{"meta":{"key":"s_id--pass-04","task":"S_ID","title":"SID Idaho customer funds and trust accounts","parent_title":"Idaho debt and debt relief law","edition":"pass-04","path":"/research/s_id--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":30,"sources":21,"review_status":"scoped_review_complete_accepted_with_limits","review_complete":true,"sha256":"8c4f93910f4fb4fcaa96b0d74fce7c437e02751cb374ae92ccedb1264ad26ae1","headings":["Current-source limitation","1. Which models Idaho’s account and funds provisions reach","1.1 Section 26-2233 uses an actual-custody trigger","1.2 The provisions do not all have the same actor scope","1.3 Exact exemptions still matter","2. Idaho account structure, records, remittance, and movement of funds","2.1 Account title, institution, and segregation","2.2 What the text does not establish","2.3 Recordkeeping and regulator access","2.4 Remittance timing","2.5 Deduction or transfer of provider compensation","2.6 Payment-processing and administrator charges","3. Affiliate receipt, independent administrators, and account control","3.1 Provider-maintained accounts","3.2 Genuinely independent third-party account","3.3 Affiliate or controlled administrator","3.4 Facts required to classify a concrete account","4. Cancellation, termination, and closure of held money","4.1 Ordinary debtor cancellation","4.2 Collection-agency closure","4.3 Property right in assigned collection accounts","5. Idaho accounts versus the federal TSR dedicated-account option","5.1 The two structures are not interchangeable","Example 1 — Collection agency receipt, commission, and creditor remittance","Example 2 — Custodial debt counselor with no proven earned fee","Conditional branch","Example 3 — Covered federal dedicated account after service withdrawal","Example 4 — Affiliate-controlled “external” account","Example 5 — Collection-agency closure","Freshly read in PASS-04","Failed public routes","Reused without false fresh-read claims","Not established"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_ID/pass-04","facets":{"geography":["us","us-id"],"debt_type":[],"stage":[],"subject":["client-money","limitations-revival"]},"scope":"Reviewedremaining Idaho funds/trustaccount component from exactP1coveragegap; C033/C035currentofficialtext/checklists and allfee/broaderholds preserved.","pending_corrections":0},"markdown":"# S_ID PASS-04 — Idaho customer funds and trust accounts\n\n**Actual fresh public-source access date:** October 25, 2026, Pacific time, America/Los_Angeles.\n\n**Review character:** Same-coordinator bounded Idaho component, not independent review.\n\n**Preservation rule:** All P1/P2/P3 raw findings, source tables, claims, fee formulas, refund analysis, and seven worked examples remain preserved. This pass does not reopen C033 or C035, rerun provider-access or fee ceilings, query a named provider, or complete the broader contracts, bonds, remedies, collection, litigation, limitations, garnishment, secured-debt, sector, local, or tribal work.\n\n## Current-source limitation\n\nThe Idaho Department of Finance’s current statutes page identifies §§ 26-2233 and 26-2234 as operative ICAA provisions and links to the Legislature. One bounded fresh attempt to each official section route failed with an internal-access error. Accordingly, the substantive Idaho statutory findings below are based on **complete 2025 secondary reproductions**, supported where available by official agency forms, historical enforcement materials, and official rule-status records. They are not relabeled as authenticated official 2026 section text, and no absence of a 2026 amendment is inferred from the failed routes. C035 remains open for these additional sections. [Department of Finance+1](https://www.finance.idaho.gov/legal/statutes-and-rules/)\n\n# A. Substantive findings\n\n## 1. Which models Idaho’s account and funds provisions reach\n\n### 1.1 Section 26-2233 uses an actual-custody trigger\n\nThe accessible text of § 26-2233(1) applies to **every ICAA licensee that receives or holds money belonging to another in connection with ICAA-authorized business**. Such a licensee must establish the required trust account. The trigger is therefore actual receipt or holding of another person’s funds, not the provider’s label. [S_ID-P4-C002; S_ID-P4-S004 §26-2233(1)]\n\nThe provision conditionally reaches:\n\n- A collection agency receiving debtor payments that are due to creditor clients.\n- A debt counselor or credit counselor receiving debtor money for payment or proration to creditors.\n- A debt-settlement provider that falls within the debt-counselor classification and itself receives or holds customer money.\n- A credit-repair organization only when, in addition to satisfying the still-conditional P2 classification, it receives or holds money belonging to another rather than merely receiving a fully earned fee belonging to the provider.\n- Any other licensed ICAA model whose actual money flow satisfies the receipt-or-holding condition.\n\nA genuinely noncustodial provider that receives only its own properly earned business revenue and never receives or holds consumer or creditor money is not shown, on those stipulated facts, to trigger § 26-2233(1). It remains subject to § 26-2233(2)’s separate business-account rule if it is an ICAA licensee. [Justia Law+1](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/)\n\nThis model mapping remains conditional on P1/P2’s classification findings. The official current text of the relevant actor definitions is still unresolved under C035, and no named entity is approved.\n\n### 1.2 The provisions do not all have the same actor scope\n\n| Provision | Actor and conduct reached by the accessible text | Important limitation |\n| --- | --- | --- |\n| **§ 26-2233(1)** | Every **licensee** that receives or holds funds belonging to another in ICAA business | Text says “licensee”; it does not itself supply an independent-provider or affiliate-account safe harbor. |\n| **§ 26-2233(2)** | Every ICAA **licensee**, whether custodial or noncustodial | Requires a separate business account for business funds. |\n| **§ 26-2234(1), (2), (6)** | Every licensee, for examinations, investigations, and GAAP-compliant records | General compliance and access provisions. |\n| **§ 26-2234(4), (5)** | Specifically every **collection agency licensee** | Detailed account records, three-year retention, monthly creditor remittance, and statements do not automatically extend to every debt counselor. |\n| **§ 26-2234(7)** | A licensee **or person required to be licensed** that receives, holds, or disburses **consumer funds** | Its express “consumer funds” object is narrower than § 26-2233’s general “funds belonging to another.” |\n| **§ 26-2229A(7)** | A person licensed or required to be licensed holding another’s funds in ICAA business | Prohibits conversion-type conduct; does not itself identify a lawful fee-earning trigger. |\n| **§ 26-2246** | A **collection agency licensee** closing or discontinuing operations | It is not a general closure statute for every debt-settlement or credit-repair model. |\n\n### 1.3 Exact exemptions still matter\n\nIf a person falls within an exact § 26-2239 exemption and acts only within the exempt capacity, the ICAA provisions do not apply by their own terms. Relevant examples include authorized banks, trust companies, credit unions, authorized escrow businesses acting in that business, regulated lenders and their affiliates or agents acting within the statutory limits, and attorneys whose covered activity is incidental to an Idaho legal practice rather than a separate covered business.\n\nThat does **not** establish that the person may hold money free of all regulation. Banking, escrow, attorney-trust, money-transmission, bankruptcy, or other regimes may separately govern the account. No such alternative regime was investigated here. [S_ID-P4-C016; S_ID-P4-S010 §26-2239] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/)\n\n## 2. Idaho account structure, records, remittance, and movement of funds\n\n### 2.1 Account title, institution, and segregation\n\nUnder the accessible § 26-2233 text, a custodial licensee must:\n\n1. Establish the trust account **in the licensee’s own name**.\n2. Keep it as a **separate trust account** for deposit and remittance of money belonging to another.\n3. Use a financial institution whose deposits are insured by the **Federal Deposit Insurance Corporation**.\n4. Maintain a separate business account for the licensee’s own business funds and money.\n5. Refrain from directly or indirectly misappropriating, misapplying, or borrowing trust money.\n\n[S_ID-P4-C003–C005; S_ID-P4-S004 §26-2233(1)–(2)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/)\n\nThis creates at least a two-account structure:\n\n- **Trust account:** another person’s money.\n- **Business account:** money belonging or due to the provider.\n\nThe phrase “in its own name” addresses the account’s required title or caption. It does not convert the underlying trust money into the provider’s property; the same sentence describes it as money belonging to another. Conversely, the statute does not say the account must be titled in the individual consumer’s name.\n\n### 2.2 What the text does not establish\n\nThe provisions actually read do **not expressly establish**:\n\n- That the financial institution must be located in Idaho.\n- A separate bank account for each debtor or creditor.\n- Whether multiple customers’ trust money may be pooled subject to subledger accounting.\n- An express interest-allocation rule for an Idaho provider-titled trust account.\n- A bank setoff waiver.\n- Bankruptcy-estate exclusion or priority.\n- Protection against garnishment or attachment.\n- A perfected security interest.\n- A transaction-level signatory or dual-signature requirement.\n- Who may initiate an ACH debit or creditor payment.\n- A general consumer right to withdraw any selected amount from the bank account on demand.\n- A statutory fee for an independent account administrator.\n\nThose issues remain unresolved rather than being inferred from the words “trust account.” [S_ID-P4-C015, C026–C027]\n\n### 2.3 Recordkeeping and regulator access\n\nThe accessible § 26-2234 text gives the director access during normal business hours to offices, books, creditor accounts, trust accounts, business accounts, records, files, safes, and vaults used in ICAA operations. Investigations may occur inside or outside Idaho. Every licensee must maintain books and financial records under generally accepted accounting principles in a form sufficient for the director to determine compliance. [S_ID-P4-C007–C008; S_ID-P4-S005 §26-2234(1), (2), (6)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/)\n\nA collection agency has additional obligations:\n\n- Written acknowledgment of each account received for collection.\n- A record of each such account.\n- A permanent record of sums collected and all disbursements.\n- Preservation of records concerning accounts, receipts, money collected, and the disposal or disbursement of creditor funds for three years after final disposition.\n- No intentional false entry, necessary-entry omission, concealment, destruction, or improper disposal before the retention period ends.\n\n[S_ID-P4-C009; S_ID-P4-S005 §26-2234(4)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/)\n\nAn official 2017 multistate settlement involving iQor required complete and accurate trust-account records, regular reconciliation of each trust account, timely clearing of reconciliation adjustments, monitoring of outstanding trust checks, and regulator access. That agreement is useful evidence of historical enforcement expectations, but it was negotiated, involved no admission, and is not a generally binding Idaho judicial interpretation. [S_ID-P4-C019; S_ID-P4-S018 printed pp. 4, 8–9] [Department of Finance+2](https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf)\n\n### 2.4 Remittance timing\n\n#### Collection agency creditor funds\n\nEvery collection agency licensee must, within 30 days after the end of each calendar month:\n\n- Remit to creditor clients all money due from collections made during that month.\n- Provide each creditor client a written statement of money collected and payments made.\n\nThis is a calendar-month settlement rule, not “30 days after each individual payment.” [S_ID-P4-C010; S_ID-P4-S005 §26-2234(5)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/)\n\n#### Debt counselor, credit counselor, and debt-settlement funds\n\nNo parallel, exact Idaho remittance deadline for a custodial debt counselor or debt-settlement provider was located in §§ 26-2233 and 26-2234. Section 26-2233 identifies the account’s deposit-and-remittance purpose, but does not state a number of days for disbursing debtor money to a creditor or returning it upon ordinary termination.\n\nThe 30-day collection-agency rule should therefore not be silently imported into a debtor-side settlement model. Contract terms, other state provisions, an order, and—when independently applicable—the federal TSR may supply additional timing. [S_ID-P4-C010, C023]\n\n### 2.5 Deduction or transfer of provider compensation\n\nA provider may not turn trust money into business money merely by labeling a debit a “fee.” Before transfer to the business account, compensation must be independently:\n\n- Permitted under the applicable Idaho fee provision.\n- Authorized by the governing agreement where required.\n- Actually earned under the relevant service-performance rule.\n- Timely under any independently applicable federal rule.\n- Properly allocated to the debt or service involved.\n- Supported by the trust ledger and business records.\n\nThe P1 fee ceilings are ceilings, not fee-earning events, and remain unchanged.\n\nFor collection agencies, the accessible § 26-2229 text permits only regular collection fees or commissions authorized under the Act and the written creditor-client contract, with its own percentage restrictions. That collection-agency rule is not a debtor-side debt-settlement fee rule. [S_ID-P4-C013; S_ID-P4-S007 §26-2229(1)–(2)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/)\n\nSection 26-2229A(7) separately prohibits a licensed or required person from misappropriating, transferring, or converting to its own use money belonging to or held for another. Section 26-2238’s accessible text exposes failure to maintain the required trust account, failure to disburse as required, or conversion-type conduct to criminal consequences upon conviction. This pass does not perform a full criminal-elements or remedies analysis. [S_ID-P4-C005, C012; S_ID-P4-S008 §26-2229A(7); S_ID-P4-S009 §26-2238(1)] [Justia Law+1](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/)\n\n### 2.6 Payment-processing and administrator charges\n\nSection 26-2229A(4)(f) supplies a narrow collection-agency rule for a charge reasonably related to the actual cost of processing a demand draft or other electronic debt payment, provided:\n\n- The debtor preauthorized the payment method.\n- The debtor received advance notice of a reasonable alternative method that would not generate an additional charge.\n\nIt does not establish:\n\n- A general dedicated-account administrator fee.\n- A percentage-of-balance administration charge.\n- A right to debit a trust account.\n- A debt-settlement provider’s fee.\n- That the administrator is unlicensed or exempt.\n- That any amount above actual processing cost is permissible.\n\n[S_ID-P4-C014; S_ID-P4-S008 §26-2229A(4)(f)] [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/)\n\n## 3. Affiliate receipt, independent administrators, and account control\n\n### 3.1 Provider-maintained accounts\n\nAn official 2010 consent order concerning Christian Debt Consolidation described a debt-settlement provider that electronically debited customers and deposited the money into a trust account maintained by the provider, from which the provider also deducted fees. The order required an accounting and later return of specified fees and unapplied trust money.\n\nThat is useful fact-specific evidence that a provider-maintained settlement account was treated as provider custody; it is not a current general ruling on every account architecture. [S_ID-P4-C018; S_ID-P4-S017 printed pp. 2, 6] [Department of Finance+1](https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf)\n\n### 3.2 Genuinely independent third-party account\n\nUnder a stipulated arrangement in which:\n\n- The customer owns the account.\n- An independent financial institution or administrator holds the money.\n- The provider cannot initiate transfers, freeze the account, change recipients, or direct disbursements except through customer-authorized settlement instructions.\n- The provider and administrator have no ownership, control, affiliation, or referral compensation.\n- The provider never receives or holds the funds.\n\nSection 26-2233(1) is **not shown to be triggered for the provider** solely by the existence of that external account. But no reviewed Idaho primary source establishes a categorical independent-account safe harbor.\n\nThe administrator may itself require analysis under the debt-counselor payment/proration branch or another Idaho financial-services regime if it receives, holds, or disburses customer money. That classification remains unresolved because:\n\n- The controlling actor definitions remain subject to C035.\n- No Idaho order or controlling case deciding this precise administrator model was located.\n- The Idaho money-transmission and banking statutes were outside this pass.\n- The actual account and servicing contracts were not supplied.\n\n[S_ID-P4-C022, C025, C027]\n\n### 3.3 Affiliate or controlled administrator\n\nRouting money through an affiliate does not automatically show that the provider has avoided receipt, holding, or control. The state analysis requires the actual facts, including who can direct, debit, freeze, sweep, pledge, or redirect the money.\n\nWhere the federal TSR dedicated-account provision applies, the result is clearer: the administering entity may not be owned or controlled by, or affiliated in any way with, the debt-relief service. An affiliate-administered account therefore fails that federal condition even if the account’s marketing materials call it “independent.” [S_ID-P4-C022, C024, C026; S_ID-P4-S021 §310.4(a)(5)(ii)(C)] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 3.4 Facts required to classify a concrete account\n\nA concrete arrangement cannot be resolved from a product name or bank-logo screenshot. At minimum, the following evidence is required:\n\n| Necessary fact | Why it matters |\n| --- | --- |\n| Exact account title and named depositor | Tests Idaho’s “in its own name” provider-trust structure versus federal customer ownership. |\n| Beneficial owner of funds and interest | Expressly material under the TSR; relevant to state trust treatment. |\n| Bank and deposit-insurance status | Idaho text and the TSR both require an insured institution, though their account structures differ. |\n| Provider, administrator, and bank ownership structure | Tests federal affiliation and factual state control. |\n| Every person with debit, ACH, freeze, sweep, or beneficiary-change authority | Determines actual receipt, holding, administration, and control. |\n| Account agreement and servicing agreement | Identifies ownership, movement authority, fees, termination, setoff, and insolvency terms. |\n| Referral or revenue-sharing agreement | Material to the federal no-referral-compensation condition. |\n| Fee schedule and debit source | Tests whether the charge is provider compensation, account administration, payment processing, or an unverified deduction. |\n| Customer authorization and revocation mechanics | Needed to determine who can initiate creditor or provider payments. |\n| Transaction ledger and reconciliation reports | Shows the real money path rather than the marketed one. |\n| Administrator’s Idaho license or exact exemption theory | Necessary before treating it as legally authorized to receive and disburse funds. |\n\n[S_ID-P4-C027]\n\n## 4. Cancellation, termination, and closure of held money\n\n### 4.1 Ordinary debtor cancellation\n\nP1’s reviewed cancellation-refund formula remains unchanged. This pass did not find a separate Idaho rule in §§ 26-2233 or 26-2234 prescribing a general number of days in which every custodial debt-settlement provider must return ordinary uncommitted trust money after cancellation.\n\nThe Christian order’s requirement to refund specified money within 10 days after the Department received an accounting was a respondent-specific remedial term. It is not converted into a generally applicable ten-day Idaho rule. [S_ID-P4-C018; S_ID-P4-S017 printed p. 6] [Department of Finance](https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf)\n\n### 4.2 Collection-agency closure\n\nThe accessible § 26-2246 text requires a closing collection agency, within 30 days after closure or discontinuance, to furnish proof that:\n\n- All money collected for and due to creditor clients has been remitted.\n- Collection accounts and judgments have been returned or assigned to the proper parties.\n- Client or third-party papers and property have been returned.\n\nIf the agency does not complete those requirements, the director may demand possession of business records, bank accounts—including creditor-client trust accounts—third-party property, and assets, and may liquidate the business and return money and accounts. Liquidation expenses may be paid from controlled funds only to the extent those funds exceed sums due creditor clients or other proper parties. [S_ID-P4-C021; S_ID-P4-S012 §26-2246(1), (3), (5)] [Justia Law+1](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/)\n\nThis creates a closure-specific protection for creditor-client money. It does **not** establish Bankruptcy Code treatment, bank setoff priority, or a general insolvency rule for debt-settlement customer accounts.\n\n### 4.3 Property right in assigned collection accounts\n\nSection 26-2243’s accessible text gives a collection agency a property right in an account assigned for collection. Reading that provision with the trust and remittance sections, the better bounded interpretation is that the assigned-account property right does not itself make creditor-client proceeds the collection agency’s business funds. This is an inference from the statutory provisions, not a bankruptcy holding. [S_ID-P4-C029; S_ID-P4-S011 §26-2243; S004–S005]\n\n## 5. Idaho accounts versus the federal TSR dedicated-account option\n\nThe federal provision was freshly checked for this pass. The eCFR page states that Title 16 was current through October 22, 2026 and last amended October 19, 2026; eCFR describes itself as authoritative but unofficial. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nWhere the TSR debt-relief rule independently applies, money may be accumulated in a dedicated account only if:\n\n- The account is at an insured financial institution.\n- The customer owns the funds and receives any accrued interest.\n- The administrator is not owned or controlled by, and is not affiliated in any way with, the debt-relief service.\n- The administrator and debt-relief service do not give or accept compensation for referrals involving the service.\n- The customer may withdraw from the **debt-relief service** at any time without penalty.\n- Within seven business days after the customer’s request, the customer receives all account funds other than provider fees already earned in compliance with the TSR’s settlement, first-payment, and allocation conditions.\n\n[S_ID-P4-C022–C024; S_ID-P4-S021 §310.4(a)(5)(ii)(A)–(E)] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 5.1 The two structures are not interchangeable\n\n| Feature | Provisional Idaho § 26-2233 provider trust | Federal TSR dedicated-account option |\n| --- | --- | --- |\n| Account title/ownership | Account established **in licensee’s own name**; funds described as belonging to another | Customer expressly owns funds |\n| Administrator | Provider may be the account holder because the rule addresses provider custody | Administrator must be independent and unaffiliated |\n| Interest | No express allocation rule in § 26-2233 | Customer receives accrued interest, if any |\n| Referral compensation | Not addressed in § 26-2233 | Prohibited between administrator and service |\n| Withdrawal rule | No general cancellation-return deadline stated in §§ 26-2233–2234 | Customer may withdraw from the **service** without penalty; covered balance returned within seven business days |\n| Fee deduction | Requires independent Idaho fee authority and earning/timing support | Only fees earned under § 310.4(a)(5)(i)(A)–(C) may be withheld |\n| Legal effect | State custody/account rule | Conditional federal safe-harbor structure under the TSR |\n\nA provider-operated Idaho trust account is therefore not automatically a compliant federal dedicated account. Conversely, a federally compliant independent dedicated account does not automatically resolve the administrator’s Idaho classification, Idaho money-transmission treatment, or any state account-administration fee. [S_ID-P4-C024–C026]\n\nThe federal rule’s object is withdrawal from the **service**, not an unconditional federal right to close or make arbitrary withdrawals from the bank account itself. That distinction is preserved exactly. [S_ID-P4-C023]\n\n# B. Conduct and account-model matrix\n\n| Model | Money facts | Idaho account result, subject to current-text hold | Records and remittance | Fee movement | Unresolved point |\n| --- | --- | --- | --- | --- | --- |\n| **Collection agency receiving debtor payments** | Debtor money is received for creditor client | § 26-2233 trust account in licensee’s name; separate business account | Detailed account/disbursement records; three-year retention; creditor remittance and statement within 30 days after month-end | Only independently authorized and earned collection commission moves to business account | Bankruptcy, setoff, per-client subaccounts |\n| **Custodial DMP or credit counseling** | Provider receives debtor money for creditor payments | Trust account triggered if provider is a covered licensee | General GAAP records and regulator access; no exact debtor-side state remittance deadline found | Fee may move only when independently earned and payable under preserved P1/state/federal conditions | Exact disbursement deadline, cancellation-return deadline |\n| **Provider-maintained debt-settlement account** | Provider debits customer and maintains account | Strongly fits receipt/holding trigger if provider is covered; Christian order provides historical fact-specific support | General records and access | Fee deduction not lawful merely because contract labels it earned | Actual current section text; contract and transaction authority |\n| **Noncustodial debt settlement** | Provider does not receive, hold, control, or disburse customer funds | § 26-2233(1) not shown triggered for provider on stipulated facts; business account still required if licensed | General licensee records | Provider’s own properly earned fee goes to business account | Whether purported noncustody matches actual permissions and money flow |\n| **Standalone credit repair receiving only a fully earned fee** | No customer money held for creditors; service fully performed before payment | Business account, not trust, assuming provider owns the fee when received | General records | Full-performance rule must first be satisfied | P2 definition exclusions and official-current text remain held |\n| **Credit-repair provider holding creditor-payment money** | Provider receives money to pay creditors | Likely overlaps debt-counselor activity and trust trigger, subject to classification facts | General records; possibly additional model-specific duties | No advance credit-repair fee; other fees require separate authority | Exact overlapping classification |\n| **Genuinely independent customer-owned account** | Independent administrator holds funds; provider has no control or possession | Provider trust trigger not shown solely from those stipulated facts | Administrator’s Idaho obligations unresolved | No provider fee until independently earned; admin fee lacks established Idaho safe harbor | Administrator licensing, money transmission, contracts |\n| **Affiliate-administered or provider-controlled account** | Affiliate holds nominal title, but provider owns/controls administrator or directs funds | No automatic Idaho avoidance; factual receipt/control analysis required | Depends on actual actors | Deduction remains unsupported absent authority | Fails TSR administrator-independence condition if TSR applies |\n| **Exactly exempt bank, escrow, lender, or attorney activity** | Entity acts only within precise § 26-2239 exemption | ICAA account rule may not apply in that exempt capacity | Other governing law may apply | No fee or custody permission inferred | Exact exemption elements and alternate regulatory regime |\n| **Collection agency closing operations** | Trust and client property remain at closure | § 26-2246 disposition requirements apply | Proof within 30 days; director takeover/liquidation possible on noncompliance | Liquidation costs only from excess over sums due clients/proper parties | Not a general debt-settlement closure rule |\n\n# C. Source and usage table\n\nAll fresh accesses in this table occurred on **October 25, 2026, Pacific time**, unless expressly labeled reused or historical.\n\n| Source ID | Document / issuer and direct literal URL | Actual read scope and pinpoint | Version / legal status | Limitations |\n| --- | --- | --- | --- | --- |\n| **S_ID-P4-S001** | IDOF, *Statutes and Rules* — https://www.finance.idaho.gov/legal/statutes-and-rules/ | Selected current page: guidance warning and ICAA links, including §§ 26-2233 and 26-2234 | Official current agency locator; page displayed current department material | Locator only; agency says guidance lacks force of law. Does not reproduce operative text. [Department of Finance+1](https://www.finance.idaho.gov/legal/statutes-and-rules/) |\n| **S_ID-P4-S002** | Idaho Legislature § 26-2233 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2233 | One bounded fresh access attempt; internal error | Intended official current section route | No statutory text or version recovered; not a read source. |\n| **S_ID-P4-S003** | Idaho Legislature § 26-2234 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2234 | One bounded fresh access attempt; internal error | Intended official current section route | No statutory text or version recovered; not a read source. |\n| **S_ID-P4-S004** | 2025 Idaho Code reproduction, § 26-2233 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/ | Complete section, subsections (1)–(2), lines 57–62 | Secondary 2025 reproduction; displayed history through 2008 | Not official current 2026 text; source itself warns it may not be current. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/) |\n| **S_ID-P4-S005** | 2025 Idaho Code reproduction, § 26-2234 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/ | Complete section, subsections (1)–(7), lines 57–69 | Secondary 2025 reproduction; displayed history through 2008 | Same currentness limitation. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/) |\n| **S_ID-P4-S006** | 2025 Idaho Code reproduction, § 26-2222 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/ | Relevant definitions: business funds, collection agency, creditor client, creditor funds, debt/credit counselor, licensee and related terms | Secondary 2025 reproduction; same underlying document as P1 S002 | Actor-definition currentness remains held under C035. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/) |\n| **S_ID-P4-S007** | 2025 Idaho Code reproduction, § 26-2229 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/ | Complete relevant collection-agency contract provisions, subsections (1)–(2); subsection (3) reused only as existing P1 context | Secondary 2025 reproduction | Does not itself establish that any fee has been earned. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/) |\n| **S_ID-P4-S008** | 2025 Idaho Code reproduction, § 26-2229A — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/ | Selected relevant subsections (1), (3), (4)(f), (7)–(9), lines 57–78 | Secondary 2025 reproduction; displayed 2022 amendment history | Current official authentication held. Payment-processing clause is model-specific. [Justia Law+1](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/) |\n| **S_ID-P4-S009** | 2025 Idaho Code reproduction, § 26-2238 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/ | Complete section, especially subsection (1), lines 57–64 | Secondary 2025 reproduction | Criminal application requires all elements, process, and conviction; full remedies analysis excluded. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/) |\n| **S_ID-P4-S010** | 2025 Idaho Code reproduction, § 26-2239 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/ | Complete exemption list, subsections (1)–(10) | Secondary 2025 reproduction; displayed history through 2020 | Exact exemption facts and alternate regulatory regimes not resolved. [Justia Law](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/) |\n| **S_ID-P4-S011** | 2025 Idaho Code reproduction, § 26-2243 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2243/ | Complete short section | Secondary 2025 reproduction | Does not decide ownership of trust proceeds, bankruptcy priority, or setoff. |\n| **S_ID-P4-S012** | 2025 Idaho Code reproduction, § 26-2246 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/ | Complete section, subsections (1)–(5), lines 57–71 | Secondary 2025 reproduction; closure-specific | Applies to collection-agency closure, not every covered provider. [Justia Law+1](https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/) |\n| **S_ID-P4-S013** | 2025 Idaho Code reproduction, § 67-5247 — https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/ | Complete emergency-proceeding section, subsections (1)–(6) | Secondary 2025 reproduction; displayed 2025 amendment history | Used only to explain § 26-2234(7)’s emergency-proceeding cross-reference. [Justia Law](https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/) |\n| **S_ID-P4-S014** | Archived IDAPA 12.01.11 — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf | Complete parsed four-page archived chapter; cover and relevant contents visually inspected | Official archive; historical, not operative | Contains no current detailed trust-account rule; incorporation and scope are historical. [ProdDFMMainSa+1](https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf) |\n| **S_ID-P4-S015** | Official IDAPA 12 cumulative index — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf | Complete four-page index; relevant entry visually inspected | Official index records IDAPA 12.01.11 expired March 31, 2022 | Does not prove no later nonindexed order or authority exists. [ProdDFMMainSa](https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf) |\n| **S_ID-P4-S016** | IDOF, *Compliance Connection*, Fall 2006 — https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download | Selected trust-account article, printed p. 5, visually inspected | Official historical agency newsletter | Pre-2008 and pre-2022; recommendations and old fee discussion are not current law. [Idaho Docs](https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download) |\n| **S_ID-P4-S017** | IDOF, *Christian Debt Consolidation, Inc. Consent Order* — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf | Selected factual and funds-disposition provisions, printed pp. 2 and 6, visually inspected | Official 2010 consent order; historical and respondent-specific | Not binding precedent; ten-day remedy is not a general statutory deadline. [Department of Finance+1](https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf) |\n| **S_ID-P4-S018** | IDOF, *iQor Settlement Agreement* — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf | Selected access and trust-account provisions, printed pp. 4, 8–9, visually inspected | Official 2017 negotiated multistate settlement | Respondents did not admit liability; requirements are agreement-specific, not a generally controlling interpretation. [Department of Finance+2](https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf) |\n| **S_ID-P4-S019** | IDOF, *Bannock Collections Judgment* press release — https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf | Complete one-page release, visually inspected | Official 2007 agency press release summarizing a stipulated judgment | Not the judgment itself; used only as historical enforcement context. [Department of Finance](https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf) |\n| **S_ID-P4-S020** | *Dun & Bradstreet, Inc. v. McEldowney*, 564 F. Supp. 257 — https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/ | Selected issue and disposition passages | Federal district-court opinion copy; historical | Although § 26-2233 appeared in the challenge, the stipulated issues decided did not resolve trust-account or affiliate administration mechanics. [Justia Law](https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/) |\n| **S_ID-P4-S021** | 16 C.F.R. § 310.4 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | Fresh complete relevant reading of § 310.4(a)(5)(i)–(ii), especially lines 115–131 | eCFR authoritative but unofficial; Title 16 current through October 22, 2026, last amended October 19, 2026 | Applies only when the TSR’s independent coverage conditions are met. Same underlying document as stable P1 S027. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n# D. Claim table\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_ID-P4-C001** | IDOF currently identifies §§ 26-2233 and 26-2234 as ICAA provisions, but their official Legislature text was not readable through the bounded public route. | S001; S002–S003 failed routes | High as to access result; no inference about amendment absence. |\n| **S_ID-P4-C002** | Section 26-2233(1)’s reproduced text triggers the trust account when an ICAA licensee actually receives or holds money belonging to another in covered business. | S004 §26-2233(1) | High for reproduced text; official-current authentication held. |\n| **S_ID-P4-C003** | The required trust account is separate, in the licensee’s own name, for deposit and remittance, at an institution whose deposits are FDIC-insured. | S004 §26-2233(1) | High for reproduced text; no Idaho-location or per-customer-account requirement stated. |\n| **S_ID-P4-C004** | Every ICAA licensee must maintain a separate business account for business funds at an FDIC-insured institution. | S004 §26-2233(2); S006 §26-2222(2) | High for reproduced text. |\n| **S_ID-P4-C005** | Direct or indirect misappropriation, misapplication, borrowing, transfer, or conversion of another’s funds is prohibited by the reproduced provisions. | S004 §26-2233(1); S008 §26-2229A(7) | High for text; lawful earned-fee movement requires separate authority. |\n| **S_ID-P4-C006** | Custodial collection, DMP, counseling, settlement, and overlapping credit-repair models can trigger the account rule when the actor is covered and actually holds another’s money. | S004; S006; preserved P1/P2 classifications | Conditional on actor classification and C035. |\n| **S_ID-P4-C007** | The director has broad examination and investigation access to trust accounts, business accounts, creditor accounts, books, files, safes, and vaults used in licensed operations. | S005 §26-2234(1)–(2) | High for reproduced text. |\n| **S_ID-P4-C008** | Every licensee must keep GAAP-compliant books and financial records sufficient for compliance review. | S005 §26-2234(6) | High for reproduced text. |\n| **S_ID-P4-C009** | Collection agencies have account-specific acknowledgment, collection/disbursement records, and three-year post-disposition retention duties. | S005 §26-2234(4) | High for reproduced text; not automatically every debt counselor. |\n| **S_ID-P4-C010** | Collection agencies must remit money due creditor clients and provide statements within 30 days after month-end; no parallel exact debtor-side deadline was found in §§26-2233–2234. | S005 §26-2234(5); S004 | High for collection branch; debtor-side absence limited to provisions reviewed. |\n| **S_ID-P4-C011** | The director may impound operating and trust accounts of a licensee or required person handling consumer funds under the stated public-interest, good-cause, and emergency-proceeding framework. | S005 §26-2234(7); S013 §67-5247 | High for reproduced text; full remedies analysis excluded. |\n| **S_ID-P4-C012** | Failure to maintain or disburse trust funds as required, or conversion-type misuse, can support felony liability upon conviction under the reproduced §26-2238. | S009 §26-2238(1) | High for text; no opinion on any actual person’s culpability. |\n| **S_ID-P4-C013** | Trust-to-business transfer requires independently authorized, earned, timely, and documented compensation; a state ceiling alone is not an earning event. | S004, S007–S008; preserved P1 timing findings | High as bounded reconciliation; exact contract facts required. |\n| **S_ID-P4-C014** | Section 26-2229A(4)(f) is a narrow collection-agency payment-processing provision, not a general dedicated-account administration-fee authorization. | S008 §26-2229A(4)(f) | High for text; current official authentication held. |\n| **S_ID-P4-C015** | The provisions reviewed do not establish per-customer accounts, interest allocation, bank-setoff protection, bankruptcy exclusion, garnishment priority, or transaction-level signatory rules. | S004–S005 | High as a bounded no-text-found conclusion; other law remains open. |\n| **S_ID-P4-C016** | Exact §26-2239 exemptions may remove an actor from ICAA coverage only within the specified exempt capacity. | S010 §26-2239 | High for reproduced text; alternate regulation not analyzed. |\n| **S_ID-P4-C017** | Neither account branding nor nominal placement with an affiliate determines receipt, holding, or control. | S004–S005; S021 §310.4(a)(5)(ii)(C) | High as factual-classification principle; Idaho affiliate safe harbor unresolved. |\n| **S_ID-P4-C018** | Christian is historical evidence that a provider-maintained settlement account with provider fee deductions was treated as provider-held trust money, but its ten-day refund term was order-specific. | S017 printed pp. 2, 6 | Moderate-high; consent order, not generally controlling precedent. |\n| **S_ID-P4-C019** | iQor supplies historical official evidence of regulator expectations for reconciliations, adjustment clearing, outstanding checks, records, and access. | S018 printed pp. 4, 8–9 | Moderate; negotiated settlement with no admission. |\n| **S_ID-P4-C020** | Former IDAPA 12.01.11 expired March 31, 2022 and provides no current trust-account mechanics. | S014–S015 | High as to official index; no exhaustive assertion that no other order exists. |\n| **S_ID-P4-C021** | Section 26-2246’s reproduced text protects creditor-client money during collection-agency closure and places liquidation costs behind sums due clients/proper parties. | S012 §26-2246(1), (3), (5) | High for reproduced text; not a bankruptcy holding or general provider-closure rule. |\n| **S_ID-P4-C022** | Where the TSR applies, a dedicated account requires insured-institution custody, customer ownership and interest, an independent unaffiliated administrator, and no referral compensation. | S021 §310.4(a)(5)(ii)(A)–(D) | High; federal coverage must be established separately. |\n| **S_ID-P4-C023** | The TSR permits withdrawal from the debt-relief service without penalty and requires return of the covered balance within seven business days; it does not state a generalized right to withdraw from or close the bank account. | S021 §310.4(a)(5)(ii)(E) | High. |\n| **S_ID-P4-C024** | A provider-titled Idaho trust account and a customer-owned TSR dedicated account are structurally different and are not interchangeable compliance devices. | S004 §26-2233; S021 §310.4(a)(5)(ii) | High comparison, subject to state-currentness hold and federal coverage. |\n| **S_ID-P4-C025** | A truly independent administrator may keep the provider outside §26-2233(1) on exact no-receipt/no-control facts, but the administrator’s own Idaho classification is unresolved. | S004; preserved classification sources | Conditional; no Idaho safe-harbor authority located. |\n| **S_ID-P4-C026** | No general Idaho authority for a separate administrator fee, provider-controlled account, or particular transaction-signature architecture was established. | S004–S008; targeted official materials | Explicit hold; no search-silence claim of prohibition. |\n| **S_ID-P4-C027** | A concrete arrangement requires account, control, affiliation, payment-authorization, fee, ledger, and licensing evidence. | S004–S005, S017–S018, S021 | High as an evidence requirement; actual result depends on documents. |\n| **S_ID-P4-C028** | No named entity, account platform, administrator, bank, or provider was approved or found authorized in this pass. | Scope and source record | Certain. |\n| **S_ID-P4-C029** | A collection agency’s property right in an assigned account does not, by itself, establish ownership of creditor-client trust proceeds. | S011 §26-2243 read with S004–S005 | Bounded statutory inference; no bankruptcy or appellate holding. |\n| **S_ID-P4-C030** | Historical agency newsletters can illuminate administration but do not replace current statutes; the 2006 trust guidance is retained only as historical context. | S016; S001 guidance warning | High. |\n\n# E. Bounded money-ledger examples\n\nAll examples use exact dollar-and-cent arithmetic. No Idaho rounding rule was located, and no rounding is required by the chosen inputs. These examples demonstrate account treatment only; they do not establish any real provider’s license, contract, fee entitlement, or factual account structure.\n\n## Example 1 — Collection agency receipt, commission, and creditor remittance\n\n**Conditions assumed**\n\n- Covered collection agency.\n- Written creditor contract.\n- $1,000.00 collected during August.\n- Contract authorizes a 20% commission.\n- Commission is already earned and lawfully retainable.\n- No other deduction.\n\n**Ledger**\n\nPlain text\n```\nTrust receipt from debtor                         +$1,000.00\nAuthorized earned commission:\n  $1,000.00 × 20%                                  -$200.00\nAmount due creditor client                         $800.00\nBusiness-account transfer                          $200.00\nCreditor remittance                                $800.00\nEnding trust balance                                 $0.00\n```\n\nThe $800.00 and written monthly statement must be provided within 30 days after August 31—September 30 in this example. The arithmetic does not independently prove the commission was earned; that is an explicit input. [C010, C013]\n\n## Example 2 — Custodial debt counselor with no proven earned fee\n\n**Conditions assumed**\n\n- Covered custodial debt counselor.\n- $500.00 received for creditor payments.\n- $400.00 is currently authorized for a creditor payment.\n- The provider asserts a $50.00 fee but supplies no evidence that it is earned or presently payable.\n- No exact Idaho debtor-side remittance deadline is assumed.\n\n**Ledger**\n\nPlain text\n```\nTrust receipt                                      +$500.00\nAuthorized creditor payment                        -$400.00\nProven earned provider fee                            $0.00\nUnproven proposed fee transfer                        $0.00\nEnding trust balance                               $100.00\n```\n\nThe $100.00 remains trust money until a lawful creditor disbursement, consumer return, or independently established earned-fee transfer occurs. A numerical fee ceiling would not change the result because mathematical eligibility is not legal earning. [C002–C005, C013]\n\n### Conditional branch\n\nOnly if separate evidence establishes that $40.00 is already earned, timely, contractually authorized, and lawfully payable:\n\nPlain text\n```\nBalance before fee transfer                        $100.00\nLawfully payable fee transfer                      -$40.00\nRemaining trust balance                             $60.00\nBusiness-account receipt                            $40.00\n```\n\nNo prior remittance is subtracted twice.\n\n## Example 3 — Covered federal dedicated account after service withdrawal\n\n**Conditions assumed**\n\n- The TSR applies.\n- The account satisfies every § 310.4(a)(5)(ii) condition.\n- Consumer-owned insured account originally held $1,200.00.\n- $700.00 was already paid to a creditor under authorized settlement instructions.\n- No provider fee has been proven earned under § 310.4(a)(5)(i).\n- Customer withdraws from the debt-relief service.\n\n**Ledger**\n\nPlain text\n```\nOriginal consumer-owned account balance          $1,200.00\nPrior authorized creditor payment                  -$700.00\nBalance at withdrawal request                       $500.00\nEarned provider fee                                   $0.00\nAmount returnable to customer                       $500.00\n```\n\nThe $500.00 must be returned within seven business days of the request. The example concerns withdrawal from the **service**, not a generalized bank-account withdrawal right. [C022–C023]\n\n## Example 4 — Affiliate-controlled “external” account\n\n**Conditions assumed**\n\n- Account contains $900.00.\n- The administrator is a provider subsidiary.\n- The provider can initiate debits.\n- A proposed $25.00 “administration fee” has no identified Idaho or contractual authority and is not proven earned.\n\n**Compliance ledger**\n\nPlain text\n```\nStarting customer funds                            $900.00\nLawfully established administration fee              $0.00\nPermitted provider transfer                           $0.00\nProtected/undistributed balance                    $900.00\n```\n\nIf the bank statement instead shows $875.00, the missing $25.00 is an **unverified outflow**, not a lawful fee merely because it was deducted. The affiliation defeats the TSR’s independent-administrator condition where the TSR applies. Idaho classification still requires the actual account and control documents. [C017, C022, C026–C027]\n\n## Example 5 — Collection-agency closure\n\n**Conditions assumed**\n\n- Trust balance: $4,500.00.\n- $3,000.00 due creditor A.\n- $1,500.00 due creditor B.\n- Separate business account contains $500.00 of already earned business funds.\n- Estimated liquidation expense: $100.00.\n\n**Ledger**\n\nPlain text\n```\nTrust balance                                    $4,500.00\nRemit creditor A                                 -$3,000.00\nRemit creditor B                                 -$1,500.00\nEnding trust balance                                  $0.00\n\nSeparate business-account funds                    $500.00\nLiquidation expense                                -$100.00\nRemaining business funds                           $400.00\n```\n\nThe $100.00 liquidation cost is not taken from the $4,500.00 due creditor clients. Section 26-2246 permits liquidation expenses from controlled funds only to the extent those funds exceed sums due creditor clients or other proper parties. [C021]\n\n# F. Component coverage and remaining gaps\n\n| Funds/account component | Status | Claims | Exact remaining evidence or next action |\n| --- | --- | --- | --- |\n| Official current § 26-2233 text | **Unresolved** | C001–C005 | Recover readable official current section and amendment/session-law chain; compare complete subsections (1)–(2). |\n| Official current § 26-2234 text | **Unresolved** | C001, C007–C011 | Recover readable official current section and amendment chain; compare complete subsections (1)–(7). |\n| Trust trigger based on receipt/holding | **Answered provisionally** | C002, C006 | Apply official-current text and actual actor/money facts. |\n| Trust-account title and FDIC requirement | **Answered provisionally** | C003 | Obtain real bank/account agreement for a concrete model. |\n| Separate business account | **Answered provisionally** | C004 | Confirm current official text and actual account ledger. |\n| Business/trust commingling | **Answered at business-versus-trust level; partial otherwise** | C003–C005, C015 | Per-customer pooling, subledgers, and sweep practices require account documents and possible interpretation. |\n| Account geographic location | **Unresolved beyond text** | C015 | Statute reviewed states FDIC condition but no Idaho-location term; check any current rule/order or alternate regime for a concrete provider. |\n| Individual customer subaccounts | **Unresolved** | C015 | No requirement or permission established; inspect bank structure and official interpretation. |\n| Interest ownership under Idaho provider trust | **Unresolved** | C015 | No express rule located; contract and other trust/banking law required. |\n| Bankruptcy, setoff, attachment, garnishment | **Unresolved / excluded for later pass** | C015, C021, C029 | Separate state trust-property, UCC, banking, and Bankruptcy Code investigation. |\n| Regulator access and GAAP records | **Answered provisionally** | C007–C008 | Official-current text authentication remains. |\n| Collection-agency account records and retention | **Answered provisionally** | C009 | Confirm official-current text; apply to actual system and account. |\n| Reconciliation frequency | **Partial** | C008, C019 | Statute requires sufficient GAAP records; iQor imposed regular reconciliation in a negotiated settlement. No generally controlling interval found. |\n| Collection-agency monthly remittance | **Answered provisionally** | C010 | Confirm current official text; actual amount due depends on earned commission and contract. |\n| Custodial counselor/settlement remittance deadline | **Unresolved** | C010 | Inspect current official sections, required agreement terms, and any applicable order or rule. |\n| Trust-to-business earned-fee transfer | **Partial / conditional** | C005, C013 | Need exact contract, state fee branch, performance evidence, federal timing, and ledger. |\n| Collection-agency electronic-payment charge | **Answered narrowly** | C014 | Need actual cost, preauthorization, free alternative notice, and source account. |\n| General dedicated-account administrator charge | **Unresolved** | C014, C026 | Locate actual Idaho authority or regulator-approved arrangement; no fee invented. |\n| Provider-maintained settlement account | **Answered conditionally** | C002–C006, C018 | Actual provider classification, account title, control, transactions, and current official text required. |\n| Genuinely independent administrator | **Partial** | C025–C027 | Analyze administrator under current official Idaho definitions, Money Transmitters Act, account agreement, and actual permissions. |\n| Affiliate-controlled administrator | **Partial** | C017, C022, C026–C027 | Federal condition answered if TSR applies; Idaho receipt/control classification requires facts and authority. |\n| Transaction authorization and signatories | **Unresolved** | C026–C027 | Obtain ACH authorization, account agreement, servicing agreement, and permission matrix. |\n| Ordinary consumer cancellation return deadline | **Unresolved under Idaho provisions reviewed** | C018, C023 | Preserve P1 refund rule; inspect current contracts and any additional official Idaho authority. |\n| Federal TSR withdrawal and return | **Answered conditionally** | C022–C024 | Must first establish TSR coverage and every dedicated-account condition. |\n| Collection-agency closure disposition | **Answered provisionally** | C021 | Confirm official-current § 26-2246; full bond/receiver/remedies analysis remains later. |\n| Emergency impound power | **Answered provisionally and narrowly** | C011 | Full due-process, order, remedy, and case-law pass remains later. |\n| Current ICAA-specific account regulation | **Partial** | C020 | Former IDAPA 12.01.11 expired; monitor for a later rule or order without treating search silence as proof. |\n| Money-transmitter treatment | **Excluded / required later** | C025–C027 | Analyze Idaho money-transmission definitions, exemptions, custodial accounts, and administrator activity. |\n| C033 NMLS checklist | **Still open; untouched** | — | P3 dependency remains exactly as recorded. |\n| C035 actor/current-text comparison | **Still open and expanded to funds sections** | C001 | Four P3 sections plus §§ 26-2233, 26-2234, and necessary funds cross-references require official-current comparison. |\n| Named-provider authorization | **Excluded and not attempted** | C028 | Requires a separately authorized exact-name/NMLS lookup. |\n| Full contract, bond, remedies, litigation, limitations, secured, sector, local, tribal work | **Excluded** | — | Remains later state research; no acceptance by implication. |\n\n# G. Researcher self-check\n\n## Freshly read in PASS-04\n\n- IDOF’s current statutes-and-rules index and the ICAA links to §§ 26-2233 and 26-2234.\n- Complete accessible 2025 reproductions of §§ 26-2233 and 26-2234.\n- Relevant complete or selected funds provisions in §§ 26-2222, 26-2229, 26-2229A, 26-2238, 26-2239, 26-2243, 26-2246, and 67-5247.\n- The current eCFR text of 16 C.F.R. § 310.4(a)(5)(i)–(ii), including the page’s October 22, 2026 current-through statement.\n- The official IDAPA cumulative index entry recording expiration of IDAPA 12.01.11.\n- The archived IDAPA chapter.\n- The relevant page of IDOF’s Fall 2006 newsletter.\n- Selected material pages of the Christian consent order and iQor settlement agreement.\n- The complete Bannock Collections press release.\n- Selected portions of *Dun & Bradstreet v. McEldowney* sufficient to determine that it did not decide the trust-account mechanics at issue.\n\nPDF evidence relied upon for substantive propositions was visually inspected, not merely identified by title.\n\n## Failed public routes\n\n- https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2233\n- https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2234\n\nEach received one bounded fresh attempt. Neither produced readable official text. These are distinct P4 access observations and do not overwrite or merge the earlier S030 failures.\n\n## Reused without false fresh-read claims\n\n- P1/P2’s classification and fee findings.\n- P1’s cancellation-refund method and fee-earning limitations.\n- P2’s definition qualifications.\n- P3’s C033 and C035 source-status records.\n- Earlier federal coverage context outside the freshly read § 310.4 account provision.\n- Earlier *Wall* findings; *Wall* was not needed for a new funds proposition and was not rerun.\n\n## Not established\n\n- An authenticated official 2026 version of the Idaho account provisions.\n- A complete 2026 amendment comparison.\n- A current generally applicable Idaho rule specifying reconciliation frequency.\n- A categorical Idaho safe harbor for independent account administrators.\n- A lawful Idaho administrator-fee amount.\n- An Idaho rule on per-customer subaccounts, account interest, bank setoff, insolvency, bankruptcy ownership, attachment, or garnishment.\n- A money-transmitter exemption.\n- A particular provider’s, administrator’s, affiliate’s, or bank’s authorization.\n- Any private account agreement, ACH authorization, servicing contract, bank ledger, or customer record.\n- Whole-component, Idaho, A066, parent-state, operational, or publication acceptance.\n\nNo application, regulator contact, named-provider search, purchase, account change, private-data access, browser-control request, or separate chat was used.\n\n**END S_ID PASS-04.**\n\n","tables":[{"headers":["Provision","Actor and conduct reached by the accessible text","Important limitation"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Provision","Actor and conduct reached by the accessible text","Important limitation"],["§ 26-2233(1)","Every licensee that receives or holds funds belonging to another in ICAA business","Text says “licensee”; it does not itself supply an independent-provider or affiliate-account safe harbor."],["§ 26-2233(2)","Every ICAA licensee, whether custodial or noncustodial","Requires a separate business account for business funds."],["§ 26-2234(1), (2), (6)","Every licensee, for examinations, investigations, and GAAP-compliant records","General compliance and access provisions."],["§ 26-2234(4), (5)","Specifically every collection agency licensee","Detailed account records, three-year retention, monthly creditor remittance, and statements do not automatically extend to every debt counselor."],["§ 26-2234(7)","A licensee or person required to be licensed that receives, holds, or disburses consumer funds","Its express “consumer funds” object is narrower than § 26-2233’s general “funds belonging to another.”"],["§ 26-2229A(7)","A person licensed or required to be licensed holding another’s funds in ICAA business","Prohibits conversion-type conduct; does not itself identify a lawful fee-earning trigger."],["§ 26-2246","A collection agency licensee closing or discontinuing operations","It is not a general closure statute for every debt-settlement or credit-repair model."]]},{"headers":["Necessary fact","Why it matters"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Necessary fact","Why it matters"],["Exact account title and named depositor","Tests Idaho’s “in its own name” provider-trust structure versus federal customer ownership."],["Beneficial owner of funds and interest","Expressly material under the TSR; relevant to state trust treatment."],["Bank and deposit-insurance status","Idaho text and the TSR both require an insured institution, though their account structures differ."],["Provider, administrator, and bank ownership structure","Tests federal affiliation and factual state control."],["Every person with debit, ACH, freeze, sweep, or beneficiary-change authority","Determines actual receipt, holding, administration, and control."],["Account agreement and servicing agreement","Identifies ownership, movement authority, fees, termination, setoff, and insolvency terms."],["Referral or revenue-sharing agreement","Material to the federal no-referral-compensation condition."],["Fee schedule and debit source","Tests whether the charge is provider compensation, account administration, payment processing, or an unverified deduction."],["Customer authorization and revocation mechanics","Needed to determine who can initiate creditor or provider payments."],["Transaction ledger and reconciliation reports","Shows the real money path rather than the marketed one."],["Administrator’s Idaho license or exact exemption theory","Necessary before treating it as legally authorized to receive and disburse funds."]]},{"headers":["Feature","Provisional Idaho § 26-2233 provider trust","Federal TSR dedicated-account option"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Feature","Provisional Idaho § 26-2233 provider trust","Federal TSR dedicated-account option"],["Account title/ownership","Account established in licensee’s own name; funds described as belonging to another","Customer expressly owns funds"],["Administrator","Provider may be the account holder because the rule addresses provider custody","Administrator must be independent and unaffiliated"],["Interest","No express allocation rule in § 26-2233","Customer receives accrued interest, if any"],["Referral compensation","Not addressed in § 26-2233","Prohibited between administrator and service"],["Withdrawal rule","No general cancellation-return deadline stated in §§ 26-2233–2234","Customer may withdraw from the service without penalty; covered balance returned within seven business days"],["Fee deduction","Requires independent Idaho fee authority and earning/timing support","Only fees earned under § 310.4(a)(5)(i)(A)–(C) may be withheld"],["Legal effect","State custody/account rule","Conditional federal safe-harbor structure under the TSR"]]},{"headers":["Model","Money facts","Idaho account result, subject to current-text hold","Records and remittance","Fee movement","Unresolved point"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model","Money facts","Idaho account result, subject to current-text hold","Records and remittance","Fee movement","Unresolved point"],["Collection agency receiving debtor payments","Debtor money is received for creditor client","§ 26-2233 trust account in licensee’s name; separate business account","Detailed account/disbursement records; three-year retention; creditor remittance and statement within 30 days after month-end","Only independently authorized and earned collection commission moves to business account","Bankruptcy, setoff, per-client subaccounts"],["Custodial DMP or credit counseling","Provider receives debtor money for creditor payments","Trust account triggered if provider is a covered licensee","General GAAP records and regulator access; no exact debtor-side state remittance deadline found","Fee may move only when independently earned and payable under preserved P1/state/federal conditions","Exact disbursement deadline, cancellation-return deadline"],["Provider-maintained debt-settlement account","Provider debits customer and maintains account","Strongly fits receipt/holding trigger if provider is covered; Christian order provides historical fact-specific support","General records and access","Fee deduction not lawful merely because contract labels it earned","Actual current section text; contract and transaction authority"],["Noncustodial debt settlement","Provider does not receive, hold, control, or disburse customer funds","§ 26-2233(1) not shown triggered for provider on stipulated facts; business account still required if licensed","General licensee records","Provider’s own properly earned fee goes to business account","Whether purported noncustody matches actual permissions and money flow"],["Standalone credit repair receiving only a fully earned fee","No customer money held for creditors; service fully performed before payment","Business account, not trust, assuming provider owns the fee when received","General records","Full-performance rule must first be satisfied","P2 definition exclusions and official-current text remain held"],["Credit-repair provider holding creditor-payment money","Provider receives money to pay creditors","Likely overlaps debt-counselor activity and trust trigger, subject to classification facts","General records; possibly additional model-specific duties","No advance credit-repair fee; other fees require separate authority","Exact overlapping classification"],["Genuinely independent customer-owned account","Independent administrator holds funds; provider has no control or possession","Provider trust trigger not shown solely from those stipulated facts","Administrator’s Idaho obligations unresolved","No provider fee until independently earned; admin fee lacks established Idaho safe harbor","Administrator licensing, money transmission, contracts"],["Affiliate-administered or provider-controlled account","Affiliate holds nominal title, but provider owns/controls administrator or directs funds","No automatic Idaho avoidance; factual receipt/control analysis required","Depends on actual actors","Deduction remains unsupported absent authority","Fails TSR administrator-independence condition if TSR applies"],["Exactly exempt bank, escrow, lender, or attorney activity","Entity acts only within precise § 26-2239 exemption","ICAA account rule may not apply in that exempt capacity","Other governing law may apply","No fee or custody permission inferred","Exact exemption elements and alternate regulatory regime"],["Collection agency closing operations","Trust and client property remain at closure","§ 26-2246 disposition requirements apply","Proof within 30 days; director takeover/liquidation possible on noncompliance","Liquidation costs only from excess over sums due clients/proper parties","Not a general debt-settlement closure rule"]]},{"headers":["Source ID","Document / issuer and direct literal URL","Actual read scope and pinpoint","Version / legal status","Limitations"],"index":4,"links":[{"href":"https://www.finance.idaho.gov/legal/statutes-and-rules/","text":"Department of Finance\n+1"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/","text":"Justia Law"},{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/","text":"Justia Law\n+1"},{"href":"https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/","text":"Justia Law"},{"href":"https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf","text":"ProdDFMMainSa\n+1"},{"href":"https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf","text":"ProdDFMMainSa"},{"href":"https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download","text":"Idaho Docs"},{"href":"https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf","text":"Department of Finance\n+1"},{"href":"https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf","text":"Department of Finance\n+2"},{"href":"https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf","text":"Department of Finance"},{"href":"https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/","text":"Justia Law"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],"row_links":[[],[{"href":"https://www.finance.idaho.gov/legal/statutes-and-rules/","text":"Department of Finance\n+1"}],[],[],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/","text":"Justia Law"}],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/","text":"Justia Law"}],[],[{"href":"https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/","text":"Justia Law"}],[{"href":"https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf","text":"ProdDFMMainSa\n+1"}],[{"href":"https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf","text":"ProdDFMMainSa"}],[{"href":"https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download","text":"Idaho Docs"}],[{"href":"https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf","text":"Department of Finance\n+1"}],[{"href":"https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf","text":"Department of Finance\n+2"}],[{"href":"https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf","text":"Department of Finance"}],[{"href":"https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/","text":"Justia Law"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}]],"rows":[["Source ID","Document / issuer and direct literal URL","Actual read scope and pinpoint","Version / legal status","Limitations"],["S_ID-P4-S001","IDOF, Statutes and Rules — https://www.finance.idaho.gov/legal/statutes-and-rules/","Selected current page: guidance warning and ICAA links, including §§ 26-2233 and 26-2234","Official current agency locator; page displayed current department material","Locator only; agency says guidance lacks force of law. Does not reproduce operative text. \nDepartment of Finance\n+1"],["S_ID-P4-S002","Idaho Legislature § 26-2233 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2233","One bounded fresh access attempt; internal error","Intended official current section route","No statutory text or version recovered; not a read source."],["S_ID-P4-S003","Idaho Legislature § 26-2234 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2234","One bounded fresh access attempt; internal error","Intended official current section route","No statutory text or version recovered; not a read source."],["S_ID-P4-S004","2025 Idaho Code reproduction, § 26-2233 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/","Complete section, subsections (1)–(2), lines 57–62","Secondary 2025 reproduction; displayed history through 2008","Not official current 2026 text; source itself warns it may not be current. \nJustia Law"],["S_ID-P4-S005","2025 Idaho Code reproduction, § 26-2234 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/","Complete section, subsections (1)–(7), lines 57–69","Secondary 2025 reproduction; displayed history through 2008","Same currentness limitation. \nJustia Law"],["S_ID-P4-S006","2025 Idaho Code reproduction, § 26-2222 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/","Relevant definitions: business funds, collection agency, creditor client, creditor funds, debt/credit counselor, licensee and related terms","Secondary 2025 reproduction; same underlying document as P1 S002","Actor-definition currentness remains held under C035. \nJustia Law"],["S_ID-P4-S007","2025 Idaho Code reproduction, § 26-2229 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/","Complete relevant collection-agency contract provisions, subsections (1)–(2); subsection (3) reused only as existing P1 context","Secondary 2025 reproduction","Does not itself establish that any fee has been earned. \nJustia Law"],["S_ID-P4-S008","2025 Idaho Code reproduction, § 26-2229A — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/","Selected relevant subsections (1), (3), (4)(f), (7)–(9), lines 57–78","Secondary 2025 reproduction; displayed 2022 amendment history","Current official authentication held. Payment-processing clause is model-specific. \nJustia Law\n+1"],["S_ID-P4-S009","2025 Idaho Code reproduction, § 26-2238 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/","Complete section, especially subsection (1), lines 57–64","Secondary 2025 reproduction","Criminal application requires all elements, process, and conviction; full remedies analysis excluded. \nJustia Law"],["S_ID-P4-S010","2025 Idaho Code reproduction, § 26-2239 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/","Complete exemption list, subsections (1)–(10)","Secondary 2025 reproduction; displayed history through 2020","Exact exemption facts and alternate regulatory regimes not resolved. \nJustia Law"],["S_ID-P4-S011","2025 Idaho Code reproduction, § 26-2243 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2243/","Complete short section","Secondary 2025 reproduction","Does not decide ownership of trust proceeds, bankruptcy priority, or setoff."],["S_ID-P4-S012","2025 Idaho Code reproduction, § 26-2246 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/","Complete section, subsections (1)–(5), lines 57–71","Secondary 2025 reproduction; closure-specific","Applies to collection-agency closure, not every covered provider. \nJustia Law\n+1"],["S_ID-P4-S013","2025 Idaho Code reproduction, § 67-5247 — https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/","Complete emergency-proceeding section, subsections (1)–(6)","Secondary 2025 reproduction; displayed 2025 amendment history","Used only to explain § 26-2234(7)’s emergency-proceeding cross-reference. \nJustia Law"],["S_ID-P4-S014","Archived IDAPA 12.01.11 — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf","Complete parsed four-page archived chapter; cover and relevant contents visually inspected","Official archive; historical, not operative","Contains no current detailed trust-account rule; incorporation and scope are historical. \nProdDFMMainSa\n+1"],["S_ID-P4-S015","Official IDAPA 12 cumulative index — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf","Complete four-page index; relevant entry visually inspected","Official index records IDAPA 12.01.11 expired March 31, 2022","Does not prove no later nonindexed order or authority exists. \nProdDFMMainSa"],["S_ID-P4-S016","IDOF, Compliance Connection, Fall 2006 — https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download","Selected trust-account article, printed p. 5, visually inspected","Official historical agency newsletter","Pre-2008 and pre-2022; recommendations and old fee discussion are not current law. \nIdaho Docs"],["S_ID-P4-S017","IDOF, Christian Debt Consolidation, Inc. Consent Order — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf","Selected factual and funds-disposition provisions, printed pp. 2 and 6, visually inspected","Official 2010 consent order; historical and respondent-specific","Not binding precedent; ten-day remedy is not a general statutory deadline. \nDepartment of Finance\n+1"],["S_ID-P4-S018","IDOF, iQor Settlement Agreement — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf","Selected access and trust-account provisions, printed pp. 4, 8–9, visually inspected","Official 2017 negotiated multistate settlement","Respondents did not admit liability; requirements are agreement-specific, not a generally controlling interpretation. \nDepartment of Finance\n+2"],["S_ID-P4-S019","IDOF, Bannock Collections Judgment press release — https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf","Complete one-page release, visually inspected","Official 2007 agency press release summarizing a stipulated judgment","Not the judgment itself; used only as historical enforcement context. \nDepartment of Finance"],["S_ID-P4-S020","Dun & Bradstreet, Inc. v. McEldowney, 564 F. Supp. 257 — https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/","Selected issue and disposition passages","Federal district-court opinion copy; historical","Although § 26-2233 appeared in the challenge, the stipulated issues decided did not resolve trust-account or affiliate administration mechanics. \nJustia Law"],["S_ID-P4-S021","16 C.F.R. § 310.4 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Fresh complete relevant reading of § 310.4(a)(5)(i)–(ii), especially lines 115–131","eCFR authoritative but unofficial; Title 16 current through October 22, 2026, last amended October 19, 2026","Applies only when the TSR’s independent coverage conditions are met. Same underlying document as stable P1 S027. \neCFR\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, confidence"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, confidence"],["S_ID-P4-C001","IDOF currently identifies §§ 26-2233 and 26-2234 as ICAA provisions, but their official Legislature text was not readable through the bounded public route.","S001; S002–S003 failed routes","High as to access result; no inference about amendment absence."],["S_ID-P4-C002","Section 26-2233(1)’s reproduced text triggers the trust account when an ICAA licensee actually receives or holds money belonging to another in covered business.","S004 §26-2233(1)","High for reproduced text; official-current authentication held."],["S_ID-P4-C003","The required trust account is separate, in the licensee’s own name, for deposit and remittance, at an institution whose deposits are FDIC-insured.","S004 §26-2233(1)","High for reproduced text; no Idaho-location or per-customer-account requirement stated."],["S_ID-P4-C004","Every ICAA licensee must maintain a separate business account for business funds at an FDIC-insured institution.","S004 §26-2233(2); S006 §26-2222(2)","High for reproduced text."],["S_ID-P4-C005","Direct or indirect misappropriation, misapplication, borrowing, transfer, or conversion of another’s funds is prohibited by the reproduced provisions.","S004 §26-2233(1); S008 §26-2229A(7)","High for text; lawful earned-fee movement requires separate authority."],["S_ID-P4-C006","Custodial collection, DMP, counseling, settlement, and overlapping credit-repair models can trigger the account rule when the actor is covered and actually holds another’s money.","S004; S006; preserved P1/P2 classifications","Conditional on actor classification and C035."],["S_ID-P4-C007","The director has broad examination and investigation access to trust accounts, business accounts, creditor accounts, books, files, safes, and vaults used in licensed operations.","S005 §26-2234(1)–(2)","High for reproduced text."],["S_ID-P4-C008","Every licensee must keep GAAP-compliant books and financial records sufficient for compliance review.","S005 §26-2234(6)","High for reproduced text."],["S_ID-P4-C009","Collection agencies have account-specific acknowledgment, collection/disbursement records, and three-year post-disposition retention duties.","S005 §26-2234(4)","High for reproduced text; not automatically every debt counselor."],["S_ID-P4-C010","Collection agencies must remit money due creditor clients and provide statements within 30 days after month-end; no parallel exact debtor-side deadline was found in §§26-2233–2234.","S005 §26-2234(5); S004","High for collection branch; debtor-side absence limited to provisions reviewed."],["S_ID-P4-C011","The director may impound operating and trust accounts of a licensee or required person handling consumer funds under the stated public-interest, good-cause, and emergency-proceeding framework.","S005 §26-2234(7); S013 §67-5247","High for reproduced text; full remedies analysis excluded."],["S_ID-P4-C012","Failure to maintain or disburse trust funds as required, or conversion-type misuse, can support felony liability upon conviction under the reproduced §26-2238.","S009 §26-2238(1)","High for text; no opinion on any actual person’s culpability."],["S_ID-P4-C013","Trust-to-business transfer requires independently authorized, earned, timely, and documented compensation; a state ceiling alone is not an earning event.","S004, S007–S008; preserved P1 timing findings","High as bounded reconciliation; exact contract facts required."],["S_ID-P4-C014","Section 26-2229A(4)(f) is a narrow collection-agency payment-processing provision, not a general dedicated-account administration-fee authorization.","S008 §26-2229A(4)(f)","High for text; current official authentication held."],["S_ID-P4-C015","The provisions reviewed do not establish per-customer accounts, interest allocation, bank-setoff protection, bankruptcy exclusion, garnishment priority, or transaction-level signatory rules.","S004–S005","High as a bounded no-text-found conclusion; other law remains open."],["S_ID-P4-C016","Exact §26-2239 exemptions may remove an actor from ICAA coverage only within the specified exempt capacity.","S010 §26-2239","High for reproduced text; alternate regulation not analyzed."],["S_ID-P4-C017","Neither account branding nor nominal placement with an affiliate determines receipt, holding, or control.","S004–S005; S021 §310.4(a)(5)(ii)(C)","High as factual-classification principle; Idaho affiliate safe harbor unresolved."],["S_ID-P4-C018","Christian is historical evidence that a provider-maintained settlement account with provider fee deductions was treated as provider-held trust money, but its ten-day refund term was order-specific.","S017 printed pp. 2, 6","Moderate-high; consent order, not generally controlling precedent."],["S_ID-P4-C019","iQor supplies historical official evidence of regulator expectations for reconciliations, adjustment clearing, outstanding checks, records, and access.","S018 printed pp. 4, 8–9","Moderate; negotiated settlement with no admission."],["S_ID-P4-C020","Former IDAPA 12.01.11 expired March 31, 2022 and provides no current trust-account mechanics.","S014–S015","High as to official index; no exhaustive assertion that no other order exists."],["S_ID-P4-C021","Section 26-2246’s reproduced text protects creditor-client money during collection-agency closure and places liquidation costs behind sums due clients/proper parties.","S012 §26-2246(1), (3), (5)","High for reproduced text; not a bankruptcy holding or general provider-closure rule."],["S_ID-P4-C022","Where the TSR applies, a dedicated account requires insured-institution custody, customer ownership and interest, an independent unaffiliated administrator, and no referral compensation.","S021 §310.4(a)(5)(ii)(A)–(D)","High; federal coverage must be established separately."],["S_ID-P4-C023","The TSR permits withdrawal from the debt-relief service without penalty and requires return of the covered balance within seven business days; it does not state a generalized right to withdraw from or close the bank account.","S021 §310.4(a)(5)(ii)(E)","High."],["S_ID-P4-C024","A provider-titled Idaho trust account and a customer-owned TSR dedicated account are structurally different and are not interchangeable compliance devices.","S004 §26-2233; S021 §310.4(a)(5)(ii)","High comparison, subject to state-currentness hold and federal coverage."],["S_ID-P4-C025","A truly independent administrator may keep the provider outside §26-2233(1) on exact no-receipt/no-control facts, but the administrator’s own Idaho classification is unresolved.","S004; preserved classification sources","Conditional; no Idaho safe-harbor authority located."],["S_ID-P4-C026","No general Idaho authority for a separate administrator fee, provider-controlled account, or particular transaction-signature architecture was established.","S004–S008; targeted official materials","Explicit hold; no search-silence claim of prohibition."],["S_ID-P4-C027","A concrete arrangement requires account, control, affiliation, payment-authorization, fee, ledger, and licensing evidence.","S004–S005, S017–S018, S021","High as an evidence requirement; actual result depends on documents."],["S_ID-P4-C028","No named entity, account platform, administrator, bank, or provider was approved or found authorized in this pass.","Scope and source record","Certain."],["S_ID-P4-C029","A collection agency’s property right in an assigned account does not, by itself, establish ownership of creditor-client trust proceeds.","S011 §26-2243 read with S004–S005","Bounded statutory inference; no bankruptcy or appellate holding."],["S_ID-P4-C030","Historical agency newsletters can illuminate administration but do not replace current statutes; the 2006 trust guidance is retained only as historical context.","S016; S001 guidance warning","High."]]},{"headers":["Funds/account component","Status","Claims","Exact remaining evidence or next action"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Funds/account component","Status","Claims","Exact remaining evidence or next action"],["Official current § 26-2233 text","Unresolved","C001–C005","Recover readable official current section and amendment/session-law chain; compare complete subsections (1)–(2)."],["Official current § 26-2234 text","Unresolved","C001, C007–C011","Recover readable official current section and amendment chain; compare complete subsections (1)–(7)."],["Trust trigger based on receipt/holding","Answered provisionally","C002, C006","Apply official-current text and actual actor/money facts."],["Trust-account title and FDIC requirement","Answered provisionally","C003","Obtain real bank/account agreement for a concrete model."],["Separate business account","Answered provisionally","C004","Confirm current official text and actual account ledger."],["Business/trust commingling","Answered at business-versus-trust level; partial otherwise","C003–C005, C015","Per-customer pooling, subledgers, and sweep practices require account documents and possible interpretation."],["Account geographic location","Unresolved beyond text","C015","Statute reviewed states FDIC condition but no Idaho-location term; check any current rule/order or alternate regime for a concrete provider."],["Individual customer subaccounts","Unresolved","C015","No requirement or permission established; inspect bank structure and official interpretation."],["Interest ownership under Idaho provider trust","Unresolved","C015","No express rule located; contract and other trust/banking law required."],["Bankruptcy, setoff, attachment, garnishment","Unresolved / excluded for later pass","C015, C021, C029","Separate state trust-property, UCC, banking, and Bankruptcy Code investigation."],["Regulator access and GAAP records","Answered provisionally","C007–C008","Official-current text authentication remains."],["Collection-agency account records and retention","Answered provisionally","C009","Confirm official-current text; apply to actual system and account."],["Reconciliation frequency","Partial","C008, C019","Statute requires sufficient GAAP records; iQor imposed regular reconciliation in a negotiated settlement. No generally controlling interval found."],["Collection-agency monthly remittance","Answered provisionally","C010","Confirm current official text; actual amount due depends on earned commission and contract."],["Custodial counselor/settlement remittance deadline","Unresolved","C010","Inspect current official sections, required agreement terms, and any applicable order or rule."],["Trust-to-business earned-fee transfer","Partial / conditional","C005, C013","Need exact contract, state fee branch, performance evidence, federal timing, and ledger."],["Collection-agency electronic-payment charge","Answered narrowly","C014","Need actual cost, preauthorization, free alternative notice, and source account."],["General dedicated-account administrator charge","Unresolved","C014, C026","Locate actual Idaho authority or regulator-approved arrangement; no fee invented."],["Provider-maintained settlement account","Answered conditionally","C002–C006, C018","Actual provider classification, account title, control, transactions, and current official text required."],["Genuinely independent administrator","Partial","C025–C027","Analyze administrator under current official Idaho definitions, Money Transmitters Act, account agreement, and actual permissions."],["Affiliate-controlled administrator","Partial","C017, C022, C026–C027","Federal condition answered if TSR applies; Idaho receipt/control classification requires facts and authority."],["Transaction authorization and signatories","Unresolved","C026–C027","Obtain ACH authorization, account agreement, servicing agreement, and permission matrix."],["Ordinary consumer cancellation return deadline","Unresolved under Idaho provisions reviewed","C018, C023","Preserve P1 refund rule; inspect current contracts and any additional official Idaho authority."],["Federal TSR withdrawal and return","Answered conditionally","C022–C024","Must first establish TSR coverage and every dedicated-account condition."],["Collection-agency closure disposition","Answered provisionally","C021","Confirm official-current § 26-2246; full bond/receiver/remedies analysis remains later."],["Emergency impound power","Answered provisionally and narrowly","C011","Full due-process, order, remedy, and case-law pass remains later."],["Current ICAA-specific account regulation","Partial","C020","Former IDAPA 12.01.11 expired; monitor for a later rule or order without treating search silence as proof."],["Money-transmitter treatment","Excluded / required later","C025–C027","Analyze Idaho money-transmission definitions, exemptions, custodial accounts, and administrator activity."],["C033 NMLS checklist","Still open; untouched","—","P3 dependency remains exactly as recorded."],["C035 actor/current-text comparison","Still open and expanded to funds sections","C001","Four P3 sections plus §§ 26-2233, 26-2234, and necessary funds cross-references require official-current comparison."],["Named-provider authorization","Excluded and not attempted","C028","Requires a separately authorized exact-name/NMLS lookup."],["Full contract, bond, remedies, litigation, limitations, secured, sector, local, tribal work","Excluded","—","Remains later state research; no acceptance by implication."]]}],"claims":[{"claim_id":"S_ID-P4-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C001","Precise assertion":"IDOF currently identifies §§ 26-2233 and 26-2234 as ICAA provisions, but their official Legislature text was not readable through the bounded public route.","Sources and pinpoints":"S001; S002–S003 failed routes","Conditions, exceptions, currentness, confidence":"High as to access result; no inference about amendment absence."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C002","Precise assertion":"Section 26-2233(1)’s reproduced text triggers the trust account when an ICAA licensee actually receives or holds money belonging to another in covered business.","Sources and pinpoints":"S004 §26-2233(1)","Conditions, exceptions, currentness, confidence":"High for reproduced text; official-current authentication held."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C003","Precise assertion":"The required trust account is separate, in the licensee’s own name, for deposit and remittance, at an institution whose deposits are FDIC-insured.","Sources and pinpoints":"S004 §26-2233(1)","Conditions, exceptions, currentness, confidence":"High for reproduced text; no Idaho-location or per-customer-account requirement stated."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C004","Precise assertion":"Every ICAA licensee must maintain a separate business account for business funds at an FDIC-insured institution.","Sources and pinpoints":"S004 §26-2233(2); S006 §26-2222(2)","Conditions, exceptions, currentness, confidence":"High for reproduced text."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C005","Precise assertion":"Direct or indirect misappropriation, misapplication, borrowing, transfer, or conversion of another’s funds is prohibited by the reproduced provisions.","Sources and pinpoints":"S004 §26-2233(1); S008 §26-2229A(7)","Conditions, exceptions, currentness, confidence":"High for text; lawful earned-fee movement requires separate authority."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C006","Precise assertion":"Custodial collection, DMP, counseling, settlement, and overlapping credit-repair models can trigger the account rule when the actor is covered and actually holds another’s money.","Sources and pinpoints":"S004; S006; preserved P1/P2 classifications","Conditions, exceptions, currentness, confidence":"Conditional on actor classification and C035."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C007","Precise assertion":"The director has broad examination and investigation access to trust accounts, business accounts, creditor accounts, books, files, safes, and vaults used in licensed operations.","Sources and pinpoints":"S005 §26-2234(1)–(2)","Conditions, exceptions, currentness, confidence":"High for reproduced text."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C008","Precise assertion":"Every licensee must keep GAAP-compliant books and financial records sufficient for compliance review.","Sources and pinpoints":"S005 §26-2234(6)","Conditions, exceptions, currentness, confidence":"High for reproduced text."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C009","Precise assertion":"Collection agencies have account-specific acknowledgment, collection/disbursement records, and three-year post-disposition retention duties.","Sources and pinpoints":"S005 §26-2234(4)","Conditions, exceptions, currentness, confidence":"High for reproduced text; not automatically every debt counselor."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C010","Precise assertion":"Collection agencies must remit money due creditor clients and provide statements within 30 days after month-end; no parallel exact debtor-side deadline was found in §§26-2233–2234.","Sources and pinpoints":"S005 §26-2234(5); S004","Conditions, exceptions, currentness, confidence":"High for collection branch; debtor-side absence limited to provisions reviewed."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C011","Precise assertion":"The director may impound operating and trust accounts of a licensee or required person handling consumer funds under the stated public-interest, good-cause, and emergency-proceeding framework.","Sources and pinpoints":"S005 §26-2234(7); S013 §67-5247","Conditions, exceptions, currentness, confidence":"High for reproduced text; full remedies analysis excluded."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C012","Precise assertion":"Failure to maintain or disburse trust funds as required, or conversion-type misuse, can support felony liability upon conviction under the reproduced §26-2238.","Sources and pinpoints":"S009 §26-2238(1)","Conditions, exceptions, currentness, confidence":"High for text; no opinion on any actual person’s culpability."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C013","Precise assertion":"Trust-to-business transfer requires independently authorized, earned, timely, and documented compensation; a state ceiling alone is not an earning event.","Sources and pinpoints":"S004, S007–S008; preserved P1 timing findings","Conditions, exceptions, currentness, confidence":"High as bounded reconciliation; exact contract facts required."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C014","Precise assertion":"Section 26-2229A(4)(f) is a narrow collection-agency payment-processing provision, not a general dedicated-account administration-fee authorization.","Sources and pinpoints":"S008 §26-2229A(4)(f)","Conditions, exceptions, currentness, confidence":"High for text; current official authentication held."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C015","Precise assertion":"The provisions reviewed do not establish per-customer accounts, interest allocation, bank-setoff protection, bankruptcy exclusion, garnishment priority, or transaction-level signatory rules.","Sources and pinpoints":"S004–S005","Conditions, exceptions, currentness, confidence":"High as a bounded no-text-found conclusion; other law remains open."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C016","Precise assertion":"Exact §26-2239 exemptions may remove an actor from ICAA coverage only within the specified exempt capacity.","Sources and pinpoints":"S010 §26-2239","Conditions, exceptions, currentness, confidence":"High for reproduced text; alternate regulation not analyzed."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C017","Precise assertion":"Neither account branding nor nominal placement with an affiliate determines receipt, holding, or control.","Sources and pinpoints":"S004–S005; S021 §310.4(a)(5)(ii)(C)","Conditions, exceptions, currentness, confidence":"High as factual-classification principle; Idaho affiliate safe harbor unresolved."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C018","Precise assertion":"Christian is historical evidence that a provider-maintained settlement account with provider fee deductions was treated as provider-held trust money, but its ten-day refund term was order-specific.","Sources and pinpoints":"S017 printed pp. 2, 6","Conditions, exceptions, currentness, confidence":"Moderate-high; consent order, not generally controlling precedent."},"coordinator_verification_status":"scoped_review_complete_historical_content_unreopened_or_unreadable","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C019","Precise assertion":"iQor supplies historical official evidence of regulator expectations for reconciliations, adjustment clearing, outstanding checks, records, and access.","Sources and pinpoints":"S018 printed pp. 4, 8–9","Conditions, exceptions, currentness, confidence":"Moderate; negotiated settlement with no admission."},"coordinator_verification_status":"scoped_review_complete_historical_content_unreopened_or_unreadable","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C020","Precise assertion":"Former IDAPA 12.01.11 expired March 31, 2022 and provides no current trust-account mechanics.","Sources and pinpoints":"S014–S015","Conditions, exceptions, currentness, confidence":"High as to official index; no exhaustive assertion that no other order exists."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C021","Precise assertion":"Section 26-2246’s reproduced text protects creditor-client money during collection-agency closure and places liquidation costs behind sums due clients/proper parties.","Sources and pinpoints":"S012 §26-2246(1), (3), (5)","Conditions, exceptions, currentness, confidence":"High for reproduced text; not a bankruptcy holding or general provider-closure rule."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C022","Precise assertion":"Where the TSR applies, a dedicated account requires insured-institution custody, customer ownership and interest, an independent unaffiliated administrator, and no referral compensation.","Sources and pinpoints":"S021 §310.4(a)(5)(ii)(A)–(D)","Conditions, exceptions, currentness, confidence":"High; federal coverage must be established separately."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C023","Precise assertion":"The TSR permits withdrawal from the debt-relief service without penalty and requires return of the covered balance within seven business days; it does not state a generalized right to withdraw from or close the bank account.","Sources and pinpoints":"S021 §310.4(a)(5)(ii)(E)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C024","Precise assertion":"A provider-titled Idaho trust account and a customer-owned TSR dedicated account are structurally different and are not interchangeable compliance devices.","Sources and pinpoints":"S004 §26-2233; S021 §310.4(a)(5)(ii)","Conditions, exceptions, currentness, confidence":"High comparison, subject to state-currentness hold and federal coverage."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C025","Precise assertion":"A truly independent administrator may keep the provider outside §26-2233(1) on exact no-receipt/no-control facts, but the administrator’s own Idaho classification is unresolved.","Sources and pinpoints":"S004; preserved classification sources","Conditions, exceptions, currentness, confidence":"Conditional; no Idaho safe-harbor authority located."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C026","Precise assertion":"No general Idaho authority for a separate administrator fee, provider-controlled account, or particular transaction-signature architecture was established.","Sources and pinpoints":"S004–S008; targeted official materials","Conditions, exceptions, currentness, confidence":"Explicit hold; no search-silence claim of prohibition."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C027","Precise assertion":"A concrete arrangement requires account, control, affiliation, payment-authorization, fee, ledger, and licensing evidence.","Sources and pinpoints":"S004–S005, S017–S018, S021","Conditions, exceptions, currentness, confidence":"High as an evidence requirement; actual result depends on documents."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C028","Precise assertion":"No named entity, account platform, administrator, bank, or provider was approved or found authorized in this pass.","Sources and pinpoints":"Scope and source record","Conditions, exceptions, currentness, confidence":"Certain."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C029","Precise assertion":"A collection agency’s property right in an assigned account does not, by itself, establish ownership of creditor-client trust proceeds.","Sources and pinpoints":"S011 §26-2243 read with S004–S005","Conditions, exceptions, currentness, confidence":"Bounded statutory inference; no bankruptcy or appellate holding."},"coordinator_verification_status":"scoped_review_complete_with_explicit_source_and_application_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_ID-P4-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ID-P4-C030","Precise assertion":"Historical agency newsletters can illuminate administration but do not replace current statutes; the 2006 trust guidance is retained only as historical context.","Sources and pinpoints":"S016; S001 guidance warning","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"scoped_review_complete_historical_content_unreopened_or_unreadable","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_ID-P4-S001","urls":["https://www.finance.idaho.gov/legal/statutes-and-rules/"],"researcher_record":{"Source ID":"S_ID-P4-S001","Document / issuer and direct literal URL":"IDOF, Statutes and Rules — https://www.finance.idaho.gov/legal/statutes-and-rules/","Actual read scope and pinpoint":"Selected current page: guidance warning and ICAA links, including §§ 26-2233 and 26-2234","Version / legal status":"Official current agency locator; page displayed current department material","Limitations":"Locator only; agency says guidance lacks force of law. Does not reproduce operative text. \nDepartment of Finance\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S002","urls":["https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2233"],"researcher_record":{"Source ID":"S_ID-P4-S002","Document / issuer and direct literal URL":"Idaho Legislature § 26-2233 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2233","Actual read scope and pinpoint":"One bounded fresh access attempt; internal error","Version / legal status":"Intended official current section route","Limitations":"No statutory text or version recovered; not a read source."},"coordinator_verification_status":"fresh_failed_official_text_not_recovered","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S003","urls":["https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2234"],"researcher_record":{"Source ID":"S_ID-P4-S003","Document / issuer and direct literal URL":"Idaho Legislature § 26-2234 route — https://legislature.idaho.gov/statutesrules/idstat/Title26/T26CH22/SECT26-2234","Actual read scope and pinpoint":"One bounded fresh access attempt; internal error","Version / legal status":"Intended official current section route","Limitations":"No statutory text or version recovered; not a read source."},"coordinator_verification_status":"fresh_failed_official_text_not_recovered","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S004","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/"],"researcher_record":{"Source ID":"S_ID-P4-S004","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2233 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2233/","Actual read scope and pinpoint":"Complete section, subsections (1)–(2), lines 57–62","Version / legal status":"Secondary 2025 reproduction; displayed history through 2008","Limitations":"Not official current 2026 text; source itself warns it may not be current. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S005","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/"],"researcher_record":{"Source ID":"S_ID-P4-S005","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2234 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2234/","Actual read scope and pinpoint":"Complete section, subsections (1)–(7), lines 57–69","Version / legal status":"Secondary 2025 reproduction; displayed history through 2008","Limitations":"Same currentness limitation. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S006","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/"],"researcher_record":{"Source ID":"S_ID-P4-S006","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2222 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2222/","Actual read scope and pinpoint":"Relevant definitions: business funds, collection agency, creditor client, creditor funds, debt/credit counselor, licensee and related terms","Version / legal status":"Secondary 2025 reproduction; same underlying document as P1 S002","Limitations":"Actor-definition currentness remains held under C035. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S007","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/"],"researcher_record":{"Source ID":"S_ID-P4-S007","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2229 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229/","Actual read scope and pinpoint":"Complete relevant collection-agency contract provisions, subsections (1)–(2); subsection (3) reused only as existing P1 context","Version / legal status":"Secondary 2025 reproduction","Limitations":"Does not itself establish that any fee has been earned. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S008","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/"],"researcher_record":{"Source ID":"S_ID-P4-S008","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2229A — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2229a/","Actual read scope and pinpoint":"Selected relevant subsections (1), (3), (4)(f), (7)–(9), lines 57–78","Version / legal status":"Secondary 2025 reproduction; displayed 2022 amendment history","Limitations":"Current official authentication held. Payment-processing clause is model-specific. \nJustia Law\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S009","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/"],"researcher_record":{"Source ID":"S_ID-P4-S009","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2238 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2238/","Actual read scope and pinpoint":"Complete section, especially subsection (1), lines 57–64","Version / legal status":"Secondary 2025 reproduction","Limitations":"Criminal application requires all elements, process, and conviction; full remedies analysis excluded. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S010","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/"],"researcher_record":{"Source ID":"S_ID-P4-S010","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2239 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2239/","Actual read scope and pinpoint":"Complete exemption list, subsections (1)–(10)","Version / legal status":"Secondary 2025 reproduction; displayed history through 2020","Limitations":"Exact exemption facts and alternate regulatory regimes not resolved. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S011","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2243/"],"researcher_record":{"Source ID":"S_ID-P4-S011","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2243 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2243/","Actual read scope and pinpoint":"Complete short section","Version / legal status":"Secondary 2025 reproduction","Limitations":"Does not decide ownership of trust proceeds, bankruptcy priority, or setoff."},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S012","urls":["https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/"],"researcher_record":{"Source ID":"S_ID-P4-S012","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 26-2246 — https://law.justia.com/codes/idaho/title-26/chapter-22/section-26-2246/","Actual read scope and pinpoint":"Complete section, subsections (1)–(5), lines 57–71","Version / legal status":"Secondary 2025 reproduction; closure-specific","Limitations":"Applies to collection-agency closure, not every covered provider. \nJustia Law\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S013","urls":["https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/"],"researcher_record":{"Source ID":"S_ID-P4-S013","Document / issuer and direct literal URL":"2025 Idaho Code reproduction, § 67-5247 — https://law.justia.com/codes/idaho/title-67/chapter-52/section-67-5247/","Actual read scope and pinpoint":"Complete emergency-proceeding section, subsections (1)–(6)","Version / legal status":"Secondary 2025 reproduction; displayed 2025 amendment history","Limitations":"Used only to explain § 26-2234(7)’s emergency-proceeding cross-reference. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S014","urls":["https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf"],"researcher_record":{"Source ID":"S_ID-P4-S014","Document / issuer and direct literal URL":"Archived IDAPA 12.01.11 — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/rules/2021%20Archive/12/120111.pdf","Actual read scope and pinpoint":"Complete parsed four-page archived chapter; cover and relevant contents visually inspected","Version / legal status":"Official archive; historical, not operative","Limitations":"Contains no current detailed trust-account rule; incorporation and scope are historical. \nProdDFMMainSa\n+1"},"coordinator_verification_status":"not_reopened_historical_not_current_authority","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S015","urls":["https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf"],"researcher_record":{"Source ID":"S_ID-P4-S015","Document / issuer and direct literal URL":"Official IDAPA 12 cumulative index — https://proddfmmainsa.blob.core.windows.net/dfm-admin-website/cindex/12.pdf","Actual read scope and pinpoint":"Complete four-page index; relevant entry visually inspected","Version / legal status":"Official index records IDAPA 12.01.11 expired March 31, 2022","Limitations":"Does not prove no later nonindexed order or authority exists. \nProdDFMMainSa"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S016","urls":["https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download"],"researcher_record":{"Source ID":"S_ID-P4-S016","Document / issuer and direct literal URL":"IDOF, Compliance Connection, Fall 2006 — https://idahodocs.contentdm.oclc.org/digital/api/collection/p16293coll3/id/90743/download","Actual read scope and pinpoint":"Selected trust-account article, printed p. 5, visually inspected","Version / legal status":"Official historical agency newsletter","Limitations":"Pre-2008 and pre-2022; recommendations and old fee discussion are not current law. \nIdaho Docs"},"coordinator_verification_status":"not_reopened_historical_not_current_authority","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S017","urls":["https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf"],"researcher_record":{"Source ID":"S_ID-P4-S017","Document / issuer and direct literal URL":"IDOF, Christian Debt Consolidation, Inc. Consent Order — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/ChristianDebtConsolidationInc.-2010-9-07-ConsentOrder.pdf","Actual read scope and pinpoint":"Selected factual and funds-disposition provisions, printed pp. 2 and 6, visually inspected","Version / legal status":"Official 2010 consent order; historical and respondent-specific","Limitations":"Not binding precedent; ten-day remedy is not a general statutory deadline. \nDepartment of Finance\n+1"},"coordinator_verification_status":"fresh_historical_PDF_attempt_no_readable_body_or_visible_pixels","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S018","urls":["https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf"],"researcher_record":{"Source ID":"S_ID-P4-S018","Document / issuer and direct literal URL":"IDOF, iQor Settlement Agreement — https://www.finance.idaho.gov/wp-content/uploads/legal/administrative-actions/consumer-finance/documents/iQor-Settlement-Agreement.pdf","Actual read scope and pinpoint":"Selected access and trust-account provisions, printed pp. 4, 8–9, visually inspected","Version / legal status":"Official 2017 negotiated multistate settlement","Limitations":"Respondents did not admit liability; requirements are agreement-specific, not a generally controlling interpretation. \nDepartment of Finance\n+2"},"coordinator_verification_status":"fresh_historical_PDF_attempt_no_readable_body_or_visible_pixels","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S019","urls":["https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf"],"researcher_record":{"Source ID":"S_ID-P4-S019","Document / issuer and direct literal URL":"IDOF, Bannock Collections Judgment press release — https://www.finance.idaho.gov/wp-content/uploads/about/press-releases/documents/2007/BannockCollectionsJudgment-1.pdf","Actual read scope and pinpoint":"Complete one-page release, visually inspected","Version / legal status":"Official 2007 agency press release summarizing a stipulated judgment","Limitations":"Not the judgment itself; used only as historical enforcement context. \nDepartment of Finance"},"coordinator_verification_status":"not_reopened_historical_not_current_authority","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S020","urls":["https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/"],"researcher_record":{"Source ID":"S_ID-P4-S020","Document / issuer and direct literal URL":"Dun & Bradstreet, Inc. v. McEldowney, 564 F. Supp. 257 — https://law.justia.com/cases/federal/district-courts/FSupp/564/257/1407776/","Actual read scope and pinpoint":"Selected issue and disposition passages","Version / legal status":"Federal district-court opinion copy; historical","Limitations":"Although § 26-2233 appeared in the challenge, the stipulated issues decided did not resolve trust-account or affiliate administration mechanics. \nJustia Law"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_ID-P4-S021","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_ID-P4-S021","Document / issuer and direct literal URL":"16 C.F.R. § 310.4 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Actual read scope and pinpoint":"Fresh complete relevant reading of § 310.4(a)(5)(i)–(ii), especially lines 115–131","Version / legal status":"eCFR authoritative but unofficial; Title 16 current through October 22, 2026, last amended October 19, 2026","Limitations":"Applies only when the TSR’s independent coverage conditions are met. Same underlying document as stable P1 S027. \neCFR\n+1"},"coordinator_verification_status":"fresh_selected_checked_with_explicit_reproduction_read_limits","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Official current § 26-2233 text","researcher_record":{"Funds/account component":"Official current § 26-2233 text","Status":"Unresolved","Claims":"C001–C005","Exact remaining evidence or next action":"Recover readable official current section and amendment/session-law chain; compare complete subsections (1)–(2)."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Official current § 26-2234 text","researcher_record":{"Funds/account component":"Official current § 26-2234 text","Status":"Unresolved","Claims":"C001, C007–C011","Exact remaining evidence or next action":"Recover readable official current section and amendment chain; compare complete subsections (1)–(7)."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Trust trigger based on receipt/holding","researcher_record":{"Funds/account component":"Trust trigger based on receipt/holding","Status":"Answered provisionally","Claims":"C002, C006","Exact remaining evidence or next action":"Apply official-current text and actual actor/money facts."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Trust-account title and FDIC requirement","researcher_record":{"Funds/account component":"Trust-account title and FDIC requirement","Status":"Answered provisionally","Claims":"C003","Exact remaining evidence or next action":"Obtain real bank/account agreement for a concrete model."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Separate business account","researcher_record":{"Funds/account component":"Separate business account","Status":"Answered provisionally","Claims":"C004","Exact remaining evidence or next action":"Confirm current official text and actual account ledger."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Business/trust commingling","researcher_record":{"Funds/account component":"Business/trust commingling","Status":"Answered at business-versus-trust level; partial otherwise","Claims":"C003–C005, C015","Exact remaining evidence or next action":"Per-customer pooling, subledgers, and sweep practices require account documents and possible interpretation."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Account geographic location","researcher_record":{"Funds/account component":"Account geographic location","Status":"Unresolved beyond text","Claims":"C015","Exact remaining evidence or next action":"Statute reviewed states FDIC condition but no Idaho-location term; check any current rule/order or alternate regime for a concrete provider."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Individual customer subaccounts","researcher_record":{"Funds/account component":"Individual customer subaccounts","Status":"Unresolved","Claims":"C015","Exact remaining evidence or next action":"No requirement or permission established; inspect bank structure and official interpretation."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Interest ownership under Idaho provider trust","researcher_record":{"Funds/account component":"Interest ownership under Idaho provider trust","Status":"Unresolved","Claims":"C015","Exact remaining evidence or next action":"No express rule located; contract and other trust/banking law required."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bankruptcy, setoff, attachment, garnishment","researcher_record":{"Funds/account component":"Bankruptcy, setoff, attachment, garnishment","Status":"Unresolved / excluded for later pass","Claims":"C015, C021, C029","Exact remaining evidence or next action":"Separate state trust-property, UCC, banking, and Bankruptcy Code investigation."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Regulator access and GAAP records","researcher_record":{"Funds/account component":"Regulator access and GAAP records","Status":"Answered provisionally","Claims":"C007–C008","Exact remaining evidence or next action":"Official-current text authentication remains."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agency account records and retention","researcher_record":{"Funds/account component":"Collection-agency account records and retention","Status":"Answered provisionally","Claims":"C009","Exact remaining evidence or next action":"Confirm official-current text; apply to actual system and account."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Reconciliation frequency","researcher_record":{"Funds/account component":"Reconciliation frequency","Status":"Partial","Claims":"C008, C019","Exact remaining evidence or next action":"Statute requires sufficient GAAP records; iQor imposed regular reconciliation in a negotiated settlement. No generally controlling interval found."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agency monthly remittance","researcher_record":{"Funds/account component":"Collection-agency monthly remittance","Status":"Answered provisionally","Claims":"C010","Exact remaining evidence or next action":"Confirm current official text; actual amount due depends on earned commission and contract."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial counselor/settlement remittance deadline","researcher_record":{"Funds/account component":"Custodial counselor/settlement remittance deadline","Status":"Unresolved","Claims":"C010","Exact remaining evidence or next action":"Inspect current official sections, required agreement terms, and any applicable order or rule."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Trust-to-business earned-fee transfer","researcher_record":{"Funds/account component":"Trust-to-business earned-fee transfer","Status":"Partial / conditional","Claims":"C005, C013","Exact remaining evidence or next action":"Need exact contract, state fee branch, performance evidence, federal timing, and ledger."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agency electronic-payment charge","researcher_record":{"Funds/account component":"Collection-agency electronic-payment charge","Status":"Answered narrowly","Claims":"C014","Exact remaining evidence or next action":"Need actual cost, preauthorization, free alternative notice, and source account."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"General dedicated-account administrator charge","researcher_record":{"Funds/account component":"General dedicated-account administrator charge","Status":"Unresolved","Claims":"C014, C026","Exact remaining evidence or next action":"Locate actual Idaho authority or regulator-approved arrangement; no fee invented."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider-maintained settlement account","researcher_record":{"Funds/account component":"Provider-maintained settlement account","Status":"Answered conditionally","Claims":"C002–C006, C018","Exact remaining evidence or next action":"Actual provider classification, account title, control, transactions, and current official text required."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Genuinely independent administrator","researcher_record":{"Funds/account component":"Genuinely independent administrator","Status":"Partial","Claims":"C025–C027","Exact remaining evidence or next action":"Analyze administrator under current official Idaho definitions, Money Transmitters Act, account agreement, and actual permissions."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Affiliate-controlled administrator","researcher_record":{"Funds/account component":"Affiliate-controlled administrator","Status":"Partial","Claims":"C017, C022, C026–C027","Exact remaining evidence or next action":"Federal condition answered if TSR applies; Idaho receipt/control classification requires facts and authority."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Transaction authorization and signatories","researcher_record":{"Funds/account component":"Transaction authorization and signatories","Status":"Unresolved","Claims":"C026–C027","Exact remaining evidence or next action":"Obtain ACH authorization, account agreement, servicing agreement, and permission matrix."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary consumer cancellation return deadline","researcher_record":{"Funds/account component":"Ordinary consumer cancellation return deadline","Status":"Unresolved under Idaho provisions reviewed","Claims":"C018, C023","Exact remaining evidence or next action":"Preserve P1 refund rule; inspect current contracts and any additional official Idaho authority."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR withdrawal and return","researcher_record":{"Funds/account component":"Federal TSR withdrawal and return","Status":"Answered conditionally","Claims":"C022–C024","Exact remaining evidence or next action":"Must first establish TSR coverage and every dedicated-account condition."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agency closure disposition","researcher_record":{"Funds/account component":"Collection-agency closure disposition","Status":"Answered provisionally","Claims":"C021","Exact remaining evidence or next action":"Confirm official-current § 26-2246; full bond/receiver/remedies analysis remains later."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Emergency impound power","researcher_record":{"Funds/account component":"Emergency impound power","Status":"Answered provisionally and narrowly","Claims":"C011","Exact remaining evidence or next action":"Full due-process, order, remedy, and case-law pass remains later."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current ICAA-specific account regulation","researcher_record":{"Funds/account component":"Current ICAA-specific account regulation","Status":"Partial","Claims":"C020","Exact remaining evidence or next action":"Former IDAPA 12.01.11 expired; monitor for a later rule or order without treating search silence as proof."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Money-transmitter treatment","researcher_record":{"Funds/account component":"Money-transmitter treatment","Status":"Excluded / required later","Claims":"C025–C027","Exact remaining evidence or next action":"Analyze Idaho money-transmission definitions, exemptions, custodial accounts, and administrator activity."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"C033 NMLS checklist","researcher_record":{"Funds/account component":"C033 NMLS checklist","Status":"Still open; untouched","Claims":"—","Exact remaining evidence or next action":"P3 dependency remains exactly as recorded."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"C035 actor/current-text comparison","researcher_record":{"Funds/account component":"C035 actor/current-text comparison","Status":"Still open and expanded to funds sections","Claims":"C001","Exact remaining evidence or next action":"Four P3 sections plus §§ 26-2233, 26-2234, and necessary funds cross-references require official-current comparison."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider authorization","researcher_record":{"Funds/account component":"Named-provider authorization","Status":"Excluded and not attempted","Claims":"C028","Exact remaining evidence or next action":"Requires a separately authorized exact-name/NMLS lookup."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full contract, bond, remedies, litigation, limitations, secured, sector, local, tribal work","researcher_record":{"Funds/account component":"Full contract, bond, remedies, litigation, limitations, secured, sector, local, tribal work","Status":"Excluded","Claims":"—","Exact remaining evidence or next action":"Remains later state research; no acceptance by implication."},"coordinator_acceptance":"scoped_review_complete_with_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T16:54:34.889243+00:00","status":"scoped_review_complete_with_evidence_and_application_holds","review":"[internal evidence reference]","raw_originals_unchanged":true,"unverified_historical_claims":["S_ID-P4-C018","S_ID-P4-C019","S_ID-P4-C030"],"additional_crossref_limits":"67-5247 immediate danger/reasonedorder/notice/promptproceeding/120days-or-earlierfinalorder retained; fullcurrentprocedure notaccepted.","no_component_acceptance":true},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_ID-P4-funds-trust-provisional-scope-20261027","status":"scoped_review_complete_with_provisional_officialtext_and_application_holds","at":"2026-10-27T16:54:34.889243+00:00"}]}