{"meta":{"key":"s_ia--pass-06","task":"S_IA","title":"Iowa mandatory agreement, disclosure, signature, electronic-consent, notice, amendment, and waiver component","parent_title":"Iowa debt and debt relief law","edition":"pass-06","path":"/research/s_ia--pass-06/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":10,"claims":38,"sources":7,"review_status":"scoped_review_complete_requested_corrections_addressed_with_holds","review_complete":true,"sha256":"2fd6e2320a3741ff809d818aed65eeb63e7ac49d3fd0e070a987e491b1072607","headings":["Iowa mandatory agreement, disclosure, signature, electronic-consent, notice, amendment, and waiver component","Bounded disposition","1.1 Coverage is activity-based","1.2 Mandatory pre-enrollment sequence","1.3 No general ordinary cooling-off period established","2.1 Mandatory pre-signature disclosures","2.2 Universal written-contract clauses","2.3 Model-specific contract and operational terms","2.4 Educational-loan contract package","2.5 Clauses not established as universally mandatory","3.1 Ordinary signatures versus educational-loan signatures","3.2 Complete agreement before execution","3.3 “True copy” delivery","3.4 Iowa UETA requirements","3.5 Separate electronic documents","3.6 Educational-loan electronic form problem","3.7 Federal E-SIGN overlay","4.1 General cancellation language","4.2 Noncustodial discontinuation notice","4.3 Educational-loan cancellation","4.4 Provider termination and licensing events","4.5 Adding debts and material amendments","4.6 Fee changes","4.7 Assignment","4.8 Prohibited and void terms","5.1 Application submission is not form approval","5.2 Public forms and checklists","5.3 Compiled rule record requirements","5.4 Iowa decisions","Burroughs v. City of Davenport Zoning Board of Adjustment","Bruggeman v. Narnus Property Management, LLC","Exact Chapter 533A decisions","S_IA-P6-E01 — Ordinary noncustodial debt-settlement enrollment","Inputs and events","Required event sequence","S_IA-P6-E02 — Electronic copy that cannot be retained","Facts","Analysis","S_IA-P6-E03 — Custodial contract and creditor-consent boundary","Inputs","Agreement result","Separate operational result","S_IA-P6-E04 — Educational-loan electronic contract and cancellation","Contract package assumptions","Event sequence","S_IA-P6-E05 — Ordinary noncustodial cancellation by mail","Events","S_IA-P6-E06 — Attempt to add another debt after enrollment","Original contract","Later event","Result","S_IA-P6-E07 — Waiver and communication restriction","Proposed clauses","Results","S_IA-P6-E08 — Email negotiations without the statutory package","Facts","Actually read or re-read in PASS-06","Reused without regeneration","Not treated as reviewed authority","Bounded searches that did not produce relied-on exact authority"],"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-06","facets":{"geography":["us","us-ia"],"debt_type":[],"stage":["origination","repossession"],"subject":["agreements-disclosures","privacy-data"]},"scope":"ExactreviewedP1remainingagreement/disclosure/consentgap, independent of P4funds/P5bondunreviewedoutputs; all broaderholdsretained.","pending_corrections":0},"markdown":"# SettleADebt S_IA PASS-06\n\n## Iowa mandatory agreement, disclosure, signature, electronic-consent, notice, amendment, and waiver component\n\n**Actual fresh research date:** October 25, 2026, Pacific; October 26, 2026 UTC\n**Review relationship:** Same-coordinator continuation of reviewed P1–P3; **not independent review**.\n**P4/P5 treatment:** PASS-04 and PASS-05 are saved but unreviewed. No new funds, trust-account, money-transmission, bond, or recovery interpretation from those passes is treated here as reviewed authority.\n**Scope:** Only mandatory enrollment prerequisites, disclosures, agreement contents, execution, copies, electronic records and signatures, cancellation notices, amendments, assignment boundaries, prohibited terms, and waiver.\n\nExact individual source-fetch times were not preserved and are not invented. Compilation, enactment, publication, filing, and effective dates below remain distinct from this PASS-06 access date.\n\n## Bounded disposition\n\nFor an ordinary covered Iowa debt-management enrollment, the operative sequence is materially more demanding than “show contract, collect signature”:\n\n1. Describe the program methodology sufficiently for an informed choice.\n2. Review the debtor’s debts and monthly budget.\n3. Determine that the program is appropriate.\n4. Complete a written, thorough budget analysis indicating that the debtor can meet the program requirements.\n5. Give the required disclosures **verbally and in a separate written document before the debtor signs**.\n6. Complete the written contract with every applicable universal and model-specific term.\n7. Do not use an unfinished or blank contract.\n8. Furnish a true copy immediately and before collecting any fee.\n9. Satisfy any additional model-specific fee or performance prerequisite independently.\n\nThe written contract is therefore not a substitute for the required separate disclosure document, and a fee stated in the contract is not automatically earned or collectible. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nEducational-loan debt management has a stricter, additional regime: a clear and conspicuous contract, detailed service description, debtor date and signature, specified 10-point and 14-point text, duplicate detachable cancellation forms, an unconditional three-business-day cancellation right, and no payment request or receipt until full performance. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nElectronic contracting is possible in principle, but “electronic” is not a compliance shortcut. Iowa’s UETA requires agreement to transact electronically, signature intent and attribution, recipient retainability, and preservation of any statutorily required format, location, method, and presentation. An expiring portal link, disabled printing, an unprovable click, or a combined disclosure-and-contract screen can fail different requirements even though the process is digital. [Iowa Legislature+3](https://www.legis.iowa.gov/docs/code/2026/554D.pdf)\n\n# 1. Agreement prerequisites and model boundaries\n\n## 1.1 Coverage is activity-based\n\nThe agreement duties attach to a Chapter 533A licensee providing compensated debt management. Covered activities include negotiating debt terms, direct or indirect receipt of money for creditor distribution, acting as an intermediary to obtain concessions, debt settlement, and educational-loan modification intermediation.\n\nA “credit counseling,” “financial education,” “credit improvement,” “legal,” “nonprofit,” or “account administration” label does not decide the issue. The statutory exemptions remain conditional:\n\n- An Iowa-admitted attorney must act solely incident to practicing law.\n- The nonprofit religious, fraternal, or cooperative exemption is for gratuitous debt-management service.\n- Institutional exemptions are entity- and activity-specific.\n- Pure education unaccompanied by compensated covered conduct may fall outside the definition, but no actual service has been classified in this pass.\n- Credit-improvement representations may create separate CROA or TSR issues, but those federal questions remain held.\n\nThe Chapter 533A agreement duties cannot be avoided simply by moving solicitation or execution online or outside Iowa when the provider solicits or contracts with an Iowa-resident debtor. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 1.2 Mandatory pre-enrollment sequence\n\n| Sequence stage | Required act | Timing | Consequence or boundary |\n| --- | --- | --- | --- |\n| **A. Program explanation** | Describe the methodology so the potential debtor can make an informed decision about whether the program is appropriate. | Before enrollment decision and contract. | A sales pitch naming the service is not the same as describing the methodology. |\n| **B. Financial review** | Conduct a comprehensive review of debts and monthly budget. | Before entering the contract. | Must be debtor-specific; a generic eligibility screen is not the statutory review. |\n| **C. Suitability determination** | Determine that the program is an appropriate option. | Before contract. | Merely meeting a debt-balance threshold is not the full suitability finding. |\n| **D. Written ability analysis** | Perform a written and thorough budget analysis indicating the debtor can meet the requirements determined by that analysis. | Before accepting the account. | “Account accepted” without the written analysis is not supported by the statute. |\n| **E. Oral disclosures** | Give all applicable §533A.8(3) disclosures at a normal rate and in a manner designed to ensure understanding. | Before the debtor signs. | A prerecorded or rushed disclosure still must meet the comprehension-oriented standard. |\n| **F. Separate written disclosures** | Give the same applicable disclosures in a document separate from the contract and designed to ensure understanding. | Before the debtor signs. | Incorporation only inside the contract does not satisfy the separate-document requirement. |\n| **G. Contract completion** | Complete the written contract with all universal and model-specific terms. | Before execution. | A contract to be signed by the debtor cannot contain blanks or unfinished provisions. |\n| **H. Execution and copy** | Execute the compliant arrangement and furnish a true copy immediately and before collecting any fee. | Immediately; in all events before fee collection. | Copy delivery is a separate pre-collection condition, not fee-earning authority. |\n| **I. Model-specific predicates** | Satisfy creditor-consent, settlement-completion, full-performance, federal timing, or other applicable requirements. | At the event specified by the governing provision. | The existence of a signed contract does not satisfy these later predicates. |\n\nEvidence: Iowa Code §§533A.8(1)–(4), 533A.11(3). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 1.3 No general ordinary cooling-off period established\n\nThe ordinary Chapter 533A provisions allow discontinuation without penalty and require cancellation-settlement terms, but they do not create a universal three-business-day rescission period for every debt-management contract.\n\nThe express three-business-day unconditional right belongs to the educational-loan branch. No ordinary statutory requirement was located requiring the provider to suspend all services for three days after a conventional DMP or debt-settlement enrollment. Fee collection and service performance remain subject to their own prerequisites. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n# 2. Complete clause, disclosure, event, and model matrix\n\n## 2.1 Mandatory pre-signature disclosures\n\nThe following disclosures must be given both verbally and in a separate written document before signing. The written contract may repeat them, but repetition does not eliminate the separate-document duty.\n\n| Disclosure | Applicable model | Required content | Required location/event |\n| --- | --- | --- | --- |\n| Total estimated fee | All covered programs | Estimated total fee if the debtor remains for the entire contractual term | Oral plus separate written disclosure before signature |\n| Results disclaimer | All covered programs | No specific result can be guaranteed | Oral plus separate written disclosure |\n| Discontinuation | All covered programs | Debtor may discontinue without penalty at any time | Oral plus separate written disclosure; also mandatory contract term |\n| Tax consequence | Program seeking principal concessions | Principal concessions may be treated as taxable income | Oral plus separate written disclosure |\n| No creditor payments by provider | Noncustodial model | Payments are not made to creditors on debtor’s behalf; debtor remains obligated to make payments | Oral plus separate written disclosure |\n| Ongoing collection | Noncustodial model | Creditors may continue collection during enrollment | Oral plus separate written disclosure |\n| Credit harm | Debt settlement | Credit report and score may be harmed | Oral plus separate written disclosure |\n| Contract/default costs | Debt settlement | Missed minimum payments may breach creditor agreements, produce fees or penalties, and permit rate increases | Oral plus separate written disclosure |\n| Lawsuit risk | Debt settlement | Creditors may sue if required minimum payments are not made | Oral plus separate written disclosure |\n| Noncontradiction | Licensee and third-party marketer/seller | Advertising, solicitation, and representations cannot contradict the required disclosures | Applies throughout marketing and enrollment |\n\nThe verbal disclosure must be delivered at a normal rate of speech and in a manner designed to ensure understanding. Iowa specifies no general type size, language, or translation rule for the ordinary separate disclosure, but its design still must promote comprehension. Educational-loan documents have additional express type-size and conspicuousness rules. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 2.2 Universal written-contract clauses\n\n| Mandatory ordinary contract term | Exact statutory requirement | Qualification |\n| --- | --- | --- |\n| Written contract | Licensee must make a written contract with the debtor | Electronic form may qualify only under applicable electronic-record law |\n| Total estimated charges | Charges agreed for licensee services and services of third parties acting for or with the licensee | Disclosure does not independently authorize passing every third-party charge to the debtor |\n| How and when charges are paid | Statement of timing and method | Must remain consistent with state and independently applicable federal collection law |\n| Discontinuation without penalty | Express statement of debtor’s right | Cannot be negated elsewhere by liquidated charge, forfeiture, waiver, or contradictory language |\n| Cancellation settlement | Clear provision for settling the parties’ account if the relationship is canceled | Does not by itself establish that any proposed retention is lawful |\n| Beginning and expiration date | Both dates | Term may not exceed 60 months |\n| Provider identity and contact | Licensee name, physical address, mailing address if different, and telephone number | Ordinary provision does not expressly require email address |\n| Services | Description of services to be provided | Must include educational and counseling services aimed at borrowing, spending, and saving habits |\n| True copy | Debtor must receive true copy immediately and before fee collection | Exact statutory text does not expressly prescribe paper versus electronic copy |\n| Fee agreed in advance | Fee must be agreed in advance and stated in the contract | Ceiling or stated fee is not earning or collection permission |\n\nEvidence: §§533A.8(4), 533A.9(1). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 2.3 Model-specific contract and operational terms\n\n| Model/event | Mandatory contract term | Separate operational event or disclosure | Important boundary |\n| --- | --- | --- | --- |\n| **Debt settlement** | Comprehensive list of every debt at enrollment to be negotiated, with creditor names and identifying information; estimated money needed to fund settlements | Debt-settlement risks must also be given orally and in separate written disclosure | Later debt addition is not expressly governed; blank insertion is prohibited |\n| **Custodial DMP** | Complete list of creditors to receive payments | Before non-initiation fees, statutory creditor-consent/accepted-distribution condition applies; debtor must be informed which creditors have not agreed | Creditor consent is not identified as a substitute for the contract or separate disclosures |\n| **Noncustodial settlement** | Universal contract terms; fee method and cancellation settlement must be accurately described | Separate pre-sign disclosure that provider does not make payments and creditors may keep collecting; debtor retains control under separate statutory provision | Account title alone does not resolve classification; P4 remains unreviewed |\n| **Collection agent plus licensee on same account** | No special enumerated contract clause | Must first disclose the dual role in writing to both debtor and creditor | Disclosure must occur before operating in both capacities |\n| **Debt challenge** | No enumerated challenge clause | Written debtor consent is required before challenging a debt | General enrollment authorization is not necessarily specific written challenge consent |\n| **Educational-loan management** | All ordinary applicable terms plus §533A.8A’s detailed form, service, signature, cancellation, and payment language | No payment request, collection, or third-party payment requirement before full performance | Educational requirements are additional and nonexclusive |\n| **Credit-improvement representations** | No separate Iowa Chapter 533A contract schedule was located solely because marketing mentions credit improvement | Debt-settlement provider cannot claim negotiations will eliminate adverse credit information | CROA/TSR applicability remains open |\n| **Counseling-only service** | Depends on whether actual compensated activity falls within “debt management” | Conditional exemptions must be proved | No label-based exemption is established |\n\nEvidence: §§533A.8(3)–(6), 533A.11(2), (9), and (15). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 2.4 Educational-loan contract package\n\nA licensee primarily engaged in educational-loan debt management must comply with the ordinary applicable Chapter 533A duties and the following additional requirements:\n\n| Educational-loan requirement | Exact condition |\n| --- | --- |\n| Language | Clear and understandable |\n| Terms | All terms, restrictions, and conditions clearly and conspicuously stated |\n| Services | Fully and specifically described |\n| Execution | Contract dated and signed by the debtor |\n| General type size | Required information at least 10-point type |\n| Cancellation contact | Licensee name, email address, and physical business address for cancellation |\n| P.O. box | Cannot serve as the only physical address; may be a mailing address only with a physical delivery address |\n| Pre-sign cancellation disclosure | Statutory language in at least 14-point bold immediately above debtor signature |\n| Cancellation forms | Completed, easily detachable form in duplicate, attached, captioned “notice of cancellation,” at least 14-point bold, in substantially prescribed form |\n| Full-performance disclosure | Separate Iowa-required statement in at least 14-point bold immediately above the cancellation form |\n| Cancellation period | Until midnight of the third business day after a compliant contract is signed and executed |\n| Cancellation medium | Any written notice showing intent not to be bound; mail, email, personal delivery, or another means |\n| Mail effectiveness | Deposit in mail, properly addressed, postage prepaid |\n| Email effectiveness | Upon transmission |\n| Personal delivery effectiveness | Upon delivery |\n| Payment timing | No demand, request, charge, collection, receipt, or compelled third-party payment before full performance |\n| Third-party consideration | Must be fully disclosed before receipt |\n| Contact restriction | Any term impeding contact with a creditor, servicer, government, lawyer, counselor, or other helper is void |\n\nThe statutory trigger is a contract **that complies with §533A.8A** and is signed and executed. The text does not support beginning the cancellation period from a materially noncompliant form. This pass did not establish an applicable Iowa rule for counting weekends or holidays, so no calendar date is computed in the examples below. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 2.5 Clauses not established as universally mandatory\n\nThe reviewed operative Chapter 533A and compiled Chapter 20 text did not establish universal consumer-contract clauses requiring:\n\n| Potential clause | PASS-06 finding |\n| --- | --- |\n| Iowa license number or NMLS ID | Not found as a mandatory consumer-contract clause |\n| Surety name, bond number, or bond amount | Not found as a mandatory consumer-contract clause; P5 is unreviewed |\n| IDOB complaint instructions | Not found as a mandatory contract clause |\n| Separate account-administrator identity | Not expressly listed as a universal contract clause |\n| Bank or account identity | Not expressly listed as a universal contract clause |\n| Arbitration | No Chapter 533A clause specifically requiring or categorically prohibiting arbitration was located |\n| Jury waiver | No specific Chapter 533A treatment located; cannot waive substantive Chapter 533A rights |\n| Class-action waiver | No specific Chapter 533A treatment located; broader enforceability is excluded |\n| Choice of law or forum | No mandatory clause located |\n| Privacy notice | No Chapter 533A consumer-contract clause located; other privacy laws remain open |\n| Assignment provision | No consumer-contract assignment procedure located |\n| Provider termination right | No prescribed provider-termination clause or notice process located |\n| Electronic-consent disclosure | Iowa UETA supplies electronic-transaction requirements; no Chapter 533A-specific electronic-consent form was located |\n| Signed acknowledgment of the separate disclosures | No express acknowledgment clause located, although the disclosure and account-file records must prove compliance |\n\nThese are bounded findings from the sources reviewed, not proof that no other applicable state or federal law imposes such terms.\n\n# 3. Execution, signatures, delivery, copies, and electronic consent\n\n## 3.1 Ordinary signatures versus educational-loan signatures\n\nThe ordinary provisions repeatedly contemplate a debtor signature:\n\n- Required disclosures must precede the debtor’s signature.\n- A contract or agreement “to be signed by the debtor” cannot be executed while incomplete.\n\nHowever, §533A.8(4) does not separately prescribe:\n\n- A provider-signature line.\n- A specific debtor-signature placement.\n- A contract date field apart from the required beginning and expiration dates.\n- Ink rather than electronic signature.\n- Witnessing or notarization.\n- A universal type size.\n\nBy contrast, §533A.8A expressly requires the educational-loan contract to be dated and signed by the debtor and places specified 14-point text immediately above the signature. Thus, the ordinary and educational signature requirements should not be described as identical. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 3.2 Complete agreement before execution\n\nIt is unlawful to execute a contract or agreement to be signed by the debtor unless it is fully and completely filled in and finished. This prevents a provider from:\n\n- Obtaining a signature on blank debt schedules.\n- Adding creditors or fee terms afterward without a legally sufficient new assent process.\n- Leaving the funding estimate unresolved.\n- Filling cancellation terms later.\n- Substituting materially different pages after execution.\n\nThe statute does not create a complete amendment procedure. A later amendment must therefore be evaluated against the original mandatory terms, the prohibition on unfinished execution, advance fee agreement, pre-sign disclosure requirements, and ordinary contract law. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 3.3 “True copy” delivery\n\nThe debtor must receive a true copy of the written contract:\n\n- Immediately.\n- Before any fee is collected.\n\nThe reviewed provision does not expressly say whether:\n\n- The copy must be paper.\n- It must contain both parties’ signatures.\n- It may be delivered by email or portal.\n- The debtor must acknowledge receipt.\n\nUnder Iowa UETA, an electronic copy can satisfy a writing/delivery requirement where the parties agreed to electronic transactions and the copy is capable of retention when received. A system that prevents printing or storage fails that UETA condition and renders the electronic record unenforceable against the recipient under §554D.110. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nA mere statement that “the contract is available in your dashboard” does not establish true-copy delivery if the debtor cannot retrieve, preserve, or accurately reproduce the final contract.\n\n## 3.4 Iowa UETA requirements\n\nIowa’s UETA applies to electronic records and signatures in transactions, subject to its statutory exclusions. Chapter 533A debt-management agreements are not among the exclusions identified in §554D.104.\n\nThe operative conditions include:\n\n1. **Agreement to use electronic means.** UETA applies only where each party agreed to transact electronically, determined from context, circumstances, and conduct.\n2. **No forced future electronic use.** A party that accepts one electronic transaction may refuse later electronic transactions; that right cannot be waived.\n3. **Writing and signature equivalence.** Electronic records and signatures cannot be denied effect solely because of electronic form.\n4. **Signature intent.** An electronic signature is an electronic sound, symbol, or process adopted with intent to sign.\n5. **Attribution.** The provider must be able to show that the electronic act was the debtor’s act; a security procedure is one possible method.\n6. **Retainability.** Required written information must be printable or storable at receipt.\n7. **Prescribed format and placement.** A separate law’s required display, method, or formatting remains applicable.\n8. **Accurate retention.** The retained electronic record must accurately reflect the final information and remain accessible.\n9. **Automated error protections.** In specified consumer automated transactions, an individual may avoid an erroneous record if the system offered no correction opportunity and the statutory notice/return/no-benefit conditions are met.\n\nUETA does not cure missing Chapter 533A content, missing budget analysis, missing oral disclosures, an incomplete contract, or a fee collected too early. [Iowa Legislature+4](https://www.legis.iowa.gov/docs/code/2026/554D.pdf)\n\n## 3.5 Separate electronic documents\n\nSection 533A.8(3)(b) requires the written disclosures to be in a document **separate from the contract**. An electronic process should therefore preserve distinct records rather than embedding the disclosures only in the contract body.\n\nA workable architecture could use:\n\nPlain text\n```\nRecord 1: Iowa pre-enrollment disclosure document\nRecord 2: Final debt-management contract\nRecord 3: Electronic-consent and attribution record\nRecord 4: Delivery record for the final true copy\n```\n\nA single scrolling webpage containing sales copy, disclosures, and contract terms without separately retrievable records has no verified safe harbor under the reviewed authority.\n\n## 3.6 Educational-loan electronic form problem\n\nUETA allows electronic records and signatures in principle, but it also preserves statutory formatting and presentation requirements. The educational-loan statute calls for:\n\n- 14-point bold text immediately above the signature.\n- A completed, easily detachable form in duplicate.\n- The form as an attachment.\n- Another 14-point bold disclosure immediately above that form.\n\nNo Iowa case or formal agency interpretation was located explaining how an electronic interface satisfies “easily detachable,” “in duplicate,” and “as an attachment.” A downloadable package containing two separately usable cancellation forms may be a plausible design, but PASS-06 does not establish it as officially approved. A simple hyperlink to one online cancellation form is not proven equivalent. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 3.7 Federal E-SIGN overlay\n\nFederal E-SIGN generally prevents denial of effect solely because a transaction uses electronic records or signatures, but it preserves substantive rights, disclosure timing, content, and required proximity. Its consumer-disclosure subsection contains affirmative-consent, paper-option, withdrawal, hardware/software, access-demonstration, and changed-technology provisions. E-SIGN also permits qualifying state UETA enactments to modify or supersede §7001 with respect to state law. [U.S. Code+1](https://uscode.house.gov/us/usc/119-118/t15/s7001/)\n\nAccordingly:\n\n- Iowa UETA is the direct state-law electronic-record authority for the Chapter 533A writings.\n- E-SIGN may independently matter for transactions affecting interstate commerce and federal-law disclosures.\n- This pass does not decide the complete §7001(c)/§7002 preemption interaction for every Iowa enrollment.\n- E-SIGN does not eliminate Iowa’s separate-document, type-size, position, duplicate-form, true-copy, or timing requirements.\n- Debt-management cancellation notices are not among §7003’s enumerated special exceptions, but that fact alone does not prove any particular electronic process compliant. [U.S. Code+2](https://uscode.house.gov/us/usc/119-118/t15/s7001/)\n\n# 4. Cancellation, provider termination, amendments, assignment, and waiver\n\n## 4.1 General cancellation language\n\nEvery ordinary contract must:\n\n- State that the debtor may discontinue participation without penalty at any time.\n- Clearly state how the parties’ account will be settled upon cancellation.\n\nThese two provisions are related but not interchangeable. “Without penalty” does not necessarily erase a fee already lawfully earned, while a cancellation-settlement clause does not authorize a fee, forfeiture, or refund denial that otherwise violates Iowa or applicable federal law. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThis pass does not reopen P1’s fee examples or decide the unresolved interaction between installment retention and a completed-settlement fee.\n\n## 4.2 Noncustodial discontinuation notice\n\nFor Iowa’s two noncustodial statutory fee methods:\n\n- The debtor may discontinue by written notice to the address specified in the contract.\n- A mailed notice is effective when properly deposited with postage paid.\n- No future installments are due after mailing.\n- The first-12-month retention/refund provisions and completed-settlement branch remain separately applicable and conditional. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe statute does not give ordinary email the express “effective upon transmission” rule that it gives educational-loan cancellation. Whether an agreed electronic notice is effective, and when, depends on the contract, UETA receipt rules, and other applicable law. It should not be assumed that clicking “cancel” or sending an email has the same deemed-effective moment as a properly mailed notice.\n\nNo exact return deadline for money held or previously collected is determined here. That belongs to the funds and fee components, and P4 remains unreviewed.\n\n## 4.3 Educational-loan cancellation\n\nThe educational-loan branch is different:\n\n- Cancellation is unconditional until midnight of the third business day following execution of a compliant contract.\n- Written notice may be delivered by any means.\n- Mail is effective upon proper deposit.\n- Email is effective upon transmission.\n- Personal delivery is effective upon delivery.\n- The debtor need not use the provider’s form; any written expression of an intent not to be bound is sufficient. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nThe statute does not expressly require the provider to delay beginning work during the cancellation window. It does, however, preserve the cancellation right and independently prohibits requesting or receiving payment before full performance.\n\n## 4.4 Provider termination and licensing events\n\nNo general Chapter 533A provision was located specifying:\n\n- A provider’s contractual right to terminate a debtor.\n- Required advance notice of provider termination.\n- Cure opportunities.\n- A service-transfer process.\n- Assignment of the consumer agreement.\n- A particular termination form.\n\nSection 533A.7 states that surrender, suspension, or revocation does not impair a **preexisting lawful contract**. That does not authorize unlicensed future conduct or prove that the provider remains able to perform. It preserves contractual obligations while leaving performance, regulatory action, assignment, restitution, and remedies to other law and facts. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 4.5 Adding debts and material amendments\n\nFor debt settlement, the contract must list every debt **at the time of enrollment** that will be negotiated and the estimated settlement funding. The statute does not prescribe a streamlined “add debt” procedure.\n\nAccordingly, no authority was established for:\n\n- Silently adding another creditor.\n- Filling a previously blank schedule.\n- Increasing the fee base without new compliant assent.\n- Changing the fee method mid-program.\n- Treating a dashboard update as a completed amendment.\n- Applying the original risk disclosures automatically to a materially different program.\n\nThe records statute expressly refers to contract “extensions,” confirming that extensions may exist, but it does not state how an extension is formed. Any material amendment must still be tested against:\n\n- Advance fee agreement.\n- Mandatory contract terms.\n- Applicable model disclosures.\n- The separate-document and pre-sign timing requirements.\n- The prohibition on incomplete execution.\n- UETA consent and attribution if electronic.\n- Nonwaiver rules. [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 4.6 Fee changes\n\nIowa requires the fee to be:\n\n- Agreed in advance.\n- Stated in the contract.\n\nNo unilateral fee-increase authority was located. A contract clause purporting to permit the provider to change fees at any time would still have to be reconciled with advance agreement, statutory ceilings, required fee disclosure, cancellation terms, and applicable federal timing.\n\nPASS-06 does not determine whether a particular modification process creates an enforceable fee amendment.\n\n## 4.7 Assignment\n\nThe license itself is nontransferable and nonassignable. That does not alone answer whether a consumer contract may be assigned.\n\nNo Chapter 533A provision reviewed expressly authorizes or prohibits assignment of the consumer contract. An assignment to a person that would perform debt-management activities raises separate licensure, disclosure, consent, data-transfer, and contract issues. Those issues remain held.\n\n## 4.8 Prohibited and void terms\n\n| Contract term or practice | Iowa treatment |\n| --- | --- |\n| Blank or unfinished contract | Provider may not execute it |\n| Waiver of Chapter 533A rights | Void and unenforceable; inducing waiver is a violation |\n| Power of attorney limiting debtor-creditor communication | Prohibited |\n| Other written term limiting debtor-creditor communication | Prohibited |\n| Educational-loan term impeding contact with creditors, servicers, government, lawyers, counselors, or helpers | Void and unenforceable |\n| Wage assignment securing provider compensation | Prohibited; void and unenforceable |\n| Lien or other real/personal-property security securing compensation | Prohibited; void and unenforceable |\n| Promissory note or other promise to pay used as the fee | Prohibited |\n| Statement contradicting mandatory disclosures | Prohibited |\n| Advice to stop creditor payments in debt settlement | Prohibited |\n| Claim that payment is a settlement without creditor written confirmation | Prohibited |\n| Claim that program guarantees debt satisfaction or prevents collection/litigation/credit harm/bankruptcy | Prohibited |\n| Claim that negotiations will eliminate adverse credit information | Prohibited |\n\nEvidence: §§533A.11 and 533A.17; educational-loan §533A.8A(5)(d). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\nA release, arbitration term, class waiver, forum clause, or choice-of-law term cannot operate as a waiver of substantive Chapter 533A protections. Their broader procedural enforceability is outside this component.\n\n# 5. Public forms, agency materials, and Iowa decisions\n\n## 5.1 Application submission is not form approval\n\nEach license applicant must furnish:\n\n- A description of its proposed program.\n- A copy of the disclosures it proposes to give under §533A.8(3).\n- A copy of its proposed debtor contract under §533A.8(4).\n\nThat is a statutory submission requirement. It does not establish that:\n\n- Iowa publishes a model contract.\n- The regulator affirmatively approved every clause.\n- A contract previously submitted remains compliant after legal changes.\n- Any provider’s current contract matches the submitted version.\n- A provider is currently licensed. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## 5.2 Public forms and checklists\n\nA bounded search of public Iowa Division of Banking, Iowa Legislature, and NMLS routes did not recover:\n\n- A current official Iowa consumer debt-management model contract.\n- A current official separate §533A.8(3) disclosure form.\n- A current official educational-loan contract package.\n- An authenticated current Iowa-specific agreement checklist.\n- A current public agency interpretation approving a particular electronic execution flow.\n\nThe NMLS Checklist Compiler page was reachable but did not expose parsed Iowa checklist content through the public route used. The guessed direct Iowa company-checklist PDF route returned a non-retryable failure and was not treated as evidence.\n\nThis is a bounded access result, not proof that no internal, account-gated, archived, or differently indexed document exists.\n\n## 5.3 Compiled rule record requirements\n\nCompiled Rule 20.9 requires the account file to contain:\n\n- The application.\n- The comprehensive debt and monthly-budget review.\n- A copy of the debt-management contract.\n- All required §533A.8(3) disclosures.\n\nRecords may be kept as hard copies or electronic equivalents. The rule therefore supports electronic retention but does not reduce the underlying statutory execution or disclosure requirements. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf)\n\nThe earlier five-year-statute versus 36-month-rule discrepancy remains held. PASS-06 does not shorten any retention period.\n\n## 5.4 Iowa decisions\n\n### Burroughs v. City of Davenport Zoning Board of Adjustment\n\nThe Iowa Supreme Court recognized that a required documentary filing could exist electronically and relied on Iowa’s UETA, including the rule that a record is not denied effect solely because it is electronic. The case concerned zoning-board records and filing—not consumer debt-management contracts, signature attribution, separate disclosures, or cancellation forms. It supports only the general availability of electronic records, not a Chapter 533A safe harbor. [Iowa Courts](https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion)\n\n### Bruggeman v. Narnus Property Management, LLC\n\nThe Iowa Court of Appeals held, on the particular settlement record before it, that emails and related writings established agreed material terms even without a final signed instrument. But the court expressly operated under ordinary settlement-contract principles, including that a settlement need not be written unless a statute or court rule requires one. Chapter 533A does require a written contract and imposes additional pre-signature and content requirements. Bruggeman therefore cannot validate a debt-management enrollment formed through incomplete sales emails. [Iowa Courts](https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion)\n\n### Exact Chapter 533A decisions\n\nTargeted official-domain searches did not locate a materially on-point Iowa appellate holding or formal public IDOB interpretation resolving:\n\n- Whether an ordinary §533A.8 contract must bear the provider’s signature.\n- Whether a particular clickwrap method proves debtor signature.\n- Electronic compliance with the educational-loan duplicate detachable-form requirement.\n- Electronic notice effectiveness under the ordinary noncustodial cancellation provision.\n- Adding debts through an amendment.\n- Assignment of the consumer contract.\n- Provider-termination notice.\n- Whether a particular arbitration or forum clause waives Chapter 533A rights.\n\nThat is a bounded negative search finding, not proof that no trial order, unpublished matter, archived agency communication, or other authority exists.\n\n# 6. Bounded agreement and notice examples\n\nThese examples apply only the verified sequence and document rules. They do not establish an actual provider, signed agreement, lawful fee, completed settlement, refund amount, or account balance.\n\n## S_IA-P6-E01 — Ordinary noncustodial debt-settlement enrollment\n\n### Inputs and events\n\nPlain text\n```\nModel:                       Noncustodial debt settlement\nDebts proposed for program:  3\nContract term:               36 months\nExecution medium:            Electronic\n```\n\n### Required event sequence\n\nPlain text\n```\nT0  Provider explains methodology.\n\nT1  Provider completes comprehensive review of:\n    - all relevant debts; and\n    - monthly budget.\n\nT2  Provider documents a written, thorough budget analysis\n    indicating the debtor can meet program requirements.\n\nT3  Provider determines the program is appropriate.\n\nT4  Before signature, provider gives:\n    - verbal universal disclosures;\n    - verbal noncustodial disclosures;\n    - verbal debt-settlement risk disclosures; and\n    - the same applicable disclosures in a separate,\n      retainable written record.\n\nT5  Provider presents a fully completed contract listing:\n    - all 3 enrolled debts and identifying information;\n    - estimated settlement funding;\n    - total estimated charges;\n    - how and when charges are paid;\n    - beginning and expiration dates;\n    - cancellation-settlement terms;\n    - provider contact information; and\n    - services, education, and counseling.\n\nT6  Debtor executes through an attributable electronic act.\n\nT7  Provider immediately supplies a retainable true copy.\n\nT8  Any fee request or collection is tested separately\n    under Iowa and applicable federal timing law.\n```\n\nA process that jumps from T0 to T6 without T1–T4 is not cured by a detailed contract. A fee disclosure inside the contract does not satisfy the separate written-disclosure requirement. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E02 — Electronic copy that cannot be retained\n\n### Facts\n\nPlain text\n```\nThe debtor clicks “I agree.”\nThe final contract appears only in a portal.\nThe portal blocks printing and downloading.\nThe link expires after 24 hours.\n```\n\n### Analysis\n\nEven assuming the debtor agreed to transact electronically and the click was attributable to the debtor, the required written copy is not shown to be capable of retention at receipt. Iowa UETA states that an electronic record is not retainable where the sender’s system inhibits printing or storage, and such a record is not enforceable against the recipient under that provision.\n\n**Result:** No verified compliance with the true-copy requirement. The click alone does not cure the defect. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/554D.pdf)\n\n## S_IA-P6-E03 — Custodial contract and creditor-consent boundary\n\n### Inputs\n\nPlain text\n```\nCreditors listed in contract:               6\nCreditors consenting to account handling:   2\nCreditors accepting a distribution:         1 additional creditor\nTotal qualifying creditors:                 3\n```\n\n### Agreement result\n\nThe contract must list all six creditors expected to receive payments.\n\n### Separate operational result\n\nThe previously reviewed custodial fee condition uses at least 50% of the creditors listed, or an equivalent number accepting distributions:\n\nPlain text\n```\n3 qualifying creditors ÷ 6 listed creditors = 50%\n```\n\nThe debtor must be informed which creditors have not agreed.\n\nThis example does not establish that any fee is otherwise earned or federally collectible. Creditor consent is not a substitute for the pre-contract budget analysis, separate disclosures, contract, or true-copy delivery. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E04 — Educational-loan electronic contract and cancellation\n\n### Contract package assumptions\n\nPlain text\n```\nGeneral required terms:              At least 10-point\nCancellation statement:              14-point bold,\n                                     immediately above signature\nCancellation forms:                  2 completed copies,\n                                     easily detachable attachment\nFull-performance notice:             14-point bold,\n                                     immediately above cancellation form\nDebtor signature:                    Attributable electronic signature\nFinal copy:                          Retainable\n```\n\n### Event sequence\n\nPlain text\n```\nT0      Compliant contract is signed and executed.\nT0–T3  Debtor has unconditional cancellation right\n        through midnight of the third business day.\nT1      Debtor sends an email stating:\n        “I cancel and do not wish to be bound.”\n```\n\nThe cancellation is effective upon transmission under §533A.8A. The debtor need not use the provider’s attached form.\n\nNo exact expiration date is calculated because the applicable business-day counting and holiday facts have not been established.\n\nNo fee can be requested or received merely because the three-day period expires. Educational-loan compensation remains barred until every contracted or represented service has been fully performed. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E05 — Ordinary noncustodial cancellation by mail\n\n### Events\n\nPlain text\n```\nT0  Debtor signs written cancellation notice.\nT1  Debtor deposits notice in mail:\n    - properly addressed to contract address;\n    - postage paid.\nT2  Provider receives the notice.\n```\n\nFor the statutory noncustodial methods, the notice is effective at **T1**, not T2. No future installments become due after T1.\n\nThis event result does not determine:\n\n- A refund amount.\n- Whether earlier collections were lawful.\n- Whether a completed-settlement amount exists.\n- How earlier credits interact with cancellation.\n- A deadline for returning money.\n\nThose matters remain under the preserved fee and funds holds. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E06 — Attempt to add another debt after enrollment\n\n### Original contract\n\nPlain text\n```\nDebt A: listed\nDebt B: listed\nDebt C: not listed\n```\n\n### Later event\n\nThe provider adds Debt C in the online dashboard and begins treating it as enrolled without obtaining a new signature or amendment.\n\n### Result\n\nThe original contract does not meet the requirement to list Debt C as a debt being negotiated at the time of enrollment. The provider also cannot rely on a blank schedule completed after execution.\n\nNo Iowa provision located supplies an automatic dashboard-addition method. A compliant amendment or new enrollment would need to be established under the applicable disclosure, contract, advance-fee, attribution, and copy requirements. Whether that can be accomplished through a particular amendment is held. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E07 — Waiver and communication restriction\n\n### Proposed clauses\n\nPlain text\n```\nClause 1:\n“Consumer waives every right provided by Iowa Code chapter 533A.”\n\nClause 2:\n“Consumer may not communicate directly with any creditor.”\n\nClause 3:\n“Consumer grants provider a lien on personal property\nto secure provider compensation.”\n```\n\n### Results\n\nPlain text\n```\nClause 1: Void and unenforceable; inducing the waiver is a violation.\nClause 2: Prohibited written restriction on debtor-creditor communication.\nClause 3: Prohibited; lien/security for compensation is void and unenforceable.\n```\n\nChanging the heading to “authorization,” “limited power of attorney,” or “program condition” does not alter the substantive restriction. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf)\n\n## S_IA-P6-E08 — Email negotiations without the statutory package\n\n### Facts\n\nPlain text\n```\nProvider emails proposed price and service summary.\nDebtor replies, “I agree.”\nNo budget analysis is completed.\nNo oral disclosures are given.\nNo separate disclosure document is provided.\nNo complete §533A.8(4) contract is delivered.\n```\n\nEven though ordinary Iowa contract law may sometimes recognize assent through email, the email exchange does not satisfy the specific Chapter 533A enrollment sequence. Bruggeman’s general settlement-contract analysis cannot override a statute requiring a written contract, separate pre-sign disclosures, suitability work, and mandatory terms. [Iowa Courts+1](https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion)\n\n# Source register — S_IA-P6-S001+\n\nAll fresh PASS-06 access occurred October 25, 2026 Pacific / October 26, 2026 UTC. Exact source-specific fetch times were not independently preserved.\n\n| Source ID | Title, issuer, and full literal URL | Exact clause / printed page and zero-based PDF index | Version and legal status | Access status and limitations |\n| --- | --- | --- | --- | --- |\n| **S_IA-P6-S001** | Iowa Legislature, **Iowa Code 2026, Chapter 533A — Debt Management**. Version-locked: https://www.legis.iowa.gov/docs/code/2026/533A.pdf Dynamic: https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf | Definitions and exemptions, printed pp.1–3/PDF indices 0–2; §533A.2(5), p.3/index 2; §533A.7(5)–(6), p.5/index 4; §533A.8(1)–(4), pp.5–6/indices 4–5; §533A.8(5)–(7), pp.6–7/indices 5–6; §533A.8A, pp.7–9/indices 6–8; §533A.9, pp.9–10/indices 8–9; §533A.11, pp.12–13/indices 11–12; §533A.17, p.14/index 13. | Official 2026 Code chapter; both routes displayed the December 9, 2025 footer and same visible chapter text. No byte-identity assertion. | **Freshly read/re-read all agreement-relevant paragraphs.** Same underlying authority used in P1; no duplicative-source claim. No complete post-compilation enactment audit. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) |\n| **S_IA-P6-S002** | Iowa Legislature, **Iowa Administrative Code, Banking Division [187]**. Index: https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187 Agency PDF: https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf | Official index dated October 14, 2026; Chapter 20 printed pp.1–5/PDF indices 68–72. Agreement use: 20.9(1), (2), and (5), printed p.3/PDF index 70; examination/discipline context on pp.4–5/indices 71–72. | Official October 14, 2026 agency compilation; Chapter 20 footer IAC 2/5/25 and source note ARC 4061C, IAB 10/10/18, effective 11/14/18. | **Complete Chapter 20 reading reused from prior reviewed work; exact account-file/electronic-record provisions freshly re-read.** Entire 75-page agency PDF not comprehensively read. Original 2018 order, later-than-October-14 changes, and ARC 0368D disposition remain held. [Iowa Legislature+1](https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187) |\n| **S_IA-P6-S003** | Iowa Legislature, **Iowa Code 2026, Chapter 554D — Electronic Transactions and Computer Agreements**. https://www.legis.iowa.gov/docs/code/2026/554D.pdf | §§554D.103–.110, printed pp.1–4/PDF indices 0–3; §§554D.111–.114, pp.4–5/indices 3–4; §§554D.116–.117, pp.5–6/indices 4–5. | Official 2026 Code chapter; footer December 9, 2025. | **Fresh targeted read of all materially relevant UETA provisions.** Not every governmental-record or computer-agreement provision was analyzed. [Iowa Legislature+4](https://www.legis.iowa.gov/docs/code/2026/554D.pdf) |\n| **S_IA-P6-S004** | U.S. House Office of the Law Revision Counsel, **Electronic Signatures in Global and National Commerce Act**. §7001: https://uscode.house.gov/us/usc/119-118/t15/s7001/ §7002: https://uscode.house.gov/us/usc/119-118/t15/s7002/ §7003: https://uscode.house.gov/us/usc/119-118/t15/s7003/ | 15 U.S.C. §§7001(a)–(f), 7002(a), and 7003(a)–(b). | Displayed text contains laws through Public Law 119-120, October 7, 2026. | **Fresh targeted read.** Used only for electronic validity, consumer disclosure consent, retention/proximity, state UETA relationship, and exceptions. No complete interstate-commerce/preemption opinion. [U.S. Code+2](https://uscode.house.gov/us/usc/119-118/t15/s7001/) |\n| **S_IA-P6-S005** | Iowa Judicial Branch, **Burroughs v. City of Davenport Zoning Board of Adjustment**, No. 17-0752, Iowa Supreme Court. https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion | Filed May 25, 2018; amended August 6, 2018. UETA discussion at printed opinion pp.16–17/PDF indices 15–16. | Final Iowa Supreme Court opinion in a zoning-filing dispute. | **Freshly read relevant holding.** Not a Chapter 533A, consumer-contract, electronic-signature, or disclosure-form case. [Iowa Courts+1](https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion) |\n| **S_IA-P6-S006** | Iowa Judicial Branch, **Craig Bruggeman d/b/a Bruggeman Realty v. Narnus Property Management, LLC**, No. 24-1486, Iowa Court of Appeals. https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion | Filed April 1, 2026. Formation and writing analysis at printed opinion pp.7–14/PDF indices 6–13. | Official Iowa Court of Appeals opinion concerning settlement formation. | **Freshly read relevant sections.** Context only; not a Chapter 533A decision and cannot displace its statutory formalities. [Iowa Courts](https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion) |\n| **S_IA-P6-S007** | NMLS, **Licensing Checklists, Requirements, and Fees — Checklist Compiler**. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx Attempted Iowa route: https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_License-New-App-Checklist.pdf | Dynamic compiler returned no parsed Iowa rows. Attempted direct PDF route returned a non-retryable open failure. | Operational discovery routes, not substantive Iowa legal authority. | **Freshly attempted.** No checklist contents authenticated, no account access attempted, and no conclusion drawn about requirements not visible in the public route. [Nationwide Licensing System](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx) |\n\n# Claim register — S_IA-P6-C001+\n\n| Claim ID | Precise assertion | Primary source and pinpoint | Conditions, exceptions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_IA-P6-C001** | The licensee must describe program methodology sufficiently to support an informed appropriateness decision. | S001, §533A.8(1), printed p.5/index 4. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for 2026 Code text; adequacy is fact-specific. |\n| **S_IA-P6-C002** | Comprehensive debt/monthly-budget review and program-appropriateness determination must occur before contract. | S001, §533A.8(2), p.5/index 4. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. No actual debtor review verified. |\n| **S_IA-P6-C003** | Account acceptance requires a written, thorough budget analysis indicating ability to meet the program requirements. | S001, §533A.8(2), p.5/index 4. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; “ability” is the statutory program-requirements standard, not a universal solvency finding. |\n| **S_IA-P6-C004** | Required disclosures must be made verbally and in writing before debtor signature; third-party marketers/sellers share the duty. | S001, §533A.8(3)(a), pp.5–6/indices 4–5. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; actual marketer role and delivery unverified. |\n| **S_IA-P6-C005** | Ordinary written disclosures must be separate from the contract; oral delivery must be normal-rate and comprehension-oriented. | S001, §533A.8(3)(b), p.6/index 5. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. No general ordinary type-size or translation rule located. |\n| **S_IA-P6-C006** | Universal pre-sign disclosures include full-term estimated fee, no guarantee, and discontinuation without penalty. | S001, §533A.8(3)(a)(1)–(3). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. Fee estimate does not authorize collection. |\n| **S_IA-P6-C007** | Principal-concession, noncustodial, and debt-settlement models require additional specified risk disclosures. | S001, §533A.8(3)(a)(4)–(6). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; applicability depends on actual model. |\n| **S_IA-P6-C008** | Licensee and marketers may not contradict mandatory disclosures in representations, advertising, or solicitation. | S001, §§533A.8(3)(b), .11(14). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C009** | A written contract is required, a true copy must be furnished immediately and before fee collection, and the term cannot exceed 60 months. | S001, §533A.8(4), p.6/index 5. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. Does not independently authorize fees or services. |\n| **S_IA-P6-C010** | Universal contract contents are charges, payment timing, discontinuation, dates, provider contact, and service/counseling descriptions. | S001, §533A.8(4)(a)–(f). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C011** | Debt-settlement contracts require the enrollment debt list and estimated settlement funding; custodial contracts require complete creditor list. | S001, §533A.8(4)(g)–(h). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; later additions/amendments unresolved. |\n| **S_IA-P6-C012** | Submission of proposed disclosures and contract with the license application does not itself prove current approval or actual provider compliance. | S001, §533A.2(5), p.3/index 2. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for submission duty; “approval” limitation is a source-bound qualification. |\n| **S_IA-P6-C013** | Ordinary Chapter 533A contemplates debtor signature but does not prescribe the same express date/signature/type rules as §533A.8A. | S001, §§533A.8(3)–(4), .11(3), .8A(4). [Iowa Legislature+2](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High as textual distinction; ordinary signature enforceability in particular facts held. |\n| **S_IA-P6-C014** | A contract to be signed by the debtor must be fully filled in and finished. | S001, §533A.11(3), p.12/index 11. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C015** | Dual collection-agent/licensee operation requires prior written disclosure to debtor and creditor; debt challenge requires written debtor consent. | S001, §533A.11(2), (9). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; content/form of consent not prescribed. |\n| **S_IA-P6-C016** | Compensation cannot be secured by promissory note, mortgage, wage assignment, lien, or other security. | S001, §533A.11(4), (12). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C017** | An agreement restricting debtor-creditor communication is prohibited; educational-loan contact-impeding terms are void. | S001, §§533A.11(11), .8A(5)(d). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C018** | Fee must be agreed in advance, stated in the contract, and cancellation settlement clearly stated. | S001, §533A.9(1), p.9/index 8. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; earning/timing remains held. |\n| **S_IA-P6-C019** | Noncustodial statutory methods use written notice to contract address; mailed notice is effective on proper deposit and stops future installments. | S001, §533A.9(4)(b)(1)–(2), p.10/index 9. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; email timing and refund ledger unresolved. |\n| **S_IA-P6-C020** | Educational-loan requirements are additional and do not displace other applicable Chapter 533A duties. | S001, §533A.8A(1). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C021** | Educational-loan compensation and payment requests are prohibited until full performance. | S001, §533A.8A(2), (5)(a). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; actual service completion unverified. |\n| **S_IA-P6-C022** | Educational-loan debtor has unconditional three-business-day cancellation right following compliant execution, with mail/email/personal effectiveness rules. | S001, §533A.8A(3). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High; exact business-day calendar not calculated. |\n| **S_IA-P6-C023** | Educational-loan contracts require clear language, full service detail, debtor date/signature, 10-point information, and specified 14-point bold notices/forms. | S001, §533A.8A(4). [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C024** | Any Chapter 533A waiver by the debtor is void; inducing waiver is a violation. | S001, §533A.17, p.14/index 13. [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High. |\n| **S_IA-P6-C025** | Iowa UETA recognizes electronic records/signatures only with other substantive law preserved and party agreement to electronic means. | S003, §§554D.104, .106, .108. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/554D.pdf) | High. |\n| **S_IA-P6-C026** | An electronic signature requires intent and must be attributable to the person; an unverified click or email is not automatically sufficient. | S003, §§554D.103(8), .111. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/554D.pdf) | High for standard; actual attribution fact-dependent. |\n| **S_IA-P6-C027** | Required electronic written information must be retainable; statutory method, display, and formatting requirements remain applicable. | S003, §554D.110. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/554D.pdf) | High. |\n| **S_IA-P6-C028** | Electronic retention must accurately reflect the final record and remain accessible. | S003, §554D.114; S002, 20.9. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/554D.pdf) | High; five-year/36-month conflict preserved. |\n| **S_IA-P6-C029** | No authoritative Iowa interpretation was found establishing how an electronic contract satisfies the educational-loan duplicate detachable-form requirement. | S001 §533A.8A(4); S003 §554D.110. | Bounded unresolved finding, not proof no interpretation exists. |\n| **S_IA-P6-C030** | E-SIGN preserves substantive content/timing/proximity and contains consumer electronic-disclosure consent conditions; Iowa UETA relationship requires fact-specific analysis. | S004, 15 U.S.C. §§7001–7002. [U.S. Code+1](https://uscode.house.gov/us/usc/119-118/t15/s7001/) | High for federal text; complete applicability/preemption analysis held. |\n| **S_IA-P6-C031** | No express Chapter 533A process was located for adding debts, materially amending the agreement, changing fee method, or assigning the consumer contract. | S001, §§533A.8(4), .8(7), .9(1), .11(3). [Iowa Legislature+3](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | Bounded statutory finding; general contract law and other regimes held. |\n| **S_IA-P6-C032** | Surrender, suspension, or revocation does not impair a preexisting lawful contract, but no general provider-termination notice procedure was located. | S001, §533A.7(5)–(6). [Iowa Legislature](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High for preservation clause; performance consequences unresolved. |\n| **S_IA-P6-C033** | No ordinary universal three-business-day cooling-off period or email-upon-transmission rule was established outside §533A.8A. | S001, §§533A.8, .8A, .9. [Iowa Legislature+1](https://www.legis.iowa.gov/docs/code/2026/533A.pdf) | High as bounded textual comparison; agreed electronic notice remains fact-specific. |\n| **S_IA-P6-C034** | Compiled Rule 20.9 requires the account file to contain the budget review, contract, and all required disclosures; electronic equivalents are permitted for records. | S002, 20.9(1), (5), printed p.3/index 70. [Iowa Legislature](https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf) | High for October 14 compilation; later changes held. |\n| **S_IA-P6-C035** | No current official public model agreement, separate disclosure, or educational-loan contract package was authenticated through the checked IDOB/NMLS routes. | S007 and bounded search record. [Nationwide Licensing System](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx) | Access limitation, not proof of nonexistence. |\n| **S_IA-P6-C036** | Burroughs supports electronic records generally; Bruggeman supports ordinary email-based assent on its facts, but neither resolves Chapter 533A compliance. | S005–S006. [Iowa Courts+1](https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion) | High as case-scope qualification. |\n| **S_IA-P6-C037** | No actual provider contract, disclosure package, signature record, electronic-consent record, amendment, cancellation notice, or debtor file was verified. | Research limitation across S001–S007. | Confirmed limitation; no contract approval follows. |\n| **S_IA-P6-C038** | Iowa full-remittance settlement completion and conditional federal first-customer-payment timing remain distinct; neither is transformed into a universal contract clause by this pass. | Preserved P2 finding; S001 §§533A.8(4), .9. | Prior finding preserved; no federal overview or fee reanalysis. |\n\n# Complete PASS-06 component coverage and gaps\n\n| Component | Status | Claims | Exact missing evidence / next action |\n| --- | --- | --- | --- |\n| Program methodology explanation | **Answered** | C001 | Actual script, call recording, and comprehension evidence |\n| Comprehensive debt/budget review | **Answered** | C002 | Actual debtor-specific review |\n| Written thorough budget analysis | **Answered** | C003 | Actual analysis and suitability methodology |\n| Appropriateness decision | **Answered at statutory level** | C001–C003 | Provider criteria and debtor facts |\n| Universal oral disclosures | **Answered** | C004–C006 | Actual recordings or contemporaneous evidence |\n| Separate written disclosures | **Answered** | C004–C008 | Actual document and delivery record |\n| Third-party marketer disclosure duty | **Answered** | C004, C008 | Actual marketer relationship and conduct |\n| Ordinary readability standard | **Answered generally** | C005 | No specific ordinary type size or translation rule located |\n| Language/translation requirement | **Unresolved beyond comprehension standard** | C005 | Other state/federal language-access authority or formal interpretation |\n| Debt-settlement risk disclosures | **Answered** | C007 | Actual applicable program and wording |\n| Noncustodial risk disclosures | **Answered** | C007 | Actual custody model remains fact-dependent |\n| Tax-consequence disclosure | **Answered conditionally** | C007 | Applies when principal concessions are sought |\n| Written ordinary contract | **Answered** | C009 | Actual final contract |\n| True-copy timing | **Answered** | C009, C027 | Actual delivery and retainability |\n| Ordinary maximum term | **Answered** | C009 | Actual dates |\n| Ordinary mandatory clauses | **Answered** | C010 | Actual text |\n| Debt-settlement debt list | **Answered** | C011 | Actual creditor schedule and identifiers |\n| Estimated settlement funding | **Answered** | C011 | Actual calculation and disclosure |\n| Custodial creditor list | **Answered** | C011 | Actual model and creditor list |\n| Creditor-consent event | **Preserved conditional boundary** | C038 | Actual consent/distribution evidence; fee pass remains controlling |\n| Settlement-completion event | **Preserved; not re-researched** | C038 | Actual full-remittance record |\n| Federal first-payment condition | **Preserved; federal facts held** | C038 | TSR coverage, call facts, valid agreement, payment evidence |\n| Ordinary debtor signature | **Partial** | C013–C014 | Controlling interpretation and actual formation record |\n| Provider signature | **Unresolved/not expressly prescribed** | C013 | Contract language, general law, or agency interpretation |\n| Ordinary contract date | **Partial** | C010, C013 | Beginning/expiration required; execution-date formality not separately prescribed |\n| Contract completeness/no blanks | **Answered** | C014 | Actual executed version |\n| Signed acknowledgment of disclosures | **Not expressly required; evidence still necessary** | C004, C034 | Actual acknowledgment and delivery proof |\n| Collection-agent dual-role disclosure | **Answered** | C015 | Actual roles and written notices |\n| Written consent to challenge debt | **Answered** | C015 | Actual specific consent |\n| General cancellation clause | **Answered** | C018 | Actual text and fee treatment |\n| Ordinary cancellation notice method | **Partial/model-specific** | C019, C033 | Contract terms and UETA facts |\n| Ordinary mailed-notice effectiveness | **Answered for statutory noncustodial methods** | C019 | Actual deposit/address/postage |\n| Ordinary email notice effectiveness | **Unresolved** | C019, C033 | Contract, electronic-consent, send/receipt facts, authoritative interpretation |\n| Ordinary return deadline | **Excluded/held** | — | P4 review or later funds pass |\n| Ordinary cancellation refund amount | **Excluded/preserved** | — | P1 fee method, actual ledger, lawful timing |\n| Educational-loan overlay | **Answered** | C020–C023 | Actual business model and contract |\n| Educational full-performance payment bar | **Answered** | C021 | Actual representations and completed services |\n| Educational three-business-day right | **Answered** | C022 | Exact signing event and applicable counting facts |\n| Business-day calendar calculation | **Unresolved** | C022 | Applicable counting/holiday authority and execution date |\n| Educational email cancellation | **Answered** | C022 | Actual transmission record |\n| Educational contract type size/position | **Answered** | C023 | Actual rendered document |\n| Electronic duplicate detachable forms | **Unresolved** | C029 | Iowa agency/court interpretation and actual interface |\n| Electronic signatures generally | **Answered conditionally** | C025–C027 | Consent, intent, attribution, retainability |\n| Clickwrap validity | **Partial** | C025–C027 | Actual screens, logs, authentication, correction opportunity |\n| Portal-only copy | **Partial** | C027 | Ability to print/store and final-version evidence |\n| Electronic separate-document requirement | **Answered conceptually** | C005, C027 | Actual interface and document architecture |\n| Federal E-SIGN consumer consent | **Partial** | C030 | Interstate-commerce facts, state-law interaction, records covered |\n| Electronic record retention | **Answered at general level** | C028, C034 | Actual repository, access, accuracy, and full retention period |\n| Five-year statute versus 36-month rule | **Preserved unresolved issue** | C028, C034 | Authoritative reconciliation; no shortened retention inferred |\n| Material amendment process | **Unresolved** | C031 | Contract, new disclosures, assent, agency interpretation |\n| Adding debts | **Partial boundary established** | C011, C014, C031 | Compliant amendment/new-enrollment method |\n| Fee change | **Partial** | C018, C031 | Advance agreement and complete applicable fee analysis |\n| Change from one fee method to another | **Unresolved** | C031 | Statutory/agency interpretation and actual contract |\n| Contract extension | **Partial** | C031 | Extension form and repeated disclosures |\n| Consumer-contract assignment | **Unresolved** | C031 | General assignment law, licensure, consent, privacy |\n| License assignment | **Answered outside consumer-contract issue** | S001 §533A.3(5) | Does not resolve contract assignment |\n| Provider termination right/notice | **Unresolved** | C032 | Contract and controlling authority |\n| License surrender effect | **Answered narrowly** | C032 | Performance and remedy consequences later |\n| Waiver of Chapter 533A | **Answered** | C024 | Actual clause |\n| Communication-limiting POA | **Answered** | C017 | Actual agreement |\n| Compensation security terms | **Answered** | C016 | Actual agreement |\n| Arbitration/class waiver/forum clause | **Unresolved except nonwaiver boundary** | C024 | Full contract, FAA/Iowa enforceability, remedies pass |\n| Complaint instructions in contract | **No mandatory clause located** | Matrix §2.5 | Other official forms or interpretations |\n| NMLS/license number in contract | **No mandatory clause located** | Matrix §2.5 | Current official checklist/form |\n| Surety/bond identity in contract | **No mandatory clause located; P5 unreviewed** | Matrix §2.5 | P5 review/current official contract form |\n| Administrator/bank identity | **No universal clause located; P4 unreviewed** | Matrix §2.5 | P4 review and actual account arrangement |\n| Privacy notice | **Not resolved under other law** | Matrix §2.5 | Federal/state privacy regimes |\n| Current official model contract | **Unresolved/not recovered** | C035 | Public authenticated IDOB/NMLS form |\n| Current official separate disclosure form | **Unresolved/not recovered** | C035 | Public authenticated IDOB/NMLS form |\n| Current NMLS Iowa checklist | **Unresolved** | C035 | Working public checklist route or authenticated copy |\n| Formal Iowa agreement interpretation | **Unresolved after bounded search** | C029, C035–C036 | Archived agency orders, cases, or formal guidance |\n| Exact Chapter 533A appellate case | **Not located in bounded search** | C036 | Broader paid/legal database or court-record review |\n| Actual provider contract compliance | **Unresolved** | C037 | Provider contract, disclosures, scripts, logs, records |\n| Provider exemption | **Preserved hold** | — | Entity/activity evidence |\n| CROA/TSR credit-repair overlap | **Excluded/preserved** | — | Separate federal applicability pass |\n| Fee earning and arithmetic | **Excluded/preserved** | — | P1/P2 and later interpretation |\n| Funds, trust, and return mechanics | **Excluded; P4 unreviewed** | — | P4 review |\n| Bond/security | **Excluded; P5 unreviewed** | — | P5 review |\n| General UTPA, tort, remedies, litigation, limitations | **Excluded** | — | Separate pass |\n| Collection, garnishment, secured debt | **Excluded** | — | Separate passes |\n| Local, tribal, country, and sector-specific law | **Excluded** | — | Separate passes |\n| Complete post-compilation statutory audit | **Unresolved** | — | Iowa session-law audit |\n| Post-October-14 rule changes | **Unresolved** | — | Later official compilation/adoption audit |\n| ARC 0368D final disposition | **Preserved hold; not re-researched** | — | Separate defined currentness task |\n| Component/state/parent/A066/operations acceptance | **Unresolved** | C037 | Entire dossier and all remaining dimensions |\n\n# Researcher self-check\n\n## Actually read or re-read in PASS-06\n\nThe following primary material was freshly inspected on October 25, 2026 Pacific:\n\n- Iowa Code Chapter 533A:Definitions and conditional exemptions.Applicant submission of proposed program, disclosures, and contract.Effect of surrender, suspension, and revocation on preexisting lawful contracts.Complete §§533A.8 and 533A.8A.Cancellation-related §533A.9 provisions necessary for agreement analysis.Complete relevant prohibited-contract and representation clauses in §533A.11.Nonwaiver provision in §533A.17.\n- Official October 14, 2026 Agency 187 compilation:Chapter 20 account-file and electronic-record provisions.Related examination and discipline context only as necessary.\n- Iowa UETA:Definitions, scope, party agreement, electronic validity, written delivery, formatting, attribution, errors, retention, automated transactions, and sending/receipt provisions.\n- Federal E-SIGN:§§7001–7003, including consumer consent, retention, proximity, state UETA treatment, and exceptions.\n- Iowa Supreme Court’s Burroughs UETA discussion.\n- Iowa Court of Appeals’ Bruggeman contract-formation discussion.\n- Public NMLS checklist routes.\n\n## Reused without regeneration\n\nThe following reviewed P1–P3 matters were preserved:\n\n- Iowa’s classification and market-access framework.\n- P1’s budget/disclosure/contract starting finding.\n- All seven P1 fee examples and reviewed quantities.\n- P2’s correction establishing existing compiled full-remittance settlement-completion wording.\n- P3’s date and alternate renewal-path correction.\n- All provider, exemption, currentness, post-compilation, ARC, NMLS, federal, and later-pass holds.\n\nNo prior fee example, fee formula, bond example, or funds ledger was rerun.\n\n## Not treated as reviewed authority\n\nPASS-04 funds/account findings and PASS-05 bond/recovery findings remain saved but unreviewed. This answer does not adopt their new interpretations. References to account identity, held money, bond identity, or refund timing are limited to identifying agreement fields that Chapter 533A does or does not expressly require.\n\n## Bounded searches that did not produce relied-on exact authority\n\nTargeted public searches were performed for:\n\n- Official IDOB model debt-management agreements.\n- Separate Iowa disclosure forms.\n- Educational-loan cancellation packages.\n- Current Iowa NMLS debt-management checklists.\n- Iowa cases applying §§533A.8, 533A.8A, 533A.9, 533A.11, or 533A.17 to electronic signatures, amendments, cancellation notices, assignment, or waiver.\n- Formal agency interpretations of electronic duplicate cancellation forms and ordinary email cancellation.\n\nNo exact public primary authority was recovered from those routes. That is not proof no archived, account-gated, trial-level, unpublished, or differently indexed material exists.\n\n## Not read or not established\n\nThis pass did not establish:\n\n- A complete post-compilation Iowa session-law audit.\n- Changes after the October 14, 2026 Agency 187 compilation.\n- Final disposition of ARC 0368D.\n- The original 2018 Chapter 20 adoption order.\n- A current complete Iowa NMLS company or branch checklist.\n- A current official public model consumer contract or disclosure package.\n- Any provider’s license, exemption, contract, script, disclosure, debtor file, signature record, consent log, delivery receipt, amendment, or cancellation notice.\n- Whether any actual click, email, text, or voice process formed a contract.\n- Full federal E-SIGN preemption/application analysis.\n- Full TSR or CROA applicability.\n- Any actual fee earning, collection, credit, or refund.\n- Any actual trust, bank, administrator, money-transmission, or return duty.\n- Any actual bond or consumer recovery.\n- General arbitration, FAA, forum-selection, assignment, privacy, UTPA, tort, contract-remedy, litigation, or limitations analysis.\n- Local, tribal, secured-sector, garnishment, collection, or country-specific coverage.\n- A controlling Iowa Chapter 533A appellate decision on the exact electronic or amendment questions.\n\nNo application was filed, no provider or regulator was contacted, no private record was accessed, no browser was controlled, no account was changed, no site or publication was altered, and no local artifact was written.\n\nThis remains a focused same-coordinator research component, **not independent review**, and does not establish contract approval, provider approval, operations approval, publication readiness, component acceptance, Iowa acceptance, parent acceptance, or A066 acceptance.\n\n**END S_IA PASS-06**\n\n","tables":[{"headers":["Sequence stage","Required act","Timing","Consequence or boundary"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Sequence stage","Required act","Timing","Consequence or boundary"],["A. Program explanation","Describe the methodology so the potential debtor can make an informed decision about whether the program is appropriate.","Before enrollment decision and contract.","A sales pitch naming the service is not the same as describing the methodology."],["B. Financial review","Conduct a comprehensive review of debts and monthly budget.","Before entering the contract.","Must be debtor-specific; a generic eligibility screen is not the statutory review."],["C. Suitability determination","Determine that the program is an appropriate option.","Before contract.","Merely meeting a debt-balance threshold is not the full suitability finding."],["D. Written ability analysis","Perform a written and thorough budget analysis indicating the debtor can meet the requirements determined by that analysis.","Before accepting the account.","“Account accepted” without the written analysis is not supported by the statute."],["E. Oral disclosures","Give all applicable §533A.8(3) disclosures at a normal rate and in a manner designed to ensure understanding.","Before the debtor signs.","A prerecorded or rushed disclosure still must meet the comprehension-oriented standard."],["F. Separate written disclosures","Give the same applicable disclosures in a document separate from the contract and designed to ensure understanding.","Before the debtor signs.","Incorporation only inside the contract does not satisfy the separate-document requirement."],["G. Contract completion","Complete the written contract with all universal and model-specific terms.","Before execution.","A contract to be signed by the debtor cannot contain blanks or unfinished provisions."],["H. Execution and copy","Execute the compliant arrangement and furnish a true copy immediately and before collecting any fee.","Immediately; in all events before fee collection.","Copy delivery is a separate pre-collection condition, not fee-earning authority."],["I. Model-specific predicates","Satisfy creditor-consent, settlement-completion, full-performance, federal timing, or other applicable requirements.","At the event specified by the governing provision.","The existence of a signed contract does not satisfy these later predicates."]]},{"headers":["Disclosure","Applicable model","Required content","Required location/event"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Disclosure","Applicable model","Required content","Required location/event"],["Total estimated fee","All covered programs","Estimated total fee if the debtor remains for the entire contractual term","Oral plus separate written disclosure before signature"],["Results disclaimer","All covered programs","No specific result can be guaranteed","Oral plus separate written disclosure"],["Discontinuation","All covered programs","Debtor may discontinue without penalty at any time","Oral plus separate written disclosure; also mandatory contract term"],["Tax consequence","Program seeking principal concessions","Principal concessions may be treated as taxable income","Oral plus separate written disclosure"],["No creditor payments by provider","Noncustodial model","Payments are not made to creditors on debtor’s behalf; debtor remains obligated to make payments","Oral plus separate written disclosure"],["Ongoing collection","Noncustodial model","Creditors may continue collection during enrollment","Oral plus separate written disclosure"],["Credit harm","Debt settlement","Credit report and score may be harmed","Oral plus separate written disclosure"],["Contract/default costs","Debt settlement","Missed minimum payments may breach creditor agreements, produce fees or penalties, and permit rate increases","Oral plus separate written disclosure"],["Lawsuit risk","Debt settlement","Creditors may sue if required minimum payments are not made","Oral plus separate written disclosure"],["Noncontradiction","Licensee and third-party marketer/seller","Advertising, solicitation, and representations cannot contradict the required disclosures","Applies throughout marketing and enrollment"]]},{"headers":["Mandatory ordinary contract term","Exact statutory requirement","Qualification"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Mandatory ordinary contract term","Exact statutory requirement","Qualification"],["Written contract","Licensee must make a written contract with the debtor","Electronic form may qualify only under applicable electronic-record law"],["Total estimated charges","Charges agreed for licensee services and services of third parties acting for or with the licensee","Disclosure does not independently authorize passing every third-party charge to the debtor"],["How and when charges are paid","Statement of timing and method","Must remain consistent with state and independently applicable federal collection law"],["Discontinuation without penalty","Express statement of debtor’s right","Cannot be negated elsewhere by liquidated charge, forfeiture, waiver, or contradictory language"],["Cancellation settlement","Clear provision for settling the parties’ account if the relationship is canceled","Does not by itself establish that any proposed retention is lawful"],["Beginning and expiration date","Both dates","Term may not exceed 60 months"],["Provider identity and contact","Licensee name, physical address, mailing address if different, and telephone number","Ordinary provision does not expressly require email address"],["Services","Description of services to be provided","Must include educational and counseling services aimed at borrowing, spending, and saving habits"],["True copy","Debtor must receive true copy immediately and before fee collection","Exact statutory text does not expressly prescribe paper versus electronic copy"],["Fee agreed in advance","Fee must be agreed in advance and stated in the contract","Ceiling or stated fee is not earning or collection permission"]]},{"headers":["Model/event","Mandatory contract term","Separate operational event or disclosure","Important boundary"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Model/event","Mandatory contract term","Separate operational event or disclosure","Important boundary"],["Debt settlement","Comprehensive list of every debt at enrollment to be negotiated, with creditor names and identifying information; estimated money needed to fund settlements","Debt-settlement risks must also be given orally and in separate written disclosure","Later debt addition is not expressly governed; blank insertion is prohibited"],["Custodial DMP","Complete list of creditors to receive payments","Before non-initiation fees, statutory creditor-consent/accepted-distribution condition applies; debtor must be informed which creditors have not agreed","Creditor consent is not identified as a substitute for the contract or separate disclosures"],["Noncustodial settlement","Universal contract terms; fee method and cancellation settlement must be accurately described","Separate pre-sign disclosure that provider does not make payments and creditors may keep collecting; debtor retains control under separate statutory provision","Account title alone does not resolve classification; P4 remains unreviewed"],["Collection agent plus licensee on same account","No special enumerated contract clause","Must first disclose the dual role in writing to both debtor and creditor","Disclosure must occur before operating in both capacities"],["Debt challenge","No enumerated challenge clause","Written debtor consent is required before challenging a debt","General enrollment authorization is not necessarily specific written challenge consent"],["Educational-loan management","All ordinary applicable terms plus §533A.8A’s detailed form, service, signature, cancellation, and payment language","No payment request, collection, or third-party payment requirement before full performance","Educational requirements are additional and nonexclusive"],["Credit-improvement representations","No separate Iowa Chapter 533A contract schedule was located solely because marketing mentions credit improvement","Debt-settlement provider cannot claim negotiations will eliminate adverse credit information","CROA/TSR applicability remains open"],["Counseling-only service","Depends on whether actual compensated activity falls within “debt management”","Conditional exemptions must be proved","No label-based exemption is established"]]},{"headers":["Educational-loan requirement","Exact condition"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Educational-loan requirement","Exact condition"],["Language","Clear and understandable"],["Terms","All terms, restrictions, and conditions clearly and conspicuously stated"],["Services","Fully and specifically described"],["Execution","Contract dated and signed by the debtor"],["General type size","Required information at least 10-point type"],["Cancellation contact","Licensee name, email address, and physical business address for cancellation"],["P.O. box","Cannot serve as the only physical address; may be a mailing address only with a physical delivery address"],["Pre-sign cancellation disclosure","Statutory language in at least 14-point bold immediately above debtor signature"],["Cancellation forms","Completed, easily detachable form in duplicate, attached, captioned “notice of cancellation,” at least 14-point bold, in substantially prescribed form"],["Full-performance disclosure","Separate Iowa-required statement in at least 14-point bold immediately above the cancellation form"],["Cancellation period","Until midnight of the third business day after a compliant contract is signed and executed"],["Cancellation medium","Any written notice showing intent not to be bound; mail, email, personal delivery, or another means"],["Mail effectiveness","Deposit in mail, properly addressed, postage prepaid"],["Email effectiveness","Upon transmission"],["Personal delivery effectiveness","Upon delivery"],["Payment timing","No demand, request, charge, collection, receipt, or compelled third-party payment before full performance"],["Third-party consideration","Must be fully disclosed before receipt"],["Contact restriction","Any term impeding contact with a creditor, servicer, government, lawyer, counselor, or other helper is void"]]},{"headers":["Potential clause","PASS-06 finding"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Potential clause","PASS-06 finding"],["Iowa license number or NMLS ID","Not found as a mandatory consumer-contract clause"],["Surety name, bond number, or bond amount","Not found as a mandatory consumer-contract clause; P5 is unreviewed"],["IDOB complaint instructions","Not found as a mandatory contract clause"],["Separate account-administrator identity","Not expressly listed as a universal contract clause"],["Bank or account identity","Not expressly listed as a universal contract clause"],["Arbitration","No Chapter 533A clause specifically requiring or categorically prohibiting arbitration was located"],["Jury waiver","No specific Chapter 533A treatment located; cannot waive substantive Chapter 533A rights"],["Class-action waiver","No specific Chapter 533A treatment located; broader enforceability is excluded"],["Choice of law or forum","No mandatory clause located"],["Privacy notice","No Chapter 533A consumer-contract clause located; other privacy laws remain open"],["Assignment provision","No consumer-contract assignment procedure located"],["Provider termination right","No prescribed provider-termination clause or notice process located"],["Electronic-consent disclosure","Iowa UETA supplies electronic-transaction requirements; no Chapter 533A-specific electronic-consent form was located"],["Signed acknowledgment of the separate disclosures","No express acknowledgment clause located, although the disclosure and account-file records must prove compliance"]]},{"headers":["Contract term or practice","Iowa treatment"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Contract term or practice","Iowa treatment"],["Blank or unfinished contract","Provider may not execute it"],["Waiver of Chapter 533A rights","Void and unenforceable; inducing waiver is a violation"],["Power of attorney limiting debtor-creditor communication","Prohibited"],["Other written term limiting debtor-creditor communication","Prohibited"],["Educational-loan term impeding contact with creditors, servicers, government, lawyers, counselors, or helpers","Void and unenforceable"],["Wage assignment securing provider compensation","Prohibited; void and unenforceable"],["Lien or other real/personal-property security securing compensation","Prohibited; void and unenforceable"],["Promissory note or other promise to pay used as the fee","Prohibited"],["Statement contradicting mandatory disclosures","Prohibited"],["Advice to stop creditor payments in debt settlement","Prohibited"],["Claim that payment is a settlement without creditor written confirmation","Prohibited"],["Claim that program guarantees debt satisfaction or prevents collection/litigation/credit harm/bankruptcy","Prohibited"],["Claim that negotiations will eliminate adverse credit information","Prohibited"]]},{"headers":["Source ID","Title, issuer, and full literal URL","Exact clause / printed page and zero-based PDF index","Version and legal status","Access status and limitations"],"index":7,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+4"},{"href":"https://uscode.house.gov/us/usc/119-118/t15/s7001/","text":"U.S. Code\n+2"},{"href":"https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","text":"Iowa Courts\n+1"},{"href":"https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion","text":"Iowa Courts"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+4"}],[{"href":"https://uscode.house.gov/us/usc/119-118/t15/s7001/","text":"U.S. Code\n+2"}],[{"href":"https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","text":"Iowa Courts\n+1"}],[{"href":"https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion","text":"Iowa Courts"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"}]],"rows":[["Source ID","Title, issuer, and full literal URL","Exact clause / printed page and zero-based PDF index","Version and legal status","Access status and limitations"],["S_IA-P6-S001","Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. Version-locked: https://www.legis.iowa.gov/docs/code/2026/533A.pdf Dynamic: https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf","Definitions and exemptions, printed pp.1–3/PDF indices 0–2; §533A.2(5), p.3/index 2; §533A.7(5)–(6), p.5/index 4; §533A.8(1)–(4), pp.5–6/indices 4–5; §533A.8(5)–(7), pp.6–7/indices 5–6; §533A.8A, pp.7–9/indices 6–8; §533A.9, pp.9–10/indices 8–9; §533A.11, pp.12–13/indices 11–12; §533A.17, p.14/index 13.","Official 2026 Code chapter; both routes displayed the December 9, 2025 footer and same visible chapter text. No byte-identity assertion.","Freshly read/re-read all agreement-relevant paragraphs. Same underlying authority used in P1; no duplicative-source claim. No complete post-compilation enactment audit. \nIowa Legislature\n+1"],["S_IA-P6-S002","Iowa Legislature, Iowa Administrative Code, Banking Division [187]. Index: https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187 Agency PDF: https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Official index dated October 14, 2026; Chapter 20 printed pp.1–5/PDF indices 68–72. Agreement use: 20.9(1), (2), and (5), printed p.3/PDF index 70; examination/discipline context on pp.4–5/indices 71–72.","Official October 14, 2026 agency compilation; Chapter 20 footer IAC 2/5/25 and source note ARC 4061C, IAB 10/10/18, effective 11/14/18.","Complete Chapter 20 reading reused from prior reviewed work; exact account-file/electronic-record provisions freshly re-read. Entire 75-page agency PDF not comprehensively read. Original 2018 order, later-than-October-14 changes, and ARC 0368D disposition remain held. \nIowa Legislature\n+1"],["S_IA-P6-S003","Iowa Legislature, Iowa Code 2026, Chapter 554D — Electronic Transactions and Computer Agreements. https://www.legis.iowa.gov/docs/code/2026/554D.pdf","§§554D.103–.110, printed pp.1–4/PDF indices 0–3; §§554D.111–.114, pp.4–5/indices 3–4; §§554D.116–.117, pp.5–6/indices 4–5.","Official 2026 Code chapter; footer December 9, 2025.","Fresh targeted read of all materially relevant UETA provisions. Not every governmental-record or computer-agreement provision was analyzed. \nIowa Legislature\n+4"],["S_IA-P6-S004","U.S. House Office of the Law Revision Counsel, Electronic Signatures in Global and National Commerce Act. §7001: https://uscode.house.gov/us/usc/119-118/t15/s7001/ §7002: https://uscode.house.gov/us/usc/119-118/t15/s7002/ §7003: https://uscode.house.gov/us/usc/119-118/t15/s7003/","15 U.S.C. §§7001(a)–(f), 7002(a), and 7003(a)–(b).","Displayed text contains laws through Public Law 119-120, October 7, 2026.","Fresh targeted read. Used only for electronic validity, consumer disclosure consent, retention/proximity, state UETA relationship, and exceptions. No complete interstate-commerce/preemption opinion. \nU.S. Code\n+2"],["S_IA-P6-S005","Iowa Judicial Branch, Burroughs v. City of Davenport Zoning Board of Adjustment, No. 17-0752, Iowa Supreme Court. https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","Filed May 25, 2018; amended August 6, 2018. UETA discussion at printed opinion pp.16–17/PDF indices 15–16.","Final Iowa Supreme Court opinion in a zoning-filing dispute.","Freshly read relevant holding. Not a Chapter 533A, consumer-contract, electronic-signature, or disclosure-form case. \nIowa Courts\n+1"],["S_IA-P6-S006","Iowa Judicial Branch, Craig Bruggeman d/b/a Bruggeman Realty v. Narnus Property Management, LLC, No. 24-1486, Iowa Court of Appeals. https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion","Filed April 1, 2026. Formation and writing analysis at printed opinion pp.7–14/PDF indices 6–13.","Official Iowa Court of Appeals opinion concerning settlement formation.","Freshly read relevant sections. Context only; not a Chapter 533A decision and cannot displace its statutory formalities. \nIowa Courts"],["S_IA-P6-S007","NMLS, Licensing Checklists, Requirements, and Fees — Checklist Compiler. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx Attempted Iowa route: https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_License-New-App-Checklist.pdf","Dynamic compiler returned no parsed Iowa rows. Attempted direct PDF route returned a non-retryable open failure.","Operational discovery routes, not substantive Iowa legal authority.","Freshly attempted. No checklist contents authenticated, no account access attempted, and no conclusion drawn about requirements not visible in the public route. \nNationwide Licensing System"]]},{"headers":["Claim ID","Precise assertion","Primary source and pinpoint","Conditions, exceptions, currentness, and confidence"],"index":8,"links":[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"},{"href":"https://uscode.house.gov/us/usc/119-118/t15/s7001/","text":"U.S. Code\n+1"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+3"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"},{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"},{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"},{"href":"https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","text":"Iowa Courts\n+1"}],"row_links":[[],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+2"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/554D.pdf","text":"Iowa Legislature\n+1"}],[],[{"href":"https://uscode.house.gov/us/usc/119-118/t15/s7001/","text":"U.S. Code\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+3"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature"}],[{"href":"https://www.legis.iowa.gov/docs/code/2026/533A.pdf","text":"Iowa Legislature\n+1"}],[{"href":"https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","text":"Iowa Legislature"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"}],[{"href":"https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","text":"Iowa Courts\n+1"}],[],[]],"rows":[["Claim ID","Precise assertion","Primary source and pinpoint","Conditions, exceptions, currentness, and confidence"],["S_IA-P6-C001","The licensee must describe program methodology sufficiently to support an informed appropriateness decision.","S001, §533A.8(1), printed p.5/index 4. \nIowa Legislature","High for 2026 Code text; adequacy is fact-specific."],["S_IA-P6-C002","Comprehensive debt/monthly-budget review and program-appropriateness determination must occur before contract.","S001, §533A.8(2), p.5/index 4. \nIowa Legislature","High. No actual debtor review verified."],["S_IA-P6-C003","Account acceptance requires a written, thorough budget analysis indicating ability to meet the program requirements.","S001, §533A.8(2), p.5/index 4. \nIowa Legislature","High; “ability” is the statutory program-requirements standard, not a universal solvency finding."],["S_IA-P6-C004","Required disclosures must be made verbally and in writing before debtor signature; third-party marketers/sellers share the duty.","S001, §533A.8(3)(a), pp.5–6/indices 4–5. \nIowa Legislature","High; actual marketer role and delivery unverified."],["S_IA-P6-C005","Ordinary written disclosures must be separate from the contract; oral delivery must be normal-rate and comprehension-oriented.","S001, §533A.8(3)(b), p.6/index 5. \nIowa Legislature","High. No general ordinary type-size or translation rule located."],["S_IA-P6-C006","Universal pre-sign disclosures include full-term estimated fee, no guarantee, and discontinuation without penalty.","S001, §533A.8(3)(a)(1)–(3). \nIowa Legislature","High. Fee estimate does not authorize collection."],["S_IA-P6-C007","Principal-concession, noncustodial, and debt-settlement models require additional specified risk disclosures.","S001, §533A.8(3)(a)(4)–(6). \nIowa Legislature","High; applicability depends on actual model."],["S_IA-P6-C008","Licensee and marketers may not contradict mandatory disclosures in representations, advertising, or solicitation.","S001, §§533A.8(3)(b), .11(14). \nIowa Legislature\n+1","High."],["S_IA-P6-C009","A written contract is required, a true copy must be furnished immediately and before fee collection, and the term cannot exceed 60 months.","S001, §533A.8(4), p.6/index 5. \nIowa Legislature","High. Does not independently authorize fees or services."],["S_IA-P6-C010","Universal contract contents are charges, payment timing, discontinuation, dates, provider contact, and service/counseling descriptions.","S001, §533A.8(4)(a)–(f). \nIowa Legislature","High."],["S_IA-P6-C011","Debt-settlement contracts require the enrollment debt list and estimated settlement funding; custodial contracts require complete creditor list.","S001, §533A.8(4)(g)–(h). \nIowa Legislature","High; later additions/amendments unresolved."],["S_IA-P6-C012","Submission of proposed disclosures and contract with the license application does not itself prove current approval or actual provider compliance.","S001, §533A.2(5), p.3/index 2. \nIowa Legislature","High for submission duty; “approval” limitation is a source-bound qualification."],["S_IA-P6-C013","Ordinary Chapter 533A contemplates debtor signature but does not prescribe the same express date/signature/type rules as §533A.8A.","S001, §§533A.8(3)–(4), .11(3), .8A(4). \nIowa Legislature\n+2","High as textual distinction; ordinary signature enforceability in particular facts held."],["S_IA-P6-C014","A contract to be signed by the debtor must be fully filled in and finished.","S001, §533A.11(3), p.12/index 11. \nIowa Legislature","High."],["S_IA-P6-C015","Dual collection-agent/licensee operation requires prior written disclosure to debtor and creditor; debt challenge requires written debtor consent.","S001, §533A.11(2), (9). \nIowa Legislature","High; content/form of consent not prescribed."],["S_IA-P6-C016","Compensation cannot be secured by promissory note, mortgage, wage assignment, lien, or other security.","S001, §533A.11(4), (12). \nIowa Legislature","High."],["S_IA-P6-C017","An agreement restricting debtor-creditor communication is prohibited; educational-loan contact-impeding terms are void.","S001, §§533A.11(11), .8A(5)(d). \nIowa Legislature\n+1","High."],["S_IA-P6-C018","Fee must be agreed in advance, stated in the contract, and cancellation settlement clearly stated.","S001, §533A.9(1), p.9/index 8. \nIowa Legislature","High; earning/timing remains held."],["S_IA-P6-C019","Noncustodial statutory methods use written notice to contract address; mailed notice is effective on proper deposit and stops future installments.","S001, §533A.9(4)(b)(1)–(2), p.10/index 9. \nIowa Legislature","High; email timing and refund ledger unresolved."],["S_IA-P6-C020","Educational-loan requirements are additional and do not displace other applicable Chapter 533A duties.","S001, §533A.8A(1). \nIowa Legislature","High."],["S_IA-P6-C021","Educational-loan compensation and payment requests are prohibited until full performance.","S001, §533A.8A(2), (5)(a). \nIowa Legislature\n+1","High; actual service completion unverified."],["S_IA-P6-C022","Educational-loan debtor has unconditional three-business-day cancellation right following compliant execution, with mail/email/personal effectiveness rules.","S001, §533A.8A(3). \nIowa Legislature","High; exact business-day calendar not calculated."],["S_IA-P6-C023","Educational-loan contracts require clear language, full service detail, debtor date/signature, 10-point information, and specified 14-point bold notices/forms.","S001, §533A.8A(4). \nIowa Legislature\n+1","High."],["S_IA-P6-C024","Any Chapter 533A waiver by the debtor is void; inducing waiver is a violation.","S001, §533A.17, p.14/index 13. \nIowa Legislature","High."],["S_IA-P6-C025","Iowa UETA recognizes electronic records/signatures only with other substantive law preserved and party agreement to electronic means.","S003, §§554D.104, .106, .108. \nIowa Legislature\n+1","High."],["S_IA-P6-C026","An electronic signature requires intent and must be attributable to the person; an unverified click or email is not automatically sufficient.","S003, §§554D.103(8), .111. \nIowa Legislature\n+1","High for standard; actual attribution fact-dependent."],["S_IA-P6-C027","Required electronic written information must be retainable; statutory method, display, and formatting requirements remain applicable.","S003, §554D.110. \nIowa Legislature\n+1","High."],["S_IA-P6-C028","Electronic retention must accurately reflect the final record and remain accessible.","S003, §554D.114; S002, 20.9. \nIowa Legislature\n+1","High; five-year/36-month conflict preserved."],["S_IA-P6-C029","No authoritative Iowa interpretation was found establishing how an electronic contract satisfies the educational-loan duplicate detachable-form requirement.","S001 §533A.8A(4); S003 §554D.110.","Bounded unresolved finding, not proof no interpretation exists."],["S_IA-P6-C030","E-SIGN preserves substantive content/timing/proximity and contains consumer electronic-disclosure consent conditions; Iowa UETA relationship requires fact-specific analysis.","S004, 15 U.S.C. §§7001–7002. \nU.S. Code\n+1","High for federal text; complete applicability/preemption analysis held."],["S_IA-P6-C031","No express Chapter 533A process was located for adding debts, materially amending the agreement, changing fee method, or assigning the consumer contract.","S001, §§533A.8(4), .8(7), .9(1), .11(3). \nIowa Legislature\n+3","Bounded statutory finding; general contract law and other regimes held."],["S_IA-P6-C032","Surrender, suspension, or revocation does not impair a preexisting lawful contract, but no general provider-termination notice procedure was located.","S001, §533A.7(5)–(6). \nIowa Legislature","High for preservation clause; performance consequences unresolved."],["S_IA-P6-C033","No ordinary universal three-business-day cooling-off period or email-upon-transmission rule was established outside §533A.8A.","S001, §§533A.8, .8A, .9. \nIowa Legislature\n+1","High as bounded textual comparison; agreed electronic notice remains fact-specific."],["S_IA-P6-C034","Compiled Rule 20.9 requires the account file to contain the budget review, contract, and all required disclosures; electronic equivalents are permitted for records.","S002, 20.9(1), (5), printed p.3/index 70. \nIowa Legislature","High for October 14 compilation; later changes held."],["S_IA-P6-C035","No current official public model agreement, separate disclosure, or educational-loan contract package was authenticated through the checked IDOB/NMLS routes.","S007 and bounded search record. \nNationwide Licensing System","Access limitation, not proof of nonexistence."],["S_IA-P6-C036","Burroughs supports electronic records generally; Bruggeman supports ordinary email-based assent on its facts, but neither resolves Chapter 533A compliance.","S005–S006. \nIowa Courts\n+1","High as case-scope qualification."],["S_IA-P6-C037","No actual provider contract, disclosure package, signature record, electronic-consent record, amendment, cancellation notice, or debtor file was verified.","Research limitation across S001–S007.","Confirmed limitation; no contract approval follows."],["S_IA-P6-C038","Iowa full-remittance settlement completion and conditional federal first-customer-payment timing remain distinct; neither is transformed into a universal contract clause by this pass.","Preserved P2 finding; S001 §§533A.8(4), .9.","Prior finding preserved; no federal overview or fee reanalysis."]]},{"headers":["Component","Status","Claims","Exact missing evidence / next action"],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Exact missing evidence / next action"],["Program methodology explanation","Answered","C001","Actual script, call recording, and comprehension evidence"],["Comprehensive debt/budget review","Answered","C002","Actual debtor-specific review"],["Written thorough budget analysis","Answered","C003","Actual analysis and suitability methodology"],["Appropriateness decision","Answered at statutory level","C001–C003","Provider criteria and debtor facts"],["Universal oral disclosures","Answered","C004–C006","Actual recordings or contemporaneous evidence"],["Separate written disclosures","Answered","C004–C008","Actual document and delivery record"],["Third-party marketer disclosure duty","Answered","C004, C008","Actual marketer relationship and conduct"],["Ordinary readability standard","Answered generally","C005","No specific ordinary type size or translation rule located"],["Language/translation requirement","Unresolved beyond comprehension standard","C005","Other state/federal language-access authority or formal interpretation"],["Debt-settlement risk disclosures","Answered","C007","Actual applicable program and wording"],["Noncustodial risk disclosures","Answered","C007","Actual custody model remains fact-dependent"],["Tax-consequence disclosure","Answered conditionally","C007","Applies when principal concessions are sought"],["Written ordinary contract","Answered","C009","Actual final contract"],["True-copy timing","Answered","C009, C027","Actual delivery and retainability"],["Ordinary maximum term","Answered","C009","Actual dates"],["Ordinary mandatory clauses","Answered","C010","Actual text"],["Debt-settlement debt list","Answered","C011","Actual creditor schedule and identifiers"],["Estimated settlement funding","Answered","C011","Actual calculation and disclosure"],["Custodial creditor list","Answered","C011","Actual model and creditor list"],["Creditor-consent event","Preserved conditional boundary","C038","Actual consent/distribution evidence; fee pass remains controlling"],["Settlement-completion event","Preserved; not re-researched","C038","Actual full-remittance record"],["Federal first-payment condition","Preserved; federal facts held","C038","TSR coverage, call facts, valid agreement, payment evidence"],["Ordinary debtor signature","Partial","C013–C014","Controlling interpretation and actual formation record"],["Provider signature","Unresolved/not expressly prescribed","C013","Contract language, general law, or agency interpretation"],["Ordinary contract date","Partial","C010, C013","Beginning/expiration required; execution-date formality not separately prescribed"],["Contract completeness/no blanks","Answered","C014","Actual executed version"],["Signed acknowledgment of disclosures","Not expressly required; evidence still necessary","C004, C034","Actual acknowledgment and delivery proof"],["Collection-agent dual-role disclosure","Answered","C015","Actual roles and written notices"],["Written consent to challenge debt","Answered","C015","Actual specific consent"],["General cancellation clause","Answered","C018","Actual text and fee treatment"],["Ordinary cancellation notice method","Partial/model-specific","C019, C033","Contract terms and UETA facts"],["Ordinary mailed-notice effectiveness","Answered for statutory noncustodial methods","C019","Actual deposit/address/postage"],["Ordinary email notice effectiveness","Unresolved","C019, C033","Contract, electronic-consent, send/receipt facts, authoritative interpretation"],["Ordinary return deadline","Excluded/held","—","P4 review or later funds pass"],["Ordinary cancellation refund amount","Excluded/preserved","—","P1 fee method, actual ledger, lawful timing"],["Educational-loan overlay","Answered","C020–C023","Actual business model and contract"],["Educational full-performance payment bar","Answered","C021","Actual representations and completed services"],["Educational three-business-day right","Answered","C022","Exact signing event and applicable counting facts"],["Business-day calendar calculation","Unresolved","C022","Applicable counting/holiday authority and execution date"],["Educational email cancellation","Answered","C022","Actual transmission record"],["Educational contract type size/position","Answered","C023","Actual rendered document"],["Electronic duplicate detachable forms","Unresolved","C029","Iowa agency/court interpretation and actual interface"],["Electronic signatures generally","Answered conditionally","C025–C027","Consent, intent, attribution, retainability"],["Clickwrap validity","Partial","C025–C027","Actual screens, logs, authentication, correction opportunity"],["Portal-only copy","Partial","C027","Ability to print/store and final-version evidence"],["Electronic separate-document requirement","Answered conceptually","C005, C027","Actual interface and document architecture"],["Federal E-SIGN consumer consent","Partial","C030","Interstate-commerce facts, state-law interaction, records covered"],["Electronic record retention","Answered at general level","C028, C034","Actual repository, access, accuracy, and full retention period"],["Five-year statute versus 36-month rule","Preserved unresolved issue","C028, C034","Authoritative reconciliation; no shortened retention inferred"],["Material amendment process","Unresolved","C031","Contract, new disclosures, assent, agency interpretation"],["Adding debts","Partial boundary established","C011, C014, C031","Compliant amendment/new-enrollment method"],["Fee change","Partial","C018, C031","Advance agreement and complete applicable fee analysis"],["Change from one fee method to another","Unresolved","C031","Statutory/agency interpretation and actual contract"],["Contract extension","Partial","C031","Extension form and repeated disclosures"],["Consumer-contract assignment","Unresolved","C031","General assignment law, licensure, consent, privacy"],["License assignment","Answered outside consumer-contract issue","S001 §533A.3(5)","Does not resolve contract assignment"],["Provider termination right/notice","Unresolved","C032","Contract and controlling authority"],["License surrender effect","Answered narrowly","C032","Performance and remedy consequences later"],["Waiver of Chapter 533A","Answered","C024","Actual clause"],["Communication-limiting POA","Answered","C017","Actual agreement"],["Compensation security terms","Answered","C016","Actual agreement"],["Arbitration/class waiver/forum clause","Unresolved except nonwaiver boundary","C024","Full contract, FAA/Iowa enforceability, remedies pass"],["Complaint instructions in contract","No mandatory clause located","Matrix §2.5","Other official forms or interpretations"],["NMLS/license number in contract","No mandatory clause located","Matrix §2.5","Current official checklist/form"],["Surety/bond identity in contract","No mandatory clause located; P5 unreviewed","Matrix §2.5","P5 review/current official contract form"],["Administrator/bank identity","No universal clause located; P4 unreviewed","Matrix §2.5","P4 review and actual account arrangement"],["Privacy notice","Not resolved under other law","Matrix §2.5","Federal/state privacy regimes"],["Current official model contract","Unresolved/not recovered","C035","Public authenticated IDOB/NMLS form"],["Current official separate disclosure form","Unresolved/not recovered","C035","Public authenticated IDOB/NMLS form"],["Current NMLS Iowa checklist","Unresolved","C035","Working public checklist route or authenticated copy"],["Formal Iowa agreement interpretation","Unresolved after bounded search","C029, C035–C036","Archived agency orders, cases, or formal guidance"],["Exact Chapter 533A appellate case","Not located in bounded search","C036","Broader paid/legal database or court-record review"],["Actual provider contract compliance","Unresolved","C037","Provider contract, disclosures, scripts, logs, records"],["Provider exemption","Preserved hold","—","Entity/activity evidence"],["CROA/TSR credit-repair overlap","Excluded/preserved","—","Separate federal applicability pass"],["Fee earning and arithmetic","Excluded/preserved","—","P1/P2 and later interpretation"],["Funds, trust, and return mechanics","Excluded; P4 unreviewed","—","P4 review"],["Bond/security","Excluded; P5 unreviewed","—","P5 review"],["General UTPA, tort, remedies, litigation, limitations","Excluded","—","Separate pass"],["Collection, garnishment, secured debt","Excluded","—","Separate passes"],["Local, tribal, country, and sector-specific law","Excluded","—","Separate passes"],["Complete post-compilation statutory audit","Unresolved","—","Iowa session-law audit"],["Post-October-14 rule changes","Unresolved","—","Later official compilation/adoption audit"],["ARC 0368D final disposition","Preserved hold; not re-researched","—","Separate defined currentness task"],["Component/state/parent/A066/operations acceptance","Unresolved","C037","Entire dossier and all remaining dimensions"]]}],"claims":[{"claim_id":"S_IA-P6-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C001","Precise assertion":"The licensee must describe program methodology sufficiently to support an informed appropriateness decision.","Primary source and pinpoint":"S001, §533A.8(1), printed p.5/index 4. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High for 2026 Code text; adequacy is fact-specific."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C002","Precise assertion":"Comprehensive debt/monthly-budget review and program-appropriateness determination must occur before contract.","Primary source and pinpoint":"S001, §533A.8(2), p.5/index 4. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High. No actual debtor review verified."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C003","Precise assertion":"Account acceptance requires a written, thorough budget analysis indicating ability to meet the program requirements.","Primary source and pinpoint":"S001, §533A.8(2), p.5/index 4. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; “ability” is the statutory program-requirements standard, not a universal solvency finding."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C004","Precise assertion":"Required disclosures must be made verbally and in writing before debtor signature; third-party marketers/sellers share the duty.","Primary source and pinpoint":"S001, §533A.8(3)(a), pp.5–6/indices 4–5. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; actual marketer role and delivery unverified."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C005","Precise assertion":"Ordinary written disclosures must be separate from the contract; oral delivery must be normal-rate and comprehension-oriented.","Primary source and pinpoint":"S001, §533A.8(3)(b), p.6/index 5. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High. No general ordinary type-size or translation rule located."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C006","Precise assertion":"Universal pre-sign disclosures include full-term estimated fee, no guarantee, and discontinuation without penalty.","Primary source and pinpoint":"S001, §533A.8(3)(a)(1)–(3). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High. Fee estimate does not authorize collection."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C007","Precise assertion":"Principal-concession, noncustodial, and debt-settlement models require additional specified risk disclosures.","Primary source and pinpoint":"S001, §533A.8(3)(a)(4)–(6). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; applicability depends on actual model."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C008","Precise assertion":"Licensee and marketers may not contradict mandatory disclosures in representations, advertising, or solicitation.","Primary source and pinpoint":"S001, §§533A.8(3)(b), .11(14). \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C009","Precise assertion":"A written contract is required, a true copy must be furnished immediately and before fee collection, and the term cannot exceed 60 months.","Primary source and pinpoint":"S001, §533A.8(4), p.6/index 5. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High. Does not independently authorize fees or services."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C010","Precise assertion":"Universal contract contents are charges, payment timing, discontinuation, dates, provider contact, and service/counseling descriptions.","Primary source and pinpoint":"S001, §533A.8(4)(a)–(f). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C011","Precise assertion":"Debt-settlement contracts require the enrollment debt list and estimated settlement funding; custodial contracts require complete creditor list.","Primary source and pinpoint":"S001, §533A.8(4)(g)–(h). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; later additions/amendments unresolved."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C012","Precise assertion":"Submission of proposed disclosures and contract with the license application does not itself prove current approval or actual provider compliance.","Primary source and pinpoint":"S001, §533A.2(5), p.3/index 2. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High for submission duty; “approval” limitation is a source-bound qualification."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C013","Precise assertion":"Ordinary Chapter 533A contemplates debtor signature but does not prescribe the same express date/signature/type rules as §533A.8A.","Primary source and pinpoint":"S001, §§533A.8(3)–(4), .11(3), .8A(4). \nIowa Legislature\n+2","Conditions, exceptions, currentness, and confidence":"High as textual distinction; ordinary signature enforceability in particular facts held."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C014","Precise assertion":"A contract to be signed by the debtor must be fully filled in and finished.","Primary source and pinpoint":"S001, §533A.11(3), p.12/index 11. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C015","Precise assertion":"Dual collection-agent/licensee operation requires prior written disclosure to debtor and creditor; debt challenge requires written debtor consent.","Primary source and pinpoint":"S001, §533A.11(2), (9). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; content/form of consent not prescribed."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C016","Precise assertion":"Compensation cannot be secured by promissory note, mortgage, wage assignment, lien, or other security.","Primary source and pinpoint":"S001, §533A.11(4), (12). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C017","Precise assertion":"An agreement restricting debtor-creditor communication is prohibited; educational-loan contact-impeding terms are void.","Primary source and pinpoint":"S001, §§533A.11(11), .8A(5)(d). \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C018","Precise assertion":"Fee must be agreed in advance, stated in the contract, and cancellation settlement clearly stated.","Primary source and pinpoint":"S001, §533A.9(1), p.9/index 8. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; earning/timing remains held."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C019","Precise assertion":"Noncustodial statutory methods use written notice to contract address; mailed notice is effective on proper deposit and stops future installments.","Primary source and pinpoint":"S001, §533A.9(4)(b)(1)–(2), p.10/index 9. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; email timing and refund ledger unresolved."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C020","Precise assertion":"Educational-loan requirements are additional and do not displace other applicable Chapter 533A duties.","Primary source and pinpoint":"S001, §533A.8A(1). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C021","Precise assertion":"Educational-loan compensation and payment requests are prohibited until full performance.","Primary source and pinpoint":"S001, §533A.8A(2), (5)(a). \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High; actual service completion unverified."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C022","Precise assertion":"Educational-loan debtor has unconditional three-business-day cancellation right following compliant execution, with mail/email/personal effectiveness rules.","Primary source and pinpoint":"S001, §533A.8A(3). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High; exact business-day calendar not calculated."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C023","Precise assertion":"Educational-loan contracts require clear language, full service detail, debtor date/signature, 10-point information, and specified 14-point bold notices/forms.","Primary source and pinpoint":"S001, §533A.8A(4). \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C024","Precise assertion":"Any Chapter 533A waiver by the debtor is void; inducing waiver is a violation.","Primary source and pinpoint":"S001, §533A.17, p.14/index 13. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C025","Precise assertion":"Iowa UETA recognizes electronic records/signatures only with other substantive law preserved and party agreement to electronic means.","Primary source and pinpoint":"S003, §§554D.104, .106, .108. \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C026","Precise assertion":"An electronic signature requires intent and must be attributable to the person; an unverified click or email is not automatically sufficient.","Primary source and pinpoint":"S003, §§554D.103(8), .111. \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High for standard; actual attribution fact-dependent."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C027","Precise assertion":"Required electronic written information must be retainable; statutory method, display, and formatting requirements remain applicable.","Primary source and pinpoint":"S003, §554D.110. \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C028","Precise assertion":"Electronic retention must accurately reflect the final record and remain accessible.","Primary source and pinpoint":"S003, §554D.114; S002, 20.9. \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High; five-year/36-month conflict preserved."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C029","Precise assertion":"No authoritative Iowa interpretation was found establishing how an electronic contract satisfies the educational-loan duplicate detachable-form requirement.","Primary source and pinpoint":"S001 §533A.8A(4); S003 §554D.110.","Conditions, exceptions, currentness, and confidence":"Bounded unresolved finding, not proof no interpretation exists."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C030","Precise assertion":"E-SIGN preserves substantive content/timing/proximity and contains consumer electronic-disclosure consent conditions; Iowa UETA relationship requires fact-specific analysis.","Primary source and pinpoint":"S004, 15 U.S.C. §§7001–7002. \nU.S. Code\n+1","Conditions, exceptions, currentness, and confidence":"High for federal text; complete applicability/preemption analysis held."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C031","Precise assertion":"No express Chapter 533A process was located for adding debts, materially amending the agreement, changing fee method, or assigning the consumer contract.","Primary source and pinpoint":"S001, §§533A.8(4), .8(7), .9(1), .11(3). \nIowa Legislature\n+3","Conditions, exceptions, currentness, and confidence":"Bounded statutory finding; general contract law and other regimes held."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C032","Precise assertion":"Surrender, suspension, or revocation does not impair a preexisting lawful contract, but no general provider-termination notice procedure was located.","Primary source and pinpoint":"S001, §533A.7(5)–(6). \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High for preservation clause; performance consequences unresolved."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C033","Precise assertion":"No ordinary universal three-business-day cooling-off period or email-upon-transmission rule was established outside §533A.8A.","Primary source and pinpoint":"S001, §§533A.8, .8A, .9. \nIowa Legislature\n+1","Conditions, exceptions, currentness, and confidence":"High as bounded textual comparison; agreed electronic notice remains fact-specific."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C034","Precise assertion":"Compiled Rule 20.9 requires the account file to contain the budget review, contract, and all required disclosures; electronic equivalents are permitted for records.","Primary source and pinpoint":"S002, 20.9(1), (5), printed p.3/index 70. \nIowa Legislature","Conditions, exceptions, currentness, and confidence":"High for October 14 compilation; later changes held."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C035","Precise assertion":"No current official public model agreement, separate disclosure, or educational-loan contract package was authenticated through the checked IDOB/NMLS routes.","Primary source and pinpoint":"S007 and bounded search record. \nNationwide Licensing System","Conditions, exceptions, currentness, and confidence":"Access limitation, not proof of nonexistence."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C036","Precise assertion":"Burroughs supports electronic records generally; Bruggeman supports ordinary email-based assent on its facts, but neither resolves Chapter 533A compliance.","Primary source and pinpoint":"S005–S006. \nIowa Courts\n+1","Conditions, exceptions, currentness, and confidence":"High as case-scope qualification."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C037","Precise assertion":"No actual provider contract, disclosure package, signature record, electronic-consent record, amendment, cancellation notice, or debtor file was verified.","Primary source and pinpoint":"Research limitation across S001–S007.","Conditions, exceptions, currentness, and confidence":"Confirmed limitation; no contract approval follows."},"coordinator_verification_status":"scoped_review_complete_with_stated_holds_and_case_qualification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IA-P6-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IA-P6-C038","Precise assertion":"Iowa full-remittance settlement completion and conditional federal first-customer-payment timing remain distinct; neither is transformed into a universal contract clause by this pass.","Primary source and pinpoint":"Preserved P2 finding; S001 §§533A.8(4), .9.","Conditions, exceptions, currentness, and confidence":"Prior finding preserved; no federal overview or fee reanalysis."},"coordinator_verification_status":"preserve_actual_C038_proposition_add_C039_for_consent_crosslink","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_IA-P6-S001","urls":["https://www.legis.iowa.gov/docs/code/2026/533A.pdf","https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf"],"researcher_record":{"Source ID":"S_IA-P6-S001","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 533A — Debt Management. Version-locked: https://www.legis.iowa.gov/docs/code/2026/533A.pdf Dynamic: https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf","Exact clause / printed page and zero-based PDF index":"Definitions and exemptions, printed pp.1–3/PDF indices 0–2; §533A.2(5), p.3/index 2; §533A.7(5)–(6), p.5/index 4; §533A.8(1)–(4), pp.5–6/indices 4–5; §533A.8(5)–(7), pp.6–7/indices 5–6; §533A.8A, pp.7–9/indices 6–8; §533A.9, pp.9–10/indices 8–9; §533A.11, pp.12–13/indices 11–12; §533A.17, p.14/index 13.","Version and legal status":"Official 2026 Code chapter; both routes displayed the December 9, 2025 footer and same visible chapter text. No byte-identity assertion.","Access status and limitations":"Freshly read/re-read all agreement-relevant paragraphs. Same underlying authority used in P1; no duplicative-source claim. No complete post-compilation enactment audit. \nIowa Legislature\n+1"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S002","urls":["https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187","https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf"],"researcher_record":{"Source ID":"S_IA-P6-S002","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Administrative Code, Banking Division [187]. Index: https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187 Agency PDF: https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf","Exact clause / printed page and zero-based PDF index":"Official index dated October 14, 2026; Chapter 20 printed pp.1–5/PDF indices 68–72. Agreement use: 20.9(1), (2), and (5), printed p.3/PDF index 70; examination/discipline context on pp.4–5/indices 71–72.","Version and legal status":"Official October 14, 2026 agency compilation; Chapter 20 footer IAC 2/5/25 and source note ARC 4061C, IAB 10/10/18, effective 11/14/18.","Access status and limitations":"Complete Chapter 20 reading reused from prior reviewed work; exact account-file/electronic-record provisions freshly re-read. Entire 75-page agency PDF not comprehensively read. Original 2018 order, later-than-October-14 changes, and ARC 0368D disposition remain held. \nIowa Legislature\n+1"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S003","urls":["https://www.legis.iowa.gov/docs/code/2026/554D.pdf"],"researcher_record":{"Source ID":"S_IA-P6-S003","Title, issuer, and full literal URL":"Iowa Legislature, Iowa Code 2026, Chapter 554D — Electronic Transactions and Computer Agreements. https://www.legis.iowa.gov/docs/code/2026/554D.pdf","Exact clause / printed page and zero-based PDF index":"§§554D.103–.110, printed pp.1–4/PDF indices 0–3; §§554D.111–.114, pp.4–5/indices 3–4; §§554D.116–.117, pp.5–6/indices 4–5.","Version and legal status":"Official 2026 Code chapter; footer December 9, 2025.","Access status and limitations":"Fresh targeted read of all materially relevant UETA provisions. Not every governmental-record or computer-agreement provision was analyzed. \nIowa Legislature\n+4"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S004","urls":["https://uscode.house.gov/us/usc/119-118/t15/s7001/","https://uscode.house.gov/us/usc/119-118/t15/s7002/","https://uscode.house.gov/us/usc/119-118/t15/s7003/"],"researcher_record":{"Source ID":"S_IA-P6-S004","Title, issuer, and full literal URL":"U.S. House Office of the Law Revision Counsel, Electronic Signatures in Global and National Commerce Act. §7001: https://uscode.house.gov/us/usc/119-118/t15/s7001/ §7002: https://uscode.house.gov/us/usc/119-118/t15/s7002/ §7003: https://uscode.house.gov/us/usc/119-118/t15/s7003/","Exact clause / printed page and zero-based PDF index":"15 U.S.C. §§7001(a)–(f), 7002(a), and 7003(a)–(b).","Version and legal status":"Displayed text contains laws through Public Law 119-120, October 7, 2026.","Access status and limitations":"Fresh targeted read. Used only for electronic validity, consumer disclosure consent, retention/proximity, state UETA relationship, and exceptions. No complete interstate-commerce/preemption opinion. \nU.S. Code\n+2"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S005","urls":["https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion"],"researcher_record":{"Source ID":"S_IA-P6-S005","Title, issuer, and full literal URL":"Iowa Judicial Branch, Burroughs v. City of Davenport Zoning Board of Adjustment, No. 17-0752, Iowa Supreme Court. https://www.iowacourts.gov/courtcases/496/embed/SupremeCourtOpinion","Exact clause / printed page and zero-based PDF index":"Filed May 25, 2018; amended August 6, 2018. UETA discussion at printed opinion pp.16–17/PDF indices 15–16.","Version and legal status":"Final Iowa Supreme Court opinion in a zoning-filing dispute.","Access status and limitations":"Freshly read relevant holding. Not a Chapter 533A, consumer-contract, electronic-signature, or disclosure-form case. \nIowa Courts\n+1"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S006","urls":["https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion"],"researcher_record":{"Source ID":"S_IA-P6-S006","Title, issuer, and full literal URL":"Iowa Judicial Branch, Craig Bruggeman d/b/a Bruggeman Realty v. Narnus Property Management, LLC, No. 24-1486, Iowa Court of Appeals. https://www.iowacourts.gov/courtcases/24950/embed/CourtAppealsOpinion","Exact clause / printed page and zero-based PDF index":"Filed April 1, 2026. Formation and writing analysis at printed opinion pp.7–14/PDF indices 6–13.","Version and legal status":"Official Iowa Court of Appeals opinion concerning settlement formation.","Access status and limitations":"Freshly read relevant sections. Context only; not a Chapter 533A decision and cannot displace its statutory formalities. \nIowa Courts"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IA-P6-S007","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_License-New-App-Checklist.pdf"],"researcher_record":{"Source ID":"S_IA-P6-S007","Title, issuer, and full literal URL":"NMLS, Licensing Checklists, Requirements, and Fees — Checklist Compiler. https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx Attempted Iowa route: https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IA_Debt_Management_License-New-App-Checklist.pdf","Exact clause / printed page and zero-based PDF index":"Dynamic compiler returned no parsed Iowa rows. Attempted direct PDF route returned a non-retryable open failure.","Version and legal status":"Operational discovery routes, not substantive Iowa legal authority.","Access status and limitations":"Freshly attempted. No checklist contents authenticated, no account access attempted, and no conclusion drawn about requirements not visible in the public route. \nNationwide Licensing System"},"coordinator_verification_status":"see_exact_selected_read_and_case_access_limits_in_source_checks","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Program methodology explanation","researcher_record":{"Component":"Program methodology explanation","Status":"Answered","Claims":"C001","Exact missing evidence / next action":"Actual script, call recording, and comprehension evidence"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Comprehensive debt/budget review","researcher_record":{"Component":"Comprehensive debt/budget review","Status":"Answered","Claims":"C002","Exact missing evidence / next action":"Actual debtor-specific review"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Written thorough budget analysis","researcher_record":{"Component":"Written thorough budget analysis","Status":"Answered","Claims":"C003","Exact missing evidence / next action":"Actual analysis and suitability methodology"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Appropriateness decision","researcher_record":{"Component":"Appropriateness decision","Status":"Answered at statutory level","Claims":"C001–C003","Exact missing evidence / next action":"Provider criteria and debtor facts"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Universal oral disclosures","researcher_record":{"Component":"Universal oral disclosures","Status":"Answered","Claims":"C004–C006","Exact missing evidence / next action":"Actual recordings or contemporaneous evidence"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Separate written disclosures","researcher_record":{"Component":"Separate written disclosures","Status":"Answered","Claims":"C004–C008","Exact missing evidence / next action":"Actual document and delivery record"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Third-party marketer disclosure duty","researcher_record":{"Component":"Third-party marketer disclosure duty","Status":"Answered","Claims":"C004, C008","Exact missing evidence / next action":"Actual marketer relationship and conduct"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary readability standard","researcher_record":{"Component":"Ordinary readability standard","Status":"Answered generally","Claims":"C005","Exact missing evidence / next action":"No specific ordinary type size or translation rule located"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Language/translation requirement","researcher_record":{"Component":"Language/translation requirement","Status":"Unresolved beyond comprehension standard","Claims":"C005","Exact missing evidence / next action":"Other state/federal language-access authority or formal interpretation"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-settlement risk disclosures","researcher_record":{"Component":"Debt-settlement risk disclosures","Status":"Answered","Claims":"C007","Exact missing evidence / next action":"Actual applicable program and wording"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial risk disclosures","researcher_record":{"Component":"Noncustodial risk disclosures","Status":"Answered","Claims":"C007","Exact missing evidence / next action":"Actual custody model remains fact-dependent"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Tax-consequence disclosure","researcher_record":{"Component":"Tax-consequence disclosure","Status":"Answered conditionally","Claims":"C007","Exact missing evidence / next action":"Applies when principal concessions are sought"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Written ordinary contract","researcher_record":{"Component":"Written ordinary contract","Status":"Answered","Claims":"C009","Exact missing evidence / next action":"Actual final contract"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"True-copy timing","researcher_record":{"Component":"True-copy timing","Status":"Answered","Claims":"C009, C027","Exact missing evidence / next action":"Actual delivery and retainability"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary maximum term","researcher_record":{"Component":"Ordinary maximum term","Status":"Answered","Claims":"C009","Exact missing evidence / next action":"Actual dates"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary mandatory clauses","researcher_record":{"Component":"Ordinary mandatory clauses","Status":"Answered","Claims":"C010","Exact missing evidence / next action":"Actual text"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-settlement debt list","researcher_record":{"Component":"Debt-settlement debt list","Status":"Answered","Claims":"C011","Exact missing evidence / next action":"Actual creditor schedule and identifiers"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Estimated settlement funding","researcher_record":{"Component":"Estimated settlement funding","Status":"Answered","Claims":"C011","Exact missing evidence / next action":"Actual calculation and disclosure"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial creditor list","researcher_record":{"Component":"Custodial creditor list","Status":"Answered","Claims":"C011","Exact missing evidence / next action":"Actual model and creditor list"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor-consent event","researcher_record":{"Component":"Creditor-consent event","Status":"Preserved conditional boundary","Claims":"C038","Exact missing evidence / next action":"Actual consent/distribution evidence; fee pass remains controlling"},"coordinator_acceptance":"consent_crosslink_and_E03_revision_pending","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement-completion event","researcher_record":{"Component":"Settlement-completion event","Status":"Preserved; not re-researched","Claims":"C038","Exact missing evidence / next action":"Actual full-remittance record"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal first-payment condition","researcher_record":{"Component":"Federal first-payment condition","Status":"Preserved; federal facts held","Claims":"C038","Exact missing evidence / next action":"TSR coverage, call facts, valid agreement, payment evidence"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary debtor signature","researcher_record":{"Component":"Ordinary debtor signature","Status":"Partial","Claims":"C013–C014","Exact missing evidence / next action":"Controlling interpretation and actual formation record"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider signature","researcher_record":{"Component":"Provider signature","Status":"Unresolved/not expressly prescribed","Claims":"C013","Exact missing evidence / next action":"Contract language, general law, or agency interpretation"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary contract date","researcher_record":{"Component":"Ordinary contract date","Status":"Partial","Claims":"C010, C013","Exact missing evidence / next action":"Beginning/expiration required; execution-date formality not separately prescribed"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Contract completeness/no blanks","researcher_record":{"Component":"Contract completeness/no blanks","Status":"Answered","Claims":"C014","Exact missing evidence / next action":"Actual executed version"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Signed acknowledgment of disclosures","researcher_record":{"Component":"Signed acknowledgment of disclosures","Status":"Not expressly required; evidence still necessary","Claims":"C004, C034","Exact missing evidence / next action":"Actual acknowledgment and delivery proof"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agent dual-role disclosure","researcher_record":{"Component":"Collection-agent dual-role disclosure","Status":"Answered","Claims":"C015","Exact missing evidence / next action":"Actual roles and written notices"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Written consent to challenge debt","researcher_record":{"Component":"Written consent to challenge debt","Status":"Answered","Claims":"C015","Exact missing evidence / next action":"Actual specific consent"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"General cancellation clause","researcher_record":{"Component":"General cancellation clause","Status":"Answered","Claims":"C018","Exact missing evidence / next action":"Actual text and fee treatment"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary cancellation notice method","researcher_record":{"Component":"Ordinary cancellation notice method","Status":"Partial/model-specific","Claims":"C019, C033","Exact missing evidence / next action":"Contract terms and UETA facts"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary mailed-notice effectiveness","researcher_record":{"Component":"Ordinary mailed-notice effectiveness","Status":"Answered for statutory noncustodial methods","Claims":"C019","Exact missing evidence / next action":"Actual deposit/address/postage"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary email notice effectiveness","researcher_record":{"Component":"Ordinary email notice effectiveness","Status":"Unresolved","Claims":"C019, C033","Exact missing evidence / next action":"Contract, electronic-consent, send/receipt facts, authoritative interpretation"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary return deadline","researcher_record":{"Component":"Ordinary return deadline","Status":"Excluded/held","Claims":"—","Exact missing evidence / next action":"P4 review or later funds pass"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary cancellation refund amount","researcher_record":{"Component":"Ordinary cancellation refund amount","Status":"Excluded/preserved","Claims":"—","Exact missing evidence / next action":"P1 fee method, actual ledger, lawful timing"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational-loan overlay","researcher_record":{"Component":"Educational-loan overlay","Status":"Answered","Claims":"C020–C023","Exact missing evidence / next action":"Actual business model and contract"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational full-performance payment bar","researcher_record":{"Component":"Educational full-performance payment bar","Status":"Answered","Claims":"C021","Exact missing evidence / next action":"Actual representations and completed services"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational three-business-day right","researcher_record":{"Component":"Educational three-business-day right","Status":"Answered","Claims":"C022","Exact missing evidence / next action":"Exact signing event and applicable counting facts"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Business-day calendar calculation","researcher_record":{"Component":"Business-day calendar calculation","Status":"Unresolved","Claims":"C022","Exact missing evidence / next action":"Applicable counting/holiday authority and execution date"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational email cancellation","researcher_record":{"Component":"Educational email cancellation","Status":"Answered","Claims":"C022","Exact missing evidence / next action":"Actual transmission record"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Educational contract type size/position","researcher_record":{"Component":"Educational contract type size/position","Status":"Answered","Claims":"C023","Exact missing evidence / next action":"Actual rendered document"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic duplicate detachable forms","researcher_record":{"Component":"Electronic duplicate detachable forms","Status":"Unresolved","Claims":"C029","Exact missing evidence / next action":"Iowa agency/court interpretation and actual interface"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic signatures generally","researcher_record":{"Component":"Electronic signatures generally","Status":"Answered conditionally","Claims":"C025–C027","Exact missing evidence / next action":"Consent, intent, attribution, retainability"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Clickwrap validity","researcher_record":{"Component":"Clickwrap validity","Status":"Partial","Claims":"C025–C027","Exact missing evidence / next action":"Actual screens, logs, authentication, correction opportunity"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Portal-only copy","researcher_record":{"Component":"Portal-only copy","Status":"Partial","Claims":"C027","Exact missing evidence / next action":"Ability to print/store and final-version evidence"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic separate-document requirement","researcher_record":{"Component":"Electronic separate-document requirement","Status":"Answered conceptually","Claims":"C005, C027","Exact missing evidence / next action":"Actual interface and document architecture"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal E-SIGN consumer consent","researcher_record":{"Component":"Federal E-SIGN consumer consent","Status":"Partial","Claims":"C030","Exact missing evidence / next action":"Interstate-commerce facts, state-law interaction, records covered"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic record retention","researcher_record":{"Component":"Electronic record retention","Status":"Answered at general level","Claims":"C028, C034","Exact missing evidence / next action":"Actual repository, access, accuracy, and full retention period"},"coordinator_acceptance":"scoped_review_complete_with_holds_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":"C028, C034","Exact missing evidence / next action":"Authoritative reconciliation; no shortened retention inferred"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Material amendment process","researcher_record":{"Component":"Material amendment process","Status":"Unresolved","Claims":"C031","Exact missing evidence / next action":"Contract, new disclosures, assent, agency interpretation"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Adding debts","researcher_record":{"Component":"Adding debts","Status":"Partial boundary established","Claims":"C011, C014, C031","Exact missing evidence / next action":"Compliant amendment/new-enrollment method"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Fee change","researcher_record":{"Component":"Fee change","Status":"Partial","Claims":"C018, C031","Exact missing evidence / next action":"Advance agreement and complete applicable fee analysis"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Change from one fee method to another","researcher_record":{"Component":"Change from one fee method to another","Status":"Unresolved","Claims":"C031","Exact missing evidence / next action":"Statutory/agency interpretation and actual contract"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Contract extension","researcher_record":{"Component":"Contract extension","Status":"Partial","Claims":"C031","Exact missing evidence / next action":"Extension form and repeated disclosures"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer-contract assignment","researcher_record":{"Component":"Consumer-contract assignment","Status":"Unresolved","Claims":"C031","Exact missing evidence / next action":"General assignment law, licensure, consent, privacy"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"License assignment","researcher_record":{"Component":"License assignment","Status":"Answered outside consumer-contract issue","Claims":"S001 §533A.3(5)","Exact missing evidence / next action":"Does not resolve contract assignment"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider termination right/notice","researcher_record":{"Component":"Provider termination right/notice","Status":"Unresolved","Claims":"C032","Exact missing evidence / next action":"Contract and controlling authority"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"License surrender effect","researcher_record":{"Component":"License surrender effect","Status":"Answered narrowly","Claims":"C032","Exact missing evidence / next action":"Performance and remedy consequences later"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Waiver of Chapter 533A","researcher_record":{"Component":"Waiver of Chapter 533A","Status":"Answered","Claims":"C024","Exact missing evidence / next action":"Actual clause"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Communication-limiting POA","researcher_record":{"Component":"Communication-limiting POA","Status":"Answered","Claims":"C017","Exact missing evidence / next action":"Actual agreement"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Compensation security terms","researcher_record":{"Component":"Compensation security terms","Status":"Answered","Claims":"C016","Exact missing evidence / next action":"Actual agreement"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Arbitration/class waiver/forum clause","researcher_record":{"Component":"Arbitration/class waiver/forum clause","Status":"Unresolved except nonwaiver boundary","Claims":"C024","Exact missing evidence / next action":"Full contract, FAA/Iowa enforceability, remedies pass"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Complaint instructions in contract","researcher_record":{"Component":"Complaint instructions in contract","Status":"No mandatory clause located","Claims":"Matrix §2.5","Exact missing evidence / next action":"Other official forms or interpretations"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"NMLS/license number in contract","researcher_record":{"Component":"NMLS/license number in contract","Status":"No mandatory clause located","Claims":"Matrix §2.5","Exact missing evidence / next action":"Current official checklist/form"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Surety/bond identity in contract","researcher_record":{"Component":"Surety/bond identity in contract","Status":"No mandatory clause located; P5 unreviewed","Claims":"Matrix §2.5","Exact missing evidence / next action":"P5 review/current official contract form"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Administrator/bank identity","researcher_record":{"Component":"Administrator/bank identity","Status":"No universal clause located; P4 unreviewed","Claims":"Matrix §2.5","Exact missing evidence / next action":"P4 review and actual account arrangement"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Privacy notice","researcher_record":{"Component":"Privacy notice","Status":"Not resolved under other law","Claims":"Matrix §2.5","Exact missing evidence / next action":"Federal/state privacy regimes"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current official model contract","researcher_record":{"Component":"Current official model contract","Status":"Unresolved/not recovered","Claims":"C035","Exact missing evidence / next action":"Public authenticated IDOB/NMLS form"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current official separate disclosure form","researcher_record":{"Component":"Current official separate disclosure form","Status":"Unresolved/not recovered","Claims":"C035","Exact missing evidence / next action":"Public authenticated IDOB/NMLS form"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current NMLS Iowa checklist","researcher_record":{"Component":"Current NMLS Iowa checklist","Status":"Unresolved","Claims":"C035","Exact missing evidence / next action":"Working public checklist route or authenticated copy"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Formal Iowa agreement interpretation","researcher_record":{"Component":"Formal Iowa agreement interpretation","Status":"Unresolved after bounded search","Claims":"C029, C035–C036","Exact missing evidence / next action":"Archived agency orders, cases, or formal guidance"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Exact Chapter 533A appellate case","researcher_record":{"Component":"Exact Chapter 533A appellate case","Status":"Not located in bounded search","Claims":"C036","Exact missing evidence / next action":"Broader paid/legal database or court-record review"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Actual provider contract compliance","researcher_record":{"Component":"Actual provider contract compliance","Status":"Unresolved","Claims":"C037","Exact missing evidence / next action":"Provider contract, disclosures, scripts, logs, records"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider exemption","researcher_record":{"Component":"Provider exemption","Status":"Preserved hold","Claims":"—","Exact missing evidence / next action":"Entity/activity evidence"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"CROA/TSR credit-repair overlap","researcher_record":{"Component":"CROA/TSR credit-repair overlap","Status":"Excluded/preserved","Claims":"—","Exact missing evidence / next action":"Separate federal applicability pass"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Fee earning and arithmetic","researcher_record":{"Component":"Fee earning and arithmetic","Status":"Excluded/preserved","Claims":"—","Exact missing evidence / next action":"P1/P2 and later interpretation"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Funds, trust, and return mechanics","researcher_record":{"Component":"Funds, trust, and return mechanics","Status":"Excluded; P4 unreviewed","Claims":"—","Exact missing evidence / next action":"P4 review"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond/security","researcher_record":{"Component":"Bond/security","Status":"Excluded; P5 unreviewed","Claims":"—","Exact missing evidence / next action":"P5 review"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"General UTPA, tort, remedies, litigation, limitations","researcher_record":{"Component":"General UTPA, tort, remedies, litigation, limitations","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate pass"},"coordinator_acceptance":"scoped_review_complete_with_holds_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_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Local, tribal, country, and sector-specific law","researcher_record":{"Component":"Local, tribal, country, and sector-specific law","Status":"Excluded","Claims":"—","Exact missing evidence / next action":"Separate passes"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Complete post-compilation statutory audit","researcher_record":{"Component":"Complete post-compilation statutory audit","Status":"Unresolved","Claims":"—","Exact missing evidence / next action":"Iowa session-law audit"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Post-October-14 rule changes","researcher_record":{"Component":"Post-October-14 rule changes","Status":"Unresolved","Claims":"—","Exact missing evidence / next action":"Later official compilation/adoption audit"},"coordinator_acceptance":"scoped_review_complete_with_holds_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":"—","Exact missing evidence / next action":"Separate defined currentness task"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Component/state/parent/A066/operations acceptance","researcher_record":{"Component":"Component/state/parent/A066/operations acceptance","Status":"Unresolved","Claims":"C037","Exact missing evidence / next action":"Entire dossier and all remaining dimensions"},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T17:17:03.509467+00:00","status":"bounded_requested_repairs_addressed_with_holds","review":"[internal evidence reference]","raw_originals_unchanged":true,"material_corrections":[{"id":"IA6-E03-branches","kind":"material example premise","affected":["E03","2.3 custodial creditor-consent boundary"],"finding":"Do not add2consentsand1separateaccepteddistribution into automaticallyqualifying3of6 without exact authority allowing mixed aggregation or evidence accepted distribution establishes consent. Scalar math passes; legal qualifying premise remains unsupported. Replace with distinct three-consent and three-accepted-distribution branches, preserving original mixed case as unresolved/no fee permission."},{"id":"IA6-coverage-C038","kind":"atomic claim traceability","affected":["Creditor-consent event coverage → C038"],"finding":"C038 asserts full-remittance settlement completion and TSRfirst-customer-payment, not creditor-count alternative. PreserveC038 and add distinct S_IA-P6-C039 for precise533A.8(5)(d)text/all qualifications. Link original consent coverage and corrected E03 to C039."},{"id":"IA6-Bruggeman-qualification","kind":"case/source-use qualification","affected":["S006","C036","section5.4","E08"],"finding":"Keep narrow fact-specific Greermajority only; add Bullerdissent17–18/summaryjudgment distinction, extend exactformationpinpointthroughprinted15/PDF14. Do not promote websiteDatePublished to verifiedprecedential publication. Exactname absent displayedselectivepublicationlist, laterdesignationheld; if treatedunpublished apply official6.904(2)(a)(2)persuasive-only/docket/database/copy rule within datedcompilationbounds."}],"correction_pass":"pass-10","no_component_acceptance":true,"correction_reviewed_at":"2026-10-27T17:50:31.151554+00:00","correction_review":"[internal evidence reference]","correction_notice":"[internal evidence reference]","issue_dispositions":[{"issue":"E03mixed-branch legal premise","status":"ADDRESSED within bounded correction","basis":"Original6/2/1inputs and true2+1/3÷6scalars preserved; mixedcaseunresolved/noautomaticqualification. Distinct3consent and3accepted-distribution alternatives require distinctcreditors; no categoricalmixed-setban orfeepermission."},{"issue":"C039atomicclaim/coverage/matrix","status":"ADDRESSED","basis":"ONEnewS_IA-P6-C039 includesreceivingmodel/otherlicensee/initiationexception/debtornotice. PreserveC038distinctfullremittance/TSRfirstpayment. ReplaceonlyCreditor-consentevent crosslink plusaffectedmatrixcells."},{"issue":"Bruggeman use and sourcequalification","status":"ADDRESSED within retained publication/currentness holds","basis":"Greermajorityformation7–15/indices6–14;result16/index15;Bullerdissent17–18/indices16–17 notholding. Officialsummarymetadata notprecedentialdesignation; selectivepublishedlisttopJuly9/nomatchingtext notfullcitator. Rule69042a2conditionalpersuasive/docket/database/copy; Burroughsnotfreshlyreread; neither533Aexception."}]},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_IA-P6-creditor-count-premise-and-atomic-crosslink-20261027","status":"requested_bounded_repairs_addressed_with_retained_holds","at":"2026-10-27T17:17:03.509467+00:00"}]}