial methods, §533A.9(4)(b)(1)–(2) provides:\n\n- Written notice of discontinuation; properly mailed notice is effective on mailing.\n- No future installments become due after the effective mailed notice.\n- If participation ends within the first 12 months, the provider may retain only 50% of the installments scheduled through the notice date and must refund excess amounts, subject to the statute's separate completed-settlement language.\n\nThe interaction between the 50% retention rule and separately earned completed-settlement fees needs careful ledger treatment. Neither all collected installments nor all potential future contract fees are automatically earned.\n\nS_IA-P1-C012 — Third-party consumer charges\n\nSection 533A.9(5) requires the licensee to pay for third-party services, including marketing, lead generation and sales, except for the debtor's own banking fees.\n\nA provider cannot evade its fee limits by routing an additional required enrollment charge through a marketing affiliate.\n\n### 3.3 Currentness and indexing\n\nThe 2026 Iowa Code PDF expressly contains the $50, 15%, 18%, $50-monthly and 30% figures. They are not figures inferred from an industry chart.\n\nNo statutory CPI-adjustment mechanism was identified in §533A.9 itself. However, a complete verification of any later-enacted amendments effective after the 2026 code compilation, agency interpretations and operative rules has not been achieved. Therefore these are verified 2026 Code figures, with post-compilation amendment status held, not a guarantee of every law in effect on October 24.\n\nNo inflation-adjusted dollar amount has been calculated or invented.\n\n## 4. Fee collection timing: state versus federal\n\nS_IA-P1-C013 — State permission is not federal advance-fee permission\n\nFor covered debt-relief telemarketing, 16 CFR §310.4(a)(5)(i) prohibits requesting or receiving fees until the required settlement/alteration, consumer agreement and payment conditions are met.\n\nIn simplified terms, the federal conditions require:\n\n1. A debt has been renegotiated, settled, reduced or otherwise altered under a valid agreement.\n2. The customer has made at least one payment under that agreement.\n3. Where individual debts are resolved separately, the provider uses a permitted proportional enrolled-debt or consistent percentage-of-savings allocation.\n\nThis federal timing restriction can prevent a provider from collecting Iowa's otherwise specified initiation fee or monthly installments before the federal conditions are met.\n\nThe federal rule's payment condition is not automatically equivalent to Iowa's separate settlement-completion language. Nor does making one settlement payment necessarily mean all later payments required to satisfy the debt have been made.\n\nFederal source: 16 CFR §310.4(a)(5)(i)(A)–(C), readable text at [16 CFR 310.4](https://www.law.cornell.edu/cfr/text/16/310.4?utm_source=chatgpt.com). LII / Legal Information Institute\n\nThe Cornell rendering is a secondary republication of federal regulatory text. A fresh direct current eCFR read and full applicability analysis remain held.\n\nS_IA-P1-C014 — Dedicated account exception\n\nThe federal provision at §310.4(a)(5)(ii) distinguishes consumer deposits into a qualifying dedicated account from fees actually earned by the provider. It includes account ownership, institutional, independence and withdrawal conditions.\n\nA consumer's deposit into a settlement savings account is not automatically provider revenue. State trust-account obligations remain independently relevant.\n\nS_IA-P1-C015 — Credit-repair representations\n\nSection 310.4(a)(2) separately regulates fees for telemarketed services represented as improving or removing derogatory credit information, subject to its specified conditions.\n\nA debt settlement business making affirmative credit-improvement promises may trigger this additional framework. It should not assume ordinary debt-relief fee timing is the only applicable federal rule.\n\nCROA applicability, including its own definitions and exceptions, remains unresolved in this pass.\n\n## 5. Regulatory access, licensing procedure and rulemaking\n\n### 5.1 Actual public licensing route\n\nS_IA-P1-C016 — Iowa's licensing infrastructure is identifiable\n\nThe Iowa Division of Banking maintains an official license-verification page that identifies Debt Management as a regulated license category and directs users to NMLS Consumer Access.\n\nIowa Division of Banking — License VerificationNMLS Consumer Access — public license lookupThe Division's page identifies December 31 as the debt-management license expiration date. No specific provider was queried or verified in this investigation. Division of Banking\n\nS_IA-P1-C017 — Statutory application requirements\n\nThe 2026 Iowa Code, §533A.2(3)–(7) and §533A.3, provides for an application to the Superintendent, organizational and control-person information, a bond, program and contract documentation, and examination of applicant fitness.\n\nThe statutory government charges identified are:\n\n| Government requirement | 2026 Code figure |\n| --- | --- |\n| Initial office license fee | $250 per office |\n| Investigation fee | $100 |\n| Surety bond | $25,000 per office |\n| NMLS processing charges | Additional; current amount not established |\n\nThese are provider-side government and licensing costs, not consumer debt-management fee allowances. A bond is security, not a fee paid to the regulator.\n\nThe statute also requires separate applications for offices and provides for an agency licensing determination. Iowa Legislature\n\n### 5.2 Important 2026 administrative-rule development\n\nS_IA-P1-C018 — Proposed Chapter 20 replacement is not proven operative\n\nIowa's Banking Division published ARC 0368D, a Notice of Intended Action proposing to rescind and replace Iowa Administrative Code agency 187, chapter 20.\n\nThe proposal includes NMLS application procedures and a definition of completed settlement tied to remittance of all payments needed to satisfy the debt.\n\nHowever, the actual opened notice identifies itself as a proposal, not a final adoption order.\n\nIowa ARC 0368D — proposed debt-management rulesThe July 2026 comment and hearing dates do not establish adoption or legal effectiveness. A final adoption notice, any subsequent changes and the actual operative consolidated Chapter 20 must be verified before the proposal's language is used as controlling law. Iowa Administrative Rules\n\nThis matters especially for determining when a debt is legally considered completed for state fee-collection purposes.\n\nHeld: The proposed definition cannot independently establish that Iowa currently requires full final remittance before every settlement-completion fee. The statute's own completion language remains controlling, subject to operative rules and interpretation.\n\n### 5.3 Market-access determination\n\nIowa is best classified at this stage as:\n\nStatutory licensing pathway established; actual provider authorization and complete current regulatory conditions not yet verified.\n\nThis supports further investigation of an Iowa business launch. It does not support marking Iowa approved for operations, accepting consumers or charging fees.\n\n## 6. Bounded worked fee examples\n\nThe following are mathematical applications of the verified 2026 statutory language. They are not recommendations to collect the illustrated amounts.\n\nAll figures use USD, with monetary results rounded to two decimals. Where a federal TSR restriction applies, collection is held until the independently required performance and payment conditions are met.\n\n### Example IA-E01 — Custodial DMP, amounts applied\n\nInputs:\n\nPlain text\n```\nModel:                 Custodial/distribution\nFunds received:        $5,000.00\nActually applied:      $4,000.00\nInitiation fee:           $50.00\nState rate ceiling:          15%\n\nAdditional fee ceiling:\n$4,000.00 × 0.15 = $600.00\n\nCombined state ceiling:\n$600.00 + $50.00 = $650.00\n```\n\nThe unapplied $1,000 does not generate an additional 15% fee merely because the provider received it.\n\nConditions: §533A.8(5)(d)'s creditor-consent or distribution threshold must also be satisfied before the covered fees can be received. Applicable federal timing is separate.\n\nDisposition: Numeric ceiling verified; lawful collection timing conditional.\n\n### Example IA-E02 — Noncustodial, low enrolled debt\n\nInputs:\n\nPlain text\n```\nOriginal enrolled debt:   $2,000.00\nAggregate rate ceiling:         18%\nInitiation ceiling:          $50.00\n\nAdditional fee ceiling:\n$2,000.00 × 0.18 = $360.00\n\nCombined state ceiling:\n$360.00 + $50.00 = $410.00\n```\n\nThis example demonstrates why a flat $500 additional charge cannot be justified by the 18% ceiling for a $2,000 enrollment.\n\nDisposition: Arithmetic and statutory aggregate ceiling verified; no conclusion about immediate collectibility.\n\n### Example IA-E03 — Percent-of-total-debt, completed partial portfolio\n\nInputs:\n\nPlain text\n```\nEnrolled debt A:       $6,000.00\nEnrolled debt B:       $4,000.00\nTotal enrolled:       $10,000.00\n\nContracted additional fee:\n18% × $10,000.00 = $1,800.00\n\nDebt A fully settled:\n$6,000 / $10,000 = 60%\n\nProportional fee A:\n60% × $1,800.00 = $1,080.00\n\nUnallocated fee:\n$1,800.00 - $1,080.00 = $720.00\n```\n\nThe $1,080 is the proportional share associated with debt A, not an additional fee on top of the $1,800 contract.\n\nAssume no earlier earned fees. If $300 had already been lawfully earned and allocated to debt A, only $780 would remain against debt A's $1,080 share. That $300 prior-earnings premise must be independently supported by the same contract method and actual performance; it cannot simply be assumed because a consumer made a payment.\n\nDisposition: Formula verified; earlier-earnings scenario conditional; federal timing and Iowa completion requirements still control.\n\n### Example IA-E04 — Percent-of-savings, one completed settlement\n\nInputs:\n\nPlain text\n```\nDebt A enrolled:       $5,000.00\nDebt B enrolled:       $5,000.00\nTotal enrolled:       $10,000.00\n\nDebt A settlement:     $3,000.00\nSavings:               $2,000.00\nContracted savings rate:     30%\n\nEarned-fee calculation:\n$2,000.00 × 30% = $600.00\n\nPortfolio additional-fee cap:\n$10,000.00 × 18% = $1,800.00\n```\n\nAssume no earlier fees were earned or collected. The calculated fee attributable to the completed settlement is $600, subject to the performance conditions.\n\nThe $1,800 portfolio ceiling does not make $1,800 immediately earned.\n\nDisposition: Savings formula verified; earned status assumes a completed qualifying settlement; collection subject to law.\n\n### Example IA-E05 — Savings-based method with prior monthly collections\n\nInputs:\n\nPlain text\n```\nSame $10,000 enrolled portfolio\nSame 30% contracted savings rate\nSame $5,000 debt A\nSame $3,000 completed settlement\n\nDebt A savings fee:          $600.00\n\nHypothetical earlier\nmonthly amounts collected:   $200.00\n\nPotential remaining amount:\n$600.00 - $200.00 = $400.00\n```\n\nImportant limitation: The $200 represents four hypothetical $50 collections under Iowa's monthly method. If federal TSR coverage prohibited those advance collections, the scenario would be noncompliant even though the subtraction is correct.\n\nThose amounts must be credited against the settlement fee. They cannot be charged again.\n\nDisposition: Numeric equality verified; lawful earlier collection not established. This is a reconciliation example, not a compliant advance-fee example.\n\n### Example IA-E06 — Cancellation within first 12 months\n\nAssume the percent-of-total-debt method, a $1,200 contracted additional fee over a 24-month contract.\n\nPlain text\n```\nCollection period:\n24 × 2/3 = 16 months\n\nScheduled installment:\n$1,200 / 16 = $75.00\n\nCancellation after 4 scheduled months:\n4 × $75.00 = $300.00\n\n50% statutory retention calculation:\n$300.00 × 50% = $150.00\n\nIf $300 was actually collected:\nPotential refund = $150.00\n```\n\nAssume no completed settlements and no separately earned settlement fee.\n\nThe statute's first-year retention rule yields $150 as the potential retained amount. The lawful origin of the four payments must still be established under federal law; a statutory retention formula cannot validate prohibited advance collection.\n\nDisposition: State cancellation arithmetic verified; overall legal collection status conditional.\n\n### Example IA-E07 — Cancellation after a completed settlement\n\nAssume the same 24-month, $1,200 percent-of-total-debt contract, with $10,000 enrolled debt and a completed settlement of an originally enrolled $2,500 debt.\n\nPlain text\n```\nDebt share:\n$2,500 / $10,000 = 25%\n\nProportional completed-settlement fee:\n$1,200 × 25% = $300.00\n\nScheduled installments through month 4:\n4 × $75 = $300.00\n\nFirst-year 50% retention calculation:\n$300 × 50% = $150.00\n```\n\nThe statute separately permits the $300 proportional completed-settlement calculation. The question is how that earned amount interacts with the $150 installment-retention figure and any amounts actually collected.\n\nIt would be incorrect simply to add $300 and $150 and announce a $450 earned fee.\n\nDisposition: Two statutory calculations verified; combined cancellation-ledger treatment held pending operative rules and interpretation.\n\n## 7. Source register — S_IA-P1-S001+\n\nAll access checks below occurred October 24, 2026, Pacific. A source's publication, compilation or rulemaking date is distinguished from the date it was accessed.\n\n| Source ID | Authority and literal URL | Pinpoint and version | Access, status and limitations |\n| --- | --- | --- | --- |\n| S_IA-P1-S001 | Iowa Legislature, Iowa Code 2026, Chapter 533A. [https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf](https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf?utm_source=chatgpt.com) | 14-page official chapter; §§533A.1–.17; 2026 compilation, dated Dec. 9, 2025 | Read: relevant definition, licensing, exemption, application, disclosure, fee and educational-loan passages. Current 2026 Code source; later amendment reconciliation incomplete. Iowa Legislature |\n| S_IA-P1-S002 | Iowa Legislature, Iowa Code 2026, §533A.9. [https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf](https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf?utm_source=chatgpt.com) | §533A.9(1)–(5), pages 1–2; compiled Dec. 12, 2025 | Read: complete fee section, including both noncustodial methods, cancellation and third-party charges. Same statute as S001, separately published section file. Iowa Legislature |\n| S_IA-P1-S003 | Iowa Legislature, 2026 Code section index. [https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026](https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026&utm_source=chatgpt.com) | Chapter 533A section listing | Discovery/index: establishes the official 2026 chapter structure, not post-compilation currency. Code Section Listings |\n| S_IA-P1-S004 | Iowa Division of Banking, License Verification. [https://idob.iowa.gov/finance/finance-license-verification](https://idob.iowa.gov/finance/finance-license-verification?utm_source=chatgpt.com) | License Search; Debt Management license type and expiration | Read: official operational lookup guidance. No individual license result obtained. Division of Banking |\n| S_IA-P1-S005 | Iowa Administrative Rules, ARC 0368D. [https://rules.iowa.gov/Notice/Details/0368D](https://rules.iowa.gov/Notice/Details/0368D?utm_source=chatgpt.com) | Notice of Intended Action; proposed 187—20.1 through 20.6 passages inspected | Read: official proposal, including licensing and settlement-completion language. Not verified as adopted or operative. Iowa Administrative Rules |\n| S_IA-P1-S006 | Cornell LII, 16 CFR §310.4. [https://www.law.cornell.edu/cfr/text/16/310.4](https://www.law.cornell.edu/cfr/text/16/310.4?utm_source=chatgpt.com) | §310.4(a)(2), (a)(5)(i)–(ii) | Read: federal regulatory republication. Federal timing text supported; direct current eCFR verification and applicability analysis incomplete. LII / Legal Information Institute |\n| S_IA-P1-S007 | U.S. Government Publishing Office, 16 CFR §310.4, 2023 edition. [https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf](https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf?utm_source=chatgpt.com) | §310.4(a)(5) | Discovery: historical official federal text; not relied on to prove October 2026 currency. GovInfo |\n| S_IA-P1-S008 | NMLS, Iowa Debt Management Branch License New Application Checklist. [https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf](https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf?utm_source=chatgpt.com) | Search-rendered checklist dated Oct. 4, 2022 | Discovery only: direct open redirected to an NMLS landing page. Checklist contents and current procedural requirements not authenticated from the original PDF. Nationwide Licensing System |\n| S_IA-P1-S009 | Iowa Legislature, Iowa Code 2018, Chapter 533A. [https://www.legis.iowa.gov/docs/code/2018/533A.html](https://www.legis.iowa.gov/docs/code/2018/533A.html?utm_source=chatgpt.com) | Historical §§533A.1, .2, .8, .9 and others | Historical comparison: older statutory text found. Not controlling for 2026; later educational-loan provisions illustrate why historical tables cannot substitute for current text. Iowa Legislature |\n| S_IA-P1-S010 | Justia, Iowa Administrative Code 187—20.3. [https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/](https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/?utm_source=chatgpt.com) | Application for License; publisher states current through June 25, 2025 | Secondary discovery: insufficient to establish operative October 2026 rule version, particularly in light of ARC 0368D. Justia |\n\nSource-status limitation: The official 2026 Code was directly read, but no comprehensive legislative session-law search was completed to establish whether a subsequent enactment changed any relevant provision by October 24, 2026. The operative consolidated administrative rules and final disposition of ARC 0368D were also not verified.\n\n## 8. Claim register — S_IA-P1-C001+\n\nConfidence refers to support for the specified assertion, not overall business compliance or publication readiness.\n\n| Claim ID | Precise assertion | Evidence and pinpoint | Confidence / limitation |\n| --- | --- | --- | --- |\n| C001 | Compensated negotiation, creditor intermediation, distribution, settlement and educational-loan modification can constitute debt management | S001 §533A.1(2)–(3) | High for 2026 Code |\n| C002 | Iowa-resident solicitation or contracting supplies statutory licensing nexus; debtor is a natural person | S001 §§533A.1(4), .2(1) | High; other-law coverage separate |\n| C003 | Chapter 533A license required absent exemption; unlicensed operation unlawful | S001 §§533A.2(1), .13 | High |\n| C004 | Attorney, institutional, employee, gratuitous nonprofit and other exemptions are conditional | S001 §533A.2(2)(a)–(h) | High for statutory wording |\n| C005 | Budget assessment, disclosures, contract and 60-month term limit apply to licensees | S001 §533A.8(1)–(4) | High |\n| C006 | Primarily educational-loan management providers face full-performance-before-payment rule | S001 §533A.8A(1)–(4) | High |\n| C007 | Custodial additional fees capped at 15% of amounts actually applied | S002 §533A.9(3) | High |\n| C008 | Noncustodial additional fees capped at 18% of original enrolled debt | S002 §533A.9(4)(a)–(b) | High |\n| C009 | Percent-of-total-debt method uses equal installments and a completed-settlement proportional provision | S002 §533A.9(4)(b)(1) | High for formula; timing interaction held |\n| C010 | Savings method uses $50 monthly installments credited against earned settlement fees; 30% savings-rate maximum | S002 §533A.9(4)(b)(2) | High for formula; federal collection restrictions separate |\n| C011 | First-year discontinuation invokes 50% scheduled-installment retention and excess refund | S002 §533A.9(4)(b)(1)–(2) | High; completed-settlement interaction held |\n| C012 | Third-party service costs cannot be imposed separately on consumers obtaining licensee services | S002 §533A.9(5) | High |\n| C013 | Covered TSR debt-relief fees require qualifying agreement, consumer payment and allocation | S006 §310.4(a)(5)(i) | High for reproduced rule text; coverage/current eCFR held |\n| C014 | Qualifying dedicated-account deposits are distinct from earned provider fees | S006 §310.4(a)(5)(ii) | High for reproduced text |\n| C015 | Telemarketed credit-improvement claims may invoke separate fee restrictions | S006 §310.4(a)(2) | Conditional; CROA not resolved |\n| C016 | Iowa Division of Banking provides an NMLS-based license lookup and identifies December 31 expiration | S004, License Search and License Types | High for operational page; provider status unverified |\n| C017 | Initial statutory charges include $250 per office and $100 investigation; $25,000 office bond | S001 §533A.2(4), (6) | High for 2026 Code; other system charges held |\n| C018 | ARC 0368D proposes replacing Chapter 20; final legal status not established | S005, notice heading and proposed rules | High that proposal exists; adoption unresolved |\n| C019 | Custodial programs face an additional creditor-consent/distribution threshold before receiving non-initiation fees | S001 §533A.8(5)(d) | High; federal restrictions separate |\n| C020 | Noncustodial debtor retains control/access to set-aside funds; licensee cannot receive related third-party consideration | S001 §533A.8(6)(a)–(b) | High |\n| C021 | An Iowa license is not established for any specific company by this investigation | S004; no named-provider lookup performed | Confirmed research limitation |\n| C022 | No verified 2026 post-compilation amendment or CPI adjustment was established | S001, S002; amendment investigation incomplete | Held, not proof of absence |\n| C023 | Proposed-rule settlement-completion definition requires verification against an adopted rule | S005 proposed 187—20.1 | High that proposal contains language; operative status held |\n| C024 | A noncustodial program's lawful collection schedule cannot be determined from Iowa fee ceilings alone | S002 §533A.9(4); S006 §310.4(a)(5) | High as conditional conclusion |\n| C025 | Complete licensing and contract compliance cannot be certified without current rules and provider-specific evidence | S001 §§533A.2–.9; S004–S005 | High as research limitation |\n\n### Additional material boundary findings\n\nTwo provisions warrant particular attention in a future operational design.\n\nC019 — Custodial creditor threshold. Section 533A.8(5)(d) requires consent from at least half of the listed creditors, or acceptance of payment distributions by a like number, before a custodial licensee may receive fees other than the permitted initiation fee. This is an additional state trigger, not a replacement for federal law. Iowa Legislature\n\nC020 — Noncustodial funds and compensation. Section 533A.8(6) requires the consumer to retain control of and access to money set aside for creditors, and prohibits the licensee from receiving third-party consideration connected with services to the debtor. This creates material constraints on referral, affiliate and account-provider economics. Iowa Legislature\n\n## 9. Full PASS-01 component coverage and gaps\n\nStatus meanings: Answered means the specified statutory issue has directly read support; Partial means meaningful findings exist but material verification remains; Unresolved means the requested evidence has not been established; Excluded means reserved for a later pass.\n\n| Component | Status | Claims | Exact missing evidence / next investigation |\n| --- | --- | --- | --- |\n| Definition of debt management | Answered | C001 | Check post-compilation amendments |\n| Principal-reduction settlement | Answered | C001 | Later interpretive case-law review |\n| Creditor concessions and DMPs | Answered | C001, C007 | Operative rules and application to hybrids |\n| Custodial versus noncustodial classification | Partial | C007–C010, C020 | Current rule text and mixed-provider structures |\n| Consumer versus business debtor | Partial | C002 | Other Iowa regimes governing business-purpose services |\n| Remote-provider Iowa nexus | Answered at statutory level | C002 | Enforcement and constitutional boundary cases later |\n| Commercial licensing pathway | Answered at statutory level | C003 | Current rules and company-specific status |\n| Attorney exemption | Partial | C004 | Interpretive authority and actual business structures |\n| Nonprofit/gratuitous exemption | Partial | C004 | Donation arrangements and interpretation |\n| Financial institution and other exemptions | Partial | C004 | Entity/activity verification |\n| Initial application and government fees | Partial | C017 | Current NMLS checklist and charges |\n| Public license lookup | Answered as procedure | C016 | Named-provider result if later requested |\n| Named provider authorization | Unresolved | C021 | Actual NMLS record, Iowa authority and active status |\n| One-time initiation ceiling | Answered for 2026 Code | C008, C024 | Independent federal collection timing |\n| Custodial 15% ceiling | Answered for 2026 Code | C007 | Current rule interpretation and federal timing |\n| Noncustodial 18% ceiling | Answered for 2026 Code | C008 | Later amendments and operative rules |\n| Percent-of-total-debt collection | Partial | C009, C011 | State/federal interaction and earned-fee accounting |\n| Percent-of-savings collection | Partial | C010, C011 | Monthly advance collection, credits and refund accounting |\n| Partial-settlement allocation | Partial | C009, C010, C013 | Completed-settlement meaning and actual performance |\n| Cancellation/refunds | Partial | C011 | Combined installment and settlement-fee interpretation |\n| Third-party consumer charges | Answered for 2026 Code | C012, C020 | Fact-specific affiliate arrangements |\n| Indexing/current adjustments | Unresolved beyond code text | C022 | Post-compilation laws and official notices |\n| Administrative Chapter 20 currency | Unresolved | C018, C023 | Final adoption order, effective date, operative rules |\n| Federal TSR debt-relief timing | Partial | C013, C014 | Direct current eCFR and applicability/exceptions |\n| Credit-repair overlap/CROA | Partial | C015 | Current CROA provisions and specific representations |\n| Educational-loan fee timing | Answered at statutory level | C006 | Other applicable educational-loan rules |\n| Contract/funds/bond comprehensive review | Excluded | C005, C017, C020 | Required later pass; limited provisions read for fee access |\n| Collection, litigation, limitations, exemptions, secured debt | Excluded | — | Separate required passes |\n| Sector/local/tribal law and full case-law review | Excluded | — | Separate required passes |\n| A066/state acceptance | Unresolved | C025 | Full dossier, subsequent passes and independent validation |\n\n## 10. Exact next investigations\n\nThe next Iowa investigation should resolve these questions in priority order:\n\n1. Final administrative-rule status: Locate the final adoption, withdrawal or other disposition of ARC 0368D, authenticate the complete operative 187—Chapter 20, and establish the actual effective date. Reconcile the settlement-completion definition and any applicable licensing requirements.\n2. Post-compilation statutory currency: Examine Iowa session laws enacted after the 2026 Code compilation for amendments to §§533A.1–.9A, especially fees, exemptions, educational loans, licensing and donations.\n3. Federal timing and coverage: Read current official eCFR §§310.2–310.4, including relevant exceptions and credit-repair restrictions, and verify the federal Credit Repair Organizations Act provisions where representations or business models trigger them.\n4. Fee and cancellation interpretation: Find Iowa Banking Division interpretations, applicable administrative orders and controlling Iowa decisions on installment collection, settlement completion, prior fee credits, first-year refunds and mixed fee methods.\n5. Actual licensing procedure: Obtain the current NMLS company and branch application checklists, government fee schedules, required documents and publicly searchable authorization criteria. Do not assume a historical checklist remains operative.\n6. Specialized classification boundaries: Investigate free counseling, optional donations, nonprofit arrangements, attorney-owned businesses, creditor-funded services, third-party settlement accounts and educational-loan modification arrangements.\n\nThese are unresolved evidence requirements, not tasks represented as completed.\n\n## 11. Researcher self-check\n\nActual evidence read\n\nThe investigation directly opened the Iowa Legislature's 2026 chapter PDF and separate fee-section PDF, read relevant operative passages, inspected the Iowa Division of Banking's license-verification page, and opened the Iowa administrative rulemaking proposal.\n\nThe statutory fee formulas and major exemptions have direct textual support. The worked examples were calculated from those formulas, with assumptions and unresolved collection conditions distinguished.\n\nEvidence not established\n\nThe investigation did not verify the final disposition of ARC 0368D, read an authenticated complete operative October 2026 Chapter 20, complete a post-compilation session-law audit, or establish the current licensing status of any named provider.\n\nIt did not complete a controlling Iowa case-law review, independently reproduce regulatory fee-accounting examples from actual consumer records, or obtain an attorney's legal opinion. The current official eCFR text and federal applicability exceptions were not fully authenticated.\n\nThe NMLS branch checklist's original document route redirected rather than providing readable source text. Its search-rendered contents were not treated as verified current instructions.\n\nNo private data was accessed. No applications were submitted, no agencies or companies contacted, no local files written, and no website or publication changed.\n\nThis is a researcher self-check, not independent review.\n\n## 12. PASS-01 disposition\n\nIowa's 2026 statutory framework establishes that compensated consumer debt settlement can be conducted through a licensed debt-management business, subject to defined exemptions, substantial operating requirements and distinct fee ceilings.\n\nFor SettleADebt.com, the key commercially relevant findings are the 18% enrolled-debt aggregate ceiling for noncustodial programs, the alternative statutory collection methods, and the independent federal fee-timing restrictions.\n\nThe statutory foundation is sufficiently supported to justify further Iowa-specific diligence. It is not sufficient to approve a provider, contract, collection schedule, operating launch or A066 acceptance.\n\nAll other Iowa state-law categories remain open and required.\n\nEND S_IA PASS-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Iowa treatment","Operational conclusion"],["For-profit debt settlement/negotiation","Expressly included in debt management","Chapter 533A license generally required"],["Noncustodial debt settlement","Expressly contemplated","License route; special 18% aggregate ceiling and collection methods"],["Custodial debt-management plan","Expressly contemplated","License route; 15% applied-funds ceiling"],["Fee-based credit counseling negotiating concessions","Potentially covered","Activity, not marketing label, controls"],["Gratuitous nonprofit religious/fraternal/cooperative service","Express conditional exemption","No general nonprofit exemption established"],["Iowa attorney providing incidental legal services","Express conditional exemption","Iowa admission and incident-to-practice conditions required"],["Pure education without debt-management activity","Fact-dependent","Classification held"],["Educational-loan modification services","Expressly included","Additional §533A.8A requirements require separate analysis"]]},{"headers":[],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Category","Conditions or limitations"],["Attorneys","Licensed and admitted in Iowa; debt management solely incidental to practicing law"],["Banks and specified financial institutions","Statutorily identified entities conducting covered activity in their regular principal business or an escrow function"],["Abstract companies","Performing an escrow function"],["Employees of licensees","Acting for their licensed employer"],["Judicial officers and others","Acting under court orders"],["Nonprofit religious, fraternal or cooperative organizations","Offering gratuitous debt-management services"],["First-mortgage originators","Principal business is originating first mortgages for portfolio retention or sale to institutional investors"],["Licensed or exempt money transmitters","Acting within the specified money-transmission activity"]]},{"headers":[],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Fee or method","Statutory calculation","Key restriction"],["Initiation","Maximum $50, once","§533A.9(2); other law may restrict timing"],["Custodial/distribution","Maximum 15% × funds actually applied to creditor accounts","§533A.9(3)"],["Noncustodial aggregate","Maximum 18% × original enrolled debt","§533A.9(4)(b)"],["Percent of total debt","Contracted additional fee collected in equal installments over first two-thirds of contract","Cancellation and settlement-completion rules"],["Percent of savings","Contracted savings percentage, maximum 30% × savings on settled debt","$50 monthly collection/credit method; aggregate 18% ceiling"],["Third-party lead generation or sales","Provider bears cost","No separate required consumer payment to obtain the licensee's services"]]},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Government requirement","2026 Code figure"],["Initial office license fee","$250 per office"],["Investigation fee","$100"],["Surety bond","$25,000 per office"],["NMLS processing charges","Additional; current amount not established"]]},{"headers":[],"index":4,"links":[{"href":"https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf"},{"href":"https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026&utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026"},{"href":"https://idob.iowa.gov/finance/finance-license-verification?utm_source=chatgpt.com","text":"https://idob.iowa.gov/finance/finance-license-verification"},{"href":"https://rules.iowa.gov/Notice/Details/0368D?utm_source=chatgpt.com","text":"https://rules.iowa.gov/Notice/Details/0368D"},{"href":"https://www.law.cornell.edu/cfr/text/16/310.4?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/cfr/text/16/310.4"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf"},{"href":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf?utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf"},{"href":"https://www.legis.iowa.gov/docs/code/2018/533A.html?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/code/2018/533A.html"},{"href":"https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/?utm_source=chatgpt.com","text":"https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf"}],[{"href":"https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026&utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026"}],[{"href":"https://idob.iowa.gov/finance/finance-license-verification?utm_source=chatgpt.com","text":"https://idob.iowa.gov/finance/finance-license-verification"}],[{"href":"https://rules.iowa.gov/Notice/Details/0368D?utm_source=chatgpt.com","text":"https://rules.iowa.gov/Notice/Details/0368D"}],[{"href":"https://www.law.cornell.edu/cfr/text/16/310.4?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/cfr/text/16/310.4"}],[{"href":"https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf?utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf"}],[{"href":"https://www.legis.iowa.gov/docs/code/2018/533A.html?utm_source=chatgpt.com","text":"https://www.legis.iowa.gov/docs/code/2018/533A.html"}],[{"href":"https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/?utm_source=chatgpt.com","text":"https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/"}]],"rows":[["Source ID","Authority and literal URL","Pinpoint and version","Access, status and limitations"],["S_IA-P1-S001","Iowa Legislature, Iowa Code 2026, Chapter 533A. https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf","14-page official chapter; §§533A.1–.17; 2026 compilation, dated Dec. 9, 2025","Read: relevant definition, licensing, exemption, application, disclosure, fee and educational-loan passages. Current 2026 Code source; later amendment reconciliation incomplete. \nIowa Legislature"],["S_IA-P1-S002","Iowa Legislature, Iowa Code 2026, §533A.9. https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf","§533A.9(1)–(5), pages 1–2; compiled Dec. 12, 2025","Read: complete fee section, including both noncustodial methods, cancellation and third-party charges. Same statute as S001, separately published section file. \nIowa Legislature"],["S_IA-P1-S003","Iowa Legislature, 2026 Code section index. https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026","Chapter 533A section listing","Discovery/index: establishes the official 2026 chapter structure, not post-compilation currency. \nCode Section Listings"],["S_IA-P1-S004","Iowa Division of Banking, License Verification. https://idob.iowa.gov/finance/finance-license-verification","License Search; Debt Management license type and expiration","Read: official operational lookup guidance. No individual license result obtained. \nDivision of Banking"],["S_IA-P1-S005","Iowa Administrative Rules, ARC 0368D. https://rules.iowa.gov/Notice/Details/0368D","Notice of Intended Action; proposed 187—20.1 through 20.6 passages inspected","Read: official proposal, including licensing and settlement-completion language. Not verified as adopted or operative. \nIowa Administrative Rules"],["S_IA-P1-S006","Cornell LII, 16 CFR §310.4. https://www.law.cornell.edu/cfr/text/16/310.4","§310.4(a)(2), (a)(5)(i)–(ii)","Read: federal regulatory republication. Federal timing text supported; direct current eCFR verification and applicability analysis incomplete. \nLII / Legal Information Institute"],["S_IA-P1-S007","U.S. Government Publishing Office, 16 CFR §310.4, 2023 edition. https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf","§310.4(a)(5)","Discovery: historical official federal text; not relied on to prove October 2026 currency. \nGovInfo"],["S_IA-P1-S008","NMLS, Iowa Debt Management Branch License New Application Checklist. https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf","Search-rendered checklist dated Oct. 4, 2022","Discovery only: direct open redirected to an NMLS landing page. Checklist contents and current procedural requirements not authenticated from the original PDF. \nNationwide Licensing System"],["S_IA-P1-S009","Iowa Legislature, Iowa Code 2018, Chapter 533A. https://www.legis.iowa.gov/docs/code/2018/533A.html","Historical §§533A.1, .2, .8, .9 and others","Historical comparison: older statutory text found. Not controlling for 2026; later educational-loan provisions illustrate why historical tables cannot substitute for current text. \nIowa Legislature"],["S_IA-P1-S010","Justia, Iowa Administrative Code 187—20.3. https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/","Application for License; publisher states current through June 25, 2025","Secondary discovery: insufficient to establish operative October 2026 rule version, particularly in light of ARC 0368D. \nJustia"]]},{"headers":[],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Evidence and pinpoint","Confidence / limitation"],["C001","Compensated negotiation, creditor intermediation, distribution, settlement and educational-loan modification can constitute debt management","S001 §533A.1(2)–(3)","High for 2026 Code"],["C002","Iowa-resident solicitation or contracting supplies statutory licensing nexus; debtor is a natural person","S001 §§533A.1(4), .2(1)","High; other-law coverage separate"],["C003","Chapter 533A license required absent exemption; unlicensed operation unlawful","S001 §§533A.2(1), .13","High"],["C004","Attorney, institutional, employee, gratuitous nonprofit and other exemptions are conditional","S001 §533A.2(2)(a)–(h)","High for statutory wording"],["C005","Budget assessment, disclosures, contract and 60-month term limit apply to licensees","S001 §533A.8(1)–(4)","High"],["C006","Primarily educational-loan management providers face full-performance-before-payment rule","S001 §533A.8A(1)–(4)","High"],["C007","Custodial additional fees capped at 15% of amounts actually applied","S002 §533A.9(3)","High"],["C008","Noncustodial additional fees capped at 18% of original enrolled debt","S002 §533A.9(4)(a)–(b)","High"],["C009","Percent-of-total-debt method uses equal installments and a completed-settlement proportional provision","S002 §533A.9(4)(b)(1)","High for formula; timing interaction held"],["C010","Savings method uses $50 monthly installments credited against earned settlement fees; 30% savings-rate maximum","S002 §533A.9(4)(b)(2)","High for formula; federal collection restrictions separate"],["C011","First-year discontinuation invokes 50% scheduled-installment retention and excess refund","S002 §533A.9(4)(b)(1)–(2)","High; completed-settlement interaction held"],["C012","Third-party service costs cannot be imposed separately on consumers obtaining licensee services","S002 §533A.9(5)","High"],["C013","Covered TSR debt-relief fees require qualifying agreement, consumer payment and allocation","S006 §310.4(a)(5)(i)","High for reproduced rule text; coverage/current eCFR held"],["C014","Qualifying dedicated-account deposits are distinct from earned provider fees","S006 §310.4(a)(5)(ii)","High for reproduced text"],["C015","Telemarketed credit-improvement claims may invoke separate fee restrictions","S006 §310.4(a)(2)","Conditional; CROA not resolved"],["C016","Iowa Division of Banking provides an NMLS-based license lookup and identifies December 31 expiration","S004, License Search and License Types","High for operational page; provider status unverified"],["C017","Initial statutory charges include $250 per office and $100 investigation; $25,000 office bond","S001 §533A.2(4), (6)","High for 2026 Code; other system charges held"],["C018","ARC 0368D proposes replacing Chapter 20; final legal status not established","S005, notice heading and proposed rules","High that proposal exists; adoption unresolved"],["C019","Custodial programs face an additional creditor-consent/distribution threshold before receiving non-initiation fees","S001 §533A.8(5)(d)","High; federal restrictions separate"],["C020","Noncustodial debtor retains control/access to set-aside funds; licensee cannot receive related third-party consideration","S001 §533A.8(6)(a)–(b)","High"],["C021","An Iowa license is not established for any specific company by this investigation","S004; no named-provider lookup performed","Confirmed research limitation"],["C022","No verified 2026 post-compilation amendment or CPI adjustment was established","S001, S002; amendment investigation incomplete","Held, not proof of absence"],["C023","Proposed-rule settlement-completion definition requires verification against an adopted rule","S005 proposed 187—20.1","High that proposal contains language; operative status held"],["C024","A noncustodial program's lawful collection schedule cannot be determined from Iowa fee ceilings alone","S002 §533A.9(4); S006 §310.4(a)(5)","High as conditional conclusion"],["C025","Complete licensing and contract compliance cannot be certified without current rules and provider-specific evidence","S001 §§533A.2–.9; S004–S005","High as research limitation"]]},{"headers":[],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Exact missing evidence / next investigation"],["Definition of debt management","Answered","C001","Check post-compilation amendments"],["Principal-reduction settlement","Answered","C001","Later interpretive case-law review"],["Creditor concessions and DMPs","Answered","C001, C007","Operative rules and application to hybrids"],["Custodial versus noncustodial classification","Partial","C007–C010, C020","Current rule text and mixed-provider structures"],["Consumer versus business debtor","Partial","C002","Other Iowa regimes governing business-purpose services"],["Remote-provider Iowa nexus","Answered at statutory level","C002","Enforcement and constitutional boundary cases later"],["Commercial licensing pathway","Answered at statutory level","C003","Current rules and company-specific status"],["Attorney exemption","Partial","C004","Interpretive authority and actual business structures"],["Nonprofit/gratuitous exemption","Partial","C004","Donation arrangements and interpretation"],["Financial institution and other exemptions","Partial","C004","Entity/activity verification"],["Initial application and government fees","Partial","C017","Current NMLS checklist and charges"],["Public license lookup","Answered as procedure","C016","Named-provider result if later requested"],["Named provider authorization","Unresolved","C021","Actual NMLS record, Iowa authority and active status"],["One-time initiation ceiling","Answered for 2026 Code","C008, C024","Independent federal collection timing"],["Custodial 15% ceiling","Answered for 2026 Code","C007","Current rule interpretation and federal timing"],["Noncustodial 18% ceiling","Answered for 2026 Code","C008","Later amendments and operative rules"],["Percent-of-total-debt collection","Partial","C009, C011","State/federal interaction and earned-fee accounting"],["Percent-of-savings collection","Partial","C010, C011","Monthly advance collection, credits and refund accounting"],["Partial-settlement allocation","Partial","C009, C010, C013","Completed-settlement meaning and actual performance"],["Cancellation/refunds","Partial","C011","Combined installment and settlement-fee interpretation"],["Third-party consumer charges","Answered for 2026 Code","C012, C020","Fact-specific affiliate arrangements"],["Indexing/current adjustments","Unresolved beyond code text","C022","Post-compilation laws and official notices"],["Administrative Chapter 20 currency","Unresolved","C018, C023","Final adoption order, effective date, operative rules"],["Federal TSR debt-relief timing","Partial","C013, C014","Direct current eCFR and applicability/exceptions"],["Credit-repair overlap/CROA","Partial","C015","Current CROA provisions and specific representations"],["Educational-loan fee timing","Answered at statutory level","C006","Other applicable educational-loan rules"],["Contract/funds/bond comprehensive review","Excluded","C005, C017, C020","Required later pass; limited provisions read for fee access"],["Collection, litigation, limitations, exemptions, secured debt","Excluded","—","Separate required passes"],["Sector/local/tribal law and full case-law review","Excluded","—","Separate required passes"],["A066/state acceptance","Unresolved","C025","Full dossier, subsequent passes and independent validation"]]}],"claims":[{"claim_id":"S_IA-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C001","Precise assertion":"Compensated negotiation, creditor intermediation, distribution, settlement and educational-loan modification can constitute debt management","Evidence and pinpoint":"S001 §533A.1(2)–(3)","Confidence / limitation":"High for 2026 Code"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"Iowa-resident solicitation or contracting supplies statutory licensing nexus; debtor is a natural person","Evidence and pinpoint":"S001 §§533A.1(4), .2(1)","Confidence / limitation":"High; other-law coverage separate"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"Chapter 533A license required absent exemption; unlicensed operation unlawful","Evidence and pinpoint":"S001 §§533A.2(1), .13","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"Attorney, institutional, employee, gratuitous nonprofit and other exemptions are conditional","Evidence and pinpoint":"S001 §533A.2(2)(a)–(h)","Confidence / limitation":"High for statutory wording"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"Budget assessment, disclosures, contract and 60-month term limit apply to licensees","Evidence and pinpoint":"S001 §533A.8(1)–(4)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Primarily educational-loan management providers face full-performance-before-payment rule","Evidence and pinpoint":"S001 §533A.8A(1)–(4)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"Custodial additional fees capped at 15% of amounts actually applied","Evidence and pinpoint":"S002 §533A.9(3)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"Noncustodial additional fees capped at 18% of original enrolled debt","Evidence and pinpoint":"S002 §533A.9(4)(a)–(b)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"Percent-of-total-debt method uses equal installments and a completed-settlement proportional provision","Evidence and pinpoint":"S002 §533A.9(4)(b)(1)","Confidence / limitation":"High for formula; timing interaction held"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"Savings method uses $50 monthly installments credited against earned settlement fees; 30% savings-rate maximum","Evidence and pinpoint":"S002 §533A.9(4)(b)(2)","Confidence / limitation":"High for formula; federal collection restrictions separate"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"First-year discontinuation invokes 50% scheduled-installment retention and excess refund","Evidence and pinpoint":"S002 §533A.9(4)(b)(1)–(2)","Confidence / limitation":"High; completed-settlement interaction held"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"Third-party service costs cannot be imposed separately on consumers obtaining licensee services","Evidence and pinpoint":"S002 §533A.9(5)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"Covered TSR debt-relief fees require qualifying agreement, consumer payment and allocation","Evidence and pinpoint":"S006 §310.4(a)(5)(i)","Confidence / limitation":"High for reproduced rule text; coverage/current eCFR held"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"Qualifying dedicated-account deposits are distinct from earned provider fees","Evidence and pinpoint":"S006 §310.4(a)(5)(ii)","Confidence / limitation":"High for reproduced text"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Telemarketed credit-improvement claims may invoke separate fee restrictions","Evidence and pinpoint":"S006 §310.4(a)(2)","Confidence / limitation":"Conditional; CROA not resolved"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"Iowa Division of Banking provides an NMLS-based license lookup and identifies December 31 expiration","Evidence and pinpoint":"S004, License Search and License Types","Confidence / limitation":"High for operational page; provider status unverified"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"Initial statutory charges include $250 per office and $100 investigation; $25,000 office bond","Evidence and pinpoint":"S001 §533A.2(4), (6)","Confidence / limitation":"High for 2026 Code; other system charges held"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"ARC 0368D proposes replacing Chapter 20; final legal status not established","Evidence and pinpoint":"S005, notice heading and proposed rules","Confidence / limitation":"High that proposal exists; adoption unresolved"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"Custodial programs face an additional creditor-consent/distribution threshold before receiving non-initiation fees","Evidence and pinpoint":"S001 §533A.8(5)(d)","Confidence / limitation":"High; federal restrictions separate"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"Noncustodial debtor retains control/access to set-aside funds; licensee cannot receive related third-party consideration","Evidence and pinpoint":"S001 §533A.8(6)(a)–(b)","Confidence / limitation":"High"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"An Iowa license is not established for any specific company by this investigation","Evidence and pinpoint":"S004; no named-provider lookup performed","Confidence / limitation":"Confirmed research limitation"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"No verified 2026 post-compilation amendment or CPI adjustment was established","Evidence and pinpoint":"S001, S002; amendment investigation incomplete","Confidence / limitation":"Held, not proof of absence"},"coordinator_verification_status":"scoped_review_completed_with_source_currentness_and_applicability_limits;no_full_clearance","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"Proposed-rule settlement-completion definition requires verification against an adopted rule","Evidence and pinpoint":"S005 proposed 187—20.1","Confidence / limitation":"High that proposal contains language; operative status held"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"A noncustodial program's lawful collection schedule cannot be determined from Iowa fee ceilings alone","Evidence and pinpoint":"S002 §533A.9(4); S006 §310.4(a)(5)","Confidence / limitation":"High as conditional conclusion"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true},{"claim_id":"S_IA-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"Complete licensing and contract compliance cannot be certified without current rules and provider-specific evidence","Evidence and pinpoint":"S001 §§533A.2–.9; S004–S005","Confidence / limitation":"High as research limitation"},"coordinator_verification_status":"qualified_by_reviewed_later_passes_remaining_legal_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_passes":["pass-02","pass-03"],"coordinator_resolution_review":"[internal evidence reference]","original_researcher_record_preserved":true}],"sources":[{"source_id":"S_IA-P1-S001","urls":["https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf","https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S001","Authority and literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 533A. https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf","Pinpoint and version":"14-page official chapter; §§533A.1–.17; 2026 compilation, dated Dec. 9, 2025","Access, status and limitations":"Read: relevant definition, licensing, exemption, application, disclosure, fee and educational-loan passages. Current 2026 Code source; later amendment reconciliation incomplete. \nIowa Legislature"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S002","urls":["https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf","https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S002","Authority and literal URL":"Iowa Legislature, Iowa Code 2026, §533A.9. https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf","Pinpoint and version":"§533A.9(1)–(5), pages 1–2; compiled Dec. 12, 2025","Access, status and limitations":"Read: complete fee section, including both noncustodial methods, cancellation and third-party charges. Same statute as S001, separately published section file. \nIowa Legislature"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S003","urls":["https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026","https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S003","Authority and literal URL":"Iowa Legislature, 2026 Code section index. https://www.legis.iowa.gov/law/iowaCode/sections?codeChapter=533A&year=2026","Pinpoint and version":"Chapter 533A section listing","Access, status and limitations":"Discovery/index: establishes the official 2026 chapter structure, not post-compilation currency. \nCode Section Listings"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S004","urls":["https://idob.iowa.gov/finance/finance-license-verification","https://idob.iowa.gov/finance/finance-license-verification?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S004","Authority and literal URL":"Iowa Division of Banking, License Verification. https://idob.iowa.gov/finance/finance-license-verification","Pinpoint and version":"License Search; Debt Management license type and expiration","Access, status and limitations":"Read: official operational lookup guidance. No individual license result obtained. \nDivision of Banking"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S005","urls":["https://rules.iowa.gov/Notice/Details/0368D","https://rules.iowa.gov/Notice/Details/0368D?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S005","Authority and literal URL":"Iowa Administrative Rules, ARC 0368D. https://rules.iowa.gov/Notice/Details/0368D","Pinpoint and version":"Notice of Intended Action; proposed 187—20.1 through 20.6 passages inspected","Access, status and limitations":"Read: official proposal, including licensing and settlement-completion language. Not verified as adopted or operative. \nIowa Administrative Rules"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S006","urls":["https://www.law.cornell.edu/cfr/text/16/310.4","https://www.law.cornell.edu/cfr/text/16/310.4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S006","Authority and literal URL":"Cornell LII, 16 CFR §310.4. https://www.law.cornell.edu/cfr/text/16/310.4","Pinpoint and version":"§310.4(a)(2), (a)(5)(i)–(ii)","Access, status and limitations":"Read: federal regulatory republication. Federal timing text supported; direct current eCFR verification and applicability analysis incomplete. \nLII / Legal Information Institute"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S007","urls":["https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf","https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S007","Authority and literal URL":"U.S. Government Publishing Office, 16 CFR §310.4, 2023 edition. https://www.govinfo.gov/content/pkg/CFR-2023-title16-vol1/pdf/CFR-2023-title16-vol1-sec310-4.pdf","Pinpoint and version":"§310.4(a)(5)","Access, status and limitations":"Discovery: historical official federal text; not relied on to prove October 2026 currency. \nGovInfo"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S008","urls":["https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf","https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S008","Authority and literal URL":"NMLS, Iowa Debt Management Branch License New Application Checklist. https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_Branch_License-New-App-Checklist.pdf","Pinpoint and version":"Search-rendered checklist dated Oct. 4, 2022","Access, status and limitations":"Discovery only: direct open redirected to an NMLS landing page. Checklist contents and current procedural requirements not authenticated from the original PDF. \nNationwide Licensing System"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S009","urls":["https://www.legis.iowa.gov/docs/code/2018/533A.html","https://www.legis.iowa.gov/docs/code/2018/533A.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S009","Authority and literal URL":"Iowa Legislature, Iowa Code 2018, Chapter 533A. https://www.legis.iowa.gov/docs/code/2018/533A.html","Pinpoint and version":"Historical §§533A.1, .2, .8, .9 and others","Access, status and limitations":"Historical comparison: older statutory text found. Not controlling for 2026; later educational-loan provisions illustrate why historical tables cannot substitute for current text. \nIowa Legislature"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P1-S010","urls":["https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/","https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IA-P1-S010","Authority and literal URL":"Justia, Iowa Administrative Code 187—20.3. https://regulations.justia.com/states/iowa/agency-187/chapter-20/rule-187-20-3/","Pinpoint and version":"Application for License; publisher states current through June 25, 2025","Access, status and limitations":"Secondary discovery: insufficient to establish operative October 2026 rule version, particularly in light of ARC 0368D. \nJustia"},"coordinator_verification_status":"see_selected_actual_read_reuse_or_unchecked_scope_in_reviews/S_IA-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Definition of debt management","researcher_record":{"Component":"Definition of debt management","Status":"Answered","Claims":"C001","Exact missing evidence / next investigation":"Check post-compilation amendments"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Principal-reduction settlement","researcher_record":{"Component":"Principal-reduction settlement","Status":"Answered","Claims":"C001","Exact missing evidence / next investigation":"Later interpretive case-law review"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor concessions and DMPs","researcher_record":{"Component":"Creditor concessions and DMPs","Status":"Answered","Claims":"C001, C007","Exact missing evidence / next investigation":"Operative rules and application to hybrids"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial versus noncustodial classification","researcher_record":{"Component":"Custodial versus noncustodial classification","Status":"Partial","Claims":"C007–C010, C020","Exact missing evidence / next investigation":"Current rule text and mixed-provider structures"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer versus business debtor","researcher_record":{"Component":"Consumer versus business debtor","Status":"Partial","Claims":"C002","Exact missing evidence / next investigation":"Other Iowa regimes governing business-purpose services"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Remote-provider Iowa nexus","researcher_record":{"Component":"Remote-provider Iowa nexus","Status":"Answered at statutory level","Claims":"C002","Exact missing evidence / next investigation":"Enforcement and constitutional boundary cases later"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Commercial licensing pathway","researcher_record":{"Component":"Commercial licensing pathway","Status":"Answered at statutory level","Claims":"C003","Exact missing evidence / next investigation":"Current rules and company-specific status"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exemption","researcher_record":{"Component":"Attorney exemption","Status":"Partial","Claims":"C004","Exact missing evidence / next investigation":"Interpretive authority and actual business structures"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit/gratuitous exemption","researcher_record":{"Component":"Nonprofit/gratuitous exemption","Status":"Partial","Claims":"C004","Exact missing evidence / next investigation":"Donation arrangements and interpretation"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Financial institution and other exemptions","researcher_record":{"Component":"Financial institution and other exemptions","Status":"Partial","Claims":"C004","Exact missing evidence / next investigation":"Entity/activity verification"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Initial application and government fees","researcher_record":{"Component":"Initial application and government fees","Status":"Partial","Claims":"C017","Exact missing evidence / next investigation":"Current NMLS checklist and charges"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Public license lookup","researcher_record":{"Component":"Public license lookup","Status":"Answered as procedure","Claims":"C016","Exact missing evidence / next investigation":"Named-provider result if later requested"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Component":"Named provider authorization","Status":"Unresolved","Claims":"C021","Exact missing evidence / next investigation":"Actual NMLS record, Iowa authority and active status"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"One-time initiation ceiling","researcher_record":{"Component":"One-time initiation ceiling","Status":"Answered for 2026 Code","Claims":"C008, C024","Exact missing evidence / next investigation":"Independent federal collection timing"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial 15% ceiling","researcher_record":{"Component":"Custodial 15% ceiling","Status":"Answered for 2026 Code","Claims":"C007","Exact missing evidence / next investigation":"Current rule interpretation and federal timing"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial 18% ceiling","researcher_record":{"Component":"Noncustodial 18% ceiling","Status":"Answered for 2026 Code","Claims":"C008","Exact missing evidence / next investigation":"Later amendments and operative rules"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Percent-of-total-debt collection","researcher_record":{"Component":"Percent-of-total-debt collection","Status":"Partial","Claims":"C009, C011","Exact missing evidence / next investigation":"State/federal interaction and earned-fee accounting"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Percent-of-savings collection","researcher_record":{"Component":"Percent-of-savings collection","Status":"Partial","Claims":"C010, C011","Exact missing evidence / next investigation":"Monthly advance collection, credits and refund accounting"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Partial-settlement allocation","researcher_record":{"Component":"Partial-settlement allocation","Status":"Partial","Claims":"C009, C010, C013","Exact missing evidence / next investigation":"Completed-settlement meaning and actual performance"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation/refunds","researcher_record":{"Component":"Cancellation/refunds","Status":"Partial","Claims":"C011","Exact missing evidence / next investigation":"Combined installment and settlement-fee interpretation"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Third-party consumer charges","researcher_record":{"Component":"Third-party consumer charges","Status":"Answered for 2026 Code","Claims":"C012, C020","Exact missing evidence / next investigation":"Fact-specific affiliate arrangements"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Indexing/current adjustments","researcher_record":{"Component":"Indexing/current adjustments","Status":"Unresolved beyond code text","Claims":"C022","Exact missing evidence / next investigation":"Post-compilation laws and official notices"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Administrative Chapter 20 currency","researcher_record":{"Component":"Administrative Chapter 20 currency","Status":"Unresolved","Claims":"C018, C023","Exact missing evidence / next investigation":"Final adoption order, effective date, operative rules"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR debt-relief timing","researcher_record":{"Component":"Federal TSR debt-relief timing","Status":"Partial","Claims":"C013, C014","Exact missing evidence / next investigation":"Direct current eCFR and applicability/exceptions"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-repair overlap/CROA","researcher_record":{"Component":"Credit-repair overlap/CROA","Status":"Partial","Claims":"C015","Exact missing evidence / next investigation":"Current CROA provisions and specific representations"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational-loan fee timing","researcher_record":{"Component":"Educational-loan fee timing","Status":"Answered at statutory level","Claims":"C006","Exact missing evidence / next investigation":"Other applicable educational-loan rules"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Contract/funds/bond comprehensive review","researcher_record":{"Component":"Contract/funds/bond comprehensive review","Status":"Excluded","Claims":"C005, C017, C020","Exact missing evidence / next investigation":"Required later pass; limited provisions read for fee access"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, litigation, limitations, exemptions, secured debt","researcher_record":{"Component":"Collection, litigation, limitations, exemptions, secured debt","Status":"Excluded","Claims":"—","Exact missing evidence / next investigation":"Separate required passes"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Sector/local/tribal law and full case-law review","researcher_record":{"Component":"Sector/local/tribal law and full case-law review","Status":"Excluded","Claims":"—","Exact missing evidence / next investigation":"Separate required passes"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"A066/state acceptance","researcher_record":{"Component":"A066/state acceptance","Status":"Unresolved","Claims":"C025","Exact missing evidence / next investigation":"Full dossier, subsequent passes and independent validation"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}