{"meta":{"key":"s_ia--pass-04","task":"S_IA","title":"Iowa consumer-money custody, trust accounts, administrators, records, and returns","parent_title":"Iowa debt and debt relief law","edition":"pass-04","path":"/research/s_ia--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":25,"sources":7,"review_status":"scoped_review_complete_requested_corrections_addressed_with_holds","review_complete":true,"sha256":"a0a0f7d13b282c0b314a87685533ee7a2685aa52e97c3f416b91a53d1d1b3680","headings":["Iowa consumer-money custody, trust accounts, administrators, records, and returns","PASS-04 disposition","1.1 Activity, not the account label, controls","1.2 Account/model matrix","2.1 Verified Iowa custodial requirements","2.2 Deposit and remittance timing","2.3 Segregation, pooling, and commingling","2.4 Fees, deductions, and principal","2.5 Shortages, reversals, and pending payments","3.1 Consumer statements and account access","3.2 Required books and consumer ledger","3.3 Reconciliation cadence","3.4 Five years versus 36 months","Reconciliation","3.5 Cessation, surrender, and insolvency","4.1 General cancellation framework","4.2 Noncustodial accounts","4.3 Rejected proposals and failed settlements","4.4 Noncustodial cancellation-fee provisions","4.5 Educational-loan cancellation","5.1 Gateway rule","5.2 Reciprocal—but entity-specific—exemptions","5.3 Potential processor exemptions","5.4 Authorized-delegate trust is not the consumer trust account","5.5 Timely transmission and refund","Federal/state distinctions","S_IA-P4-E01 — Custodial account, no fee deducted","S_IA-P4-E02 — Fee already deducted and posted once","S_IA-P4-E03 — Rejected settlement proposal","S_IA-P4-E04 — Federal dedicated account and no double subtraction","Case A — Earned fee remains inside current account balance","Case B — Same fee was already withdrawn","S_IA-P4-E05 — Separate Chapter 533C transmitter","S_IA-P4-E06 — Sum-certain accumulation","S_IA-P4-E07 — Records-period reconciliation","Actually read or re-read in PASS-04","Reused from reviewed P1–P3","Targeted searches that did not produce relied-on authority","Not read or not established"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_IA/pass-04","facets":{"geography":["us","us-ia"],"debt_type":[],"stage":["repossession"],"subject":["client-money"]},"scope":"ReviewedP1remainingIowafunds/trust/account/administrator/return component plusactual36month/fiveyearrecordsgap; P2/P3completion/renewal/currentness/provider/broaderholdsretained.","pending_corrections":0},"markdown":"# SettleADebt S_IA PASS-04\n\n## Iowa consumer-money custody, trust accounts, administrators, records, and returns\n\n**Actual fresh research date:** October 25, 2026, Pacific; October 26, 2026 UTC\n**Review relationship:** Same-coordinator continuation of the saved P1–P3 work; **not independent review**.\n**Preserved:** All immutable P1–P3 findings, examples, calculations, date corrections, proposal-status limitations, provider and contract holds, post-compilation holds, and later-pass categories.\n\nThis pass does **not** reopen Iowa’s fee ceilings or rerun the seven prior fee examples. Fee provisions appear only where necessary to determine whether money may leave a consumer-money account or must be returned.\n\n## PASS-04 disposition\n\nIowa’s current compiled framework creates two materially different money models:\n\n1. **Custodial model:** If the program requires the licensee—or any Iowa debt-management licensee—to receive money from the debtor for creditor distribution, the receiving licensee must use a separate bank trust account, deposit all creditor-benefit payments into it, keep those payments there until remitted to the debtor or creditor, comply with creditor-remittance timing, and maintain consumer-level statements and ledgers.\n2. **Noncustodial model:** If the program does not require any licensee to receive consumer money for creditor distribution, the debtor must retain full control of and access to the money set aside for creditors. Merely calling an account “consumer owned,” using an independent administrator, locating the administrator outside Iowa, or giving the account a trust label does not establish this classification. Actual control and payment authority remain fact-dependent. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nA separate administrator or processor is not automatically covered by the provider’s Iowa exemption or license. If that separate entity receives money from an Iowa consumer for transmission, Chapter 533C supplies an independent licensing, authorized-delegate, or exemption gateway. Each entity and each activity must be classified separately. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nThe clearest remaining operational defect is the records-period mismatch. Iowa Code §533A.8(7) requires at least **five years after the final entry on a transaction**, while compiled Rule 20.9 says at least **36 months after the final transaction with the debtor**. The 36-month rule cannot be used to shorten the express five-year statutory minimum. Exact trigger-edge cases and the treatment of purely nontransactional records remain held because no controlling Iowa interpretation resolving the differing language was located. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n# 1. Custody classification and actual control\n\n## 1.1 Activity, not the account label, controls\n\nIowa’s definition of debt management expressly includes receiving money from a debtor **directly or indirectly** for distribution to one or more creditors. It also separately includes negotiation, creditor intermediation, and debt settlement. “Fee” excludes creditor principal held for distribution and money distributed back to a debtor as a refund, which confirms that held principal and provider compensation must remain separate in the accounting. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nFor operational purposes:\n\n- A payment to only **one** creditor can still be covered; the statute says “one or more creditors.”\n- A remote headquarters does not determine custody.\n- A consumer’s name on an account is relevant but does not alone establish full control.\n- A separate account administrator does not establish noncustody if a licensee directly or indirectly controls withdrawals, payment instructions, freezes, fee releases, or creditor remittances.\n- A single payment to a creditor does not by itself establish a completed Iowa settlement. Iowa separately prohibits representing a payment as settling a debt without creditor written confirmation that the payment is full settlement or part of a full-settlement payment plan. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nNo controlling Iowa administrative interpretation or court decision defining “indirectly,” “full control,” or “access” for a modern third-party settlement-account platform was located in the official routes checked. Therefore, an actual account must be classified from its agreements and operating permissions rather than its marketing label.\n\n## 1.2 Account/model matrix\n\n| Account or payment model | Iowa Chapter 533A classification | Required money treatment | Separate Chapter 533C issue | Status and material facts still needed |\n| --- | --- | --- | --- | --- |\n| **Licensee directly receives monthly DMP payments for creditor distribution** | Custodial under §533A.8(5) | Receiving licensee must maintain the separate bank trust account, deposit all creditor-benefit payments, remit under the 45/30-day framework, issue monthly statements, and maintain a per-debtor ledger. | The licensed/exempt debt-management person has a Chapter 533C exemption for the covered debt-management activity, but that does not eliminate Chapter 533A duties. | Statutory classification answered. Actual bank, account title, signers, and transaction records unverified. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **A second Iowa debt-management licensee receives the money** | Still custodial; §533A.8(5) expressly reaches a model in which “the licensee or any licensee” receives funds. | The receiving licensee bears the account, remittance, statement, and ledger duties. The first licensee cannot cause another licensee to receive fees outside the statutory predicates. | Each entity’s actual authority and contractual role must be established. | Statutory allocation answered; actual intercompany contracts and licenses held. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Consumer sends payments directly to creditors or operates personal bill pay** | Potentially noncustodial if no licensee directly or indirectly receives money for distribution. | Debtor must retain full control and access; provider does not make creditor payments on the debtor’s behalf. | A neutral bank’s ordinary consumer payment service may implicate separate banking or payment-system rules, not resolved here. | Classification depends on provider access, payment authority, and reimbursement facts. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Consumer-titled dedicated account administered by an independent entity** | Potentially noncustodial only if no licensee directly or indirectly receives the money and the debtor genuinely retains full control and access. | Iowa does not, merely from the account title, establish that the administrator can release money or fees without debtor control. | Administrator may need a Chapter 533C license, authorized-delegate status, or a fact-specific exemption. Federal dedicated-account conditions may also apply. | Account agreement, withdrawal rights, signature authority, fee-release instructions, affiliation, referral compensation, and loss allocation required. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Consumer-titled account but provider or affiliate can unilaterally direct withdrawals or fee releases** | Significant risk of direct or indirect receipt/control; noncustodial status is not established. | If facts amount to a licensee receiving funds for creditor distribution, the custodial trust-account duties apply. | Affiliated administration also fails the federal dedicated-account independence condition when the TSR applies. | Iowa has no located bright-line interpretation; actual agreements and system permissions are indispensable. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Independent processor receives consumer money and forwards it to creditors** | Processor’s pure transmission activity may fall outside Chapter 533A under §533A.2(2)(h), but the debt-management provider’s own duties are not transferred automatically. | Provider must still satisfy whichever Chapter 533A model its actual conduct creates. | Processor independently needs a Chapter 533C license, authorized-delegate relationship, or applicable exemption. | Processor identity, license, delegate contract, receipts, payee agreements, and actual loss allocation unverified. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Provider receives only its service fee; consumer principal never enters provider-controlled channels** | The creditor-principal trust-account clause may not apply to the fee-only receipt, but all fee-contract, fee-timing, credit, and refund provisions remain applicable. | Consumer principal must remain outside licensee receipt/control for the model to remain noncustodial. | The fee processor’s own money-transmission status remains fact-dependent. | Actual payment flow and whether the fee processor receives money as agent of the provider must be documented. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **Educational-loan modification service** | Educational-loan rules are additional, not exclusive. If the provider also receives money for creditor distribution, ordinary Chapter 533A custody rules continue to apply. | Provider cannot request or receive compensation, or require payment to a third party, until full performance of all promised services. | Separate processor questions remain entity-specific. | Actual service scope and money flow required; no assumption that student-loan status displaces trust duties. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n\n# 2. State trust-account and money-handling requirements\n\n## 2.1 Verified Iowa custodial requirements\n\nWhen the custodial branch applies, the receiving licensee must:\n\n1. Maintain a **separate bank trust account**.\n2. Deposit into it all payments received from debtors for creditors’ benefit.\n3. Keep the payments there until remitted to either the debtor or the creditor.\n4. Make the first creditor remittance within 45 days after initial receipt.\n5. Make later creditor remittances within 30 days of receipt.\n6. Deduct only fees that are otherwise legally collectible.\n7. Use the longer-hold exception only where the reasonable payment of an obligation requires accumulation of a definite sum.\n8. Give the debtor a monthly written statement of disbursements and deducted fees.\n9. Give a verbal accounting of disbursements and fees whenever requested during normal business hours.\n10. Observe the creditor-consent or accepted-distribution condition before receiving non-initiation fees under the custodial branch. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe trust-principal definition matters. Iowa’s definition of “fee” excludes money paid to or held by the licensee for creditor distribution and excludes a distribution to the debtor as a refund. Creditor principal cannot be relabeled as compensation merely because it is in the same operational platform. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 2.2 Deposit and remittance timing\n\nThe statute commands that all covered receipts be deposited into the trust account, but the reviewed Chapter 533A and Chapter 20 text does **not** specify a fixed number of hours or days between receipt and bank deposit. That deposit-timing detail remains unresolved.\n\nThe creditor-remittance timing is explicit:\n\n- Initial remittance: within 45 days after initial receipt.\n- Later remittances: within 30 days of receipt.\n- Exception: a longer hold where reasonable payment requires accumulating a definite sum. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe accumulation exception is not unlimited storage authority. Its application requires at least an identified obligation, a definite required amount, and facts showing why waiting is reasonably necessary. The statute does not supply a maximum extended period, approval mechanism, or presumption that every planned settlement justifies the delay.\n\n## 2.3 Segregation, pooling, and commingling\n\nThe requirement for a **separate bank trust account** is a segregation command: creditor-benefit money must go into the trust account rather than an ordinary operating account. The operative text does not expressly answer whether:\n\n- Each debtor must have an individual bank account.\n- Multiple debtors may be carried in one omnibus trust account.\n- Separate subaccounts are required.\n- A credit union account qualifies as the required “bank” account.\n- The account must be located in Iowa.\n- A particular account-title formulation is mandatory.\n- The consumer, provider, creditors, or another person has beneficial ownership for all non-Chapter-533A purposes.\n- Any interest belongs to the debtor, provider, or trust.\n- The balance receives FDIC pass-through coverage.\n- Consumer money has bankruptcy priority.\n- An account reserve or minimum balance is permitted.\n\nThe compiled rule requires a separate **consumer-level ledger** even though it does not specify one bank account per debtor. Thus, a pooled architecture, if otherwise permissible, still must permit exact attribution of every receipt, creditor payment, fee, correction, and current balance to the individual debtor. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nNo state-law conclusion about deposit insurance, pass-through coverage, bankruptcy priority, interest ownership, or credit-union eligibility is made in this pass.\n\n## 2.4 Fees, deductions, and principal\n\nThe words “less fees” in §533A.8(5)(b) do not independently authorize a withdrawal. Before a fee can reduce trust principal, the fee must satisfy all applicable predicates, including:\n\n- The written contract’s charge and payment terms.\n- The applicable Chapter 533A fee method and limit.\n- The custodial creditor-consent or accepted-distribution condition, except where the initiation-fee branch applies.\n- Any required Iowa settlement-completion condition.\n- Any independently applicable federal fee-timing requirements.\n- Proper posting to the consumer ledger on the actual collection date. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.html)\n\nA fee already deducted and posted is not deducted again when calculating the balance to return. Conversely, a fee that was never legally earned does not become earned merely because it was previously withdrawn.\n\nIowa also prohibits deducting a requested donation from a creditor payment, the debtor’s account, or payments made under the debt-management contract. Third-party services used to obtain the licensee’s services generally must be paid for by the licensee, apart from the debtor’s own banking fees. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.html)\n\n## 2.5 Shortages, reversals, and pending payments\n\nThe reviewed Chapter 533A provisions do not allocate loss from:\n\n- Returned ACH entries.\n- Reversed card payments.\n- Dishonored checks.\n- Bank failure.\n- Fraudulent account access.\n- Processor insolvency.\n- Creditor-payment rejection.\n- Negative trust balances.\n\nRule 20.9 does require all transactions to be described and corrections to be made by corrective entry rather than erasure. That establishes traceability but not substantive loss allocation. Any example below therefore assumes no pending ACH entries, checks, reversals, chargebacks, accrued interest, or unidentified shortages unless explicitly stated. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\n# 3. Statements, ledgers, access, examinations, and retention\n\n## 3.1 Consumer statements and account access\n\nA custodial licensee must give each debtor:\n\n- A monthly written statement of disbursements and deducted fees.\n- A verbal accounting of disbursements and deducted fees whenever the debtor requests it during normal business hours. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe statute does not prescribe a monthly statement form, delivery medium, beginning balance, ending balance, pending-transaction field, or reconciliation certification. Those are operational gaps, not permission to omit transaction information needed to explain the account.\n\n## 3.2 Required books and consumer ledger\n\nCompiled Rule 20.9 requires the licensee to keep at its principal place of business:\n\n- An index.\n- A chronological active/inactive client log.\n- An account file.\n- An account ledger.\n\nRecords must be accessible by debtor name and account number. The client log must show opening, closing, and expiration dates. The account file contains the application, budget/debt review, contract, and disclosures. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nFor a custodial program, the per-debtor ledger must show:\n\n- Debtor name and address.\n- Account number.\n- Outstanding debts.\n- Total payments made to the licensee.\n- Every debtor and creditor transaction.\n- Debtor receipts posted effective on their receipt date.\n- Creditor payments posted effective on their payment date.\n- Payment amount and application.\n- Fees posted effective on their collection date.\n- Total fees collected.\n- Full descriptions of other transactions.\n- Corrections through corrective entries, not erasure. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nThe general business records include checkbooks, registers, bank statements, deposit and withdrawal slips, cancelled checks, support for expenses and fees, compensation records, bond records, audits, examinations, and Iowa-directed advertising. The superintendent can examine the licensee’s books, accounts, records, and files as often as considered necessary. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\n## 3.3 Reconciliation cadence\n\nThe reviewed Chapter 533A and Chapter 20 provisions require source records and transaction-level posting but do not prescribe an express daily, weekly, or monthly trust-account reconciliation cadence.\n\nA separate Chapter 533C money-transmission licensee must maintain, among other records, a general ledger posted at least monthly and bank statements and bank-reconciliation records. That requirement belongs to the Chapter 533C entity; it is not automatically a substitute for the debt-management licensee’s Chapter 533A ledger. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\n## 3.4 Five years versus 36 months\n\nThe two relevant texts are:\n\n- **Statute:** at least five years after the final entry on any recorded transaction.\n- **Rule:** at least 36 months from the final transaction with the debtor; general business records also carry a 36-month statement. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n### Reconciliation\n\nThe provisions can be obeyed together by retaining overlapping transaction and compliance records for at least the longer statutory period. Iowa’s Administrative Procedure Act states that an agency has only delegated authority and that rulemaking authority is construed narrowly. Consequently, the compiled rule is not a safe harbor for destroying records before the express statutory five-year minimum expires. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/17A.html)\n\nOperationally:\n\nEarliest destruction date for a §533A.8(7) record≥final entry date+5 years\\text{Earliest destruction date for a §533A.8(7) record}\n\\geq\n\\text{final entry date} + 5\\text{ years}Earliest destruction date for a §533A.8(7) record≥final entry date+5 yearsThe following remain unresolved:\n\n- Whether a “final transaction with the debtor” and the “final entry on any transaction” are the same event in a particular file.\n- Whether a later corrective entry restarts the statutory five-year period.\n- Which general-business records, if wholly unrelated to a recorded consumer transaction, fall within the statute’s broader books-and-records language.\n- Whether another statute or litigation hold requires longer retention.\n\nNo authoritative Iowa agency or court reconciliation of those trigger differences was located. The conservative traceability rule is to retain covered records until at least five years after the latest relevant final entry and longer where another applicable duty requires.\n\n## 3.5 Cessation, surrender, and insolvency\n\nRule 20.9 expressly continues the record-maintenance obligation after a licensee ceases Iowa operations or surrenders its license; owners and directors remain responsible. Disposal at the end of the applicable retention period must reasonably safeguard identifying information. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nA licensee must report bankruptcy or reorganization immediately and in writing within ten days. Insolvency can support discipline, and the compiled rule calls for immediate revocation when the licensee is found insolvent. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.html)\n\nThe reviewed provisions do **not** establish a complete consumer-money wind-down protocol. They do not expressly identify:\n\n- A successor trust-account administrator.\n- A mass-return deadline.\n- Required consumer notice specific to trust-account closure.\n- Superintendent preapproval of a transfer.\n- Bankruptcy priority.\n- A permitted setoff.\n- A special insolvency reserve.\n- Who bears processor or bank losses.\n\nNothing located converts held creditor principal into provider property because operations cease. The funds remain subject to the applicable trust and remittance duties, but the exact wind-down mechanism remains held.\n\n# 4. Cancellation, failed plans, and return of money\n\n## 4.1 General cancellation framework\n\nThe contract must state the agreed fee and the provision for settlement of the parties’ account upon cancellation. The consumer must be told that participation may be discontinued without penalty. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.html)\n\nFor a custodial account, §533A.8(5)(a) supplies the money path: payments remain in the trust account until remitted to either the debtor or the creditor. Thus, on cancellation, the current held principal does not become a provider fee. It remains trust money until one of those remittances occurs. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nNo fixed number-of-days state return deadline was located in the reviewed Chapter 533A custody/cancellation clauses or compiled Chapter 20. The contract’s cancellation-settlement provision is therefore important, but it cannot create a fee or forfeiture contrary to the statute.\n\n## 4.2 Noncustodial accounts\n\nIn a genuine noncustodial model, the provider should not possess creditor principal to return. The debtor already retains full control and access. Ending the provider’s service is legally and operationally different from:\n\n- Revoking an ACH authorization.\n- Cancelling a scheduled transfer.\n- Closing the bank account.\n- Directing the account administrator to return funds.\n- Terminating a bank-account agreement.\n\nFederal or Chapter 533C return duties may govern the administrator, but those duties do not prove Iowa noncustodial classification.\n\n## 4.3 Rejected proposals and failed settlements\n\nA rejected creditor proposal is not a completed settlement. Under the previously established compiled Rule 20.1, Iowa’s completed-settlement fee branch requires all payments necessary to satisfy the debt to have been remitted to the creditor. A proposed settlement, creditor discussion, creditor consent to account handling, or one consumer payment does not satisfy that full-remittance condition by itself.\n\nFor money tracing:\n\n- Funds not yet remitted remain current held principal.\n- A rejected proposal does not itself create a settlement-completion fee.\n- A creditor’s acceptance of one distribution for the separate §533A.8(5)(d) creditor-count condition does not necessarily mean the debt has been settled.\n- A previously deducted fee must be tested independently for lawful earning and timing.\n\n## 4.4 Noncustodial cancellation-fee provisions\n\nIowa’s noncustodial provisions stop future installments after effective notice, impose the first-12-month retention/refund calculation, require prior monthly savings-method collections to be credited against earned settlement fees, and separately recognize a completed-settlement fee branch. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.html)\n\nThis pass does not resolve the prior open question about combining the installment-retention calculation with a completed-settlement calculation. In particular:\n\n- P1 E05’s assumed earlier collections may have been prohibited under federal timing rules.\n- P1 E06 remains a scalar cancellation illustration.\n- P1 E07’s separate $300 and $150 calculations do not create a $450 entitlement.\n- No prior remittance or previously deducted fee may be subtracted twice.\n- Numeric equality is not proof that a fee was legally earned.\n\n## 4.5 Educational-loan cancellation\n\nFor a licensee primarily engaged in educational-loan debt management:\n\n- The specific three-business-day cancellation right applies.\n- The provider cannot demand, receive, or require third-party payment for its services before full performance.\n- These requirements are additional to other applicable Chapter 533A duties.\n- If the provider receives consumer money for creditor distribution, the general custodial provisions remain relevant. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe educational-loan cancellation provision does not itself establish a separate deadline for returning creditor principal already received into a custodial account.\n\n# 5. Independent administrators and Iowa money transmission\n\n## 5.1 Gateway rule\n\nChapter 533C defines money transmission to include receiving money for transmission from a person located in Iowa. “Receiving money for transmission” includes receipt in the United States for transmission by electronic or other means. A person generally may not engage in or advertise money transmission without a Chapter 533C license unless acting within a licensed authorized-delegate relationship or within a statutory exemption. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nA separate administrator that receives Iowa consumer money and forwards it to a creditor, debt-management provider, settlement account, or other recipient therefore requires an independent Chapter 533C analysis.\n\n## 5.2 Reciprocal—but entity-specific—exemptions\n\nThe two chapters contain reciprocal activity exemptions:\n\n- Chapter 533C exempts a person engaging in debt management who is licensed or exempt under §533A.2.\n- Chapter 533A exempts a Chapter 533C licensee, authorized delegate, or exempt person when engaging in money transmission. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nThose provisions do not merge the entities or transfer one company’s status to another. A licensed debt-management provider’s Chapter 533C exemption does not automatically exempt an independent administrator. Conversely, a money transmitter’s exemption from Chapter 533A for pure transmission does not authorize that entity to negotiate debts, make debt-settlement representations, or operate outside its transmission role.\n\n## 5.3 Potential processor exemptions\n\nPossible Chapter 533C pathways are conditional:\n\n| Potential pathway | Required predicates | Why it cannot be assumed |\n| --- | --- | --- |\n| **Authorized delegate** | Written contract with a Chapter 533C licensee; activity within delegated scope; required policies, background review, compliance, records, and examination consent. | A software integration or processor agreement is not necessarily an authorized-delegate appointment. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **Intermediary processor** | The primary entity must itself be licensed or exempt, identify itself to the sender as the transmission provider, and bear sole responsibility to satisfy the transmission obligation and make the sender whole. | A processor that bears consumer loss, or cannot identify the liable transmitting entity, may fail the conditions. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **Payment-system operator** | Processing, clearing, or settlement between excluded persons or licensees in connection with ACH, card, wire, stored-value, or similar transfers. | Merely using ACH does not prove operator status or that the parties on both sides satisfy the provision. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **Agent of payee** | Written payee-agent agreement; payee publicly holds the agent out; consumer payment is treated as received by the payee and extinguishes the obligation without consumer loss if the agent fails to remit. | A settlement savings-account administrator normally cannot be assumed to be the creditor’s agent or to extinguish the debt on receipt. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **Employee** | Individual employee acting within employment and under supervision; independent contractors are excluded from this employee provision. | Corporate affiliates and independent processors do not qualify merely because they perform functions for the provider. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **Service provider to federally insured depository institution** | Specific written appointment and functions; the exempt institution assumes all risk and legal responsibility for the outstanding transmission obligations. | Bank sponsorship, account location, or API access alone does not establish the required risk assumption. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n\nThe superintendent may require a person claiming exemption to provide documentation establishing it. No exemption is inferred from a website statement or account label. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\n## 5.4 Authorized-delegate trust is not the consumer trust account\n\nAn authorized delegate holds money received from transmission, net of fees, in trust **for the Chapter 533C licensee**. If the delegate commingles those funds with other property, the statute treats the commingled property as held in trust for the licensee to the relevant amount. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nThat provision does not by itself establish:\n\n- Consumer ownership.\n- Compliance with §533A.8(5)’s separate bank trust account.\n- Federal dedicated-account compliance.\n- FDIC pass-through coverage.\n- A consumer right to interest.\n- Bankruptcy priority.\n- Lawful deduction of the debt-management provider’s fee.\n\nA Chapter 533C delegate also cannot appoint a subdelegate. On suspension, revocation, surrender, or expiration of the transmitting licensee’s license, the applicable delegates must immediately stop operating as delegates. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\n## 5.5 Timely transmission and refund\n\nA covered Chapter 533C licensee must forward money according to its agreement with the sender unless it has a reasonable fraud or illegality concern. It must explain a failure to forward when permitted by law. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nSection 533C.702 generally requires refund within ten days after receiving the sender’s written request, but exceptions include:\n\n- Funds already forwarded within the statutory period.\n- Instructions committing an equivalent amount to the designated recipient.\n- A later transmission time specified by agreement.\n- Reasonable crime or legal-violation concerns.\n- Inability to identify the sender or transaction.\n- Transfers governed by the federal remittance-transfer rule.\n- Certain written licensee-payee payment-processing agreements. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\nThis ten-day rule is **not** automatically a return deadline for a Chapter 533A debt-management provider because Chapter 533C expressly exempts qualifying debt-management persons. It applies only after the actual entity and transaction are shown to be governed by Chapter 533C.\n\nNo administrator, processor, provider, bank, authorized delegate, or exemption was verified for any actual business in this pass.\n\n# 6. Conditional federal dedicated-account overlay\n\nFor debt-relief services within the federal Telemarketing Sales Rule, §310.4(a)(5)(ii) permits requiring funds in an account only when:\n\n1. The account is at an insured financial institution.\n2. The customer owns the funds.\n3. The customer receives accrued interest, if any.\n4. The account administrator is not owned, controlled by, or affiliated with the debt-relief service.\n5. The administrator neither gives nor accepts compensation for debt-relief-service referrals.\n6. The consumer can withdraw from the service at any time without penalty.\n7. Within seven business days of the consumer’s request, the consumer receives all account money except fees earned in compliance with all three federal fee conditions. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe three incorporated federal earning conditions are:\n\n- An executed valid agreement altering at least one debt.\n- At least one customer payment under that agreement.\n- A permitted proportional-debt or consistently applied percentage-of-savings allocation. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## Federal/state distinctions\n\n| Issue | Federal conditional rule | Iowa rule | Required treatment |\n| --- | --- | --- | --- |\n| Account institution | Insured financial institution | Separate **bank** trust account for the custodial Iowa model | Do not infer that satisfying one term automatically satisfies the other. |\n| Ownership | Customer owns dedicated-account money | Chapter 533A says funds remain in trust until remitted to debtor or creditor but does not specify all beneficial-ownership consequences | Do not infer bankruptcy priority or pass-through insurance. |\n| Interest | Customer receives accrued interest, if any | No interest-allocation clause located in the reviewed Chapter 533A provisions | Federal condition controls only if TSR applies. |\n| Administrator affiliation | Must be independent and nonaffiliated | Iowa classification turns on whether a licensee directly or indirectly receives money and whether the debtor retains full control/access | Both tests may matter. |\n| Fee earning | Valid alteration, one customer payment, and permitted allocation | Iowa completed-settlement fee branch requires the previously verified full creditor remittance | One federal customer payment does not satisfy Iowa’s full-remittance completion requirement. |\n| Return | Seven business days after service-withdrawal request | No fixed Chapter 533A number-of-days return rule located | Apply the seven-day rule only where federal coverage and account predicates are established. |\n\nThe federal requirement to return account money after withdrawal from the **service** is not automatically an order to close the bank account, cancel every pending ACH authorization, or terminate the separate account agreement. Those operational actions depend on the bank and administrator agreements.\n\nFull federal coverage, exemptions, outbound versus inbound call facts, sales-channel facts, and CROA overlap remain held.\n\n# 7. Bounded ledger examples\n\nAll amounts are in U.S. dollars and shown to two decimal places. These examples assume no interest, pending ACH entries, uncashed checks, reversals, chargebacks, bank fees, unidentified deposits, or shortages unless stated. Arithmetic equality is not legal permission or proof of an actual bank balance.\n\n## S_IA-P4-E01 — Custodial account, no fee deducted\n\nPlain text\n```\nConsumer receipts posted:                 $1,200.00\nCompleted creditor remittances posted:      -800.00\nFees collected:                                0.00\nOther posted transactions:                     0.00\n                                         -----------\nCurrent held trust balance:                 $400.00\n```\n\nIf the consumer cancels and no further creditor remittance is authorized or committed, the traced principal is **$400.00**. It must remain in the trust account until remitted to the debtor or creditor. The prior $800 creditor payment is not subtracted a second time.\n\n**Conditional debtor return amount:** $400.00.\n**State deadline:** Not established as a fixed number of days in the reviewed Chapter 533A provisions.\n**Legal limitation:** Contract terms, pending payment facts, and any applicable federal rule must still be checked. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P4-E02 — Fee already deducted and posted once\n\nAssume, solely for this example, that a $150 fee satisfied every applicable contractual, Iowa, creditor-count, completion, amount, and federal timing predicate.\n\nPlain text\n```\nConsumer receipts posted:                 $2,000.00\nCompleted creditor remittances posted:    -1,250.00\nFee already collected and posted:           -150.00\nOther posted transactions:                     0.00\n                                         -----------\nCurrent held trust balance:                 $600.00\n```\n\nOn cancellation, the current held balance is **$600.00**, not $450.00. The $150 fee was already removed and cannot be deducted again.\n\nIf the $150 fee did **not** satisfy the applicable predicates, the potential principal/refund exposure would be:\n\nPlain text\n```\nCurrent held balance:                       $600.00\nPotential restoration of unlawful fee:      +150.00\n                                         -----------\nPotential consumer amount:                  $750.00\n```\n\nThat $750 figure is only a tracing result. Whether restoration, restitution, damages, or another remedy applies is outside this pass and remains held.\n\n## S_IA-P4-E03 — Rejected settlement proposal\n\nPlain text\n```\nConsumer receipts posted:                 $1,100.00\nCreditor remittances posted:                   0.00\nLawfully earned and collected fee:             0.00\n                                         -----------\nCurrent held trust balance:               $1,100.00\n```\n\nAssumptions:\n\n- The provider proposed a settlement.\n- The creditor rejected it.\n- No payment was committed or remitted.\n- No independent initiation-fee issue is included.\n\nA rejected proposal does not establish completed settlement. The $1,100 remains principal; no settlement fee is deducted merely because negotiations occurred.\n\n**Conditional debtor return amount:** $1,100.00.\n**Possible federal timing:** Seven business days only if the account and transaction satisfy the federal dedicated-account rule. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## S_IA-P4-E04 — Federal dedicated account and no double subtraction\n\nAssume the TSR applies and every account predicate is satisfied.\n\n### Case A — Earned fee remains inside current account balance\n\nPlain text\n```\nCurrent bank-account balance:             $1,200.00\nFee established as earned under all\napplicable state and federal conditions:    -200.00\n                                         -----------\nAmount returned within federal period:    $1,000.00\n```\n\n### Case B — Same fee was already withdrawn\n\nPlain text\n```\nBalance before fee withdrawal:            $1,200.00\nFee already withdrawn:                      -200.00\n                                         -----------\nCurrent bank-account balance:             $1,000.00\n\nFurther deduction at return:                    0.00\nAmount returned:                          $1,000.00\n```\n\nThe return is not $800.00. The same fee cannot be removed twice.\n\nIf the $200 was not lawfully earned under both applicable federal and state conditions, the federal exclusion for earned fees is not established.\n\n## S_IA-P4-E05 — Separate Chapter 533C transmitter\n\nAssume:\n\n- The independent administrator is actually governed by Chapter 533C.\n- It received $900 for transmission.\n- It has not forwarded or committed any of that money.\n- The sender made an identifiable written refund request.\n- None of §533C.702’s exceptions applies.\n\nPlain text\n```\nMoney received for transmission:            $900.00\nForwarded:                                     0.00\nCommitted to recipient:                        0.00\n                                         -----------\nRefund under assumed facts:                  $900.00\n```\n\n**Conditional deadline:** Within ten days after receipt of the written request.\n\nThe example fails if the administrator is not governed by Chapter 533C, the funds have been forwarded or committed, a later transmission date controls, an identification problem exists, or another statutory exception applies. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf)\n\n## S_IA-P4-E06 — Sum-certain accumulation\n\nAssume:\n\nPlain text\n```\nFirst consumer receipt:                     $500.00\nDocumented creditor lump-sum requirement: $1,000.00\nSecond expected receipt:                    $500.00\nCurrent creditor remittance:                  $0.00\nFee deduction:                                $0.00\n                                         -----------\nCurrent held trust balance:                 $500.00\n```\n\nThe statute can permit a longer hold only if a reasonable creditor payment actually requires accumulating the $1,000 sum. The example does not prove:\n\n- That the creditor agreed to the amount.\n- That waiting is reasonable.\n- That an unlimited delay is permitted.\n- That a fee has been earned.\n- That the first $500 may be forfeited if the second deposit never arrives.\n\nIf the consumer cancels before accumulation, the $500 remains current held principal unless and until it is properly remitted to the debtor or creditor.\n\n## S_IA-P4-E07 — Records-period reconciliation\n\nPlain text\n```\nFinal consumer transaction:                T0\nLater final ledger/corrective entry:        T1\nRule 20.9 minimum date:                     T0 + 36 months\nStatutory §533A.8(7) minimum date:          T1 + 5 years\nOperational destruction floor:             Not before T1 + 5 years\n```\n\nThis example assumes T1 is the final entry on the recorded transaction. If another correction, reversal, disbursement, or charge is posted later, that later entry must be evaluated as the possible statutory trigger.\n\n# Account-flow decision record\n\nFor any proposed Iowa account architecture, the following facts are necessary before assigning a custodial, noncustodial, or transmission classification:\n\n| Required fact | Why it matters |\n| --- | --- |\n| Legal account owner and exact title | Relevant to federal ownership and state trust architecture, but not dispositive alone |\n| Bank or credit-union identity and charter | Iowa says “bank”; federal rule says insured financial institution |\n| All authorized signers | Shows who can move money |\n| Consumer’s unilateral withdrawal rights | Central to Iowa full-control/access and federal dedicated-account status |\n| Provider’s withdrawal, freeze, or instruction rights | May show direct or indirect receipt/control |\n| Administrator ownership and affiliation | Federal independence condition |\n| Referral compensation | Federal administrator condition and Iowa third-party-compensation issues |\n| ACH origination and revocation authority | Determines actual payment control; not inferred from account title |\n| Fee-release process | Shows who determines and executes fee collection |\n| Creditor-payment instructions | Identifies sender, transmitting entity, and actual obligation |\n| Risk of loss if administrator fails | Material to Chapter 533C intermediary, payee-agent, and bank-service-provider exemptions |\n| Written payee or bank agreement | Required for several Chapter 533C exemptions |\n| Provider and administrator licenses/delegate records | Necessary to establish each entity’s authority |\n| Consumer statements and transaction ledger | Necessary to reconcile current held principal and prior deductions |\n| Pending checks, ACH transactions, reversals, and chargebacks | Necessary to calculate the actual current balance |\n| Cancellation notice and contract settlement clause | Necessary to determine the authorized return path |\n| Creditor settlement agreement and payment record | Necessary to establish Iowa completion and any fee predicate |\n\nWithout those materials, “consumer owned,” “FDIC insured,” “independent administrator,” “trust,” “remote processor,” and similar labels remain unverified representations rather than legal conclusions.\n\n# Source register — S_IA-P4-S001+\n\nAll fresh PASS-04 access occurred October 25, 2026 Pacific, corresponding to October 26 UTC. Exact per-source fetch timestamps were not independently recovered and are not invented.\n\n| Source ID | Primary source, issuer, and full literal URL | Exact passage used | Version/effective status | Access status and limitations |\n| --- | --- | --- | --- | --- |\n| **S_IA-P4-S001** | Iowa Legislature, **Iowa Code 2026, Chapter 533A — Debt Management**. PDF: https://www.legis.iowa.gov/docs/code/2026/533A.pdf HTML: https://www.legis.iowa.gov/docs/code/2026/533A.html | §533A.1(2), (7), PDF p.1/index 0; §533A.2(2)(h), p.2/index 1; §533A.7, p.5/index 4; §533A.8(3)–(8), pp.5–7/indices 4–6; §533A.8A, pp.7–9/indices 6–8; §533A.9(1), (3)–(5), pp.9–10; §533A.9A; §533A.10; §533A.11(15)(b). | Official 2026 Code chapter; PDF footer December 9, 2025. Operative compiled statutory text used. | **Freshly read/re-read relevant clauses.** Same underlying authority previously used in P1; no duplicate document inference. No complete post-compilation session-law audit. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **S_IA-P4-S002** | Iowa Legislature, **Iowa Administrative Code, Agency 187, October 14, 2026 compilation**. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf | Chapter 20 printed pp.1–5/PDF indices 68–72. PASS-04 reliance: 20.7; 20.9(1)–(8), especially printed pp.3–4/PDF indices 70–71; 20.10; 20.11. | Official agency compilation dated October 14, 2026. Chapter footer IAC 2/5/25; source note ARC 4061C, IAB 10/10/18, effective 11/14/18. | **Complete Chapter 20 read reused from reviewed prior work; exact records, cessation, examination, and insolvency passages freshly re-read.** Entire 75-page Agency 187 PDF was not read. Original 2018 order and changes after October 14 remain unverified. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) |\n| **S_IA-P4-S003** | Iowa Legislature, **Iowa Code 2026, Chapter 17A — Iowa Administrative Procedure Act**. https://www.legis.iowa.gov/docs/code/2026/17A.html | §17A.23(3)–(4), official HTML lines 891–892. | Official 2026 Code text. | **Fresh targeted read.** Used only for the agency-authority and rule-narrowing qualification; no broader administrative-law analysis. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/17A.html) |\n| **S_IA-P4-S004** | Iowa Legislature, **Iowa Code 2026, Chapter 533C — Uniform Money Transmission Modernization Act**. https://www.legis.iowa.gov/docs/code/2026/533C.pdf | §533C.102(19), (28)–(29), printed pp.2–3; §533C.103(8), (9), (14), (17)–(19), pp.3–4; §533C.301, p.7; §533C.501–.502, pp.14–15; §533C.606, p.17; §§533C.701–.702, pp.18–19. | Official 2026 Code chapter; PDF footer December 9, 2025. | **Fresh targeted read with relevant PDF pages inspected.** The entire 31-page chapter was not comprehensively analyzed. No actual administrator license, delegate status, exemption, agreement, or transaction was verified. [Iowa Legislature+3](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) |\n| **S_IA-P4-S005** | Electronic Code of Federal Regulations, **16 CFR §310.4**. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | §310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E). | Current eCFR display accessed October 25 Pacific; source display indicated current material through October 22, 2026. | **Fresh targeted read.** Used only for fee-earning and dedicated-account predicates. Full TSR definitions, exemptions, call-channel coverage, §310.2, §310.6, and CROA were not reanalyzed. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_IA-P4-S006** | Iowa Legislature, **HF 2326 and SF 2298 official bill histories**. HF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91 SF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=SF2298&ga=91 | HF 2326 displayed status “Passed House”; April 1 passage, April 2 attachment to SF 2298, later Senate amendments. SF 2298 history showed introduction, unfinished-business placement, attachment, and amendment activity. | Pending legislative-history material, not operative law in the status displayed. | **Fresh narrow currentness check.** Does not constitute a complete 2026 session-law audit and does not prove no other legislation affects Chapter 533A. [Iowa Legislature+2](https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91) |\n| **S_IA-P4-S007** | Iowa Legislature, **Senate File 2298 — Introduced**. https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf | Introduced bill p.1/PDF index 1, lines 12–22, proposing “bank trust account or dedicated account”; explanation p.3/PDF index 2, lines 72–83 distinguishing then-current bank-trust language from the proposal. | Introduced bill; nonoperative proposal. | **Relevant pages freshly read and visually inspected.** Amendments and final text were not analyzed. It cannot alter the operative 2026 Code unless enacted. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf) |\n\n# Claim register — S_IA-P4-C001+\n\n| Claim ID | Precise assertion | Sources and pinpoints | Predicates, exceptions, and confidence limits |\n| --- | --- | --- | --- |\n| **S_IA-P4-C001** | Compensated direct or indirect receipt of debtor money for distribution to one or more creditors is debt management; principal held for creditor distribution or refund is not a provider fee. | S001, §533A.1(2)(b), (7), PDF p.1/index 0. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for statutory text; actual indirect-control facts remain case-specific. |\n| **S_IA-P4-C002** | A model requiring the licensee or any licensee to receive creditor money is custodial, and the receiving licensee bears the statutory money-handling duties. | S001, §533A.8(5), PDF pp.6–7/indices 5–6. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for statutory allocation; another entity’s actual license and role remain unverified. |\n| **S_IA-P4-C003** | Custodial funds must be deposited in a separate bank trust account and remain there until remitted to the debtor or creditor. | S001, §533A.8(5)(a). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. No conclusion about location, insurance, title, interest, credit unions, or bankruptcy priority. |\n| **S_IA-P4-C004** | Initial creditor remittance is due within 45 days and later remittances within 30 days, subject to the reasonable sum-certain accumulation exception. | S001, §533A.8(5)(b). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for text; reasonableness and exact extended period are fact-dependent. |\n| **S_IA-P4-C005** | “Less fees” does not independently authorize fee withdrawal; all contractual, state, completion, and applicable federal predicates must be satisfied. | S001, §§533A.8(4)–(5), .9; S005, §310.4(a)(5)(i). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.html) | High as a harmonized conclusion; actual fee earning remains held. |\n| **S_IA-P4-C006** | A custodial debtor is entitled to monthly written disbursement/fee statements and verbal accounting on request during business hours. | S001, §533A.8(5)(c). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. Statement format and reconciliation certification are not prescribed in the reviewed text. |\n| **S_IA-P4-C007** | A noncustodial model requires the debtor to retain full control and access and forbids the licensee from receiving third-party consideration connected with debtor services. | S001, §533A.8(6). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for text; “full control” is not defined by located primary interpretation. |\n| **S_IA-P4-C008** | Account title, remote administrator, consumer name, or provider characterization alone cannot resolve custody where actual withdrawal and instruction rights are unknown. | S001, §§533A.1(2)(b), .8(5)–(6). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | Reasoned application of statutory text; no Iowa bright-line interpretation located. |\n| **S_IA-P4-C009** | On custodial cancellation, current held principal remains trust money until remitted to the debtor or creditor; no fixed state return period was located in the reviewed clauses. | S001, §§533A.8(4)–(5), .9(1). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.html) | High for money path; absence statement limited to reviewed Chapter 533A/Chapter 20 sources. |\n| **S_IA-P4-C010** | A rejected proposal or incomplete payment sequence does not establish Iowa completed settlement or independently create a settlement fee. | S001, §533A.11(15)(b); preserved P2 Rule 20.1 completion finding. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.html) | High as conditional conclusion; actual creditor agreement and payment history required. |\n| **S_IA-P4-C011** | Donations cannot be deducted from creditor payments, debtor accounts, or contract payments; required third-party service charges generally fall on the licensee. | S001, §§533A.9(5), .9A. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.html) | High; debtor’s own banking fees are the stated third-party-charge exception. |\n| **S_IA-P4-C012** | Statutory records must be retained at least five years after the final entry on a recorded transaction and include complete contract, payment, disbursement, and charge information. | S001, §533A.8(7), PDF p.7/index 6. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. Exact “final entry” edge cases remain unresolved. |\n| **S_IA-P4-C013** | Compiled Rule 20.9 states 36 months from the final transaction, requires records after cessation, and mandates consumer index, log, file, and custodial ledger structures. | S002, 20.9(1)–(6), printed pp.3–4/PDF indices 70–71. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) | High for compiled text; later-than-October-14 changes held. |\n| **S_IA-P4-C014** | The rule’s 36-month language is not permission to destroy overlapping statutory records before the five-year statutory minimum. | S001 §533A.8(7); S002 20.9; S003 §17A.23(3). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High as source-hierarchy conclusion; no controlling agency/court reconciliation located. |\n| **S_IA-P4-C015** | Custodial ledgers must post receipts, creditor payments, and fees at their respective effective dates, fully describe other transactions, and correct by entry rather than erasure. | S002, 20.9(6), printed p.4/PDF index 71. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) | High. Does not determine substantive entitlement to any posted fee. |\n| **S_IA-P4-C016** | Record duties continue after cessation or surrender; bankruptcy/reorganization must be reported, and insolvency can result in immediate revocation. | S002, 20.7, 20.9(1)(d), 20.11(2)(c). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) | High for duties; consumer-money wind-down process and priority unresolved. |\n| **S_IA-P4-C017** | A separate administrator receiving Iowa consumer money for transmission generally needs Chapter 533C authority unless acting within an authorized-delegate or exemption pathway. | S004, §§533C.102(19), (28); .301. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) | High for statutory gateway; actual entity and transaction unverified. |\n| **S_IA-P4-C018** | The Chapter 533A debt-management exemption and Chapter 533C transmission exemptions are entity- and activity-specific; one entity’s status does not automatically cover another. | S001 §533A.2(2)(h); S004 §533C.103(14). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. Hybrid roles require separate classification. |\n| **S_IA-P4-C019** | Authorized-delegate trust is for the transmission licensee, and commingling creates a statutory trust in the appropriate amount for that licensee; it does not prove consumer ownership or Chapter 533A compliance. | S004, §533C.501(3)(e), (5). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) | High for trust beneficiary; cross-regime compliance remains separate. |\n| **S_IA-P4-C020** | A covered Chapter 533C licensee must transmit according to the sender agreement and generally refund within ten days after a qualifying written request, subject to enumerated exceptions. | S004, §§533C.701–.702. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533C.pdf) | High for text; does not automatically apply to an exempt §533A provider. |\n| **S_IA-P4-C021** | The conditional federal dedicated-account rule requires insured institution, consumer ownership and interest, independent nonreferral administrator, penalty-free withdrawal, and seven-business-day return of non-earned funds. | S005, §310.4(a)(5)(ii)(A)–(E). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High for rule text; federal coverage and exceptions unresolved. |\n| **S_IA-P4-C022** | Federal first-customer-payment timing and Iowa full-remittance settlement completion are distinct conditions; neither substitutes for the other. | S005 §310.4(a)(5)(i); preserved P2 Rule 20.1 finding. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High for textual distinction; actual transaction facts held. |\n| **S_IA-P4-C023** | Educational-loan fee timing is an additional full-performance condition and does not displace ordinary custody duties when creditor money is received. | S001, §533A.8A(1)–(3), (5). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for statutory structure; actual service and account model unverified. |\n| **S_IA-P4-C024** | A 2026 proposal would add “dedicated account” language, but the official histories checked did not show enactment; the proposal is not operative authority. | S006–S007. [Iowa Legislature+1](https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91) | High for the proposal/status displayed; full post-compilation legislative audit remains open. |\n| **S_IA-P4-C025** | No actual provider, administrator, bank, trust account, delegate, exemption, ACH permission, insurance treatment, or current account balance was established in this pass. | Research limitation across S001–S007. | Confirmed limitation; no operational approval follows. |\n\n# Complete PASS-04 component coverage and gaps\n\n| Component | Status | Claims | Exact missing evidence / next action |\n| --- | --- | --- | --- |\n| Direct custodial classification | **Answered at statutory level** | C001–C003 | Obtain actual contracts and money-flow records for any proposed provider. |\n| Another Chapter 533A licensee receiving funds | **Answered at statutory level** | C002 | Verify both licenses, roles, contracts, and receiving entity. |\n| Indirect receipt or provider control | **Partial** | C001, C008 | Account agreement, signers, withdrawal rights, fee-release permissions, ACH instructions, system access, and authoritative Iowa interpretation. |\n| Consumer-owned dedicated-account classification | **Partial** | C007–C008, C021 | Verify actual ownership, control, administrator independence, and state/federal coverage. |\n| Single-creditor payments | **Answered narrowly** | C001, C010 | Actual creditor agreement and written settlement confirmation still needed. |\n| Separate bank trust account | **Answered** | C003 | Actual account and bank records unverified. |\n| Iowa account location requirement | **Unresolved** | C003 | No location clause found; obtain agency interpretation or controlling authority. |\n| Credit-union eligibility | **Unresolved** | C003 | The statute says “bank”; no authority equating a credit-union account was established. |\n| Deposit insurance and FDIC pass-through | **Unresolved** | C003, C021 | Bank title, account structure, deposit agreement, federal insurance analysis. |\n| Account title and beneficial ownership | **Unresolved** | C003, C008 | Signature card, deposit contract, trust document, applicable property/trust law. |\n| Interest ownership | **Unresolved under state law; conditional federal answer** | C003, C021 | Actual account terms and TSR applicability. |\n| Segregation from operating funds | **Answered at statutory level** | C003 | Actual bank statements and accounting records. |\n| Omnibus pooling versus one account per debtor | **Unresolved** | C003, C015 | Agency interpretation and actual trust architecture; individual ledgers are still required. |\n| Deposit deadline | **Partial** | C003 | Statute commands deposit but provides no fixed elapsed-time deadline in reviewed text. |\n| Initial and subsequent remittance deadlines | **Answered with exception** | C004 | Actual receipt dates, creditor payment requirements, and sum-certain justification. |\n| Sum-certain longer hold | **Partial** | C004 | Creditor terms and evidence that the longer hold was reasonable and necessary. |\n| Fee withdrawal predicate | **Partial; prior fee pass preserved** | C005, C015 | Actual contract, creditor-count condition, completion record, fee ledger, and federal coverage. |\n| Donation deduction | **Answered** | C011 | Actual transactions unverified. |\n| Monthly written statement | **Answered** | C006 | Actual statement form and delivery records. |\n| Verbal accounting access | **Answered** | C006 | Actual procedures unverified. |\n| Consumer-level account ledger | **Answered** | C013, C015 | Actual ledger and source documents unverified. |\n| Bank-account reconciliation cadence under Chapter 533A | **Unresolved** | C013 | No express cadence located; seek agency guidance or examination standard. |\n| Chapter 533C bank reconciliations | **Answered conditionally** | C017 | Applies only to an actual Chapter 533C licensee. |\n| Five-year statutory records period | **Answered as minimum** | C012, C014 | Exact final-entry date and other longer holds must be established. |\n| 36-month rule interaction | **Partial but operational floor resolved** | C013–C014 | Authoritative Iowa interpretation of differing triggers and nontransaction records. |\n| Record duties after cessation | **Answered** | C016 | Actual custodian, storage location, and access plan unverified. |\n| Account change or closure procedures | **Unresolved** | C016 | No detailed Chapter 533A procedure located; obtain account contract and agency authority. |\n| Bankruptcy/insolvency notification | **Answered narrowly** | C016 | Full insolvency, priority, receiver, bond, and remedy analysis excluded. |\n| Cancellation return recipient | **Partial** | C009 | Contract cancellation-settlement provision and existing creditor commitments required. |\n| Iowa cancellation-return deadline | **Unresolved** | C009 | No fixed deadline found in reviewed clauses; investigate authoritative interpretation/case law. |\n| Rejected settlement proposal | **Answered narrowly** | C010 | Actual creditor correspondence and transaction record required. |\n| Provider termination or failed plan | **Partial** | C009, C016 | Actual contract, cancellation notice, pending payments, successor arrangements, and regulator action. |\n| Prior fee credits and no double subtraction | **Answered as ledger principle** | C005, C015 | Actual earning and prior-payment legality remain unresolved. |\n| Combined installment/pro-rata cancellation entitlement | **Unresolved and preserved** | C005, C009 | Agency interpretation, controlling case, and actual contract ledger. |\n| Independent administrator Chapter 533C gateway | **Answered at statutory level** | C017–C018 | Administrator identity, license, delegate status, and exemption documents. |\n| Authorized-delegate trust | **Answered at statutory level** | C019 | Actual delegate contract and consumer-account relationship unverified. |\n| Intermediary/payment-operator/payee-agent exemptions | **Partial** | C018 | Actual receipts, payee agreements, public holding-out, risk allocation, and parties’ licenses. |\n| Chapter 533C ten-day refund | **Answered conditionally** | C020 | Actual applicability, written request, forwarding/commitment, and exceptions. |\n| Federal dedicated-account requirements | **Answered conditionally** | C021–C022 | TSR coverage, administrator facts, insured institution, account ownership, and fee earning. |\n| Seven-business-day federal return | **Answered conditionally** | C021 | Service-withdrawal request and all federal predicates must be proved. |\n| ACH revocation and bank-account closure | **Unresolved** | C021 | Bank agreement, NACHA/EFTA facts, authorization records, and federal coverage. |\n| Educational-loan money flows | **Partial** | C023 | Actual service promises, full-performance evidence, and custody model. |\n| Targeted 2026 dedicated-account proposal status | **Partial currentness check** | C024 | Amendments, final disposition, and complete post-compilation enactment audit remain open. |\n| Actual provider/account authorization | **Unresolved** | C025 | Provider, administrator, bank, account, and license records. |\n| Full agreement enforceability | **Excluded** | — | Later contract pass. |\n| Bond claims and consumer recovery | **Excluded** | — | Later bond/remedies pass. |\n| Restitution, damages, injunctions, and private remedies | **Excluded** | — | Later remedies/litigation pass. |\n| Bankruptcy priority, receivership, and insolvency distribution | **Excluded** | — | Later insolvency/remedies pass. |\n| Collection, courts, limitations, garnishment, and secured debt | **Excluded** | — | Separate required passes. |\n| Local, tribal, and sector-specific law | **Excluded** | — | Separate required passes. |\n| Full federal TSR/CROA applicability | **Excluded except narrow overlay** | C021–C022 | Separate federal facts and coverage pass. |\n| Prior P1 fee examples | **Preserved; not rerun** | P1 claims and examples | No numerical or legal change made in PASS-04. |\n| Iowa operational approval, parent acceptance, or A066 | **Unresolved** | C025 | Full dossier and all remaining dimensions required. |\n\n# Researcher self-check\n\n## Actually read or re-read in PASS-04\n\nThe following primary material was freshly inspected on October 25, 2026 Pacific:\n\n- Iowa Code Chapter 533A’s definitions, reciprocal money-transmission exception, custody/noncustody provisions, records provision, educational-loan conditions, cancellation-related fee language, donation restriction, examination provisions, and settlement-representation restriction.\n- Compiled Chapter 20’s significant-event, recordkeeping, ledger, continuing-retention, examination, disposal, insolvency, and discipline provisions.\n- Iowa Code §17A.23’s agency-authority limitation.\n- Targeted Chapter 533C definitions, licensing gateway, relevant exemptions, authorized-delegate duties and trust, records, timely-transmission, and refund provisions.\n- Current eCFR §310.4(a)(5)(i)–(ii).\n- Official HF 2326 and SF 2298 histories.\n- The relevant pages of the introduced SF 2298 PDF, including visual page inspection.\n\n## Reused from reviewed P1–P3\n\nThe following were reused rather than regenerated:\n\n- Iowa’s basic licensing and fee framework.\n- All seven P1 examples and all reviewed P1 quantities.\n- P2’s correction establishing existing Rule 20.1 full-remittance completion language.\n- P3’s access-date and renewal-branch correction.\n- Existing proposal-status, provider-status, post-compilation, federal-coverage, and contract limitations.\n\nNo prior example was recalculated.\n\n## Targeted searches that did not produce relied-on authority\n\nTargeted official-domain searches were conducted for Iowa Banking Division interpretations, orders, and Iowa court decisions addressing:\n\n- “Directly or indirectly” receiving money through a third-party administrator.\n- The meaning of full consumer control and access.\n- Omnibus versus individual trust accounts.\n- The five-year statute/36-month rule mismatch.\n- A fixed Chapter 533A cancellation-return deadline.\n\nNo sufficiently relevant primary interpretation was located in those routes. That is a research limitation, **not proof that no such authority exists**.\n\n## Not read or not established\n\nThis pass did not establish:\n\n- The original 2018 Chapter 20 adoption order.\n- Complete Chapter 20 rule history.\n- Final disposition of ARC 0368D.\n- Changes after the October 14, 2026 agency compilation.\n- A complete post-compilation session-law audit.\n- Every provision of the 31-page Chapter 533C.\n- Every amendment to HF 2326 or SF 2298.\n- Any provider, administrator, bank, authorized delegate, or exemption status.\n- Any actual contract, trust agreement, bank statement, signature card, ledger, ACH authorization, processor agreement, payee agreement, cancellation notice, or creditor settlement.\n- FDIC pass-through insurance.\n- Credit-union eligibility for the Iowa “bank trust account.”\n- Interest ownership under Iowa law.\n- Bankruptcy priority or insolvency distribution.\n- Actual processor-loss allocation.\n- A fixed Iowa return deadline.\n- A controlling Iowa judicial interpretation of the custody boundary or retention mismatch.\n- Full TSR definitions, exceptions, outbound/inbound call facts, CROA, EFTA, NACHA, or bank-account closure rules.\n- Full agreement, bond, remedies, collections, litigation, limitations, secured-sector, local, or tribal coverage.\n\nNo application, filing, provider lookup, account access, communication, purchase, private-data review, browser control, local write, site change, or publication action occurred.\n\nThis is a focused same-coordinator research component, **not independent review**, and it does not support Iowa launch approval, provider approval, account approval, contract approval, publication readiness, state acceptance, parent acceptance, or A066 acceptance.\n\n**END S_IA PASS-04**\n\n","tables":[{"headers":["Account or payment model","Iowa Chapter 533A classification","Required money treatment","Separate Chapter 533C issue","Status and material facts still needed"],"index":0,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}]],"rows":[["Account or payment model","Iowa Chapter 533A classification","Required money treatment","Separate Chapter 533C issue","Status and material facts still needed"],["Licensee directly receives monthly DMP payments for creditor distribution","Custodial under §533A.8(5)","Receiving licensee must maintain the separate bank trust account, deposit all creditor-benefit payments, remit under the 45/30-day framework, issue monthly statements, and maintain a per-debtor ledger.","The licensed/exempt debt-management person has a Chapter 533C exemption for the covered debt-management activity, but that does not eliminate Chapter 533A duties.","Statutory classification answered. Actual bank, account title, signers, and transaction records unverified. \nIowa Legislature\n+1"],["A second Iowa debt-management licensee receives the money","Still custodial; §533A.8(5) expressly reaches a model in which “the licensee or any licensee” receives funds.","The receiving licensee bears the account, remittance, statement, and ledger duties. The first licensee cannot cause another licensee to receive fees outside the statutory predicates.","Each entity’s actual authority and contractual role must be established.","Statutory allocation answered; actual intercompany contracts and licenses held. \nIowa Legislature"],["Consumer sends payments directly to creditors or operates personal bill pay","Potentially noncustodial if no licensee directly or indirectly receives money for distribution.","Debtor must retain full control and access; provider does not make creditor payments on the debtor’s behalf.","A neutral bank’s ordinary consumer payment service may implicate separate banking or payment-system rules, not resolved here.","Classification depends on provider access, payment authority, and reimbursement facts. \nIowa Legislature"],["Consumer-titled dedicated account administered by an independent entity","Potentially noncustodial only if no licensee directly or indirectly receives the money and the debtor genuinely retains full control and access.","Iowa does not, merely from the account title, establish that the administrator can release money or fees without debtor control.","Administrator may need a Chapter 533C license, authorized-delegate status, or a fact-specific exemption. Federal dedicated-account conditions may also apply.","Account agreement, withdrawal rights, signature authority, fee-release instructions, affiliation, referral compensation, and loss allocation required. \nIowa Legislature\n+2"],["Consumer-titled account but provider or affiliate can unilaterally direct withdrawals or fee releases","Significant risk of direct or indirect receipt/control; noncustodial status is not established.","If facts amount to a licensee receiving funds for creditor distribution, the custodial trust-account duties apply.","Affiliated administration also fails the federal dedicated-account independence condition when the TSR applies.","Iowa has no located bright-line interpretation; actual agreements and system permissions are indispensable. \nIowa Legislature\n+2"],["Independent processor receives consumer money and forwards it to creditors","Processor’s pure transmission activity may fall outside Chapter 533A under §533A.2(2)(h), but the debt-management provider’s own duties are not transferred automatically.","Provider must still satisfy whichever Chapter 533A model its actual conduct creates.","Processor independently needs a Chapter 533C license, authorized-delegate relationship, or applicable exemption.","Processor identity, license, delegate contract, receipts, payee agreements, and actual loss allocation unverified. \nIowa Legislature\n+1"],["Provider receives only its service fee; consumer principal never enters provider-controlled channels","The creditor-principal trust-account clause may not apply to the fee-only receipt, but all fee-contract, fee-timing, credit, and refund provisions remain applicable.","Consumer principal must remain outside licensee receipt/control for the model to remain noncustodial.","The fee processor’s own money-transmission status remains fact-dependent.","Actual payment flow and whether the fee processor receives money as agent of the provider must be documented. \nIowa Legislature\n+1"],["Educational-loan modification service","Educational-loan rules are additional, not exclusive. If the provider also receives money for creditor distribution, ordinary Chapter 533A custody rules continue to apply.","Provider cannot request or receive compensation, or require payment to a third party, until full performance of all promised services.","Separate processor questions remain entity-specific.","Actual service scope and money flow required; no assumption that student-loan status displaces trust duties. \nIowa Legislature"]]},{"headers":["Potential pathway","Required predicates","Why it cannot be assumed"],"index":1,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature"}]],"rows":[["Potential pathway","Required predicates","Why it cannot be assumed"],["Authorized delegate","Written contract with a Chapter 533C licensee; activity within delegated scope; required policies, background review, compliance, records, and examination consent.","A software integration or processor agreement is not necessarily an authorized-delegate appointment. \nIowa Legislature\n+1"],["Intermediary processor","The primary entity must itself be licensed or exempt, identify itself to the sender as the transmission provider, and bear sole responsibility to satisfy the transmission obligation and make the sender whole.","A processor that bears consumer loss, or cannot identify the liable transmitting entity, may fail the conditions. \nIowa Legislature"],["Payment-system operator","Processing, clearing, or settlement between excluded persons or licensees in connection with ACH, card, wire, stored-value, or similar transfers.","Merely using ACH does not prove operator status or that the parties on both sides satisfy the provision. \nIowa Legislature"],["Agent of payee","Written payee-agent agreement; payee publicly holds the agent out; consumer payment is treated as received by the payee and extinguishes the obligation without consumer loss if the agent fails to remit.","A settlement savings-account administrator normally cannot be assumed to be the creditor’s agent or to extinguish the debt on receipt. \nIowa Legislature"],["Employee","Individual employee acting within employment and under supervision; independent contractors are excluded from this employee provision.","Corporate affiliates and independent processors do not qualify merely because they perform functions for the provider. \nIowa Legislature"],["Service provider to federally insured depository institution","Specific written appointment and functions; the exempt institution assumes all risk and legal responsibility for the outstanding transmission obligations.","Bank sponsorship, account location, or API access alone does not establish the required risk assumption. \nIowa Legislature"]]},{"headers":["Issue","Federal conditional rule","Iowa rule","Required treatment"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Issue","Federal conditional rule","Iowa rule","Required treatment"],["Account institution","Insured financial institution","Separate bank trust account for the custodial Iowa model","Do not infer that satisfying one term automatically satisfies the other."],["Ownership","Customer owns dedicated-account money","Chapter 533A says funds remain in trust until remitted to debtor or creditor but does not specify all beneficial-ownership consequences","Do not infer bankruptcy priority or pass-through insurance."],["Interest","Customer receives accrued interest, if any","No interest-allocation clause located in the reviewed Chapter 533A provisions","Federal condition controls only if TSR applies."],["Administrator affiliation","Must be independent and nonaffiliated","Iowa classification turns on whether a licensee directly or indirectly receives money and whether the debtor retains full control/access","Both tests may matter."],["Fee earning","Valid alteration, one customer payment, and permitted allocation","Iowa completed-settlement fee branch requires the previously verified full creditor remittance","One federal customer payment does not satisfy Iowa’s full-remittance completion requirement."],["Return","Seven business days after service-withdrawal request","No fixed Chapter 533A number-of-days return rule located","Apply the seven-day rule only where federal coverage and account predicates are established."]]},{"headers":["Required fact","Why it matters"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Required fact","Why it matters"],["Legal account owner and exact title","Relevant to federal ownership and state trust architecture, but not dispositive alone"],["Bank or credit-union identity and charter","Iowa says “bank”; federal rule says insured financial institution"],["All authorized signers","Shows who can move money"],["Consumer’s unilateral withdrawal rights","Central to Iowa full-control/access and federal dedicated-account status"],["Provider’s withdrawal, freeze, or instruction rights","May show direct or indirect receipt/control"],["Administrator ownership and affiliation","Federal independence condition"],["Referral compensation","Federal administrator condition and Iowa third-party-compensation issues"],["ACH origination and revocation authority","Determines actual payment control; not inferred from account title"],["Fee-release process","Shows who determines and executes fee collection"],["Creditor-payment instructions","Identifies sender, transmitting entity, and actual obligation"],["Risk of loss if administrator fails","Material to Chapter 533C intermediary, payee-agent, and bank-service-provider exemptions"],["Written payee or bank agreement","Required for several Chapter 533C exemptions"],["Provider and administrator licenses/delegate records","Necessary to establish each entity’s authority"],["Consumer statements and transaction ledger","Necessary to reconcile current held principal and prior deductions"],["Pending checks, ACH transactions, reversals, and chargebacks","Necessary to calculate the actual current balance"],["Cancellation notice and contract settlement clause","Necessary to determine the authorized return path"],["Creditor settlement agreement and payment record","Necessary to establish Iowa completion and any fee predicate"]]},{"headers":["Source ID","Primary source, issuer, and full literal URL","Exact passage used","Version/effective status","Access status and limitations"],"index":4,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/17A.html","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+3"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"},{"href":"https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf","text":"Iowa Legislature\n+1"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/17A.html","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+3"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"}],[{"href":"https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf","text":"Iowa Legislature\n+1"}]],"rows":[["Source ID","Primary source, issuer, and full literal URL","Exact passage used","Version/effective status","Access status and limitations"],["S_IA-P4-S001","Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. PDF: https://www.legis.iowa.gov/docs/code/2026/533A.pdf HTML: https://www.legis.iowa.gov/docs/code/2026/533A.html","§533A.1(2), (7), PDF p.1/index 0; §533A.2(2)(h), p.2/index 1; §533A.7, p.5/index 4; §533A.8(3)–(8), pp.5–7/indices 4–6; §533A.8A, pp.7–9/indices 6–8; §533A.9(1), (3)–(5), pp.9–10; §533A.9A; §533A.10; §533A.11(15)(b).","Official 2026 Code chapter; PDF footer December 9, 2025. Operative compiled statutory text used.","Freshly read/re-read relevant clauses. Same underlying authority previously used in P1; no duplicate document inference. No complete post-compilation session-law audit. \nIowa Legislature\n+2"],["S_IA-P4-S002","Iowa Legislature, Iowa Administrative Code, Agency 187, October 14, 2026 compilation. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Chapter 20 printed pp.1–5/PDF indices 68–72. PASS-04 reliance: 20.7; 20.9(1)–(8), especially printed pp.3–4/PDF indices 70–71; 20.10; 20.11.","Official agency compilation dated October 14, 2026. Chapter footer IAC 2/5/25; source note ARC 4061C, IAB 10/10/18, effective 11/14/18.","Complete Chapter 20 read reused from reviewed prior work; exact records, cessation, examination, and insolvency passages freshly re-read. Entire 75-page Agency 187 PDF was not read. Original 2018 order and changes after October 14 remain unverified. \nIowa Legislature\n+2"],["S_IA-P4-S003","Iowa Legislature, Iowa Code 2026, Chapter 17A — Iowa Administrative Procedure Act. https://www.legis.iowa.gov/docs/code/2026/17A.html","§17A.23(3)–(4), official HTML lines 891–892.","Official 2026 Code text.","Fresh targeted read. Used only for the agency-authority and rule-narrowing qualification; no broader administrative-law analysis. \nIowa Legislature"],["S_IA-P4-S004","Iowa Legislature, Iowa Code 2026, Chapter 533C — Uniform Money Transmission Modernization Act. https://www.legis.iowa.gov/docs/code/2026/533C.pdf","§533C.102(19), (28)–(29), printed pp.2–3; §533C.103(8), (9), (14), (17)–(19), pp.3–4; §533C.301, p.7; §533C.501–.502, pp.14–15; §533C.606, p.17; §§533C.701–.702, pp.18–19.","Official 2026 Code chapter; PDF footer December 9, 2025.","Fresh targeted read with relevant PDF pages inspected. The entire 31-page chapter was not comprehensively analyzed. No actual administrator license, delegate status, exemption, agreement, or transaction was verified. \nIowa Legislature\n+3"],["S_IA-P4-S005","Electronic Code of Federal Regulations, 16 CFR §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E).","Current eCFR display accessed October 25 Pacific; source display indicated current material through October 22, 2026.","Fresh targeted read. Used only for fee-earning and dedicated-account predicates. Full TSR definitions, exemptions, call-channel coverage, §310.2, §310.6, and CROA were not reanalyzed. \neCFR\n+2"],["S_IA-P4-S006","Iowa Legislature, HF 2326 and SF 2298 official bill histories. HF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91 SF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=SF2298&ga=91","HF 2326 displayed status “Passed House”; April 1 passage, April 2 attachment to SF 2298, later Senate amendments. SF 2298 history showed introduction, unfinished-business placement, attachment, and amendment activity.","Pending legislative-history material, not operative law in the status displayed.","Fresh narrow currentness check. Does not constitute a complete 2026 session-law audit and does not prove no other legislation affects Chapter 533A. \nIowa Legislature\n+2"],["S_IA-P4-S007","Iowa Legislature, Senate File 2298 — Introduced. https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf","Introduced bill p.1/PDF index 1, lines 12–22, proposing “bank trust account or dedicated account”; explanation p.3/PDF index 2, lines 72–83 distinguishing then-current bank-trust language from the proposal.","Introduced bill; nonoperative proposal.","Relevant pages freshly read and visually inspected. Amendments and final text were not analyzed. It cannot alter the operative 2026 Code unless enacted. \nIowa Legislature\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Predicates, exceptions, and confidence limits"],"index":5,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91","text":"Iowa Legislature\n+1"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.html","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533C.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91","text":"Iowa Legislature\n+1"}],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Predicates, exceptions, and confidence limits"],["S_IA-P4-C001","Compensated direct or indirect receipt of debtor money for distribution to one or more creditors is debt management; principal held for creditor distribution or refund is not a provider fee.","S001, §533A.1(2)(b), (7), PDF p.1/index 0. \nIowa Legislature","High for statutory text; actual indirect-control facts remain case-specific."],["S_IA-P4-C002","A model requiring the licensee or any licensee to receive creditor money is custodial, and the receiving licensee bears the statutory money-handling duties.","S001, §533A.8(5), PDF pp.6–7/indices 5–6. \nIowa Legislature","High for statutory allocation; another entity’s actual license and role remain unverified."],["S_IA-P4-C003","Custodial funds must be deposited in a separate bank trust account and remain there until remitted to the debtor or creditor.","S001, §533A.8(5)(a). \nIowa Legislature","High. No conclusion about location, insurance, title, interest, credit unions, or bankruptcy priority."],["S_IA-P4-C004","Initial creditor remittance is due within 45 days and later remittances within 30 days, subject to the reasonable sum-certain accumulation exception.","S001, §533A.8(5)(b). \nIowa Legislature","High for text; reasonableness and exact extended period are fact-dependent."],["S_IA-P4-C005","“Less fees” does not independently authorize fee withdrawal; all contractual, state, completion, and applicable federal predicates must be satisfied.","S001, §§533A.8(4)–(5), .9; S005, §310.4(a)(5)(i). \nIowa Legislature\n+2","High as a harmonized conclusion; actual fee earning remains held."],["S_IA-P4-C006","A custodial debtor is entitled to monthly written disbursement/fee statements and verbal accounting on request during business hours.","S001, §533A.8(5)(c). \nIowa Legislature","High. Statement format and reconciliation certification are not prescribed in the reviewed text."],["S_IA-P4-C007","A noncustodial model requires the debtor to retain full control and access and forbids the licensee from receiving third-party consideration connected with debtor services.","S001, §533A.8(6). \nIowa Legislature","High for text; “full control” is not defined by located primary interpretation."],["S_IA-P4-C008","Account title, remote administrator, consumer name, or provider characterization alone cannot resolve custody where actual withdrawal and instruction rights are unknown.","S001, §§533A.1(2)(b), .8(5)–(6). \nIowa Legislature\n+1","Reasoned application of statutory text; no Iowa bright-line interpretation located."],["S_IA-P4-C009","On custodial cancellation, current held principal remains trust money until remitted to the debtor or creditor; no fixed state return period was located in the reviewed clauses.","S001, §§533A.8(4)–(5), .9(1). \nIowa Legislature\n+1","High for money path; absence statement limited to reviewed Chapter 533A/Chapter 20 sources."],["S_IA-P4-C010","A rejected proposal or incomplete payment sequence does not establish Iowa completed settlement or independently create a settlement fee.","S001, §533A.11(15)(b); preserved P2 Rule 20.1 completion finding. \nIowa Legislature","High as conditional conclusion; actual creditor agreement and payment history required."],["S_IA-P4-C011","Donations cannot be deducted from creditor payments, debtor accounts, or contract payments; required third-party service charges generally fall on the licensee.","S001, §§533A.9(5), .9A. \nIowa Legislature\n+1","High; debtor’s own banking fees are the stated third-party-charge exception."],["S_IA-P4-C012","Statutory records must be retained at least five years after the final entry on a recorded transaction and include complete contract, payment, disbursement, and charge information.","S001, §533A.8(7), PDF p.7/index 6. \nIowa Legislature","High. Exact “final entry” edge cases remain unresolved."],["S_IA-P4-C013","Compiled Rule 20.9 states 36 months from the final transaction, requires records after cessation, and mandates consumer index, log, file, and custodial ledger structures.","S002, 20.9(1)–(6), printed pp.3–4/PDF indices 70–71. \nIowa Legislature\n+2","High for compiled text; later-than-October-14 changes held."],["S_IA-P4-C014","The rule’s 36-month language is not permission to destroy overlapping statutory records before the five-year statutory minimum.","S001 §533A.8(7); S002 20.9; S003 §17A.23(3). \nIowa Legislature\n+2","High as source-hierarchy conclusion; no controlling agency/court reconciliation located."],["S_IA-P4-C015","Custodial ledgers must post receipts, creditor payments, and fees at their respective effective dates, fully describe other transactions, and correct by entry rather than erasure.","S002, 20.9(6), printed p.4/PDF index 71. \nIowa Legislature","High. Does not determine substantive entitlement to any posted fee."],["S_IA-P4-C016","Record duties continue after cessation or surrender; bankruptcy/reorganization must be reported, and insolvency can result in immediate revocation.","S002, 20.7, 20.9(1)(d), 20.11(2)(c). \nIowa Legislature\n+2","High for duties; consumer-money wind-down process and priority unresolved."],["S_IA-P4-C017","A separate administrator receiving Iowa consumer money for transmission generally needs Chapter 533C authority unless acting within an authorized-delegate or exemption pathway.","S004, §§533C.102(19), (28); .301. \nIowa Legislature\n+2","High for statutory gateway; actual entity and transaction unverified."],["S_IA-P4-C018","The Chapter 533A debt-management exemption and Chapter 533C transmission exemptions are entity- and activity-specific; one entity’s status does not automatically cover another.","S001 §533A.2(2)(h); S004 §533C.103(14). \nIowa Legislature\n+1","High. Hybrid roles require separate classification."],["S_IA-P4-C019","Authorized-delegate trust is for the transmission licensee, and commingling creates a statutory trust in the appropriate amount for that licensee; it does not prove consumer ownership or Chapter 533A compliance.","S004, §533C.501(3)(e), (5). \nIowa Legislature\n+1","High for trust beneficiary; cross-regime compliance remains separate."],["S_IA-P4-C020","A covered Chapter 533C licensee must transmit according to the sender agreement and generally refund within ten days after a qualifying written request, subject to enumerated exceptions.","S004, §§533C.701–.702. \nIowa Legislature\n+2","High for text; does not automatically apply to an exempt §533A provider."],["S_IA-P4-C021","The conditional federal dedicated-account rule requires insured institution, consumer ownership and interest, independent nonreferral administrator, penalty-free withdrawal, and seven-business-day return of non-earned funds.","S005, §310.4(a)(5)(ii)(A)–(E). \neCFR","High for rule text; federal coverage and exceptions unresolved."],["S_IA-P4-C022","Federal first-customer-payment timing and Iowa full-remittance settlement completion are distinct conditions; neither substitutes for the other.","S005 §310.4(a)(5)(i); preserved P2 Rule 20.1 finding. \neCFR\n+1","High for textual distinction; actual transaction facts held."],["S_IA-P4-C023","Educational-loan fee timing is an additional full-performance condition and does not displace ordinary custody duties when creditor money is received.","S001, §533A.8A(1)–(3), (5). \nIowa Legislature\n+1","High for statutory structure; actual service and account model unverified."],["S_IA-P4-C024","A 2026 proposal would add “dedicated account” language, but the official histories checked did not show enactment; the proposal is not operative authority.","S006–S007. \nIowa Legislature\n+1","High for the proposal/status displayed; full post-compilation legislative audit remains open."],["S_IA-P4-C025","No actual provider, administrator, bank, trust account, delegate, exemption, ACH permission, insurance treatment, or current account balance was established in this pass.","Research limitation across S001–S007.","Confirmed limitation; no operational approval follows."]]},{"headers":["Component","Status","Claims","Exact missing evidence / next action"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Exact missing evidence / next action"],["Direct custodial classification","Answered at statutory level","C001–C003","Obtain actual contracts and money-flow records for any proposed provider."],["Another Chapter 533A licensee receiving funds","Answered at statutory level","C002","Verify both licenses, roles, contracts, and receiving entity."],["Indirect receipt or provider control","Partial","C001, C008","Account agreement, signers, withdrawal rights, fee-release permissions, ACH instructions, system access, and authoritative Iowa interpretation."],["Consumer-owned dedicated-account classification","Partial","C007–C008, C021","Verify actual ownership, control, administrator independence, and state/federal coverage."],["Single-creditor payments","Answered narrowly","C001, C010","Actual creditor agreement and written settlement confirmation still needed."],["Separate bank trust account","Answered","C003","Actual account and bank records unverified."],["Iowa account location requirement","Unresolved","C003","No location clause found; obtain agency interpretation or controlling authority."],["Credit-union eligibility","Unresolved","C003","The statute says “bank”; no authority equating a credit-union account was established."],["Deposit insurance and FDIC pass-through","Unresolved","C003, C021","Bank title, account structure, deposit agreement, federal insurance analysis."],["Account title and beneficial ownership","Unresolved","C003, C008","Signature card, deposit contract, trust document, applicable property/trust law."],["Interest ownership","Unresolved under state law; conditional federal answer","C003, C021","Actual account terms and TSR applicability."],["Segregation from operating funds","Answered at statutory level","C003","Actual bank statements and accounting records."],["Omnibus pooling versus one account per debtor","Unresolved","C003, C015","Agency interpretation and actual trust architecture; individual ledgers are still required."],["Deposit deadline","Partial","C003","Statute commands deposit but provides no fixed elapsed-time deadline in reviewed text."],["Initial and subsequent remittance deadlines","Answered with exception","C004","Actual receipt dates, creditor payment requirements, and sum-certain justification."],["Sum-certain longer hold","Partial","C004","Creditor terms and evidence that the longer hold was reasonable and necessary."],["Fee withdrawal predicate","Partial; prior fee pass preserved","C005, C015","Actual contract, creditor-count condition, completion record, fee ledger, and federal coverage."],["Donation deduction","Answered","C011","Actual transactions unverified."],["Monthly written statement","Answered","C006","Actual statement form and delivery records."],["Verbal accounting access","Answered","C006","Actual procedures unverified."],["Consumer-level account ledger","Answered","C013, C015","Actual ledger and source documents unverified."],["Bank-account reconciliation cadence under Chapter 533A","Unresolved","C013","No express cadence located; seek agency guidance or examination standard."],["Chapter 533C bank reconciliations","Answered conditionally","C017","Applies only to an actual Chapter 533C licensee."],["Five-year statutory records period","Answered as minimum","C012, C014","Exact final-entry date and other longer holds must be established."],["36-month rule interaction","Partial but operational floor resolved","C013–C014","Authoritative Iowa interpretation of differing triggers and nontransaction records."],["Record duties after cessation","Answered","C016","Actual custodian, storage location, and access plan unverified."],["Account change or closure procedures","Unresolved","C016","No detailed Chapter 533A procedure located; obtain account contract and agency authority."],["Bankruptcy/insolvency notification","Answered narrowly","C016","Full insolvency, priority, receiver, bond, and remedy analysis excluded."],["Cancellation return recipient","Partial","C009","Contract cancellation-settlement provision and existing creditor commitments required."],["Iowa cancellation-return deadline","Unresolved","C009","No fixed deadline found in reviewed clauses; investigate authoritative interpretation/case law."],["Rejected settlement proposal","Answered narrowly","C010","Actual creditor correspondence and transaction record required."],["Provider termination or failed plan","Partial","C009, C016","Actual contract, cancellation notice, pending payments, successor arrangements, and regulator action."],["Prior fee credits and no double subtraction","Answered as ledger principle","C005, C015","Actual earning and prior-payment legality remain unresolved."],["Combined installment/pro-rata cancellation entitlement","Unresolved and preserved","C005, C009","Agency interpretation, controlling case, and actual contract ledger."],["Independent administrator Chapter 533C gateway","Answered at statutory level","C017–C018","Administrator identity, license, delegate status, and exemption documents."],["Authorized-delegate trust","Answered at statutory level","C019","Actual delegate contract and consumer-account relationship unverified."],["Intermediary/payment-operator/payee-agent exemptions","Partial","C018","Actual receipts, payee agreements, public holding-out, risk allocation, and parties’ licenses."],["Chapter 533C ten-day refund","Answered conditionally","C020","Actual applicability, written request, forwarding/commitment, and exceptions."],["Federal dedicated-account requirements","Answered conditionally","C021–C022","TSR coverage, administrator facts, insured institution, account ownership, and fee earning."],["Seven-business-day federal return","Answered conditionally","C021","Service-withdrawal request and all federal predicates must be proved."],["ACH revocation and bank-account closure","Unresolved","C021","Bank agreement, NACHA/EFTA facts, authorization records, and federal coverage."],["Educational-loan money flows","Partial","C023","Actual service promises, full-performance evidence, and custody model."],["Targeted 2026 dedicated-account proposal status","Partial currentness check","C024","Amendments, final disposition, and complete post-compilation enactment audit remain open."],["Actual provider/account authorization","Unresolved","C025","Provider, administrator, bank, account, and license records."],["Full agreement enforceability","Excluded","—","Later contract pass."],["Bond claims and consumer recovery","Excluded","—","Later bond/remedies pass."],["Restitution, damages, injunctions, and private remedies","Excluded","—","Later remedies/litigation pass."],["Bankruptcy priority, receivership, and insolvency distribution","Excluded","—","Later insolvency/remedies pass."],["Collection, courts, limitations, garnishment, and secured debt","Excluded","—","Separate required passes."],["Local, tribal, and sector-specific law","Excluded","—","Separate required passes."],["Full federal TSR/CROA applicability","Excluded except narrow overlay","C021–C022","Separate federal facts and coverage pass."],["Prior P1 fee examples","Preserved; not rerun","P1 claims and examples","No numerical or legal change made in PASS-04."],["Iowa operational approval, parent acceptance, or A066","Unresolved","C025","Full dossier and all remaining dimensions required."]]}],"claims":[{"claim_id":"S_IA-P4-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C001","Precise assertion":"Compensated direct or indirect receipt of debtor money for distribution to one or more creditors is debt management; principal held for creditor distribution or refund is not a provider fee.","Sources and pinpoints":"S001, §533A.1(2)(b), (7), PDF p.1/index 0. \nIowa Legislature","Predicates, exceptions, and confidence limits":"High for statutory text; actual indirect-control facts remain case-specific."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C002","Precise assertion":"A model requiring the licensee or any licensee to receive creditor money is custodial, and the receiving licensee bears the statutory money-handling duties.","Sources and pinpoints":"S001, §533A.8(5), PDF pp.6–7/indices 5–6. \nIowa Legislature","Predicates, exceptions, and confidence limits":"High for statutory allocation; another entity’s actual license and role remain unverified."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C003","Precise assertion":"Custodial funds must be deposited in a separate bank trust account and remain there until remitted to the debtor or creditor.","Sources and pinpoints":"S001, §533A.8(5)(a). \nIowa Legislature","Predicates, exceptions, and confidence limits":"High. No conclusion about location, insurance, title, interest, credit unions, or bankruptcy priority."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C004","Precise assertion":"Initial creditor remittance is due within 45 days and later remittances within 30 days, subject to the reasonable sum-certain accumulation exception.","Sources and pinpoints":"S001, §533A.8(5)(b). \nIowa Legislature","Predicates, exceptions, and confidence limits":"High for text; reasonableness and exact extended period are fact-dependent."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C005","Precise assertion":"“Less fees” does not independently authorize fee withdrawal; all contractual, state, completion, and applicable federal predicates must be satisfied.","Sources and pinpoints":"S001, §§533A.8(4)–(5), .9; S005, §310.4(a)(5)(i). \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High as a harmonized conclusion; actual fee earning remains held."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C006","Precise assertion":"A custodial debtor is entitled to monthly written disbursement/fee statements and verbal accounting on request during business hours.","Sources and pinpoints":"S001, §533A.8(5)(c). \nIowa Legislature","Predicates, exceptions, and confidence limits":"High. Statement format and reconciliation certification are not prescribed in the reviewed text."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C007","Precise assertion":"A noncustodial model requires the debtor to retain full control and access and forbids the licensee from receiving third-party consideration connected with debtor services.","Sources and pinpoints":"S001, §533A.8(6). \nIowa Legislature","Predicates, exceptions, and confidence limits":"High for text; “full control” is not defined by located primary interpretation."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C008","Precise assertion":"Account title, remote administrator, consumer name, or provider characterization alone cannot resolve custody where actual withdrawal and instruction rights are unknown.","Sources and pinpoints":"S001, §§533A.1(2)(b), .8(5)–(6). \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"Reasoned application of statutory text; no Iowa bright-line interpretation located."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C009","Precise assertion":"On custodial cancellation, current held principal remains trust money until remitted to the debtor or creditor; no fixed state return period was located in the reviewed clauses.","Sources and pinpoints":"S001, §§533A.8(4)–(5), .9(1). \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High for money path; absence statement limited to reviewed Chapter 533A/Chapter 20 sources."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C010","Precise assertion":"A rejected proposal or incomplete payment sequence does not establish Iowa completed settlement or independently create a settlement fee.","Sources and pinpoints":"S001, §533A.11(15)(b); preserved P2 Rule 20.1 completion finding. \nIowa Legislature","Predicates, exceptions, and confidence limits":"High as conditional conclusion; actual creditor agreement and payment history required."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C011","Precise assertion":"Donations cannot be deducted from creditor payments, debtor accounts, or contract payments; required third-party service charges generally fall on the licensee.","Sources and pinpoints":"S001, §§533A.9(5), .9A. \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High; debtor’s own banking fees are the stated third-party-charge exception."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C012","Precise assertion":"Statutory records must be retained at least five years after the final entry on a recorded transaction and include complete contract, payment, disbursement, and charge information.","Sources and pinpoints":"S001, §533A.8(7), PDF p.7/index 6. \nIowa Legislature","Predicates, exceptions, and confidence limits":"High. Exact “final entry” edge cases remain unresolved."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C013","Precise assertion":"Compiled Rule 20.9 states 36 months from the final transaction, requires records after cessation, and mandates consumer index, log, file, and custodial ledger structures.","Sources and pinpoints":"S002, 20.9(1)–(6), printed pp.3–4/PDF indices 70–71. \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High for compiled text; later-than-October-14 changes held."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C014","Precise assertion":"The rule’s 36-month language is not permission to destroy overlapping statutory records before the five-year statutory minimum.","Sources and pinpoints":"S001 §533A.8(7); S002 20.9; S003 §17A.23(3). \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High as source-hierarchy conclusion; no controlling agency/court reconciliation located."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C015","Precise assertion":"Custodial ledgers must post receipts, creditor payments, and fees at their respective effective dates, fully describe other transactions, and correct by entry rather than erasure.","Sources and pinpoints":"S002, 20.9(6), printed p.4/PDF index 71. \nIowa Legislature","Predicates, exceptions, and confidence limits":"High. Does not determine substantive entitlement to any posted fee."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C016","Precise assertion":"Record duties continue after cessation or surrender; bankruptcy/reorganization must be reported, and insolvency can result in immediate revocation.","Sources and pinpoints":"S002, 20.7, 20.9(1)(d), 20.11(2)(c). \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High for duties; consumer-money wind-down process and priority unresolved."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C017","Precise assertion":"A separate administrator receiving Iowa consumer money for transmission generally needs Chapter 533C authority unless acting within an authorized-delegate or exemption pathway.","Sources and pinpoints":"S004, §§533C.102(19), (28); .301. \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High for statutory gateway; actual entity and transaction unverified."},"coordinator_verification_status":"gatewayclaim_valid_but_wronglyusedfor_recordscrosslink_addC026","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C018","Precise assertion":"The Chapter 533A debt-management exemption and Chapter 533C transmission exemptions are entity- and activity-specific; one entity’s status does not automatically cover another.","Sources and pinpoints":"S001 §533A.2(2)(h); S004 §533C.103(14). \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High. Hybrid roles require separate classification."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C019","Precise assertion":"Authorized-delegate trust is for the transmission licensee, and commingling creates a statutory trust in the appropriate amount for that licensee; it does not prove consumer ownership or Chapter 533A compliance.","Sources and pinpoints":"S004, §533C.501(3)(e), (5). \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High for trust beneficiary; cross-regime compliance remains separate."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C020","Precise assertion":"A covered Chapter 533C licensee must transmit according to the sender agreement and generally refund within ten days after a qualifying written request, subject to enumerated exceptions.","Sources and pinpoints":"S004, §§533C.701–.702. \nIowa Legislature\n+2","Predicates, exceptions, and confidence limits":"High for text; does not automatically apply to an exempt §533A provider."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C021","Precise assertion":"The conditional federal dedicated-account rule requires insured institution, consumer ownership and interest, independent nonreferral administrator, penalty-free withdrawal, and seven-business-day return of non-earned funds.","Sources and pinpoints":"S005, §310.4(a)(5)(ii)(A)–(E). \neCFR","Predicates, exceptions, and confidence limits":"High for rule text; federal coverage and exceptions unresolved."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C022","Precise assertion":"Federal first-customer-payment timing and Iowa full-remittance settlement completion are distinct conditions; neither substitutes for the other.","Sources and pinpoints":"S005 §310.4(a)(5)(i); preserved P2 Rule 20.1 finding. \neCFR\n+1","Predicates, exceptions, and confidence limits":"High for textual distinction; actual transaction facts held."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C023","Precise assertion":"Educational-loan fee timing is an additional full-performance condition and does not displace ordinary custody duties when creditor money is received.","Sources and pinpoints":"S001, §533A.8A(1)–(3), (5). \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High for statutory structure; actual service and account model unverified."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C024","Precise assertion":"A 2026 proposal would add “dedicated account” language, but the official histories checked did not show enactment; the proposal is not operative authority.","Sources and pinpoints":"S006–S007. \nIowa Legislature\n+1","Predicates, exceptions, and confidence limits":"High for the proposal/status displayed; full post-compilation legislative audit remains open."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P4-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P4-C025","Precise assertion":"No actual provider, administrator, bank, trust account, delegate, exemption, ACH permission, insurance treatment, or current account balance was established in this pass.","Sources and pinpoints":"Research limitation across S001–S007.","Predicates, exceptions, and confidence limits":"Confirmed limitation; no operational approval follows."},"coordinator_verification_status":"scoped_review_complete_with_currentness_application_holds","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_IA-P4-S001","urls":["https://www.legis.iowa.gov/docs/code/2026/533A.pdf","https://www.legis.iowa.gov/docs/code/2026/533A.html"],"researcher_record":{"Source ID":"S_IA-P4-S001","Primary source, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. PDF: https://www.legis.iowa.gov/docs/code/2026/533A.pdf HTML: https://www.legis.iowa.gov/docs/code/2026/533A.html","Exact passage used":"§533A.1(2), (7), PDF p.1/index 0; §533A.2(2)(h), p.2/index 1; §533A.7, p.5/index 4; §533A.8(3)–(8), pp.5–7/indices 4–6; §533A.8A, pp.7–9/indices 6–8; §533A.9(1), (3)–(5), pp.9–10; §533A.9A; §533A.10; §533A.11(15)(b).","Version/effective status":"Official 2026 Code chapter; PDF footer December 9, 2025. Operative compiled statutory text used.","Access status and limitations":"Freshly read/re-read relevant clauses. Same underlying authority previously used in P1; no duplicate document inference. No complete post-compilation session-law audit. \nIowa Legislature\n+2"},"coordinator_verification_status":"selected_body_checked_bounded_locator_revision_required","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S002","urls":["https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf"],"researcher_record":{"Source ID":"S_IA-P4-S002","Primary source, issuer, and full literal URL":"Iowa Legislature, Iowa Administrative Code, Agency 187, October 14, 2026 compilation. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Exact passage used":"Chapter 20 printed pp.1–5/PDF indices 68–72. PASS-04 reliance: 20.7; 20.9(1)–(8), especially printed pp.3–4/PDF indices 70–71; 20.10; 20.11.","Version/effective status":"Official agency compilation dated October 14, 2026. Chapter footer IAC 2/5/25; source note ARC 4061C, IAB 10/10/18, effective 11/14/18.","Access status and limitations":"Complete Chapter 20 read reused from reviewed prior work; exact records, cessation, examination, and insolvency passages freshly re-read. Entire 75-page Agency 187 PDF was not read. Original 2018 order and changes after October 14 remain unverified. \nIowa Legislature\n+2"},"coordinator_verification_status":"fresh_selected_checked_with_readlimits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S003","urls":["https://www.legis.iowa.gov/docs/code/2026/17A.html"],"researcher_record":{"Source ID":"S_IA-P4-S003","Primary source, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 17A — Iowa Administrative Procedure Act. https://www.legis.iowa.gov/docs/code/2026/17A.html","Exact passage used":"§17A.23(3)–(4), official HTML lines 891–892.","Version/effective status":"Official 2026 Code text.","Access status and limitations":"Fresh targeted read. Used only for the agency-authority and rule-narrowing qualification; no broader administrative-law analysis. \nIowa Legislature"},"coordinator_verification_status":"fresh_selected_checked_with_readlimits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S004","urls":["https://www.legis.iowa.gov/docs/code/2026/533C.pdf"],"researcher_record":{"Source ID":"S_IA-P4-S004","Primary source, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 533C — Uniform Money Transmission Modernization Act. https://www.legis.iowa.gov/docs/code/2026/533C.pdf","Exact passage used":"§533C.102(19), (28)–(29), printed pp.2–3; §533C.103(8), (9), (14), (17)–(19), pp.3–4; §533C.301, p.7; §533C.501–.502, pp.14–15; §533C.606, p.17; §§533C.701–.702, pp.18–19.","Version/effective status":"Official 2026 Code chapter; PDF footer December 9, 2025.","Access status and limitations":"Fresh targeted read with relevant PDF pages inspected. The entire 31-page chapter was not comprehensively analyzed. No actual administrator license, delegate status, exemption, agreement, or transaction was verified. \nIowa Legislature\n+3"},"coordinator_verification_status":"selected_body_checked_bounded_locator_revision_required","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S005","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_IA-P4-S005","Primary source, issuer, and full literal URL":"Electronic Code of Federal Regulations, 16 CFR §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact passage used":"§310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E).","Version/effective status":"Current eCFR display accessed October 25 Pacific; source display indicated current material through October 22, 2026.","Access status and limitations":"Fresh targeted read. Used only for fee-earning and dedicated-account predicates. Full TSR definitions, exemptions, call-channel coverage, §310.2, §310.6, and CROA were not reanalyzed. \neCFR\n+2"},"coordinator_verification_status":"explicit_samecoordinator_dated_reuse_checked_withlimits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S006","urls":["https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91","https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=SF2298&ga=91"],"researcher_record":{"Source ID":"S_IA-P4-S006","Primary source, issuer, and full literal URL":"Iowa Legislature, HF 2326 and SF 2298 official bill histories. HF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=HF2326&ga=91 SF: https://www.legis.iowa.gov/legislation/billTracking/billHistory?billName=SF2298&ga=91","Exact passage used":"HF 2326 displayed status “Passed House”; April 1 passage, April 2 attachment to SF 2298, later Senate amendments. SF 2298 history showed introduction, unfinished-business placement, attachment, and amendment activity.","Version/effective status":"Pending legislative-history material, not operative law in the status displayed.","Access status and limitations":"Fresh narrow currentness check. Does not constitute a complete 2026 session-law audit and does not prove no other legislation affects Chapter 533A. \nIowa Legislature\n+2"},"coordinator_verification_status":"fresh_selected_checked_with_readlimits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P4-S007","urls":["https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf"],"researcher_record":{"Source ID":"S_IA-P4-S007","Primary source, issuer, and full literal URL":"Iowa Legislature, Senate File 2298 — Introduced. https://www.legis.iowa.gov/docs/publications/LGI/91/SF2298.pdf","Exact passage used":"Introduced bill p.1/PDF index 1, lines 12–22, proposing “bank trust account or dedicated account”; explanation p.3/PDF index 2, lines 72–83 distinguishing then-current bank-trust language from the proposal.","Version/effective status":"Introduced bill; nonoperative proposal.","Access status and limitations":"Relevant pages freshly read and visually inspected. Amendments and final text were not analyzed. It cannot alter the operative 2026 Code unless enacted. \nIowa Legislature\n+1"},"coordinator_verification_status":"selected_body_checked_bounded_locator_revision_required","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Direct custodial classification","researcher_record":{"Component":"Direct custodial classification","Status":"Answered at statutory level","Claims":"C001–C003","Exact missing evidence / next action":"Obtain actual contracts and money-flow records for any proposed provider."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Another Chapter 533A licensee receiving funds","researcher_record":{"Component":"Another Chapter 533A licensee receiving funds","Status":"Answered at statutory level","Claims":"C002","Exact missing evidence / next action":"Verify both licenses, roles, contracts, and receiving entity."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Indirect receipt or provider control","researcher_record":{"Component":"Indirect receipt or provider control","Status":"Partial","Claims":"C001, C008","Exact missing evidence / next action":"Account agreement, signers, withdrawal rights, fee-release permissions, ACH instructions, system access, and authoritative Iowa interpretation."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer-owned dedicated-account classification","researcher_record":{"Component":"Consumer-owned dedicated-account classification","Status":"Partial","Claims":"C007–C008, C021","Exact missing evidence / next action":"Verify actual ownership, control, administrator independence, and state/federal coverage."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Single-creditor payments","researcher_record":{"Component":"Single-creditor payments","Status":"Answered narrowly","Claims":"C001, C010","Exact missing evidence / next action":"Actual creditor agreement and written settlement confirmation still needed."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Separate bank trust account","researcher_record":{"Component":"Separate bank trust account","Status":"Answered","Claims":"C003","Exact missing evidence / next action":"Actual account and bank records unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Iowa account location requirement","researcher_record":{"Component":"Iowa account location requirement","Status":"Unresolved","Claims":"C003","Exact missing evidence / next action":"No location clause found; obtain agency interpretation or controlling authority."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-union eligibility","researcher_record":{"Component":"Credit-union eligibility","Status":"Unresolved","Claims":"C003","Exact missing evidence / next action":"The statute says “bank”; no authority equating a credit-union account was established."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Deposit insurance and FDIC pass-through","researcher_record":{"Component":"Deposit insurance and FDIC pass-through","Status":"Unresolved","Claims":"C003, C021","Exact missing evidence / next action":"Bank title, account structure, deposit agreement, federal insurance analysis."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Account title and beneficial ownership","researcher_record":{"Component":"Account title and beneficial ownership","Status":"Unresolved","Claims":"C003, C008","Exact missing evidence / next action":"Signature card, deposit contract, trust document, applicable property/trust law."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Interest ownership","researcher_record":{"Component":"Interest ownership","Status":"Unresolved under state law; conditional federal answer","Claims":"C003, C021","Exact missing evidence / next action":"Actual account terms and TSR applicability."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Segregation from operating funds","researcher_record":{"Component":"Segregation from operating funds","Status":"Answered at statutory level","Claims":"C003","Exact missing evidence / next action":"Actual bank statements and accounting records."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Omnibus pooling versus one account per debtor","researcher_record":{"Component":"Omnibus pooling versus one account per debtor","Status":"Unresolved","Claims":"C003, C015","Exact missing evidence / next action":"Agency interpretation and actual trust architecture; individual ledgers are still required."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Deposit deadline","researcher_record":{"Component":"Deposit deadline","Status":"Partial","Claims":"C003","Exact missing evidence / next action":"Statute commands deposit but provides no fixed elapsed-time deadline in reviewed text."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Initial and subsequent remittance deadlines","researcher_record":{"Component":"Initial and subsequent remittance deadlines","Status":"Answered with exception","Claims":"C004","Exact missing evidence / next action":"Actual receipt dates, creditor payment requirements, and sum-certain justification."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Sum-certain longer hold","researcher_record":{"Component":"Sum-certain longer hold","Status":"Partial","Claims":"C004","Exact missing evidence / next action":"Creditor terms and evidence that the longer hold was reasonable and necessary."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Fee withdrawal predicate","researcher_record":{"Component":"Fee withdrawal predicate","Status":"Partial; prior fee pass preserved","Claims":"C005, C015","Exact missing evidence / next action":"Actual contract, creditor-count condition, completion record, fee ledger, and federal coverage."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Donation deduction","researcher_record":{"Component":"Donation deduction","Status":"Answered","Claims":"C011","Exact missing evidence / next action":"Actual transactions unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Monthly written statement","researcher_record":{"Component":"Monthly written statement","Status":"Answered","Claims":"C006","Exact missing evidence / next action":"Actual statement form and delivery records."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Verbal accounting access","researcher_record":{"Component":"Verbal accounting access","Status":"Answered","Claims":"C006","Exact missing evidence / next action":"Actual procedures unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer-level account ledger","researcher_record":{"Component":"Consumer-level account ledger","Status":"Answered","Claims":"C013, C015","Exact missing evidence / next action":"Actual ledger and source documents unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Bank-account reconciliation cadence under Chapter 533A","researcher_record":{"Component":"Bank-account reconciliation cadence under Chapter 533A","Status":"Unresolved","Claims":"C013","Exact missing evidence / next action":"No express cadence located; seek agency guidance or examination standard."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Chapter 533C bank reconciliations","researcher_record":{"Component":"Chapter 533C bank reconciliations","Status":"Answered conditionally","Claims":"C017","Exact missing evidence / next action":"Applies only to an actual Chapter 533C licensee."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Five-year statutory records period","researcher_record":{"Component":"Five-year statutory records period","Status":"Answered as minimum","Claims":"C012, C014","Exact missing evidence / next action":"Exact final-entry date and other longer holds must be established."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"36-month rule interaction","researcher_record":{"Component":"36-month rule interaction","Status":"Partial but operational floor resolved","Claims":"C013–C014","Exact missing evidence / next action":"Authoritative Iowa interpretation of differing triggers and nontransaction records."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Record duties after cessation","researcher_record":{"Component":"Record duties after cessation","Status":"Answered","Claims":"C016","Exact missing evidence / next action":"Actual custodian, storage location, and access plan unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Account change or closure procedures","researcher_record":{"Component":"Account change or closure procedures","Status":"Unresolved","Claims":"C016","Exact missing evidence / next action":"No detailed Chapter 533A procedure located; obtain account contract and agency authority."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Bankruptcy/insolvency notification","researcher_record":{"Component":"Bankruptcy/insolvency notification","Status":"Answered narrowly","Claims":"C016","Exact missing evidence / next action":"Full insolvency, priority, receiver, bond, and remedy analysis excluded."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation return recipient","researcher_record":{"Component":"Cancellation return recipient","Status":"Partial","Claims":"C009","Exact missing evidence / next action":"Contract cancellation-settlement provision and existing creditor commitments required."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Iowa cancellation-return deadline","researcher_record":{"Component":"Iowa cancellation-return deadline","Status":"Unresolved","Claims":"C009","Exact missing evidence / next action":"No fixed deadline found in reviewed clauses; investigate authoritative interpretation/case law."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Rejected settlement proposal","researcher_record":{"Component":"Rejected settlement proposal","Status":"Answered narrowly","Claims":"C010","Exact missing evidence / next action":"Actual creditor correspondence and transaction record required."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Provider termination or failed plan","researcher_record":{"Component":"Provider termination or failed plan","Status":"Partial","Claims":"C009, C016","Exact missing evidence / next action":"Actual contract, cancellation notice, pending payments, successor arrangements, and regulator action."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Prior fee credits and no double subtraction","researcher_record":{"Component":"Prior fee credits and no double subtraction","Status":"Answered as ledger principle","Claims":"C005, C015","Exact missing evidence / next action":"Actual earning and prior-payment legality remain unresolved."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Combined installment/pro-rata cancellation entitlement","researcher_record":{"Component":"Combined installment/pro-rata cancellation entitlement","Status":"Unresolved and preserved","Claims":"C005, C009","Exact missing evidence / next action":"Agency interpretation, controlling case, and actual contract ledger."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Independent administrator Chapter 533C gateway","researcher_record":{"Component":"Independent administrator Chapter 533C gateway","Status":"Answered at statutory level","Claims":"C017–C018","Exact missing evidence / next action":"Administrator identity, license, delegate status, and exemption documents."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Authorized-delegate trust","researcher_record":{"Component":"Authorized-delegate trust","Status":"Answered at statutory level","Claims":"C019","Exact missing evidence / next action":"Actual delegate contract and consumer-account relationship unverified."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Intermediary/payment-operator/payee-agent exemptions","researcher_record":{"Component":"Intermediary/payment-operator/payee-agent exemptions","Status":"Partial","Claims":"C018","Exact missing evidence / next action":"Actual receipts, payee agreements, public holding-out, risk allocation, and parties’ licenses."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Chapter 533C ten-day refund","researcher_record":{"Component":"Chapter 533C ten-day refund","Status":"Answered conditionally","Claims":"C020","Exact missing evidence / next action":"Actual applicability, written request, forwarding/commitment, and exceptions."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Federal dedicated-account requirements","researcher_record":{"Component":"Federal dedicated-account requirements","Status":"Answered conditionally","Claims":"C021–C022","Exact missing evidence / next action":"TSR coverage, administrator facts, insured institution, account ownership, and fee earning."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Seven-business-day federal return","researcher_record":{"Component":"Seven-business-day federal return","Status":"Answered conditionally","Claims":"C021","Exact missing evidence / next action":"Service-withdrawal request and all federal predicates must be proved."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"ACH revocation and bank-account closure","researcher_record":{"Component":"ACH revocation and bank-account closure","Status":"Unresolved","Claims":"C021","Exact missing evidence / next action":"Bank agreement, NACHA/EFTA facts, authorization records, and federal coverage."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Educational-loan money flows","researcher_record":{"Component":"Educational-loan money flows","Status":"Partial","Claims":"C023","Exact missing evidence / next action":"Actual service promises, full-performance evidence, and custody model."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Targeted 2026 dedicated-account proposal status","researcher_record":{"Component":"Targeted 2026 dedicated-account proposal status","Status":"Partial currentness check","Claims":"C024","Exact missing evidence / next action":"Amendments, final disposition, and complete post-compilation enactment audit remain open."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Actual provider/account authorization","researcher_record":{"Component":"Actual provider/account authorization","Status":"Unresolved","Claims":"C025","Exact missing evidence / next action":"Provider, administrator, bank, account, and license records."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Full agreement enforceability","researcher_record":{"Component":"Full agreement enforceability","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Later contract pass."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Bond claims and consumer recovery","researcher_record":{"Component":"Bond claims and consumer recovery","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Later bond/remedies pass."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Restitution, damages, injunctions, and private remedies","researcher_record":{"Component":"Restitution, damages, injunctions, and private remedies","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Later remedies/litigation pass."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Bankruptcy priority, receivership, and insolvency distribution","researcher_record":{"Component":"Bankruptcy priority, receivership, and insolvency distribution","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Later insolvency/remedies pass."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, courts, limitations, garnishment, and secured debt","researcher_record":{"Component":"Collection, courts, limitations, garnishment, and secured debt","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate required passes."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Local, tribal, and sector-specific law","researcher_record":{"Component":"Local, tribal, and sector-specific law","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate required passes."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Full federal TSR/CROA applicability","researcher_record":{"Component":"Full federal TSR/CROA applicability","Status":"Excluded except narrow overlay","Claims":"C021–C022","Exact missing evidence / next action":"Separate federal facts and coverage pass."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Prior P1 fee examples","researcher_record":{"Component":"Prior P1 fee examples","Status":"Preserved; not rerun","Claims":"P1 claims and examples","Exact missing evidence / next action":"No numerical or legal change made in PASS-04."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Iowa operational approval, parent acceptance, or A066","researcher_record":{"Component":"Iowa operational approval, parent acceptance, or A066","Status":"Unresolved","Claims":"C025","Exact missing evidence / next action":"Full dossier and all remaining dimensions required."},"coordinator_acceptance":"scoped_review_complete_with_holds_records_crosslink_and_locator_revision_pending","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T17:01:47.600913+00:00","status":"bounded_requested_repairs_addressed_with_holds","review":"[internal evidence reference]","raw_originals_unchanged":true,"affected":["C017wrongcoveragecrosslink","newC026recordsclaim","S004printedpages","S007printedversusextractionlines","S0019(5)crosspage"],"correction_pass":"pass-09","no_component_acceptance":true,"correction_reviewed_at":"2026-10-27T17:35:10.951832+00:00","correction_review":"[internal evidence reference]","correction_notice":"[internal evidence reference]","issue_dispositions":[{"issue":"P04recordsatomicclaim/crosslink","status":"ADDRESSED within bounded correction","evidence":"P09table0ONEnewS_IA-P4-C026; table1samecoverageidentity C017→C026; body3.3replacement. C017licensingclaimunchanged. All monthly/retention/access/inspection/predicates correct, no universalreconciliationcadence."},{"issue":"P04S004printed-PDFpinpoints","status":"ADDRESSED","evidence":"P09table2distinguishes103introfromselectedsubsections and701crosspagefrom702singlepage, not blindone-pageshift; definition203supportreadboundsidentified."},{"issue":"P04S007printedversusextractionlocators","status":"ADDRESSED","evidence":"P09table2cover0/bodyprinted1/index1/explanationprinted2/index2; exactglobalversusprintedline bounds repaired; proposalremainsnonoperative."},{"issue":"P04S0019(5)continuation","status":"ADDRESSED","evidence":"P09table2includesfinalsentenceprinted11/index10; no feereanalysis."}]},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_IA-P4-records-atomic-trace-and-source-locators-20261027","status":"requested_bounded_repairs_addressed_with_retained_holds","at":"2026-10-27T17:01:47.600913+00:00"}]}