{"meta":{"key":"s_ia--pass-05","task":"S_IA","title":"Iowa debt-management bond, security, and necessary consumer-recovery component","parent_title":"Iowa debt and debt relief law","edition":"pass-05","path":"/research/s_ia--pass-05/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":5,"claims":28,"sources":10,"review_status":"scoped_review_complete_bounded_correction_addressed_other_holds_remain","review_complete":true,"sha256":"0f0c34b829b68e1745b21a6517fdbbc6c3350da6fba4e55f46a570d1d6991bd4","headings":["Iowa debt-management bond, security, and necessary consumer-recovery component","Bounded conclusion","1.1 Who must obtain and maintain the bond","1.2 Amount, office base, and branch treatment","1.3 Issuer and approval","1.4 Authorized security form","2.1 Bond conditions","2.2 Payee and intended protected class","2.3 Debtor loss versus provider liability","3.1 Continuing maintenance","3.2 Surety cancellation and breach cutoff","3.3 Aggregate liability","3.4 Name, location, and branch changes","3.5 Bond records","3.6 Surety insolvency and guaranty association","4.1 NMLS electronic bond process","4.2 Current Iowa-specific bond form","4.3 Public complaint route","4.4 Public availability of provider bond details","5.1 Superintendent remedies against a licensee","5.2 Private action","5.3 Judgment or agency order as a prerequisite","5.4 Decisions and formal interpretations","S_IA-P5-E01 — One consumer, loss below available penal sum","S_IA-P5-E02 — Money already returned is credited once","S_IA-P5-E03 — Multiple consumers exceed one office’s aggregate","S_IA-P5-E04 — Cancellation cutoff","S_IA-P5-E05 — Two offices do not automatically stack","S_IA-P5-E06 — Prior payments and uncertain remaining capacity","S_IA-P5-E07 — Restitution and bond recovery are not additive for the same loss","S_IA-P5-E08 — Statutory per-office requirement versus NMLS filing architecture","Actually read or re-read in PASS-05","Reused but not regenerated","Not treated as reviewed","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-05","facets":{"geography":["us","us-ia"],"debt_type":[],"stage":[],"subject":["counseling-dmp","provider-security","provider-remedies"]},"scope":"ExactreviewedP1excluded bond/security/necessaryrecoverygap, independent of P4unreviewedfundsreport; all broaderholdsretained.","pending_corrections":0},"markdown":"# SettleADebt S_IA PASS-05\n\n## Iowa debt-management bond, security, and necessary consumer-recovery component\n\n**Actual fresh research date:** October 25, 2026, Pacific; October 26, 2026 UTC\n**Review relationship:** Same-coordinator continuation of the saved and reviewed P1–P3 work; **not independent review**.\n**P4 treatment:** PASS-04 is saved but unreviewed. No new P4 legal conclusion is treated here as reviewed or used to expand this component.\n**Scope:** Bond/security and the minimum recovery mechanics necessary to understand that security. Fees, trust-account ledgers, agreement enforceability, general civil litigation, limitations, remedies, and earlier examples are not rerun.\n\nExact individual source-fetch timestamps were not preserved and are not invented. Historical enactment, compilation, publication, and effective dates below remain distinct from this PASS-05 access date.\n\n## Bounded conclusion\n\nIowa’s official 2026 Code requires a debt-management applicant to provide a superintendent-approved bond:\n\n- **$25,000 for each office**;\n- **in favor of the people of Iowa**;\n- conditioned on compliance with laws pertaining to the business and faithful accounting for entrusted money by the provider, employees, and agents;\n- expressly for indemnifying debtors against loss resulting from conduct prohibited by Chapter 533A; and\n- capped so that the surety’s aggregate liability to all debtors doing business with the bonded office never exceeds that office bond’s penal sum. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThat is an **aggregate office-level ceiling**, not $25,000 per consumer, per violation, or per claim. A $25,000 requirement also does not prove that a particular provider has a valid bond, that capacity remains available, that a claimant’s loss is covered, or that the claimant will receive $25,000.\n\nThe operative statute and compiled rule do not authorize a cash deposit, letter of credit, fidelity policy, self-insurance, or other substitute for the required surety bond. The public NMLS material confirms an electronic surety-bond system for the Iowa Debt Management License, but the current Iowa-specific rendered form and claim instructions were not recovered through the public routes checked. NMLS’s July 29, 2025 adoption table also says branch bonds are not accepted in its ESB system, creating an unresolved **filing-mechanics** question because Iowa law still calculates the required penal amount “for each office.” [Iowa Legislature+1](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\n# 1. Operative bond and security requirements\n\n## 1.1 Who must obtain and maintain the bond\n\nThe bond obligation attaches to each covered Chapter 533A license application. A person cannot engage in Iowa debt management until a good and sufficient bond has been filed. Compiled Rule 187—20.3(5) likewise requires an applicant to file a $25,000 surety bond complying with §533A.2(4). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe obligation does not independently apply to a person who actually satisfies one of §533A.2(2)’s conditional exemptions because those persons are not required to be licensed or otherwise comply with Chapter 533A. That exemption conclusion is only as sound as the underlying entity and activity facts. An attorney relationship, nonprofit label, institutional affiliation, or money-transmitter role cannot be assumed to satisfy an exemption. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nEmployees acting for their licensed employer are conditionally exempt from separate licensure, but the bond’s accounting condition expressly reaches money entrusted to the provider and its employees and agents. Thus, the principal’s bond may respond to covered employee or agent conduct; the employee is not shown to need an independent bond merely because the employee handles an account. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 1.2 Amount, office base, and branch treatment\n\nThe statutory base is:\n\n$25,000×number of covered offices\\$25{,}000 \\times \\text{number of covered offices}$25,000×number of covered offices“Office” means each location, identified by street number, building number, city, and state, where a person engages in debt management. Each application must carry a $25,000 penal sum **for each office**. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nCompiled Rule 20.6 treats a branch office as an independently licensed branch and requires a branch application through NMLS. A name or location change requires proof that the licensee obtained a new bond or amended the existing bond to reflect the new name or location. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nThat supports a separate security amount attributable to each covered office. It does **not**, without the current rendered form and filing instructions, establish whether Iowa currently requires:\n\n- a wholly separate bond instrument for every office;\n- one company bond with a multiplied penal sum;\n- a schedule of offices;\n- an office rider; or\n- some other NMLS implementation.\n\nThat distinction matters because NMLS’s July 29, 2025 ESB adoption table lists the Iowa Debt Management License as a company license and carries the heading “Branch Bonds are Not Accepted.” The NMLS statement addresses its electronic filing architecture; it does not amend Iowa’s statutory $25,000-per-office calculation. [NMLS Resource Center+1](https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf)\n\n## 1.3 Issuer and approval\n\nThe bond must be approved by Iowa’s Superintendent of Banking. Iowa’s general surety-company law provides that the insurance commissioner maintains a list of corporate sureties with current authority, and an approving public body must accept a bond guaranteed by an Iowa-organized or Iowa-authorized company holding the required insurance certificate of authority. That certificate is sufficient evidence of authority for bond approval. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/636.html)\n\nNo actual surety company, producer, certificate of authority, bond number, or superintendent approval was verified in this pass.\n\n## 1.4 Authorized security form\n\nThe operative debt-management statute and compiled rule identify a **bond** and, more specifically, a **surety bond**. No operative provision reviewed authorizes the applicant to substitute:\n\n- cash or a certificate of deposit;\n- a letter of credit;\n- a fidelity bond;\n- a trust balance;\n- errors-and-omissions insurance;\n- self-insurance;\n- a parent guarantee; or\n- a money-transmitter security instrument.\n\nThe result is bounded: **no alternative security pathway was established in the reviewed Chapter 533A and Chapter 20 provisions.** It is not a conclusion about every possible agency power or subsequently enacted law.\n\nThe $250 office-license fee, $100 investigation fee, NMLS charges, consumer fees, and consumer principal are legally distinct from the $25,000 surety bond. Paying one does not satisfy another.\n\n# 2. Covered duties, protected persons, and recovery predicates\n\n## 2.1 Bond conditions\n\nSection 533A.2(4) states two connected bond conditions:\n\n1. The obligor will not violate any law pertaining to the debt-management business.\n2. The obligor will faithfully account for all money collected on entrusted accounts by the provider, employees, and agents.\n\nThe statute then states the bond’s indemnity purpose: protecting debtors from loss resulting from conduct prohibited by Chapter 533A. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe broad “any law pertaining to such business” condition should not be converted automatically into a private bond claim for every conceivable regulatory violation. For a consumer-recovery conclusion, the strongest express statutory pathway requires:\n\n- a person qualifying as a Chapter 533A debtor;\n- a loss, not merely a technical violation;\n- causal connection between the loss and conduct prohibited by Chapter 533A;\n- connection to the office for which the bond was filed;\n- a breach occurring before the surety’s effective cancellation cutoff;\n- a valid bond and available penal capacity; and\n- compliance with whatever claim, suit, notice, and timeliness requirements apply under the current official bond and governing law.\n\nThe first several elements are supported by the statute. The final procedural elements remain unresolved because the current official bond form and materially on-point controlling decision were not recovered.\n\n## 2.2 Payee and intended protected class\n\nThe bond is expressly:\n\n- **in favor of the people of the state of Iowa**; and\n- intended to indemnify **debtors** for covered loss. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThis identifies debtors as the protected class but does not, in the statutory paragraph itself, state:\n\n- the precise person to whom a claim must be submitted;\n- whether a consumer may proceed directly against the surety;\n- whether the State or superintendent must be named;\n- whether administrative approval is required;\n- whether a final judgment against the provider is required;\n- the form or content of proof of loss;\n- the deadline for notice or suit; or\n- whether a claimant must first exhaust recovery against the provider.\n\nIowa Code §636.20 supplies service mechanics **when suit is otherwise required on a corporate-surety bond**: service may be made on the surety’s Iowa agent, or on the insurance commissioner if the surety has no Iowa agent. It does not itself create a cause of action, establish standing, or set a Chapter 533A claim period. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/636.html)\n\n## 2.3 Debtor loss versus provider liability\n\nThe bond is security for covered loss; it is not the full measure of the provider’s potential liability. The following remain legally distinct:\n\n| Item | Character | Bond relationship |\n| --- | --- | --- |\n| Consumer principal or refund already owed | Consumer money or provider debt | Not transformed into bond proceeds merely because unpaid |\n| Provider liability for covered loss | Liability of principal/provider | May potentially be secured by bond, subject to coverage and cap |\n| Surety liability | Secondary/capped bond obligation | Aggregate limited to penal sum for that office |\n| Superintendent-ordered restitution | Administrative remedial order | Separate from bond recovery; no automatic double recovery |\n| Civil penalty | Public enforcement sanction | Not stated to be payable to the consumer |\n| Injunction or license discipline | Regulatory relief | Does not itself establish a consumer’s bond payout |\n| Special educational-loan damages action | Express statutory private remedy under §533A.8A | Separate claim against licensee; bond coverage still requires its own analysis |\n\nA consumer should not receive the same loss twice. But neither §533A.2(4) nor the other provisions reviewed establish the detailed offset, subrogation, or priority rules between restitution, provider payment, bond payment, bankruptcy distribution, and another recovery source.\n\n# 3. Cancellation, maintenance, aggregate limits, and exhaustion\n\n## 3.1 Continuing maintenance\n\nIowa law bars operation until a good and sufficient bond is filed. Failure to post the required bond, receipt by the superintendent of a cancellation notice, and failure to maintain the required bond are grounds for discipline. Available discipline includes revocation, suspension, probation, civil penalties, warning, and restitution. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThis establishes an ongoing operational need for uninterrupted compliant security. It does not establish that the license automatically terminates at the instant a cancellation notice is received. The statute instead identifies cancellation notice as a disciplinary ground, while the no-bond operating prohibition remains independently applicable.\n\nA replacement must therefore be effective in time to prevent an uncovered operating gap. The exact superintendent processing sequence, replacement acceptance mechanics, and overlap between predecessor and successor bonds were not stated in the provisions reviewed.\n\n## 3.2 Surety cancellation and breach cutoff\n\nThe surety may cancel by giving the superintendent 30 days’ notice. The surety is relieved from liability for a breach occurring **after the effective date of cancellation**. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThis supports the following distinction:\n\n- A pre-effective-date breach is not released merely because cancellation later becomes effective.\n- A post-effective-date breach falls outside the canceled surety’s statutory liability.\n- The statute does not state an unlimited post-cancellation claims tail.\n- The date a claimant discovers the loss, files a complaint, files suit, or obtains judgment is not expressly made the coverage trigger in §533A.2(4).\n\nThe current official bond form, applicable limitation period, and controlling interpretation are needed to determine the deadline for asserting an otherwise pre-cancellation covered loss.\n\n## 3.3 Aggregate liability\n\nThe surety’s aggregate liability to **all debtors doing business with the office for which the bond was filed** cannot exceed that bond’s penal sum. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nTherefore:\n\n- $25,000 is not a per-debtor entitlement.\n- $25,000 is not restored automatically for each new claim.\n- A court judgment exceeding $25,000 would not, by itself, increase the surety’s statutory cap.\n- Multiple violations involving one debtor do not establish multiple $25,000 limits.\n- Bonds attributable to other offices cannot automatically be stacked for a debtor who did business with only one office.\n- The aggregate-cap language does not itself explain how competing claims are prioritized or allocated.\n\nNo verified provision established:\n\n- first-to-file priority;\n- first-to-judgment priority;\n- pro-rata distribution;\n- superintendent allocation;\n- interpleader procedure;\n- a per-consumer sublimit;\n- mandatory replenishment after payment;\n- annual restoration of the penal sum;\n- a separate aggregate for each bond year;\n- automatic increase based on consumer volume or trust balances; or\n- how claims overlap across a replacement bond and prior bond.\n\nThese remain explicit holds.\n\n## 3.4 Name, location, and branch changes\n\nBefore a name or location change, Rule 20.6 requires proof of a new bond or an amendment to the existing bond reflecting the changed name or location. A branch requires its own license application, and branch licenses are treated as independent licenses for renewal. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nThe rule does not say what happens to:\n\n- claims tied to the old legal name;\n- conduct spanning a location change;\n- a rider issued after the requested change date;\n- predecessor-provider liabilities after a merger or conversion;\n- a bond issued to an entity with a similar but legally different name; or\n- claims involving consumers serviced from multiple offices.\n\nThose questions require the actual bond, riders, corporate records, office facts, and controlling law.\n\n## 3.5 Bond records\n\nCompiled Rule 20.9(7)(d) requires the licensee to keep all correspondence and records concerning maintenance of the Chapter 533A surety bond. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nThe rule states a 36-month minimum, while the previously reviewed statute states a five-year period for covered records after the final entry on a transaction. PASS-05 preserves the existing hold: the rule does not authorize shortening a longer statutory retention duty. The precise classification and trigger for bond-maintenance correspondence remain unresolved.\n\n## 3.6 Surety insolvency and guaranty association\n\nIowa’s Insurance Guaranty Association chapter expressly excludes “fidelity or surety bonds, or any other bonding obligations.” Therefore, Chapter 515B is not an established fallback source for a consumer if the debt-management surety becomes insolvent. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/515B.html)\n\nThis does not resolve:\n\n- the surety’s domiciliary liquidation process;\n- proof-of-claim deadlines;\n- reinsurance;\n- collateral securing the surety;\n- subrogation;\n- receivership priority;\n- another state’s guaranty mechanism; or\n- the claimant’s recovery from the provider or its estate.\n\nThose matters remain outside this bounded pass.\n\n# 4. Official form, NMLS instructions, complaint route, and public records\n\n## 4.1 NMLS electronic bond process\n\nNMLS states that its electronic surety bond system allows company licensees to submit and manage bonds electronically, including new bonds, riders, status history, changes, and cancellations. NMLS further explains that the state regulator creates the bond form, which is then rendered in NMLS, and the surety supplies the licensee-specific information and electronic execution. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html)\n\nThe NMLS ESB adoption table dated July 29, 2025 lists the Iowa Division of Banking’s Debt Management License and states that branch bonds are not accepted through that company-license ESB architecture. [NMLS Resource Center+1](https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf)\n\nThis establishes an electronic operational channel, but it does not answer:\n\n- the exact current Iowa bond language;\n- how the per-office statutory amount is represented when branch bonds are not accepted;\n- whether the penal sum is multiplied in one bond;\n- whether riders or schedules identify offices;\n- the current surety cancellation transaction;\n- public claim instructions; or\n- whether consumers can see bond identifiers in NMLS Consumer Access.\n\n## 4.2 Current Iowa-specific bond form\n\nA one-page document found on a private surety website is dated September 10, 2016 and expressly says it is **“for reference ONLY”** because the bond form is rendered electronically in NMLS for official use. It includes language on a continuing obligation, direct action by the State or persons suffering loss, a $25,000 aggregate, and survival of obligations arising before termination. [Axcess Surety+1](https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf)\n\nThat document is useful only as a discovery lead. It is not:\n\n- hosted by the Iowa Division of Banking;\n- the live NMLS-rendered form;\n- demonstrated current as of October 2026;\n- proof of any actual provider’s bond; or\n- sufficient authority for a current direct-action, tail, or continuous-term conclusion.\n\nAccordingly, PASS-05 does **not** elevate its direct-action or continuous-obligation wording into a controlling claim.\n\n## 4.3 Public complaint route\n\nThe Iowa Division of Banking’s official complaint page directs consumers to determine whether the Division regulates the business, including through NMLS Consumer Access, and then permits an online complaint. The page states that the licensee ordinarily receives 10–20 business days to research and respond. It also says the Division does not act as a judge to settle contract disputes, does not intervene in formal legal proceedings, and does not provide legal advice. [Iowa Division of Banking+1](https://idob.iowa.gov/how-do-i-file-complaint)\n\nThus, an IDOB complaint is:\n\n- a regulator-investigation route;\n- potential evidence for discipline or restitution;\n- not itself a verified surety claim form;\n- not a judgment;\n- not proof of coverage;\n- not an adjudication of bond liability; and\n- not a substitute for satisfying any applicable notice or suit deadline.\n\nCompiled Rule 20.10 confirms that a written consumer complaint is a complaint the superintendent may investigate. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\n## 4.4 Public availability of provider bond details\n\nThe reviewed public IDOB/NMLS routes establish a license-verification path, but no actual provider search was conducted and no public record was recovered showing:\n\n- the provider’s surety;\n- bond number;\n- effective date;\n- cancellation date;\n- riders;\n- covered offices;\n- penal sum;\n- prior paid claims; or\n- remaining aggregate capacity.\n\nChapter 533A also makes most supervisory documents concerning licensees confidential, subject to specified enforcement, interagency, statistical, and complaint-summary exceptions. That confidentiality provision may limit public access to examination or supervisory bond information; it does not establish that every bond or bond identifier is confidential. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n# 5. Consumer, superintendent, and court remedies\n\n## 5.1 Superintendent remedies against a licensee\n\nFor a licensed provider, the superintendent may impose:\n\n- revocation;\n- suspension;\n- probation;\n- a civil penalty up to $5,000 per violation;\n- citation and warning; and\n- restitution. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nFor an unlicensed person, the superintendent may order compliance, impose a civil penalty up to $5,000 per violation, order restitution, and seek an injunction. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThese are separate remedies:\n\n- **Restitution** is remedial and may compensate affected persons according to an order.\n- **Civil penalties** are public sanctions; Chapter 533A does not state that the penalty amount becomes consumer bond proceeds.\n- **Discipline** protects the licensing system but does not quantify a consumer’s loss.\n- **Injunctions** stop or prevent conduct but do not automatically establish a bond claim.\n\nA restitution order might supply evidence of provider liability or loss, but the bond statute does not state that an agency restitution order is either necessary or conclusive against the surety.\n\n## 5.2 Private action\n\nThe general bond paragraph does not provide a detailed private-action procedure. The current official rendered bond form and controlling Iowa bond law are needed to determine the exact direct-action route.\n\nChapter 533A does contain an express private cause of action for violations of the **educational-loan debt-management section**, §533A.8A. In that narrow branch, an affected debtor may recover actual damages, appropriate equitable relief, costs, and reasonable attorney fees; a non-governmental action under that section must be commenced within four years. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThat four-year period is **not** established as:\n\n- the limitation period for an ordinary debt-management bond claim;\n- the time to notify the surety;\n- the period for a non-educational Chapter 533A claim; or\n- a universal Chapter 533A private-action deadline.\n\nLikewise, the attorney-fee provision is special to the statutory §533A.8A action. No universal fee-shifting rule for bond litigation was established.\n\n## 5.3 Judgment or agency order as a prerequisite\n\nNo provision reviewed in the official 2026 Chapter 533A text, compiled Chapter 20, or the targeted Chapter 636 provisions expressly says that a consumer must first obtain:\n\n- a judgment against the provider;\n- an IDOB restitution order;\n- a criminal conviction;\n- revocation of the provider’s license;\n- proof that the provider is insolvent; or\n- a denied demand to the provider\n\nbefore making a bond claim.\n\nThat is an evidence gap, not a conclusion that none of those conditions applies. The live bond form, surety defenses, and governing procedural law remain necessary.\n\n## 5.4 Decisions and formal interpretations\n\nTargeted searches of official Iowa court and agency domains were performed for Chapter 533A bond actions, §533A.2(4), debtor standing, surety notice, claim deadlines, aggregate allocation, cancellation tails, successor security, and bond exhaustion.\n\nNo materially on-point Iowa appellate decision or formal public Iowa Division of Banking interpretation was located through those searches. The returned judicial materials concerned unrelated statutory bond regimes and were not imported into this analysis.\n\nThat is a bounded search result, **not proof that no relevant case, trial-court order, administrative file, unpublished decision, or archived interpretation exists**.\n\n# 6. Security, claimant, remedy, and conditions matrix\n\n| Issue | Verified rule | Actor or beneficiary | Required condition | Limit | Unresolved |\n| --- | --- | --- | --- | --- | --- |\n| Initial bond | Applicant must file superintendent-approved bond before engaging | Applicant/licensee; superintendent approves | Covered Chapter 533A application | $25,000 for each office | Current rendered form and actual approval |\n| Exempt person | Person satisfying §533A.2(2) need not otherwise comply with chapter | Exact exempt entity/activity | All exemption conditions actually met | Exemption is activity/entity specific | Actual facts and hybrid activities |\n| Bond issuer | Authorized corporate surety may provide an approvable bond | Iowa-authorized surety | Current certificate of authority; superintendent approval | Subject to surety authority and bond terms | Actual issuer and certificate |\n| Bond obligee | Bond is in favor of Iowa’s people | State/public obligee structure | Valid bond | Penal sum | Current official wording |\n| Protected class | Bond intended to indemnify debtors | Natural-person debtor | Causal loss from Chapter 533A-prohibited conduct | Available aggregate | Direct claim procedure |\n| Faithful accounting | Bond covers faithful accounting for entrusted money by provider, employees, and agents | Debtors | Covered entrusted-account loss | Available aggregate | Meaning of covered loss in particular facts |\n| Other legal violations | Bond condition refers to laws pertaining to business | State/surety/possible claimant | Violation and applicable causal loss | Bond terms and cap | Whether each non-533A violation supports private recovery |\n| Per-office base | $25,000 for each office | Each covered office | Office within statutory definition | $25,000 aggregate attributable to office | Current NMLS implementation |\n| Branch | Branch is independently licensed | Licensee/branch | Branch application and authorization | Statutory office base remains | NMLS says branch ESBs not accepted; filing mechanism unresolved |\n| Name/location change | New or amended bond must reflect new name/location | Licensee and surety | Advance change process | Existing penal sum unless law/form requires otherwise | Continuity and old-name claims |\n| Surety cancellation | 30 days’ notice to superintendent | Surety | Proper notice | Liability relieved for post-effective-date breaches | Claim deadline and notice to consumers |\n| Replacement | No operation without good bond; maintenance required | Licensee | Effective compliant replacement before gap | Required office security | Exact overlap and NMLS transaction |\n| Failure to maintain | Ground for discipline | Superintendent | Failure/cancellation notice | Discipline and other remedies | Automatic versus discretionary license effect |\n| Aggregate exhaustion | All debtors of the office share penal sum | Covered claimants | Covered and timely claims | $25,000 total per office bond | Priority and allocation |\n| Restitution | Superintendent can order provider restitution | Affected persons under order | Enforcement finding and process | Order-specific | Interaction with surety and offsets |\n| Civil penalty | Up to $5,000 per violation | State enforcement | Proven violation | $5,000 per violation | Not stated as consumer compensation |\n| Injunction | Superintendent may seek court order | State/public | Violation or threatened violation | Equitable relief | Consumer damages separate |\n| Educational-loan action | Express private cause under §533A.8A | Affected debtor | Violation of that section | Actual damages/equitable relief/costs/fees | Separate bond coverage |\n| IDOB complaint | Written consumer complaint may trigger investigation | Consumer and superintendent | Written complaint; regulated entity | Administrative process | Not a verified bond claim |\n| Corporate-surety service | Service on Iowa agent or insurance commissioner when suit otherwise lies | Litigant | Existing right to sue on bond | Procedural only | Cause, venue, deadline |\n| Surety insolvency | Iowa guaranty association excludes surety bonds | Claimant/surety estate | Surety insolvency | No Chapter 515B fallback established | Liquidation and other recovery |\n| Bond records | Licensee must retain bond-maintenance records | Licensee/superintendent | Applicable record duties | Retention periods | Five-year/36-month trigger reconciliation preserved |\n\n# Bounded recovery examples\n\nThese examples are comparison ledgers, not findings of actual liability. All figures are U.S. dollars and rounded to two decimals. Each assumes a valid applicable bond, a covered office, timely action, and no defenses unless stated.\n\n## S_IA-P5-E01 — One consumer, loss below available penal sum\n\nPlain text\n```\nProven covered uncompensated loss:          $7,500.00\nOffice bond penal sum:                     $25,000.00\nPrior valid payments from same aggregate:       $0.00\nRemaining arithmetic capacity:             $25,000.00\n\nUpper-bound bond comparison:\nmin($7,500.00, $25,000.00) =                $7,500.00\n```\n\n**Conditional result:** $7,500 is the numerical upper bound under the stated assumptions.\n\nIt is not a payout guarantee. The claimant still must establish protected status, covered conduct, causation, applicable office, bond period, timeliness, and current capacity. The statute’s penal sum cannot increase the consumer’s compensable loss. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P5-E02 — Money already returned is credited once\n\nPlain text\n```\nGross claimed causal loss:                 $12,000.00\nMoney already restored by provider:         -4,000.00\n                                           ----------\nNet uncompensated comparison loss:           $8,000.00\n\nAssumed remaining bond capacity:            $25,000.00\nUpper-bound comparison:\nmin($8,000.00, $25,000.00) =                 $8,000.00\n```\n\nThe same $4,000 cannot be recovered again from the surety as part of the identical loss.\n\nThis example does not resolve whether Iowa applies collateral-source, subrogation, settlement-credit, or allocation rules differently in a particular action.\n\n## S_IA-P5-E03 — Multiple consumers exceed one office’s aggregate\n\nAssume all three claims are valid, timely, covered by the same office bond, and uncompensated:\n\nPlain text\n```\nConsumer A covered loss:                   $18,000.00\nConsumer B covered loss:                    12,000.00\nConsumer C covered loss:                     5,000.00\n                                           ----------\nTotal covered losses:                      $35,000.00\n\nOffice aggregate penal sum:                $25,000.00\nAggregate shortfall:                       $10,000.00\n```\n\nThe surety’s maximum collective exposure is $25,000, not $35,000. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n**No individual payout is calculated.** Iowa’s reviewed provisions do not establish first-filed, first-judgment, pro-rata, superintendent-controlled, or another allocation method.\n\nFor comparison only, an equal-percentage pro-rata allocation would use:\n\n$25,000$35,000=71.428571%\\frac{\\$25{,}000}{\\$35{,}000}=71.428571\\%$35,000$25,000​=71.428571%But applying that percentage would invent an allocation rule. It is therefore **not used** as a legal payout result.\n\n## S_IA-P5-E04 — Cancellation cutoff\n\nAssume:\n\nPlain text\n```\nDay 0:  Surety gives compliant cancellation notice.\nDay 30: Cancellation becomes effective.\n```\n\nTwo separate alleged breaches:\n\nPlain text\n```\nBreach 1: Day 20; covered loss =             $6,000.00\nBreach 2: Day 40; covered loss =              6,000.00\n```\n\nUnder §533A.2(4):\n\n- Breach 1 occurred before effective cancellation and is not released merely by the later cancellation.\n- Breach 2 occurred after effective cancellation and falls outside that surety’s statutory liability. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThis does not establish when the Day-20 claim must be presented or sued upon. The claim deadline and current official tail terms remain unresolved.\n\n## S_IA-P5-E05 — Two offices do not automatically stack\n\nAssume:\n\nPlain text\n```\nOffice A statutory penal amount:            $25,000.00\nOffice B statutory penal amount:             25,000.00\nConsumer dealt only with Office A.\nCovered uncompensated loss:                 $30,000.00\n```\n\nComparison tied to Office A:\n\nPlain text\n```\nmin($30,000.00, $25,000.00) =               $25,000.00\nPotential uncovered shortfall:                $5,000.00\n```\n\nOffice B’s amount is not added merely because the same company operates both offices. The statute caps the surety’s liability to debtors doing business with the office for which the bond was filed. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nDifferent facts could require analysis where multiple offices actually participated, but no stacking rule was established.\n\n## S_IA-P5-E06 — Prior payments and uncertain remaining capacity\n\nAssume the same unchanged office bond and no replenishment, annual reset, or replacement:\n\nPlain text\n```\nPenal sum:                                  $25,000.00\nEarlier valid bond payments:                 -9,000.00\n                                           ----------\nArithmetic remaining capacity:              $16,000.00\n\nNew otherwise covered loss:                 $20,000.00\nUpper-bound comparison:\nmin($20,000.00, $16,000.00) =               $16,000.00\n```\n\nThe $16,000 result is valid only under the explicit same-bond/no-reset assumptions.\n\nThe operative provisions reviewed do not establish whether:\n\n- the earlier payment actually eroded the same aggregate;\n- a successor bond began a new aggregate;\n- the surety replenished capacity;\n- the bond resets annually; or\n- the claims span different office bonds.\n\nWithout the actual bond history and paid-claim record, remaining capacity cannot be verified.\n\n## S_IA-P5-E07 — Restitution and bond recovery are not additive for the same loss\n\nAssume:\n\nPlain text\n```\nEstablished consumer loss:                 $20,000.00\nProvider restitution actually paid:         -8,000.00\n                                           ----------\nRemaining uncompensated loss:               $12,000.00\n\nAssumed remaining bond capacity:            $25,000.00\nUpper-bound bond comparison:                $12,000.00\n```\n\nThe consumer cannot use the same $8,000 loss twice to produce a $28,000 recovery from a $20,000 loss.\n\nThis does not determine:\n\n- whether the restitution order binds the surety;\n- whether the surety receives a credit;\n- whether the surety has subrogation rights;\n- the order of collection; or\n- whether another category of legally recoverable damage exists.\n\n## S_IA-P5-E08 — Statutory per-office requirement versus NMLS filing architecture\n\nAssume three covered offices:\n\nPlain text\n```\nOffice count:                                        3\nStatutory base per office:                  × $25,000.00\n                                           -------------\nTotal required statutory penal amount:        $75,000.00\n```\n\nThis arithmetic follows the statute’s $25,000-for-each-office language.\n\nIt does **not** determine whether NMLS requires:\n\nPlain text\n```\nOne $75,000 company ESB,\nThree office schedules under one ESB,\nOne $25,000 ESB plus office riders,\nor another regulator-approved structure.\n```\n\nNMLS’s published table says branch bonds are not accepted, while Iowa law retains a per-office base. The current Iowa-specific checklist and rendered form are necessary to reconcile those filing mechanics. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n# Source register — S_IA-P5-S001+\n\nAll fresh accesses occurred October 25, 2026 Pacific / October 26, 2026 UTC. No source below is assigned multiple IDs merely because several clauses were used.\n\n| Source ID | Title, issuer, and full literal URL | Exact clause/page/index used | Version/effective status | Access status and limits |\n| --- | --- | --- | --- | --- |\n| **S_IA-P5-S001** | Iowa Legislature, **Iowa Code 2026, Chapter 533A — Debt Management**. https://www.legis.iowa.gov/docs/code/2026/533A.pdf | §533A.1(4), (7), (12), (14), printed pp.1–2/PDF indices 0–1; §533A.2(1)–(4), (6), pp.2–3/indices 1–2; §533A.7, p.5/index 4; §533A.8A(6), p.9/index 8; §533A.10, p.11/index 10; §533A.16, p.13/index 12. | Official 2026 Code chapter; PDF footer December 9, 2025. | **Freshly read/re-read relevant complete paragraphs.** Same underlying authority used in P1, but new bond/remedy passages were inspected for this component. No complete post-compilation session-law audit. [Iowa Legislature+3](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **S_IA-P5-S002** | Iowa Legislature, **Iowa Administrative Code, Banking Division [187], Agency PDF**. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf | Chapter 20: 20.3(5), printed p.1/PDF index 68; 20.6(1)–(2), p.2/index 69; 20.9(7)(d), p.4/index 71; 20.10, pp.4–5/indices 71–72; 20.11(2)(n), p.5/index 72. | 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 previously reviewed; exact bond, change, record, complaint, and discipline clauses freshly re-read.** Entire 75-page agency PDF not read. Original 2018 order, post-October-14 changes, and ARC 0368D final disposition remain held. [Iowa Legislature+3](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) |\n| **S_IA-P5-S003** | Iowa Legislature, **Iowa Code 2026, Chapter 636 — Sureties, Fiduciaries, Trusts, Investments**. https://www.legis.iowa.gov/docs/code/2026/636.html | §§636.11, 636.14, 636.16, and 636.20. | Official 2026 Code HTML. | **Fresh targeted read.** Used only for corporate-surety authority, approval evidence, and service when suit otherwise lies. It does not establish Chapter 533A standing, coverage, or claim deadline. [Iowa Legislature+3](https://www.legis.iowa.gov/docs/code/2026/636.html) |\n| **S_IA-P5-S004** | Iowa Legislature, **Iowa Code 2026, Chapter 515B — Insurance Guaranty Association**. https://www.legis.iowa.gov/docs/code/2026/515B.html | §515B.1(3), scope exclusion for fidelity or surety bonds and other bonding obligations. | Official 2026 Code HTML. | **Fresh targeted read.** Establishes only the Chapter 515B exclusion; broader surety-liquidation recovery not reviewed. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/515B.html) |\n| **S_IA-P5-S005** | Iowa Division of Banking, **How Do I File a Complaint?** https://idob.iowa.gov/how-do-i-file-complaint | “Find the regulator,” “Submit a complaint form,” “After you submit,” and contract-dispute limitation. | Official IDOB page displayed in 2026. | **Freshly read.** Administrative complaint route only; not a bond claim form or adjudication procedure. [Iowa Division of Banking+1](https://idob.iowa.gov/how-do-i-file-complaint) |\n| **S_IA-P5-S006** | Iowa Division of Banking, **Finance License Verification**. https://idob.iowa.gov/finance/finance-license-verification | NMLS Consumer Access route and Debt Management license category. | Official operational page. | **Reused from P1/P3 and freshly checked narrowly.** No provider lookup, bond record, surety, or license result obtained. |\n| **S_IA-P5-S007** | NMLS, **Managing NMLS Electronic Surety Bonds for Licensees**. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html | ESB submission, tracking, riders, status history, increases/cancellations, and state-specific qualification. | Current public NMLS operational guide accessed October 25, 2026 Pacific. | **Freshly read.** Generic NMLS process, not Iowa law or Iowa’s rendered bond form. [Nationwide Licensing System](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html) |\n| **S_IA-P5-S008** | NMLS, **Bond Creation**. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html | Statement that regulator creates the form and NMLS renders it for license-specific completion. | Current public NMLS policy guide accessed October 25, 2026 Pacific. | **Freshly read.** Does not expose the Iowa form or consumer claim process. [Nationwide Licensing System](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html) |\n| **S_IA-P5-S009** | NMLS, **ESB Adoption Table**. https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf | Updated July 29, 2025; Iowa Division of Banking row, Debt Management License; heading “Branch Bonds are Not Accepted,” PDF index 3. | Dated NMLS operational table, not Iowa statutory authority; hosted on NMLS QA domain. | **Freshly opened, parsed, and visually inspected.** Supports historical/current operational architecture only. It does not reconcile the statutory per-office amount or prove October 2026 checklist currency. [NMLS Resource Center+1](https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf) |\n| **S_IA-P5-S010** | Private surety-site copy, **Debt Management License Bond (Iowa)**. https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf | One page/PDF index 0; dated September 10, 2016; reference-only warning; clauses 1–4. | Historical/private discovery copy; expressly “for reference ONLY.” | **Freshly read and visually inspected, but not treated as controlling.** Current official form, amendments, and legal status not verified. [Axcess Surety+1](https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf) |\n\n# Claim register — S_IA-P5-C001+\n\n| Claim ID | Precise assertion | Source and pinpoint | Conditions, exceptions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_IA-P5-C001** | A nonexempt covered Chapter 533A applicant must file a superintendent-approved bond before engaging in debt management. | S001 §533A.2(1), (4); S002 20.3(5). | High for 2026 Code and October 14 compiled rule; exemption facts and later amendments held. |\n| **S_IA-P5-C002** | The required penal amount is $25,000 for each statutory office. | S001 §§533A.1(12), .2(4). | High for statutory text; current NMLS instrument structure unresolved. |\n| **S_IA-P5-C003** | The bond is in favor of the people of Iowa and is intended to indemnify debtors for loss from Chapter 533A-prohibited conduct. | S001 §533A.2(4). | High for text; direct-action procedure and coverage adjudication held. |\n| **S_IA-P5-C004** | Bond conditions include compliance with laws pertaining to the business and faithful accounting for entrusted money handled by the provider, employees, and agents. | S001 §533A.2(4). | High for text; effect of a non-533A violation on a private claim is unresolved. |\n| **S_IA-P5-C005** | The surety’s aggregate liability to all debtors doing business with the bonded office cannot exceed the penal sum. | S001 §533A.2(4). | High. Not per debtor, claim, violation, or judgment. |\n| **S_IA-P5-C006** | The surety may cancel on 30 days’ notice to the superintendent and is relieved for breaches after effective cancellation. | S001 §533A.2(4). | High for cutoff; claim-notice and suit tail unresolved. |\n| **S_IA-P5-C007** | Failure to post or maintain the bond, or notice of cancellation, exposes the licensee to discipline; operating without a good bond is prohibited. | S001 §§533A.2(4), .7(1)(f); S002 20.11(2)(n). | High; automatic license termination not established. |\n| **S_IA-P5-C008** | A name or location change requires proof of a new or amended bond reflecting the change. | S002 20.6(1). | High for compiled rule; predecessor/successor claim treatment held. |\n| **S_IA-P5-C009** | Branches are independently licensed, but the current NMLS mechanism for satisfying the per-office bond base is unresolved because NMLS’s ESB table says branch bonds are not accepted. | S001 §§533A.1(12), .2(4); S002 20.6(2); S009 PDF index 3. | High for each source’s wording; reconciliation requires current Iowa form/checklist. |\n| **S_IA-P5-C010** | No cash deposit, letter of credit, fidelity, self-insurance, or other substitute was authorized in the operative Chapter 533A and Chapter 20 provisions reviewed. | S001 §533A.2(4); S002 20.3(5). | High as a bounded negative finding; not a complete audit of every possible later enactment/order. |\n| **S_IA-P5-C011** | Iowa-authorized corporate sureties holding the required insurance authority may provide approvable bonds. | S003 §§636.11, .14, .16. | High for general surety law; actual issuer and approval unverified. |\n| **S_IA-P5-C012** | Chapter 636’s service provision applies when suit otherwise lies and does not itself create a Chapter 533A cause of action or deadline. | S003 §636.20. | High as textual limitation. |\n| **S_IA-P5-C013** | Chapter 533A’s bond paragraph does not expressly state a claim form, notice recipient, judgment prerequisite, exhaustion prerequisite, or filing deadline. | S001 §533A.2(4). | High for the reviewed paragraph; other controlling law or live form may add requirements. |\n| **S_IA-P5-C014** | The IDOB complaint system is an administrative investigation route, not a verified bond claim or court adjudication route. | S005; S002 20.10. | High for official process description. |\n| **S_IA-P5-C015** | Restitution, civil penalties, discipline, and injunctions are separate from surety liability. | S001 §§533A.7, .16. | High. Interaction and offsets in actual cases remain held. |\n| **S_IA-P5-C016** | A civil penalty up to $5,000 per violation is not stated to be payable to a consumer or added to the bond’s penal sum. | S001 §§533A.7(2)(d), .16(3). | High for statutory structure; no contrary specific order reviewed. |\n| **S_IA-P5-C017** | Section 533A.8A creates a special educational-loan private action for actual damages, equitable relief, costs, and attorney fees, with a four-year period for nongovernmental actions. | S001 §533A.8A(6). | High; not a universal bond or Chapter 533A limitation period. |\n| **S_IA-P5-C018** | Multiple claims share the office aggregate, but no allocation priority or pro-rata rule was established. | S001 §533A.2(4). | High for cap; allocation unresolved. |\n| **S_IA-P5-C019** | Bonds attributable to other offices cannot automatically be stacked for a claimant tied only to one office. | S001 §533A.2(4). | High as office-specific reading; multi-office factual cases held. |\n| **S_IA-P5-C020** | No mandatory replenishment, annual reset, payment notice, per-consumer sublimit, or predecessor/successor overlap rule was established. | S001 §533A.2(4); S002 relevant bond clauses. | Bounded unresolved finding; current form and decisions needed. |\n| **S_IA-P5-C021** | Licensees must preserve correspondence and records relating to required surety bonds. | S002 20.9(7)(d). | High; statutory five-year versus rule 36-month issue remains preserved and unresolved. |\n| **S_IA-P5-C022** | Iowa’s Insurance Guaranty Association does not cover fidelity or surety bonds or other bonding obligations. | S004 §515B.1(3). | High for Chapter 515B; other insolvency recoveries excluded. |\n| **S_IA-P5-C023** | NMLS provides electronic bond submission and lifecycle management, and the state regulator creates the rendered form. | S007–S008. | High for generic system operation; Iowa-specific form and claim rules not established. |\n| **S_IA-P5-C024** | The privately hosted 2016 reference form cannot authenticate current direct-action, continuing-obligation, or tail terms. | S010, index 0. | High as source-status qualification. |\n| **S_IA-P5-C025** | No actual provider, bond, surety, bond number, office schedule, cancellation, claim payment, or remaining capacity was verified. | Research limitation across S001–S010. | Confirmed limitation; no operational or claimant approval follows. |\n| **S_IA-P5-C026** | Targeted official-domain searches did not locate a materially on-point controlling Iowa appellate decision or formal public IDOB interpretation on Chapter 533A bond claims. | Search process; no contrary authority relied upon. | Bounded negative search only; not proof no authority exists. |\n| **S_IA-P5-C027** | The official 2026 Code and October 14, 2026 rule compilation support the stated framework, but a complete post-compilation enactment audit and post-October-14 rule audit were not completed. | S001–S002 version data. | Currentness hold preserved. |\n| **S_IA-P5-C028** | The bond does not replace trust principal, refunds, provider liability, restitution, or other legally available recovery. | S001 §§533A.2(4), .7, .16. | High as structural distinction; actual offsets and remedies held. |\n\n# Complete PASS-05 component coverage and gaps\n\n| Component | Status | Claims | Exact missing evidence / next action |\n| --- | --- | --- | --- |\n| Covered applicant bond requirement | **Answered at statutory level** | C001 | Verify actual applicant and exemptions. |\n| Conditional exemptions from bond requirement | **Partial; P1 preserved** | C001 | Entity documents, activity facts, attorney/nonprofit/institutional conditions. |\n| Bond amount | **Answered** | C002 | Post-compilation amendment audit remains. |\n| Per-office base | **Answered legally; filing mechanics partial** | C002, C009 | Current Iowa rendered form, checklist, office schedule, and NMLS configuration. |\n| Branch bond treatment | **Partial** | C008–C009 | Explain NMLS no-branch-bond architecture against statutory per-office amount. |\n| Bond obligee | **Answered** | C003 | Current official form wording still desirable. |\n| Protected consumer class | **Answered at statute level** | C003 | Actual debtor status and office relationship. |\n| Covered accounting duties | **Answered at statute level** | C004 | Actual entrusted money, employee/agent conduct, and loss tracing. |\n| Coverage for non-533A laws | **Partial** | C004 | Current form and controlling interpretation of broad condition. |\n| Surety issuer authorization | **Answered generally** | C011 | Actual surety certificate and bond approval. |\n| Current actual bond form | **Unresolved** | C023–C024 | Obtain public official NMLS-rendered Iowa form or authenticated regulator copy without filing/contacting. |\n| Security alternatives | **No alternative established** | C010 | Later legislation, formal order, or official instruction if any. |\n| Indexing or variable bond amount | **No mechanism established** | C002, C010 | Complete later-enactment audit. |\n| Continuous maintenance | **Answered operationally** | C006–C007 | Exact replacement processing and overlap. |\n| Cancellation notice | **Answered** | C006 | Actual notice, service date, and bond terms. |\n| Post-cancellation breach cutoff | **Answered** | C006 | Claim-presentation deadline remains unresolved. |\n| Replacement bond | **Partial** | C007–C008 | Effective dates, riders, predecessor/successor terms, and NMLS record. |\n| Name/location bond change | **Answered procedurally** | C008 | Actual amended bond and old-location coverage. |\n| Surrender/cessation effect on provider liability | **Answered narrowly in prior statute** | C007, C028 | Surety tail, successor claims, and wind-down remain unresolved. |\n| Aggregate office cap | **Answered** | C005 | Actual remaining capacity required. |\n| Per-consumer limit | **No separate sublimit established** | C005, C020 | Current official form or controlling case. |\n| Multiple claims allocation | **Unresolved** | C018 | Statute, form, court decision, administrative process, or interpleader record. |\n| First-filed/first-judgment priority | **Unresolved** | C018 | Controlling law or actual bond proceeding. |\n| Replenishment after payment | **Unresolved** | C020 | Current bond, rider, NMLS history, or formal interpretation. |\n| Annual reset or bond-year aggregates | **Unresolved** | C020 | Current official form and bond history. |\n| Multiple-office stacking | **Answered only as no automatic stacking** | C019 | Actual multi-office conduct and instrument structure. |\n| Provider insolvency | **Excluded except narrow bond implications** | C022, C028 | Bankruptcy, receivership, estate priority, and provider assets later. |\n| Surety insolvency | **Partial** | C022 | Domiciliary liquidation, proof deadline, reinsurance, and estate priority. |\n| Iowa guaranty-association fallback | **Answered negatively** | C022 | Other-state or liquidation mechanisms held. |\n| Consumer direct action against surety | **Unresolved under current authenticated sources** | C003, C012–C013, C024 | Current official form and controlling Iowa authority. |\n| State action on bond | **Partial** | C003, C024 | Current form, agency practice, and actual proceeding. |\n| Claim recipient and form | **Unresolved** | C013–C014 | Official consumer claim instructions or surety form. |\n| Notice to surety | **Unresolved** | C013 | Current form and procedural law. |\n| Judgment prerequisite | **Unresolved** | C013 | Current form, case, or agency interpretation. |\n| Exhaustion against provider | **Unresolved** | C013 | Current form and controlling law. |\n| Bond claim deadline | **Unresolved** | C006, C013, C017 | Bond terms, applicable limitations statute, accrual, and cases. |\n| Discovery versus breach date | **Unresolved** | C006 | Controlling claim and limitations law. |\n| Corporate-surety service | **Answered conditionally** | C012 | Applies only where a suit otherwise lies. |\n| IDOB complaint route | **Answered** | C014 | Complaint is not established as bond notice. |\n| Superintendent restitution | **Answered as separate remedy** | C015 | Actual order, beneficiary, offsets, collection, and appeal. |\n| Civil penalties | **Answered as public/separate** | C015–C016 | Actual enforcement order if later relevant. |\n| Injunction | **Answered as separate remedy** | C015 | Full enforcement pass remains later. |\n| General Chapter 533A private damages action | **Unresolved/not established here** | C013, C017 | Full Iowa litigation and UTPA pass. |\n| Educational-loan private action | **Answered narrowly** | C017 | Bond coverage, actual violation, and other remedies. |\n| Attorney fees and costs | **Answered only for §533A.8A** | C017 | No universal bond fee shifting established. |\n| Double recovery/credits | **Answered only as ledger principle** | C028 and examples | Actual settlement, subrogation, collateral-source, and order language. |\n| Subrogation | **Unresolved** | C020, C028 | Bond terms and general surety law. |\n| Bond-maintenance records | **Answered** | C021 | Actual records and retention trigger. |\n| Five-year statute versus 36-month rule | **Preserved unresolved issue** | C021 | Authoritative reconciliation; no shorter retention inferred. |\n| Public provider bond details | **Unresolved** | C025 | Actual NMLS record or other lawfully public source. |\n| NMLS ESB operation | **Answered generically** | C023 | Current Iowa-specific instructions and form remain unavailable. |\n| Controlling decisions/formal interpretations | **Unresolved after bounded search** | C026 | Broader case databases, trial records, archived orders, or authenticated agency interpretation. |\n| Complete post-compilation currentness | **Unresolved** | C027 | Enacted-session-law and later-rule audit. |\n| ARC 0368D final disposition | **Preserved hold; not re-researched** | C027 | Separate already-defined currentness task. |\n| Full contract enforceability | **Excluded** | — | Later agreement pass. |\n| Full trust/funds treatment | **Excluded; P4 unreviewed** | — | P4 review or later funds work. |\n| Fee earning and refunds | **Excluded except bond offsets** | — | P1 and later fee/contract interpretation. |\n| General civil claims, torts, UTPA, limitations | **Excluded** | — | Separate litigation/remedies pass. |\n| Collection, garnishment, secured debt | **Excluded** | — | Separate passes. |\n| Local, tribal, sector, federal TSR/CROA | **Excluded** | — | Separate required passes. |\n| Actual operational approval, state acceptance, parent acceptance, or A066 | **Unresolved** | C025, C027 | Entire dossier and all remaining dimensions required. |\n\n# Researcher self-check\n\n## Actually read or re-read in PASS-05\n\nThe following public primary or official operational material was freshly inspected on October 25, 2026 Pacific:\n\n- Complete operative bond paragraph in Iowa Code §533A.2(4).\n- Necessary Chapter 533A definitions, exemptions, discipline, examination/confidentiality, educational-loan private remedy, injunction, civil-penalty, and restitution clauses.\n- Compiled Rules 20.3(5), 20.6, 20.9(7)(d), 20.10, and 20.11.\n- Iowa Code Chapter 636 provisions on authorized corporate sureties, approval certificates, and service where suit otherwise lies.\n- Iowa Code §515B.1’s surety-bond exclusion.\n- IDOB’s complaint and license-verification routes.\n- NMLS’s generic ESB management and bond-creation instructions.\n- The NMLS ESB adoption table’s Iowa row and no-branch-bond heading, including visual PDF inspection.\n- The privately hosted 2016 Iowa reference form, including visual PDF inspection, solely as a noncontrolling discovery source.\n- Targeted official-domain searches for Iowa decisions and formal agency interpretations concerning Chapter 533A bond recovery.\n\n## Reused but not regenerated\n\nThe following reviewed material was preserved:\n\n- P1’s $25,000-per-office bond finding and source limits.\n- P1’s classifications, fees, examples, quantities, and comparisons.\n- P2’s operative-rule and completion correction.\n- P3’s date and renewal correction.\n- All existing currentness, provider, contract, NMLS-checklist, proposal, federal, local, tribal, and parent-level holds.\n\nNo P1 fee example or quantity was recalculated.\n\n## Not treated as reviewed\n\nPASS-04 is saved but unreviewed. No new P4 funds, trust, money-transmission, or return conclusion is adopted here as reviewed. References to principal, refunds, or double recovery are limited to what is necessary to distinguish bond security from other recovery sources.\n\n## Not read or not established\n\nThis pass did not establish:\n\n- A current official Iowa rendered debt-management bond form.\n- A complete current Iowa NMLS company or branch checklist.\n- Current NMLS fees or every system instruction.\n- Any actual provider, office, license, bond, surety, producer, bond number, rider, cancellation, or claim.\n- Any surety’s current certificate of authority.\n- Remaining bond capacity or prior claim payments.\n- A consumer bond-claim form or official claim instructions.\n- A judgment, agency-order, exhaustion, or notice prerequisite.\n- A general Chapter 533A bond-claim limitation period.\n- Multiple-claim priority, pro-rata allocation, replenishment, annual reset, subrogation, or successor-bond overlap.\n- Surety liquidation, reinsurance, collateral, or bankruptcy priority.\n- The original 2018 Chapter 20 adoption order.\n- Complete rule history, post-October-14 rule changes, or ARC 0368D’s final disposition.\n- A complete post-compilation legislative audit.\n- A materially on-point controlling Iowa appellate decision or formal public IDOB interpretation.\n- Full general civil, contract, UTPA, tort, fee-shifting, remedies, or limitations analysis.\n- Any bond filing, application, provider contact, regulator contact, legal opinion request, account access, private record, or claim submission.\n\nNo files were written, no site was changed, and no publication action occurred.\n\nThis is a focused same-coordinator component, **not independent review**, and it does not establish provider authorization, bond validity, claim coverage, claim timeliness, remaining surety capacity, Iowa launch approval, publication readiness, component acceptance, state acceptance, parent acceptance, or A066 acceptance.\n\n**END S_IA PASS-05**\n\n","tables":[{"headers":["Item","Character","Bond relationship"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Item","Character","Bond relationship"],["Consumer principal or refund already owed","Consumer money or provider debt","Not transformed into bond proceeds merely because unpaid"],["Provider liability for covered loss","Liability of principal/provider","May potentially be secured by bond, subject to coverage and cap"],["Surety liability","Secondary/capped bond obligation","Aggregate limited to penal sum for that office"],["Superintendent-ordered restitution","Administrative remedial order","Separate from bond recovery; no automatic double recovery"],["Civil penalty","Public enforcement sanction","Not stated to be payable to the consumer"],["Injunction or license discipline","Regulatory relief","Does not itself establish a consumer’s bond payout"],["Special educational-loan damages action","Express statutory private remedy under §533A.8A","Separate claim against licensee; bond coverage still requires its own analysis"]]},{"headers":["Issue","Verified rule","Actor or beneficiary","Required condition","Limit","Unresolved"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Issue","Verified rule","Actor or beneficiary","Required condition","Limit","Unresolved"],["Initial bond","Applicant must file superintendent-approved bond before engaging","Applicant/licensee; superintendent approves","Covered Chapter 533A application","$25,000 for each office","Current rendered form and actual approval"],["Exempt person","Person satisfying §533A.2(2) need not otherwise comply with chapter","Exact exempt entity/activity","All exemption conditions actually met","Exemption is activity/entity specific","Actual facts and hybrid activities"],["Bond issuer","Authorized corporate surety may provide an approvable bond","Iowa-authorized surety","Current certificate of authority; superintendent approval","Subject to surety authority and bond terms","Actual issuer and certificate"],["Bond obligee","Bond is in favor of Iowa’s people","State/public obligee structure","Valid bond","Penal sum","Current official wording"],["Protected class","Bond intended to indemnify debtors","Natural-person debtor","Causal loss from Chapter 533A-prohibited conduct","Available aggregate","Direct claim procedure"],["Faithful accounting","Bond covers faithful accounting for entrusted money by provider, employees, and agents","Debtors","Covered entrusted-account loss","Available aggregate","Meaning of covered loss in particular facts"],["Other legal violations","Bond condition refers to laws pertaining to business","State/surety/possible claimant","Violation and applicable causal loss","Bond terms and cap","Whether each non-533A violation supports private recovery"],["Per-office base","$25,000 for each office","Each covered office","Office within statutory definition","$25,000 aggregate attributable to office","Current NMLS implementation"],["Branch","Branch is independently licensed","Licensee/branch","Branch application and authorization","Statutory office base remains","NMLS says branch ESBs not accepted; filing mechanism unresolved"],["Name/location change","New or amended bond must reflect new name/location","Licensee and surety","Advance change process","Existing penal sum unless law/form requires otherwise","Continuity and old-name claims"],["Surety cancellation","30 days’ notice to superintendent","Surety","Proper notice","Liability relieved for post-effective-date breaches","Claim deadline and notice to consumers"],["Replacement","No operation without good bond; maintenance required","Licensee","Effective compliant replacement before gap","Required office security","Exact overlap and NMLS transaction"],["Failure to maintain","Ground for discipline","Superintendent","Failure/cancellation notice","Discipline and other remedies","Automatic versus discretionary license effect"],["Aggregate exhaustion","All debtors of the office share penal sum","Covered claimants","Covered and timely claims","$25,000 total per office bond","Priority and allocation"],["Restitution","Superintendent can order provider restitution","Affected persons under order","Enforcement finding and process","Order-specific","Interaction with surety and offsets"],["Civil penalty","Up to $5,000 per violation","State enforcement","Proven violation","$5,000 per violation","Not stated as consumer compensation"],["Injunction","Superintendent may seek court order","State/public","Violation or threatened violation","Equitable relief","Consumer damages separate"],["Educational-loan action","Express private cause under §533A.8A","Affected debtor","Violation of that section","Actual damages/equitable relief/costs/fees","Separate bond coverage"],["IDOB complaint","Written consumer complaint may trigger investigation","Consumer and superintendent","Written complaint; regulated entity","Administrative process","Not a verified bond claim"],["Corporate-surety service","Service on Iowa agent or insurance commissioner when suit otherwise lies","Litigant","Existing right to sue on bond","Procedural only","Cause, venue, deadline"],["Surety insolvency","Iowa guaranty association excludes surety bonds","Claimant/surety estate","Surety insolvency","No Chapter 515B fallback established","Liquidation and other recovery"],["Bond records","Licensee must retain bond-maintenance records","Licensee/superintendent","Applicable record duties","Retention periods","Five-year/36-month trigger reconciliation preserved"]]},{"headers":["Source ID","Title, issuer, and full literal URL","Exact clause/page/index used","Version/effective status","Access status and limits"],"index":2,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+3"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+3"},{"href":"https://www.legis.iowa.gov/docs/code/2026/636.html","text":"Iowa Legislature\n+3"},{"href":"https://www.legis.iowa.gov/docs/code/2026/515B.html","text":"Iowa Legislature"},{"href":"https://idob.iowa.gov/how-do-i-file-complaint","text":"Iowa Division of Banking\n+1"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html","text":"Nationwide Licensing System"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html","text":"Nationwide Licensing System"},{"href":"https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf","text":"NMLS Resource Center\n+1"},{"href":"https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf","text":"Axcess Surety\n+1"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+3"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature\n+3"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/636.html","text":"Iowa Legislature\n+3"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/515B.html","text":"Iowa Legislature"}],[{"href":"https://idob.iowa.gov/how-do-i-file-complaint","text":"Iowa Division of Banking\n+1"}],[],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html","text":"Nationwide Licensing System"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html","text":"Nationwide Licensing System"}],[{"href":"https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf","text":"NMLS Resource Center\n+1"}],[{"href":"https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf","text":"Axcess Surety\n+1"}]],"rows":[["Source ID","Title, issuer, and full literal URL","Exact clause/page/index used","Version/effective status","Access status and limits"],["S_IA-P5-S001","Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. https://www.legis.iowa.gov/docs/code/2026/533A.pdf","§533A.1(4), (7), (12), (14), printed pp.1–2/PDF indices 0–1; §533A.2(1)–(4), (6), pp.2–3/indices 1–2; §533A.7, p.5/index 4; §533A.8A(6), p.9/index 8; §533A.10, p.11/index 10; §533A.16, p.13/index 12.","Official 2026 Code chapter; PDF footer December 9, 2025.","Freshly read/re-read relevant complete paragraphs. Same underlying authority used in P1, but new bond/remedy passages were inspected for this component. No complete post-compilation session-law audit. \nIowa Legislature\n+3"],["S_IA-P5-S002","Iowa Legislature, Iowa Administrative Code, Banking Division [187], Agency PDF. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Chapter 20: 20.3(5), printed p.1/PDF index 68; 20.6(1)–(2), p.2/index 69; 20.9(7)(d), p.4/index 71; 20.10, pp.4–5/indices 71–72; 20.11(2)(n), p.5/index 72.","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 previously reviewed; exact bond, change, record, complaint, and discipline clauses freshly re-read. Entire 75-page agency PDF not read. Original 2018 order, post-October-14 changes, and ARC 0368D final disposition remain held. \nIowa Legislature\n+3"],["S_IA-P5-S003","Iowa Legislature, Iowa Code 2026, Chapter 636 — Sureties, Fiduciaries, Trusts, Investments. https://www.legis.iowa.gov/docs/code/2026/636.html","§§636.11, 636.14, 636.16, and 636.20.","Official 2026 Code HTML.","Fresh targeted read. Used only for corporate-surety authority, approval evidence, and service when suit otherwise lies. It does not establish Chapter 533A standing, coverage, or claim deadline. \nIowa Legislature\n+3"],["S_IA-P5-S004","Iowa Legislature, Iowa Code 2026, Chapter 515B — Insurance Guaranty Association. https://www.legis.iowa.gov/docs/code/2026/515B.html","§515B.1(3), scope exclusion for fidelity or surety bonds and other bonding obligations.","Official 2026 Code HTML.","Fresh targeted read. Establishes only the Chapter 515B exclusion; broader surety-liquidation recovery not reviewed. \nIowa Legislature"],["S_IA-P5-S005","Iowa Division of Banking, How Do I File a Complaint? https://idob.iowa.gov/how-do-i-file-complaint","“Find the regulator,” “Submit a complaint form,” “After you submit,” and contract-dispute limitation.","Official IDOB page displayed in 2026.","Freshly read. Administrative complaint route only; not a bond claim form or adjudication procedure. \nIowa Division of Banking\n+1"],["S_IA-P5-S006","Iowa Division of Banking, Finance License Verification. https://idob.iowa.gov/finance/finance-license-verification","NMLS Consumer Access route and Debt Management license category.","Official operational page.","Reused from P1/P3 and freshly checked narrowly. No provider lookup, bond record, surety, or license result obtained."],["S_IA-P5-S007","NMLS, Managing NMLS Electronic Surety Bonds for Licensees. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html","ESB submission, tracking, riders, status history, increases/cancellations, and state-specific qualification.","Current public NMLS operational guide accessed October 25, 2026 Pacific.","Freshly read. Generic NMLS process, not Iowa law or Iowa’s rendered bond form. \nNationwide Licensing System"],["S_IA-P5-S008","NMLS, Bond Creation. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html","Statement that regulator creates the form and NMLS renders it for license-specific completion.","Current public NMLS policy guide accessed October 25, 2026 Pacific.","Freshly read. Does not expose the Iowa form or consumer claim process. \nNationwide Licensing System"],["S_IA-P5-S009","NMLS, ESB Adoption Table. https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf","Updated July 29, 2025; Iowa Division of Banking row, Debt Management License; heading “Branch Bonds are Not Accepted,” PDF index 3.","Dated NMLS operational table, not Iowa statutory authority; hosted on NMLS QA domain.","Freshly opened, parsed, and visually inspected. Supports historical/current operational architecture only. It does not reconcile the statutory per-office amount or prove October 2026 checklist currency. \nNMLS Resource Center\n+1"],["S_IA-P5-S010","Private surety-site copy, Debt Management License Bond (Iowa). https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf","One page/PDF index 0; dated September 10, 2016; reference-only warning; clauses 1–4.","Historical/private discovery copy; expressly “for reference ONLY.”","Freshly read and visually inspected, but not treated as controlling. Current official form, amendments, and legal status not verified. \nAxcess Surety\n+1"]]},{"headers":["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, currentness, and confidence"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, currentness, and confidence"],["S_IA-P5-C001","A nonexempt covered Chapter 533A applicant must file a superintendent-approved bond before engaging in debt management.","S001 §533A.2(1), (4); S002 20.3(5).","High for 2026 Code and October 14 compiled rule; exemption facts and later amendments held."],["S_IA-P5-C002","The required penal amount is $25,000 for each statutory office.","S001 §§533A.1(12), .2(4).","High for statutory text; current NMLS instrument structure unresolved."],["S_IA-P5-C003","The bond is in favor of the people of Iowa and is intended to indemnify debtors for loss from Chapter 533A-prohibited conduct.","S001 §533A.2(4).","High for text; direct-action procedure and coverage adjudication held."],["S_IA-P5-C004","Bond conditions include compliance with laws pertaining to the business and faithful accounting for entrusted money handled by the provider, employees, and agents.","S001 §533A.2(4).","High for text; effect of a non-533A violation on a private claim is unresolved."],["S_IA-P5-C005","The surety’s aggregate liability to all debtors doing business with the bonded office cannot exceed the penal sum.","S001 §533A.2(4).","High. Not per debtor, claim, violation, or judgment."],["S_IA-P5-C006","The surety may cancel on 30 days’ notice to the superintendent and is relieved for breaches after effective cancellation.","S001 §533A.2(4).","High for cutoff; claim-notice and suit tail unresolved."],["S_IA-P5-C007","Failure to post or maintain the bond, or notice of cancellation, exposes the licensee to discipline; operating without a good bond is prohibited.","S001 §§533A.2(4), .7(1)(f); S002 20.11(2)(n).","High; automatic license termination not established."],["S_IA-P5-C008","A name or location change requires proof of a new or amended bond reflecting the change.","S002 20.6(1).","High for compiled rule; predecessor/successor claim treatment held."],["S_IA-P5-C009","Branches are independently licensed, but the current NMLS mechanism for satisfying the per-office bond base is unresolved because NMLS’s ESB table says branch bonds are not accepted.","S001 §§533A.1(12), .2(4); S002 20.6(2); S009 PDF index 3.","High for each source’s wording; reconciliation requires current Iowa form/checklist."],["S_IA-P5-C010","No cash deposit, letter of credit, fidelity, self-insurance, or other substitute was authorized in the operative Chapter 533A and Chapter 20 provisions reviewed.","S001 §533A.2(4); S002 20.3(5).","High as a bounded negative finding; not a complete audit of every possible later enactment/order."],["S_IA-P5-C011","Iowa-authorized corporate sureties holding the required insurance authority may provide approvable bonds.","S003 §§636.11, .14, .16.","High for general surety law; actual issuer and approval unverified."],["S_IA-P5-C012","Chapter 636’s service provision applies when suit otherwise lies and does not itself create a Chapter 533A cause of action or deadline.","S003 §636.20.","High as textual limitation."],["S_IA-P5-C013","Chapter 533A’s bond paragraph does not expressly state a claim form, notice recipient, judgment prerequisite, exhaustion prerequisite, or filing deadline.","S001 §533A.2(4).","High for the reviewed paragraph; other controlling law or live form may add requirements."],["S_IA-P5-C014","The IDOB complaint system is an administrative investigation route, not a verified bond claim or court adjudication route.","S005; S002 20.10.","High for official process description."],["S_IA-P5-C015","Restitution, civil penalties, discipline, and injunctions are separate from surety liability.","S001 §§533A.7, .16.","High. Interaction and offsets in actual cases remain held."],["S_IA-P5-C016","A civil penalty up to $5,000 per violation is not stated to be payable to a consumer or added to the bond’s penal sum.","S001 §§533A.7(2)(d), .16(3).","High for statutory structure; no contrary specific order reviewed."],["S_IA-P5-C017","Section 533A.8A creates a special educational-loan private action for actual damages, equitable relief, costs, and attorney fees, with a four-year period for nongovernmental actions.","S001 §533A.8A(6).","High; not a universal bond or Chapter 533A limitation period."],["S_IA-P5-C018","Multiple claims share the office aggregate, but no allocation priority or pro-rata rule was established.","S001 §533A.2(4).","High for cap; allocation unresolved."],["S_IA-P5-C019","Bonds attributable to other offices cannot automatically be stacked for a claimant tied only to one office.","S001 §533A.2(4).","High as office-specific reading; multi-office factual cases held."],["S_IA-P5-C020","No mandatory replenishment, annual reset, payment notice, per-consumer sublimit, or predecessor/successor overlap rule was established.","S001 §533A.2(4); S002 relevant bond clauses.","Bounded unresolved finding; current form and decisions needed."],["S_IA-P5-C021","Licensees must preserve correspondence and records relating to required surety bonds.","S002 20.9(7)(d).","High; statutory five-year versus rule 36-month issue remains preserved and unresolved."],["S_IA-P5-C022","Iowa’s Insurance Guaranty Association does not cover fidelity or surety bonds or other bonding obligations.","S004 §515B.1(3).","High for Chapter 515B; other insolvency recoveries excluded."],["S_IA-P5-C023","NMLS provides electronic bond submission and lifecycle management, and the state regulator creates the rendered form.","S007–S008.","High for generic system operation; Iowa-specific form and claim rules not established."],["S_IA-P5-C024","The privately hosted 2016 reference form cannot authenticate current direct-action, continuing-obligation, or tail terms.","S010, index 0.","High as source-status qualification."],["S_IA-P5-C025","No actual provider, bond, surety, bond number, office schedule, cancellation, claim payment, or remaining capacity was verified.","Research limitation across S001–S010.","Confirmed limitation; no operational or claimant approval follows."],["S_IA-P5-C026","Targeted official-domain searches did not locate a materially on-point controlling Iowa appellate decision or formal public IDOB interpretation on Chapter 533A bond claims.","Search process; no contrary authority relied upon.","Bounded negative search only; not proof no authority exists."],["S_IA-P5-C027","The official 2026 Code and October 14, 2026 rule compilation support the stated framework, but a complete post-compilation enactment audit and post-October-14 rule audit were not completed.","S001–S002 version data.","Currentness hold preserved."],["S_IA-P5-C028","The bond does not replace trust principal, refunds, provider liability, restitution, or other legally available recovery.","S001 §§533A.2(4), .7, .16.","High as structural distinction; actual offsets and remedies held."]]},{"headers":["Component","Status","Claims","Exact missing evidence / next action"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Exact missing evidence / next action"],["Covered applicant bond requirement","Answered at statutory level","C001","Verify actual applicant and exemptions."],["Conditional exemptions from bond requirement","Partial; P1 preserved","C001","Entity documents, activity facts, attorney/nonprofit/institutional conditions."],["Bond amount","Answered","C002","Post-compilation amendment audit remains."],["Per-office base","Answered legally; filing mechanics partial","C002, C009","Current Iowa rendered form, checklist, office schedule, and NMLS configuration."],["Branch bond treatment","Partial","C008–C009","Explain NMLS no-branch-bond architecture against statutory per-office amount."],["Bond obligee","Answered","C003","Current official form wording still desirable."],["Protected consumer class","Answered at statute level","C003","Actual debtor status and office relationship."],["Covered accounting duties","Answered at statute level","C004","Actual entrusted money, employee/agent conduct, and loss tracing."],["Coverage for non-533A laws","Partial","C004","Current form and controlling interpretation of broad condition."],["Surety issuer authorization","Answered generally","C011","Actual surety certificate and bond approval."],["Current actual bond form","Unresolved","C023–C024","Obtain public official NMLS-rendered Iowa form or authenticated regulator copy without filing/contacting."],["Security alternatives","No alternative established","C010","Later legislation, formal order, or official instruction if any."],["Indexing or variable bond amount","No mechanism established","C002, C010","Complete later-enactment audit."],["Continuous maintenance","Answered operationally","C006–C007","Exact replacement processing and overlap."],["Cancellation notice","Answered","C006","Actual notice, service date, and bond terms."],["Post-cancellation breach cutoff","Answered","C006","Claim-presentation deadline remains unresolved."],["Replacement bond","Partial","C007–C008","Effective dates, riders, predecessor/successor terms, and NMLS record."],["Name/location bond change","Answered procedurally","C008","Actual amended bond and old-location coverage."],["Surrender/cessation effect on provider liability","Answered narrowly in prior statute","C007, C028","Surety tail, successor claims, and wind-down remain unresolved."],["Aggregate office cap","Answered","C005","Actual remaining capacity required."],["Per-consumer limit","No separate sublimit established","C005, C020","Current official form or controlling case."],["Multiple claims allocation","Unresolved","C018","Statute, form, court decision, administrative process, or interpleader record."],["First-filed/first-judgment priority","Unresolved","C018","Controlling law or actual bond proceeding."],["Replenishment after payment","Unresolved","C020","Current bond, rider, NMLS history, or formal interpretation."],["Annual reset or bond-year aggregates","Unresolved","C020","Current official form and bond history."],["Multiple-office stacking","Answered only as no automatic stacking","C019","Actual multi-office conduct and instrument structure."],["Provider insolvency","Excluded except narrow bond implications","C022, C028","Bankruptcy, receivership, estate priority, and provider assets later."],["Surety insolvency","Partial","C022","Domiciliary liquidation, proof deadline, reinsurance, and estate priority."],["Iowa guaranty-association fallback","Answered negatively","C022","Other-state or liquidation mechanisms held."],["Consumer direct action against surety","Unresolved under current authenticated sources","C003, C012–C013, C024","Current official form and controlling Iowa authority."],["State action on bond","Partial","C003, C024","Current form, agency practice, and actual proceeding."],["Claim recipient and form","Unresolved","C013–C014","Official consumer claim instructions or surety form."],["Notice to surety","Unresolved","C013","Current form and procedural law."],["Judgment prerequisite","Unresolved","C013","Current form, case, or agency interpretation."],["Exhaustion against provider","Unresolved","C013","Current form and controlling law."],["Bond claim deadline","Unresolved","C006, C013, C017","Bond terms, applicable limitations statute, accrual, and cases."],["Discovery versus breach date","Unresolved","C006","Controlling claim and limitations law."],["Corporate-surety service","Answered conditionally","C012","Applies only where a suit otherwise lies."],["IDOB complaint route","Answered","C014","Complaint is not established as bond notice."],["Superintendent restitution","Answered as separate remedy","C015","Actual order, beneficiary, offsets, collection, and appeal."],["Civil penalties","Answered as public/separate","C015–C016","Actual enforcement order if later relevant."],["Injunction","Answered as separate remedy","C015","Full enforcement pass remains later."],["General Chapter 533A private damages action","Unresolved/not established here","C013, C017","Full Iowa litigation and UTPA pass."],["Educational-loan private action","Answered narrowly","C017","Bond coverage, actual violation, and other remedies."],["Attorney fees and costs","Answered only for §533A.8A","C017","No universal bond fee shifting established."],["Double recovery/credits","Answered only as ledger principle","C028 and examples","Actual settlement, subrogation, collateral-source, and order language."],["Subrogation","Unresolved","C020, C028","Bond terms and general surety law."],["Bond-maintenance records","Answered","C021","Actual records and retention trigger."],["Five-year statute versus 36-month rule","Preserved unresolved issue","C021","Authoritative reconciliation; no shorter retention inferred."],["Public provider bond details","Unresolved","C025","Actual NMLS record or other lawfully public source."],["NMLS ESB operation","Answered generically","C023","Current Iowa-specific instructions and form remain unavailable."],["Controlling decisions/formal interpretations","Unresolved after bounded search","C026","Broader case databases, trial records, archived orders, or authenticated agency interpretation."],["Complete post-compilation currentness","Unresolved","C027","Enacted-session-law and later-rule audit."],["ARC 0368D final disposition","Preserved hold; not re-researched","C027","Separate already-defined currentness task."],["Full contract enforceability","Excluded","—","Later agreement pass."],["Full trust/funds treatment","Excluded; P4 unreviewed","—","P4 review or later funds work."],["Fee earning and refunds","Excluded except bond offsets","—","P1 and later fee/contract interpretation."],["General civil claims, torts, UTPA, limitations","Excluded","—","Separate litigation/remedies pass."],["Collection, garnishment, secured debt","Excluded","—","Separate passes."],["Local, tribal, sector, federal TSR/CROA","Excluded","—","Separate required passes."],["Actual operational approval, state acceptance, parent acceptance, or A066","Unresolved","C025, C027","Entire dossier and all remaining dimensions required."]]}],"claims":[{"claim_id":"S_IA-P5-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C001","Precise assertion":"A nonexempt covered Chapter 533A applicant must file a superintendent-approved bond before engaging in debt management.","Source and pinpoint":"S001 §533A.2(1), (4); S002 20.3(5).","Conditions, exceptions, currentness, and confidence":"High for 2026 Code and October 14 compiled rule; exemption facts and later amendments held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C002","Precise assertion":"The required penal amount is $25,000 for each statutory office.","Source and pinpoint":"S001 §§533A.1(12), .2(4).","Conditions, exceptions, currentness, and confidence":"High for statutory text; current NMLS instrument structure unresolved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C003","Precise assertion":"The bond is in favor of the people of Iowa and is intended to indemnify debtors for loss from Chapter 533A-prohibited conduct.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High for text; direct-action procedure and coverage adjudication held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C004","Precise assertion":"Bond conditions include compliance with laws pertaining to the business and faithful accounting for entrusted money handled by the provider, employees, and agents.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High for text; effect of a non-533A violation on a private claim is unresolved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C005","Precise assertion":"The surety’s aggregate liability to all debtors doing business with the bonded office cannot exceed the penal sum.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High. Not per debtor, claim, violation, or judgment."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C006","Precise assertion":"The surety may cancel on 30 days’ notice to the superintendent and is relieved for breaches after effective cancellation.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High for cutoff; claim-notice and suit tail unresolved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C007","Precise assertion":"Failure to post or maintain the bond, or notice of cancellation, exposes the licensee to discipline; operating without a good bond is prohibited.","Source and pinpoint":"S001 §§533A.2(4), .7(1)(f); S002 20.11(2)(n).","Conditions, exceptions, currentness, and confidence":"High; automatic license termination not established."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C008","Precise assertion":"A name or location change requires proof of a new or amended bond reflecting the change.","Source and pinpoint":"S002 20.6(1).","Conditions, exceptions, currentness, and confidence":"High for compiled rule; predecessor/successor claim treatment held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C009","Precise assertion":"Branches are independently licensed, but the current NMLS mechanism for satisfying the per-office bond base is unresolved because NMLS’s ESB table says branch bonds are not accepted.","Source and pinpoint":"S001 §§533A.1(12), .2(4); S002 20.6(2); S009 PDF index 3.","Conditions, exceptions, currentness, and confidence":"High for each source’s wording; reconciliation requires current Iowa form/checklist."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C010","Precise assertion":"No cash deposit, letter of credit, fidelity, self-insurance, or other substitute was authorized in the operative Chapter 533A and Chapter 20 provisions reviewed.","Source and pinpoint":"S001 §533A.2(4); S002 20.3(5).","Conditions, exceptions, currentness, and confidence":"High as a bounded negative finding; not a complete audit of every possible later enactment/order."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C011","Precise assertion":"Iowa-authorized corporate sureties holding the required insurance authority may provide approvable bonds.","Source and pinpoint":"S003 §§636.11, .14, .16.","Conditions, exceptions, currentness, and confidence":"High for general surety law; actual issuer and approval unverified."},"coordinator_verification_status":"original_qualified_by_checked_P07_replacement_not_raw_edit","coordinator_review":"[internal evidence reference]","correction_review":"[internal evidence reference]","corrected_claims":["S_IA-P5-C011","S_IA-P5-C012","S_IA-P5-C029","S_IA-P5-C030"]},{"claim_id":"S_IA-P5-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C012","Precise assertion":"Chapter 636’s service provision applies when suit otherwise lies and does not itself create a Chapter 533A cause of action or deadline.","Source and pinpoint":"S003 §636.20.","Conditions, exceptions, currentness, and confidence":"High as textual limitation."},"coordinator_verification_status":"original_qualified_by_checked_P07_replacement_not_raw_edit","coordinator_review":"[internal evidence reference]","correction_review":"[internal evidence reference]","corrected_claims":["S_IA-P5-C011","S_IA-P5-C012","S_IA-P5-C029","S_IA-P5-C030"]},{"claim_id":"S_IA-P5-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C013","Precise assertion":"Chapter 533A’s bond paragraph does not expressly state a claim form, notice recipient, judgment prerequisite, exhaustion prerequisite, or filing deadline.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High for the reviewed paragraph; other controlling law or live form may add requirements."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C014","Precise assertion":"The IDOB complaint system is an administrative investigation route, not a verified bond claim or court adjudication route.","Source and pinpoint":"S005; S002 20.10.","Conditions, exceptions, currentness, and confidence":"High for official process description."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C015","Precise assertion":"Restitution, civil penalties, discipline, and injunctions are separate from surety liability.","Source and pinpoint":"S001 §§533A.7, .16.","Conditions, exceptions, currentness, and confidence":"High. Interaction and offsets in actual cases remain held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C016","Precise assertion":"A civil penalty up to $5,000 per violation is not stated to be payable to a consumer or added to the bond’s penal sum.","Source and pinpoint":"S001 §§533A.7(2)(d), .16(3).","Conditions, exceptions, currentness, and confidence":"High for statutory structure; no contrary specific order reviewed."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C017","Precise assertion":"Section 533A.8A creates a special educational-loan private action for actual damages, equitable relief, costs, and attorney fees, with a four-year period for nongovernmental actions.","Source and pinpoint":"S001 §533A.8A(6).","Conditions, exceptions, currentness, and confidence":"High; not a universal bond or Chapter 533A limitation period."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C018","Precise assertion":"Multiple claims share the office aggregate, but no allocation priority or pro-rata rule was established.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High for cap; allocation unresolved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C019","Precise assertion":"Bonds attributable to other offices cannot automatically be stacked for a claimant tied only to one office.","Source and pinpoint":"S001 §533A.2(4).","Conditions, exceptions, currentness, and confidence":"High as office-specific reading; multi-office factual cases held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C020","Precise assertion":"No mandatory replenishment, annual reset, payment notice, per-consumer sublimit, or predecessor/successor overlap rule was established.","Source and pinpoint":"S001 §533A.2(4); S002 relevant bond clauses.","Conditions, exceptions, currentness, and confidence":"Bounded unresolved finding; current form and decisions needed."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C021","Precise assertion":"Licensees must preserve correspondence and records relating to required surety bonds.","Source and pinpoint":"S002 20.9(7)(d).","Conditions, exceptions, currentness, and confidence":"High; statutory five-year versus rule 36-month issue remains preserved and unresolved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C022","Precise assertion":"Iowa’s Insurance Guaranty Association does not cover fidelity or surety bonds or other bonding obligations.","Source and pinpoint":"S004 §515B.1(3).","Conditions, exceptions, currentness, and confidence":"High for Chapter 515B; other insolvency recoveries excluded."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C023","Precise assertion":"NMLS provides electronic bond submission and lifecycle management, and the state regulator creates the rendered form.","Source and pinpoint":"S007–S008.","Conditions, exceptions, currentness, and confidence":"High for generic system operation; Iowa-specific form and claim rules not established."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C024","Precise assertion":"The privately hosted 2016 reference form cannot authenticate current direct-action, continuing-obligation, or tail terms.","Source and pinpoint":"S010, index 0.","Conditions, exceptions, currentness, and confidence":"High as source-status qualification."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C025","Precise assertion":"No actual provider, bond, surety, bond number, office schedule, cancellation, claim payment, or remaining capacity was verified.","Source and pinpoint":"Research limitation across S001–S010.","Conditions, exceptions, currentness, and confidence":"Confirmed limitation; no operational or claimant approval follows."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C026","Precise assertion":"Targeted official-domain searches did not locate a materially on-point controlling Iowa appellate decision or formal public IDOB interpretation on Chapter 533A bond claims.","Source and pinpoint":"Search process; no contrary authority relied upon.","Conditions, exceptions, currentness, and confidence":"Bounded negative search only; not proof no authority exists."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C027","Precise assertion":"The official 2026 Code and October 14, 2026 rule compilation support the stated framework, but a complete post-compilation enactment audit and post-October-14 rule audit were not completed.","Source and pinpoint":"S001–S002 version data.","Conditions, exceptions, currentness, and confidence":"Currentness hold preserved."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P5-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P5-C028","Precise assertion":"The bond does not replace trust principal, refunds, provider liability, restitution, or other legally available recovery.","Source and pinpoint":"S001 §§533A.2(4), .7, .16.","Conditions, exceptions, currentness, and confidence":"High as structural distinction; actual offsets and remedies held."},"coordinator_verification_status":"scoped_review_complete_source_applicability_holds_preserved","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_IA-P5-S001","urls":["https://www.legis.iowa.gov/docs/code/2026/533A.pdf"],"researcher_record":{"Source ID":"S_IA-P5-S001","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. https://www.legis.iowa.gov/docs/code/2026/533A.pdf","Exact clause/page/index used":"§533A.1(4), (7), (12), (14), printed pp.1–2/PDF indices 0–1; §533A.2(1)–(4), (6), pp.2–3/indices 1–2; §533A.7, p.5/index 4; §533A.8A(6), p.9/index 8; §533A.10, p.11/index 10; §533A.16, p.13/index 12.","Version/effective status":"Official 2026 Code chapter; PDF footer December 9, 2025.","Access status and limits":"Freshly read/re-read relevant complete paragraphs. Same underlying authority used in P1, but new bond/remedy passages were inspected for this component. No complete post-compilation session-law audit. \nIowa Legislature\n+3"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S002","urls":["https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf"],"researcher_record":{"Source ID":"S_IA-P5-S002","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Administrative Code, Banking Division [187], Agency PDF. https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Exact clause/page/index used":"Chapter 20: 20.3(5), printed p.1/PDF index 68; 20.6(1)–(2), p.2/index 69; 20.9(7)(d), p.4/index 71; 20.10, pp.4–5/indices 71–72; 20.11(2)(n), p.5/index 72.","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 limits":"Complete Chapter 20 read previously reviewed; exact bond, change, record, complaint, and discipline clauses freshly re-read. Entire 75-page agency PDF not read. Original 2018 order, post-October-14 changes, and ARC 0368D final disposition remain held. \nIowa Legislature\n+3"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S003","urls":["https://www.legis.iowa.gov/docs/code/2026/636.html"],"researcher_record":{"Source ID":"S_IA-P5-S003","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 636 — Sureties, Fiduciaries, Trusts, Investments. https://www.legis.iowa.gov/docs/code/2026/636.html","Exact clause/page/index used":"§§636.11, 636.14, 636.16, and 636.20.","Version/effective status":"Official 2026 Code HTML.","Access status and limits":"Fresh targeted read. Used only for corporate-surety authority, approval evidence, and service when suit otherwise lies. It does not establish Chapter 533A standing, coverage, or claim deadline. \nIowa Legislature\n+3"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S004","urls":["https://www.legis.iowa.gov/docs/code/2026/515B.html"],"researcher_record":{"Source ID":"S_IA-P5-S004","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 515B — Insurance Guaranty Association. https://www.legis.iowa.gov/docs/code/2026/515B.html","Exact clause/page/index used":"§515B.1(3), scope exclusion for fidelity or surety bonds and other bonding obligations.","Version/effective status":"Official 2026 Code HTML.","Access status and limits":"Fresh targeted read. Establishes only the Chapter 515B exclusion; broader surety-liquidation recovery not reviewed. \nIowa Legislature"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S005","urls":["https://idob.iowa.gov/how-do-i-file-complaint"],"researcher_record":{"Source ID":"S_IA-P5-S005","Title, issuer, and full literal URL":"Iowa Division of Banking, How Do I File a Complaint? https://idob.iowa.gov/how-do-i-file-complaint","Exact clause/page/index used":"“Find the regulator,” “Submit a complaint form,” “After you submit,” and contract-dispute limitation.","Version/effective status":"Official IDOB page displayed in 2026.","Access status and limits":"Freshly read. Administrative complaint route only; not a bond claim form or adjudication procedure. \nIowa Division of Banking\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S006","urls":["https://idob.iowa.gov/finance/finance-license-verification"],"researcher_record":{"Source ID":"S_IA-P5-S006","Title, issuer, and full literal URL":"Iowa Division of Banking, Finance License Verification. https://idob.iowa.gov/finance/finance-license-verification","Exact clause/page/index used":"NMLS Consumer Access route and Debt Management license category.","Version/effective status":"Official operational page.","Access status and limits":"Reused from P1/P3 and freshly checked narrowly. No provider lookup, bond record, surety, or license result obtained."},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S007","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html"],"researcher_record":{"Source ID":"S_IA-P5-S007","Title, issuer, and full literal URL":"NMLS, Managing NMLS Electronic Surety Bonds for Licensees. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/ugCompState/licensing/company/topics/licCompESB_ESBforLicensees_managing.html","Exact clause/page/index used":"ESB submission, tracking, riders, status history, increases/cancellations, and state-specific qualification.","Version/effective status":"Current public NMLS operational guide accessed October 25, 2026 Pacific.","Access status and limits":"Freshly read. Generic NMLS process, not Iowa law or Iowa’s rendered bond form. \nNationwide Licensing System"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S008","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html"],"researcher_record":{"Source ID":"S_IA-P5-S008","Title, issuer, and full literal URL":"NMLS, Bond Creation. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/policyGuide/reference/policyGuide/maps/topics/nmlsPG_ESB_bondCreation.html","Exact clause/page/index used":"Statement that regulator creates the form and NMLS renders it for license-specific completion.","Version/effective status":"Current public NMLS policy guide accessed October 25, 2026 Pacific.","Access status and limits":"Freshly read. Does not expose the Iowa form or consumer claim process. \nNationwide Licensing System"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S009","urls":["https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf"],"researcher_record":{"Source ID":"S_IA-P5-S009","Title, issuer, and full literal URL":"NMLS, ESB Adoption Table. https://qa.mortgage.nationwidelicensingsystem.org/news/Documents/ESB%20Adoption%20Map%20and%20Table.pdf","Exact clause/page/index used":"Updated July 29, 2025; Iowa Division of Banking row, Debt Management License; heading “Branch Bonds are Not Accepted,” PDF index 3.","Version/effective status":"Dated NMLS operational table, not Iowa statutory authority; hosted on NMLS QA domain.","Access status and limits":"Freshly opened, parsed, and visually inspected. Supports historical/current operational architecture only. It does not reconcile the statutory per-office amount or prove October 2026 checklist currency. \nNMLS Resource Center\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_scope_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P5-S010","urls":["https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf"],"researcher_record":{"Source ID":"S_IA-P5-S010","Title, issuer, and full literal URL":"Private surety-site copy, Debt Management License Bond (Iowa). https://axcess-surety.com/wp-content/uploads/2022/03/State-of-Iowa-Department-of-Commerce-Debt-Management-License.pdf","Exact clause/page/index used":"One page/PDF index 0; dated September 10, 2016; reference-only warning; clauses 1–4.","Version/effective status":"Historical/private discovery copy; expressly “for reference ONLY.”","Access status and limits":"Freshly read and visually inspected, but not treated as controlling. Current official form, amendments, and legal status not verified. \nAxcess Surety\n+1"},"coordinator_verification_status":"unreopened_private_discovery_copy_not_controlling","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Covered applicant bond requirement","researcher_record":{"Component":"Covered applicant bond requirement","Status":"Answered at statutory level","Claims":"C001","Exact missing evidence / next action":"Verify actual applicant and exemptions."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Conditional exemptions from bond requirement","researcher_record":{"Component":"Conditional exemptions from bond requirement","Status":"Partial; P1 preserved","Claims":"C001","Exact missing evidence / next action":"Entity documents, activity facts, attorney/nonprofit/institutional conditions."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond amount","researcher_record":{"Component":"Bond amount","Status":"Answered","Claims":"C002","Exact missing evidence / next action":"Post-compilation amendment audit remains."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Per-office base","researcher_record":{"Component":"Per-office base","Status":"Answered legally; filing mechanics partial","Claims":"C002, C009","Exact missing evidence / next action":"Current Iowa rendered form, checklist, office schedule, and NMLS configuration."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Branch bond treatment","researcher_record":{"Component":"Branch bond treatment","Status":"Partial","Claims":"C008–C009","Exact missing evidence / next action":"Explain NMLS no-branch-bond architecture against statutory per-office amount."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond obligee","researcher_record":{"Component":"Bond obligee","Status":"Answered","Claims":"C003","Exact missing evidence / next action":"Current official form wording still desirable."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Protected consumer class","researcher_record":{"Component":"Protected consumer class","Status":"Answered at statute level","Claims":"C003","Exact missing evidence / next action":"Actual debtor status and office relationship."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Covered accounting duties","researcher_record":{"Component":"Covered accounting duties","Status":"Answered at statute level","Claims":"C004","Exact missing evidence / next action":"Actual entrusted money, employee/agent conduct, and loss tracing."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Coverage for non-533A laws","researcher_record":{"Component":"Coverage for non-533A laws","Status":"Partial","Claims":"C004","Exact missing evidence / next action":"Current form and controlling interpretation of broad condition."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Surety issuer authorization","researcher_record":{"Component":"Surety issuer authorization","Status":"Answered generally","Claims":"C011","Exact missing evidence / next action":"Actual surety certificate and bond approval."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current actual bond form","researcher_record":{"Component":"Current actual bond form","Status":"Unresolved","Claims":"C023–C024","Exact missing evidence / next action":"Obtain public official NMLS-rendered Iowa form or authenticated regulator copy without filing/contacting."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Security alternatives","researcher_record":{"Component":"Security alternatives","Status":"No alternative established","Claims":"C010","Exact missing evidence / next action":"Later legislation, formal order, or official instruction if any."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Indexing or variable bond amount","researcher_record":{"Component":"Indexing or variable bond amount","Status":"No mechanism established","Claims":"C002, C010","Exact missing evidence / next action":"Complete later-enactment audit."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Continuous maintenance","researcher_record":{"Component":"Continuous maintenance","Status":"Answered operationally","Claims":"C006–C007","Exact missing evidence / next action":"Exact replacement processing and overlap."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation notice","researcher_record":{"Component":"Cancellation notice","Status":"Answered","Claims":"C006","Exact missing evidence / next action":"Actual notice, service date, and bond terms."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Post-cancellation breach cutoff","researcher_record":{"Component":"Post-cancellation breach cutoff","Status":"Answered","Claims":"C006","Exact missing evidence / next action":"Claim-presentation deadline remains unresolved."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Replacement bond","researcher_record":{"Component":"Replacement bond","Status":"Partial","Claims":"C007–C008","Exact missing evidence / next action":"Effective dates, riders, predecessor/successor terms, and NMLS record."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Name/location bond change","researcher_record":{"Component":"Name/location bond change","Status":"Answered procedurally","Claims":"C008","Exact missing evidence / next action":"Actual amended bond and old-location coverage."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Surrender/cessation effect on provider liability","researcher_record":{"Component":"Surrender/cessation effect on provider liability","Status":"Answered narrowly in prior statute","Claims":"C007, C028","Exact missing evidence / next action":"Surety tail, successor claims, and wind-down remain unresolved."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Aggregate office cap","researcher_record":{"Component":"Aggregate office cap","Status":"Answered","Claims":"C005","Exact missing evidence / next action":"Actual remaining capacity required."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Per-consumer limit","researcher_record":{"Component":"Per-consumer limit","Status":"No separate sublimit established","Claims":"C005, C020","Exact missing evidence / next action":"Current official form or controlling case."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Multiple claims allocation","researcher_record":{"Component":"Multiple claims allocation","Status":"Unresolved","Claims":"C018","Exact missing evidence / next action":"Statute, form, court decision, administrative process, or interpleader record."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"First-filed/first-judgment priority","researcher_record":{"Component":"First-filed/first-judgment priority","Status":"Unresolved","Claims":"C018","Exact missing evidence / next action":"Controlling law or actual bond proceeding."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Replenishment after payment","researcher_record":{"Component":"Replenishment after payment","Status":"Unresolved","Claims":"C020","Exact missing evidence / next action":"Current bond, rider, NMLS history, or formal interpretation."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Annual reset or bond-year aggregates","researcher_record":{"Component":"Annual reset or bond-year aggregates","Status":"Unresolved","Claims":"C020","Exact missing evidence / next action":"Current official form and bond history."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Multiple-office stacking","researcher_record":{"Component":"Multiple-office stacking","Status":"Answered only as no automatic stacking","Claims":"C019","Exact missing evidence / next action":"Actual multi-office conduct and instrument structure."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider insolvency","researcher_record":{"Component":"Provider insolvency","Status":"Excluded except narrow bond implications","Claims":"C022, C028","Exact missing evidence / next action":"Bankruptcy, receivership, estate priority, and provider assets later."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Surety insolvency","researcher_record":{"Component":"Surety insolvency","Status":"Partial","Claims":"C022","Exact missing evidence / next action":"Domiciliary liquidation, proof deadline, reinsurance, and estate priority."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Iowa guaranty-association fallback","researcher_record":{"Component":"Iowa guaranty-association fallback","Status":"Answered negatively","Claims":"C022","Exact missing evidence / next action":"Other-state or liquidation mechanisms held."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer direct action against surety","researcher_record":{"Component":"Consumer direct action against surety","Status":"Unresolved under current authenticated sources","Claims":"C003, C012–C013, C024","Exact missing evidence / next action":"Current official form and controlling Iowa authority."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State action on bond","researcher_record":{"Component":"State action on bond","Status":"Partial","Claims":"C003, C024","Exact missing evidence / next action":"Current form, agency practice, and actual proceeding."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Claim recipient and form","researcher_record":{"Component":"Claim recipient and form","Status":"Unresolved","Claims":"C013–C014","Exact missing evidence / next action":"Official consumer claim instructions or surety form."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Notice to surety","researcher_record":{"Component":"Notice to surety","Status":"Unresolved","Claims":"C013","Exact missing evidence / next action":"Current form and procedural law."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Judgment prerequisite","researcher_record":{"Component":"Judgment prerequisite","Status":"Unresolved","Claims":"C013","Exact missing evidence / next action":"Current form, case, or agency interpretation."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Exhaustion against provider","researcher_record":{"Component":"Exhaustion against provider","Status":"Unresolved","Claims":"C013","Exact missing evidence / next action":"Current form and controlling law."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond claim deadline","researcher_record":{"Component":"Bond claim deadline","Status":"Unresolved","Claims":"C006, C013, C017","Exact missing evidence / next action":"Bond terms, applicable limitations statute, accrual, and cases."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Discovery versus breach date","researcher_record":{"Component":"Discovery versus breach date","Status":"Unresolved","Claims":"C006","Exact missing evidence / next action":"Controlling claim and limitations law."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Corporate-surety service","researcher_record":{"Component":"Corporate-surety service","Status":"Answered conditionally","Claims":"C012","Exact missing evidence / next action":"Applies only where a suit otherwise lies."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"IDOB complaint route","researcher_record":{"Component":"IDOB complaint route","Status":"Answered","Claims":"C014","Exact missing evidence / next action":"Complaint is not established as bond notice."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Superintendent restitution","researcher_record":{"Component":"Superintendent restitution","Status":"Answered as separate remedy","Claims":"C015","Exact missing evidence / next action":"Actual order, beneficiary, offsets, collection, and appeal."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Civil penalties","researcher_record":{"Component":"Civil penalties","Status":"Answered as public/separate","Claims":"C015–C016","Exact missing evidence / next action":"Actual enforcement order if later relevant."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Injunction","researcher_record":{"Component":"Injunction","Status":"Answered as separate remedy","Claims":"C015","Exact missing evidence / next action":"Full enforcement pass remains later."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"General Chapter 533A private damages action","researcher_record":{"Component":"General Chapter 533A private damages action","Status":"Unresolved/not established here","Claims":"C013, C017","Exact missing evidence / next action":"Full Iowa litigation and UTPA pass."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational-loan private action","researcher_record":{"Component":"Educational-loan private action","Status":"Answered narrowly","Claims":"C017","Exact missing evidence / next action":"Bond coverage, actual violation, and other remedies."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney fees and costs","researcher_record":{"Component":"Attorney fees and costs","Status":"Answered only for §533A.8A","Claims":"C017","Exact missing evidence / next action":"No universal bond fee shifting established."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Double recovery/credits","researcher_record":{"Component":"Double recovery/credits","Status":"Answered only as ledger principle","Claims":"C028 and examples","Exact missing evidence / next action":"Actual settlement, subrogation, collateral-source, and order language."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Subrogation","researcher_record":{"Component":"Subrogation","Status":"Unresolved","Claims":"C020, C028","Exact missing evidence / next action":"Bond terms and general surety law."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond-maintenance records","researcher_record":{"Component":"Bond-maintenance records","Status":"Answered","Claims":"C021","Exact missing evidence / next action":"Actual records and retention trigger."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Five-year statute versus 36-month rule","researcher_record":{"Component":"Five-year statute versus 36-month rule","Status":"Preserved unresolved issue","Claims":"C021","Exact missing evidence / next action":"Authoritative reconciliation; no shorter retention inferred."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Public provider bond details","researcher_record":{"Component":"Public provider bond details","Status":"Unresolved","Claims":"C025","Exact missing evidence / next action":"Actual NMLS record or other lawfully public source."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"NMLS ESB operation","researcher_record":{"Component":"NMLS ESB operation","Status":"Answered generically","Claims":"C023","Exact missing evidence / next action":"Current Iowa-specific instructions and form remain unavailable."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling decisions/formal interpretations","researcher_record":{"Component":"Controlling decisions/formal interpretations","Status":"Unresolved after bounded search","Claims":"C026","Exact missing evidence / next action":"Broader case databases, trial records, archived orders, or authenticated agency interpretation."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Complete post-compilation currentness","researcher_record":{"Component":"Complete post-compilation currentness","Status":"Unresolved","Claims":"C027","Exact missing evidence / next action":"Enacted-session-law and later-rule audit."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"ARC 0368D final disposition","researcher_record":{"Component":"ARC 0368D final disposition","Status":"Preserved hold; not re-researched","Claims":"C027","Exact missing evidence / next action":"Separate already-defined currentness task."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full contract enforceability","researcher_record":{"Component":"Full contract enforceability","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Later agreement pass."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full trust/funds treatment","researcher_record":{"Component":"Full trust/funds treatment","Status":"Excluded; P4 unreviewed","Claims":"—","Exact missing evidence / next action":"P4 review or later funds work."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Fee earning and refunds","researcher_record":{"Component":"Fee earning and refunds","Status":"Excluded except bond offsets","Claims":"—","Exact missing evidence / next action":"P1 and later fee/contract interpretation."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"General civil claims, torts, UTPA, limitations","researcher_record":{"Component":"General civil claims, torts, UTPA, limitations","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate litigation/remedies pass."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, garnishment, secured debt","researcher_record":{"Component":"Collection, garnishment, secured debt","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate passes."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Local, tribal, sector, federal TSR/CROA","researcher_record":{"Component":"Local, tribal, sector, federal TSR/CROA","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate required passes."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Actual operational approval, state acceptance, parent acceptance, or A066","researcher_record":{"Component":"Actual operational approval, state acceptance, parent acceptance, or A066","Status":"Unresolved","Claims":"C025, C027","Exact missing evidence / next action":"Entire dossier and all remaining dimensions required."},"coordinator_acceptance":"scoped_review_with_holds_two_source_qualifications_addressed_by_P07_no_component_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T16:23:02.769878+00:00","status":"two_source_qualifications_addressed_other_holds_remain","review":"[internal evidence reference]","source_checks":"[internal evidence reference]","raw_originals_unchanged":true,"affected_claims":["S_IA-P5-C011","S_IA-P5-C012"],"correction_pass":"S_IA/pass-07","no_parent_acceptance":true,"correction_review":"[internal evidence reference]","correction_notice":"CORRECTION-NOTICE-20261027-P07.md","correction_addressed_at":"2026-10-27T16:36:06.182031+00:00"},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_IA-P5-corporate-surety-acceptance-service-qualifications-20261027","status":"two_bounded_source_qualifications_addressed_by_checked_P07_all_other_holds_remain","at":"2026-10-27T16:23:02.769878+00:00"}]}