{"meta":{"key":"s_il--pass-01","task":"S_IL","title":"SIL Illinois provider market access and consumer fees","parent_title":"Illinois debt and debt relief law","edition":"pass-01","path":"/research/s_il--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-23","tables":8,"claims":38,"sources":26,"review_status":"revise","review_complete":true,"sha256":"9e8726976c4dc9e17b140bb8281928bb274e5db13ce74999ec8750dc1e15f8e2","headings":["1. Classification follows the service and compensation, not its name","Core activity boundaries","Consumer versus business purpose","Illinois residents and remote providers","2. Which models are licensed, excluded, or prohibited?","Affirmative licensing pathways","Conditional exclusions","Self-creditors and prohibited combinations","3. Consumer fee structures, bases, limits, credits, and refunds","Verified fee schedule","Settlement savings: the baseline matters","Refund and cancellation distinctions","Currentness, indexing, and conflicting numbers","4. When fees may be requested or received","Illinois settlement timing","Illinois DMP timing","Independently applicable federal TSR baseline","5. Public market-access procedure and lookup","6. Worked fee and boundary results","7. Component coverage","Worked examples","E1 — Later balance growth does not enlarge settlement savings","E2 — One debt settled; another unresolved; earlier fee already paid","E3 — Installment settlement: federal first payment does not settle the state issue","E4 — Lower debt and zero/negative savings","E5 — State enrollment ceiling with an unmet federal trigger","E6 — DMP ordinary fees after required performance","E7 — DMP additional processing charge and small-debt boundary","E8 — DMP cancellation","E9 — Settlement cancellation with unearned money","E10 — Paid-referral and student-payment-reduction boundaries","Component coverage and exact next investigations"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","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_IL/pass-01","facets":{"geography":["us","us-il"],"debt_type":["unknown"],"stage":[],"subject":["definitions-classification","fees-outcomes","provider-licensing"]},"scope":"Provider market access and consumer fee framework only; allotherstatecategories remainrequired","pending_corrections":0},"markdown":"# S_IL PASS-01 — Illinois provider market access and consumer fees\n\n**Baseline:** October 22, 2026, Pacific.\n**Actual research access:** October 22, 2026, PDT, corresponding to October 23, 2026, UTC. The final access check was **06:12 UTC / 11:12 p.m. PDT**.\n\n**Core finding:** Illinois establishes separate licensing pathways for covered debt settlement and debt management services. The verified statutory consumer-fee limits are:\n\n- **Debt settlement:** one enrollment fee of up to **$50**, plus a settlement fee of up to **15% of defined savings**, subject to the settlement and payment conditions discussed below.\n- **Debt management:** initial counseling of up to **$50 per debtor counseled**, plus additional fees of up to **$50 per month** after completion of initial counseling.\n\nThese permissions come from the statutes. They do not authorize every activity associated with a debt-relief business: customer-referral compensation, for example, is expressly prohibited for covered licensees. State fee limits also do not override independently applicable federal advance-fee restrictions. **C013, C017–C023, C029, C033–C036.** [my.ilga.gov+4](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com)\n\nThis is a component investigation. Several specific evidence gaps remain, including the detailed settlement-refund provision, portions of the current DMP rules, and readable current application checklists. They are identified below without substituting secondary text for an actual primary read. **No Illinois-wide or A066 acceptance is implied.**\n\n**Identifier convention:** References such as **S001** and **C001** below mean **S_IL-P1-S001** and **S_IL-P1-C001**. The source and claim tables contain the full identifiers.\n\n# A. Substantive answers\n\n## 1. Classification follows the service and compensation, not its name\n\n### Core activity boundaries\n\n| Actual conduct | Illinois classification and consequence | Claims |\n| --- | --- | --- |\n| Compensated advice, negotiation, or intermediation whose primary purpose is to settle, adjust, or satisfy unsecured debt below its defined principal amount **or current outstanding balance** | Falls within the ordinary debt-settlement definition, unless a specified exclusion applies. Calling it “negotiation,” “consulting,” or “debt adjustment” does not establish an exemption. | C001 |\n| Helping, encouraging, or counseling a consumer to accumulate money for such settlements | Expressly within settlement services. The provider need not possess the settlement money. | C001, C016 |\n| Planning and managing a debtor’s financial affairs for a fee, receiving money for distribution to creditors in full or partial payment, or conduct involving the definition’s express creditor-contribution limb | Analyze under the Debt Management Service Act. Its definition includes **soliciting financial contributions from creditors**; it should not be rewritten as an invariably custody-only test. | C002 |\n| A repayment/distribution plan that repays the relevant debt balance while obtaining concessions on future interest or payment terms | A typical DMP candidate, subject to the actual statutory definition. A concession reducing an existing balance can instead implicate settlement coverage when that reduction is the service’s primary purpose. | C001–C002 |\n| Budgeting, financial-literacy, saving/spending, or personal-finance counseling without performing covered DMP or settlement activity | The DMSA defines and conditionally excludes a “credit counselor” providing those services. This does **not** establish unrestricted permission to charge for credit repair, credit improvement, or loan procurement. | C003 |\n| Federal student-loan assistance involving repayment-plan enrollment, forbearance, deferment, consolidation, or changes to rates, payments, or fees | Special statutory student-loan-relief coverage can apply without a principal reduction. Its fees remain subject to §125; a lower monthly payment is not itself the statutory savings base. | C006 |\n| A compensated business soliciting for or acting on behalf of a settlement provider | The settlement-provider definition can reach the intermediary. A referral or marketing label is not a reliable coverage exclusion, and separate referral-payment prohibitions apply. | C001, C029 |\n\nThe two Acts expressly exclude each other’s defined services. That requires classification of the actual arrangement; it does not make the provider’s preferred label controlling. A hybrid program promising both distribution services and reductions of existing balances requires a specific analysis of its contracts, representations, compensation, and cash flows. **C001–C003.** [my.ilga.gov](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com)\n\n### Consumer versus business purpose\n\nNeither definition supplies a simple, express “personal, family, or household purposes only” exclusion:\n\n- The settlement Act defines a consumer as a person purchasing or contracting for the services, with additional student-loan language.\n- The DMSA’s definition of “person” expressly includes firms, partnerships, associations, LLCs, corporations, and nonprofit corporations.\n\nConsequently, **business purpose is not an established automatic escape from these Acts**. This is a textual boundary finding, not a completed opinion on every corporate workout. Specific business-debt applications, including the settlement exclusion for services incidental to dissolution, winding up, or liquidation, remain fact dependent. **C005, C010.**\n\n### Illinois residents and remote providers\n\nThe DMSA expressly reaches a business whose business, employees, or agents are in Illinois **or which solicits or contracts with debtors located in Illinois**. The settlement Act requires separate applications for locations doing business with Illinois residents. An out-of-state office therefore does not itself establish exemption.\n\nThe investigation does not resolve whether a particular passive website, without Illinois solicitation or contracting, creates sufficient nexus. Actual solicitation, contracting, customer location, and business locations must be established. **C004.**\n\n## 2. Which models are licensed, excluded, or prohibited?\n\n### Affirmative licensing pathways\n\n| Model | Governing permission | Entry conditions material to this pass |\n| --- | --- | --- |\n| Covered debt settlement | **225 ILCS 429/15, 20, 25**; IDFPR Secretary; **38 Ill. Adm. Code Part 145** | License before acting; sworn application; financial and character fitness; location-specific licensing; statutory bond floor of **$100,000**, potentially higher; rule-based net worth of at least **$30,000** and at least **six months’ relevant experience**. |\n| Covered debt management | **205 ILCS 665/3–5**; IDFPR Secretary; **38 Ill. Adm. Code Part 140** | License before covered business; sworn application; financial and character fitness; location-specific licensing; bond floor of **$25,000**, potentially higher; positive net worth and at least **six months’ relevant experience** under the rule. |\n| Noncustodial settlement | Same settlement license pathway | Section 65(d)’s exception from establishing a trust account, where the provider holds or controls no consumer funds other than earned settlement fees, is **not a license exemption**. |\n| Paid customer referrals involving covered providers | Subject to the prohibitions described below | A license does not authorize compensation that the statute or rule prohibits. |\n\nBoth license systems contemplate nonprofit and for-profit applicants. Their annual renewal provisions use a December 1 renewal deadline and January 1 expiration structure. Full bond administration, fund handling, and renewal-compliance work remain later-pass subjects. **C013–C016.** [my.ilga.gov+2](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com)\n\n**Provider-to-regulator charges are separate from consumer fees.** The retrieved settlement rule states a **$350 nonrefundable application fee plus a $1,000 annual license fee**. The DMSA states **$30 investigation and $100 license charges**, with a $100 renewal charge. These are the legal schedule amounts retrieved, not a verified current NMLS checkout quote; no additional NMLS processing amount was established. The 2026 rulemaking authority discussed below must also be considered before a filing. **C014–C015, C027.**\n\n### Conditional exclusions\n\n| Actor or model | Settlement Act | Debt Management Service Act |\n| --- | --- | --- |\n| **Attorney** | Illinois licensure or authorization **and actual practice of law** are required. An attorney’s ownership, affiliation, referral, or nominal participation alone does not establish the exclusion. | Likewise requires Illinois authorization and actual practice of law, within the regular course of the profession. |\n| **Nonprofit** | The specified exclusion is cumulative: **501(c)(3)** status, being subject to **501(q)**, exemption under **501(a)**, and being governed by the DMSA. | No blanket nonprofit exclusion. Nonprofits are included in the Act’s entity definitions and licensing provisions. |\n| **Banks and other financial institutions** | Enumerated banks, bank agents/operating subsidiaries/affiliates, trust companies, savings institutions, credit unions, specified credit/development entities, title insurers/agents, independent escrowees, insurers, and authorized lenders have stated statutory conditions, including operation under applicable law and ordinary-business limitations. | Enumerated banks, operating subsidiaries/affiliates, fiduciaries, credit unions, and savings institutions must be authorized/admitted to transact Illinois business and perform the relevant adjusting services in their ordinary principal business. |\n| **Escrow, accounting, securities professionals** | Specified professionals must act in their ordinary profession through the ordinary professional entity. | Title insurers, agents, independent escrowees, and abstract companies are excluded while doing escrow business; no general exclusion for every accountant or financial adviser was established. |\n| **Employer/employee arrangements** | Regular salaried or wage employees performing credit services for an employer that is not in the settlement business are excluded. | Employers acting for employees are excluded. An outside DMP vendor serving the employer’s employees must be licensed. |\n| **Collection agency** | A collection agency licensed under the Collection Agency Act, collecting its own or third-party debt, is expressly excluded. | No comparable general collection-agency exclusion was established from §2. |\n| **Public/court actors** | Public officers acting officially and persons acting under court order. | Judicial officers and persons acting under court order. |\n| **Other specified actors** | Services incidental to business dissolution/winding up/liquidation; real-estate licensees acting ordinarily without holding out as settlement providers; qualifying higher-education institutions. Defined student-loan servicers and other education-loan originators, guarantors, or servicers also receive service-definition exclusions. | Defined bill-payment services and defined credit counselors, while performing the excluded activities. The bill-payment cross-reference needs reconciliation with the newer money-transmission framework in a later pass. |\n\nThese are exclusions from the identified Act, **not findings that all fees charged by an excluded actor are lawful under every other law**. Attorney entity structure, professional rules, credit-services law, lending law, and federal coverage may still matter. **C007–C012, C038.** [my.ilga.gov](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com)\n\n### Self-creditors and prohibited combinations\n\nNeither reviewed definition supplies an unlimited, standalone “self-creditor” exemption. Ordinary adjustment of one’s own receivable may fall outside the relevant service definition or within a specific lender or licensed-collector exclusion. That does not automatically exempt a separate borrower-paid advisory or intermediation business. **C012.**\n\nFor covered providers:\n\n- **Settlement:** Rule 145.70(d)–(e) prohibits receiving compensation for referring potential customers and paying an attorney, lender, or other source for customer referrals.\n- **DMP:** Section 13(3) prohibits directly or indirectly receiving or paying cash or in-kind consideration for the specified referrals.\n- **DMP:** Section 13 also prohibits making loans, acting as a loan broker, specified credit-card/customer-procurement activity, requiring ancillary purchases, and operating another business at the licensed location.\n\nA paid-referral or prohibited bundled-business model cannot be converted into an ordinarily licensable model merely because IDFPR accepts applications for debt management or settlement. Whether a particular advertising arrangement is compensation for referrals requires its actual terms; this investigation does not approve a fixed-advertising alternative. **C029–C030.** [ilsos.gov+1](https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com)\n\n## 3. Consumer fee structures, bases, limits, credits, and refunds\n\n### Verified fee schedule\n\n| Fee | Verified Illinois rule | Base and limits |\n| --- | --- | --- |\n| Settlement enrollment | §125(b): one-time enrollment fee **up to $50** | Not $50 per creditor, settlement, or month. Federal timing remains separate. |\n| Settlement success fee | §125(c): **up to 15% of savings** | Savings use the debt balance at contract entry, less the amount actually paid to the creditor for full and complete satisfaction. |\n| Settlement monthly maintenance, additional setup, or other upfront fees | §125(b) prohibits these outside the limited enrollment exception | A generic rule definition mentioning a fee does not authorize a fee prohibited by the statute. |\n| Settlement statements, proof of payment, receipts | Rules 145.70(i), 145.120(b) prohibit these charges | They cannot be added as independent administrative fees. |\n| DMP initial counseling | §12(1): **up to $50 per debtor counseled** | A fee for the initial counseling, not a repeated setup charge for each debt. |\n| DMP additional fees | §12(2): **up to $50 per month**, at completion of initial counseling | No verified per-creditor supplement or current percentage-of-disbursement formula. All additional monthly charges must fit the limit and other conditions. |\n\n**C017–C022.** [ilga.gov+2](https://www.ilga.gov/legislation/ilcs/fulltext.asp?DocName=022504290K125&utm_source=chatgpt.com)\n\n### Settlement savings: the baseline matters\n\nThe Act’s defined “principal amount” is the **outstanding balance when the consumer enters the settlement contract**. It is not necessarily the original loan principal, and it is not the later balance after additional interest or penalties.\n\nConsequently:\n\n- Later balance growth cannot inflate the statutory savings base.\n- A settlement above the enrollment balance produces **no settlement fee**, even if it is below the later current balance.\n- Equal enrollment and payoff balances produce a zero savings-based fee.\n- An unresolved debt does not generate a success fee merely because it was enrolled.\n- Fees already collected for the same settlement must be accounted for within the applicable ceiling.\n\nNo separate fixed per-debt charge, additional aggregate program-dollar cap, or mandatory enrollment-fee credit against the settlement fee was found in the retrieved fee provisions. That last finding is **not** permission to front-load or duplicate fees; the contract and federal allocation rules still matter. **C017–C020.**\n\n### Refund and cancellation distinctions\n\n**Settlement—verified primary minimum:** Sections 115(c) and 120(c)(14) establish the disclosed right to cancel and obtain a refund of **unearned fees and settlement funds not paid to creditors**. **C024.** [ilga.gov+1](https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html?utm_source=chatgpt.com)\n\n**Settlement—detail held:** The actually read 2025 secondary reproduction of §135 says cancellation or a material violation triggers refunds, with exceptions described as an “application fee” and earned settlement fees, and requires refund/accounting within **five business days** after cancellation notice. The current primary §135 passage could not be retrieved. Therefore:\n\n- The five-business-day deadline is **not promoted here to primary-verified current law**.\n- The “application fee” wording is not treated as a second authorized consumer charge.\n- Retention of the $50 enrollment charge is not approved without resolving the operative text and its application.\n\n**C025; exact recovery task in Section D.**\n\n**DMP—verified:** Written cancellation is effective on the first day of the following month after receipt. The rule does not authorize a separate cancellation penalty beyond §12, and current §12 supplies no such penalty. The retrieved provisions do not establish a general numeric refund deadline or an automatic refund of all properly earned earlier counseling/service fees. **C023.** [ilsos.gov](https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com)\n\n### Currentness, indexing, and conflicting numbers\n\nNo automatic CPI formula was found in the operative consumer-fee sections. **No CPI calculation or invented adjusted dollar amount is used here.**\n\nThe currentness reconciliation is:\n\n| Material | Status and consequence |\n| --- | --- |\n| Current §125 and §12 | Support the **$50 / 15%-of-savings** settlement structure and **$50 / $50-monthly** DMP structure. |\n| 2011 adopted rules | Effective March 29, 2011. They establish relevant licensing, earning, cancellation, and prohibited-fee rules. Their historical transition deadline is not current permission to operate before licensing. |\n| 2022 adopted amendments | Effective July 8, 2022. The retrieved amendments concern hearing/procedure provisions, not new consumer-fee amounts. |\n| September 18, 2026 Title 38 index | Lists the 2022 amendments as the latest amendments to Parts 140 and 145. The index-update date is not a legal effective date. |\n| Register issues 39–42, September 25–October 16, 2026 | Contents and relevant text searches did not identify intervening Part 140/145 fee amendments. This is a bounded published-record check, not a guarantee about an unlocated filing. |\n| **P.A. 104-520 / HB5384** | New fee-amendment rulemaking authority is enacted. DMSA §6.5 was actually read; the Governor’s June 26, 2026 announcement confirms signing and immediate effectiveness. Full Public Act text and exact settlement §78 language remain held. Authority to amend fees is not itself a changed fee amount. |\n| July 2026 regulatory agenda | Anticipates first notice in **November 2026** for Parts 140/145. It is planning material, not an adopted fee change. Its “if signed” wording does not override the actual June 26 signing. |\n| **HB4814** | Proposed DMP percentage/creditor-tier fees—15% of monthly disbursements, with proposed $75/$100 caps—were not established as enacted law. They must not replace current §12. |\n| **HB1289** | Proposed replacement Debt Resolution Services Act; the retrieved status does not establish enactment. Its prospective provisions are not current authorization. |\n\n**C026–C028.** [Title 38+5](https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf?utm_source=chatgpt.com)\n\n## 4. When fees may be requested or received\n\n### Illinois settlement timing\n\nSection 125(d) requires a **legally enforceable creditor agreement** accepting a specified amount as full and complete satisfaction **and provision of those funds to the creditor**, either by the provider or directly by the consumer pursuant to the negotiated agreement.\n\nThat language does not simply reproduce the federal first-payment rule. For an installment settlement requiring all installments for full satisfaction, this pass **does not approve collection of the settlement fee after the first installment alone**. The worked example below holds that collection pending the state condition or an authoritative interpretation. No controlling decision resolving that installment question was established. **C019.** [ilga.gov](https://www.ilga.gov/legislation/ilcs/fulltext.asp?DocName=022504290K125&utm_source=chatgpt.com)\n\nA signed settlement-services contract must also identify fees and timing under §120. A cap does not independently establish that a charge has been earned or may be collected.\n\n### Illinois DMP timing\n\nSection 12(2) permits additional fees at completion of initial counseling. Rule 140.50(i) limits earning to one monthly service fee per contract-anniversary month, using the corresponding-date/last-day convention specified there.\n\nRule 140.50(c)(1) also limits earning after a debtor stops making payments for more than 30 days: the rule refers to **30 days after the next monthly contract date**. It should not be replaced with an invented daily-proration formula.\n\nThis pass does not establish a general right to collect the initial counseling charge before counseling is performed, or to precollect future monthly service fees. **C021–C023.**\n\n### Independently applicable federal TSR baseline\n\nFor a covered telemarketing transaction, **16 CFR 310.4(a)(5)(i)(A)–(C)** prohibits **requesting or receiving** debt-relief fees until:\n\n1. At least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid agreement executed by the customer;\n2. The customer has made at least one payment under that agreement; and\n3. For debts resolved individually, the fee follows either the specified proportional-debt allocation or a consistent percentage-of-savings method.\n\nThe applicable Illinois cap and state earning conditions must also be satisfied. Federal first-payment compliance does not establish Illinois settlement-fee maturity. Conversely, Illinois’s $50 enrollment exception does not establish a federal advance-fee exception. **C034–C036.** [ecfr.gov](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com)\n\nThe TSR includes relevant inbound responses to debt-relief advertising; coverage cannot be decided merely by calling the business “online.” FTC staff guidance does not recognize a general attorney exemption from the debt-relief fee rule. Genuine nonprofit jurisdiction and other exemptions require their actual conditions; a nonprofit label is insufficient. The staff guide is interpretive guidance, not the regulation itself. **C033.** [ecfr.gov+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com)\n\nA qualifying consumer-owned dedicated account under §310.4(a)(5)(ii) is not payment of an earned provider fee. The provision has insurance, ownership, independence, referral-compensation, withdrawal, and seven-business-day return conditions. Full account administration remains a later investigation. **C035.**\n\n## 5. Public market-access procedure and lookup\n\nThe actual IDFPR **Consumer Credit Section** page lists both debt-management and debt-settlement licensing and links to their application routes. The actual **Division of Financial Institutions License Lookup** page lists both categories under Consumer Credit. These are verified operational routes, supported by the separate statutory licensing authority. **C031–C032.** [Consumer Credit+1](https://idfpr.illinois.gov/dfi/ccd/ccd-main.html?utm_source=chatgpt.com)\n\nThe actual link-following results were:\n\n- **DMP application:** IDFPR’s NMLS link redirected to the NMLS State Resource Center, but yielded no readable current checklist.\n- **Settlement application:** the linked NMLS “New Application Checklist” PDF route redirected to the resource center and yielded no readable checklist.\n- **License lookup:** the IDFPR-linked lookup endpoint failed or was restricted in this browsing environment. No provider-specific results were obtained.\n\nThus, **the public application and lookup routes are verified; the current checklist contents and any named provider’s authorization are not**. No claim is made about SettleADebt.com or another provider’s actual license, exemption, branch coverage, standing, or disciplinary status.\n\n## 6. Worked fee and boundary results\n\nSection D supplies the complete arithmetic. It includes lower balances, one settled debt within a larger program, previously collected fees, installment settlements, cancellation, and models for which no lawful fee pathway was established.\n\n## 7. Component coverage\n\nThe final coverage table distinguishes answered issues from documentary holds and later-pass exclusions. Agreement, funds, bonds, remedies, collection, litigation, limitations, property exemptions, secured debt, sectors, local/tribal issues, full contract analysis, and full case-law coverage remain open except for the narrow provisions needed above.\n\n# B. Source table\n\n**Access notation:** Every entry was checked on **October 22, 2026 PDT / October 23 UTC**. “Read” means actual returned document passages were examined. “Partial” does not imply the entire document was read. Failed routes and indexed discoveries are identified separately.\n\n| Source ID | Title / issuer / jurisdiction | Direct literal URL(s) | Exact pinpoint, version, legal status, and access limitation |\n| --- | --- | --- | --- |\n| **S_IL-P1-S001** | **Debt Settlement Consumer Protection Act, 225 ILCS 429** — Illinois General Assembly; IL | [https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS,+OCCUPATIONS,+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com) ; [https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm](https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm) ; [https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html](https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html?utm_source=chatgpt.com) ; [https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm](https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm) | **Partial current-code read:** §10 definitions/exclusions; §§15, 20, 25, 30, 65; full relevant §§115, 120, 125. §§10/115/125 carry P.A.102-298, effective **8/6/2021**; §120 source P.A.96-1420, effective **8/3/2010**. Full current §§78, 110, 135, 145, 150 not successfully read. Later reopen failures do not erase earlier successful reads. |\n| **S_IL-P1-S002** | **Debt Management Service Act, 205 ILCS 665** — ILGA; IL | [https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION](https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION&utm_source=chatgpt.com) ; [https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12](https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12&utm_source=chatgpt.com) ; [https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html](https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html?utm_source=chatgpt.com) | **Read:** relevant §§1–16.6, including §§2–6.5, 12, 13, 14, 16(b). Independent successful section reads for §§12–13. §2 source P.A.100-201, effective **8/18/2017**; §§12–13 P.A.96-1420, **8/3/2010**; §6.5 P.A.104-520, **6/26/2026**. Whole-Act later reopen failed. |\n| **S_IL-P1-S003** | **Illinois Register 35, issue 16** — Illinois Secretary of State; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com) | **Read:** DMP adoption **pp.6350–6363**, especially §§140.40–.50, pp.6355–6357; full original Part145 adoption **pp.6364–6385**, including .40/.45/.50/.70/.105/.120. Published **4/15/2011**, effective **3/29/2011**. State-hosted reproduction; not a certified print copy. |\n| **S_IL-P1-S004** | **Illinois Register 46, issue 30** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf?utm_source=chatgpt.com) | **Read:** Part140 amendment **pp.12514–12521**, §§140.120/.140; Part145 amendment **pp.12522–12528**, §§145.80/.125. Effective **7/8/2022**, published **7/22/2022**. Operative additions/deletions checked; no consumer-fee change in these amendments. |\n| **S_IL-P1-S005** | **Illinois Administrative Code, Title 38 index** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf](https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf?utm_source=chatgpt.com) | **Read:** document pp.5–6, Parts140/145; index updated **9/18/2026**. Latest listed amendments: 46 Ill.Reg.12514 and 12522, effective 7/8/2022. Index is a currentness aid, not operative text. |\n| **S_IL-P1-S006** | **Illinois Register 50, issue 27; IDFPR regulatory agenda** — SOS/IDFPR; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf?utm_source=chatgpt.com) | **Read:** **pp.8977–8978**, items II(c)–(d), Parts140/145. Published **7/6/2026**; anticipated first notice November2026. **Planning, not adopted law.** |\n| **S_IL-P1-S007** | **“Gov. Pritzker Takes Bill Action”** — Illinois Office of the Governor; IL | [https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz](https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz?utm_source=chatgpt.com) | **Read:** dated **6/26/2026**, **HB5384 entry**, lines343–348: signed, effective immediately; describes fee-rulemaking amendments. Confirms executive action, not the full statutory clauses or a changed fee schedule. |\n| **S_IL-P1-S008** | **HB1289 bill status, 104th GA** — ILGA; IL | [https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114](https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114&utm_source=chatgpt.com) | **Read:** synopsis and actions; displayed referral to House Rules **1/28/2025**. Replacement-act proposal; enactment not established. |\n| **S_IL-P1-S009** | **HB4814 bill status, 104th GA** — ILGA; IL | [https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114](https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114) | **Read in parallel research:** synopsis/actions; House passage4/14/2026, Senate actions through displayed7/2/2026; no Public Act established. Proposed DMP fee changes remain proposed. Subsequent reopen failed. |\n| **S_IL-P1-S010** | **Consumer Credit Section** — IDFPR; IL | [https://idfpr.illinois.gov/dfi/ccd/ccd-main.html](https://idfpr.illinois.gov/dfi/ccd/ccd-main.html?utm_source=chatgpt.com) | **Read:** “Debt Management Services,” “Debt Settlement,” application links, governing Acts/rules. Current operational routing; not proof of an applicant’s authority. |\n| **S_IL-P1-S011** | **DFI License Lookup** — IDFPR; IL | [https://idfpr.illinois.gov/dfi/dfilicenselookup.html](https://idfpr.illinois.gov/dfi/dfilicenselookup.html?utm_source=chatgpt.com) | **Read:** Consumer Credit categories include both license types and link to lookup. Directory route only. |\n| **S_IL-P1-S012** | **Consumer Credit FAQ/brochure** — IDFPR; IL | [https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html](https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html?utm_source=chatgpt.com) | **Read:** DMP fee FAQ and licensing references. Corroborates $50 initial/$50 monthly; undated operational explanation does not establish legal effective date. |\n| **S_IL-P1-S013** | **Illinois NMLS application routing** — NMLS, linked by IDFPR; IL application procedure | [https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL](https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL&utm_source=chatgpt.com) | **Followed, not readable:** redirected to State Resource Center; no current DMP checklist text returned. |\n| **S_IL-P1-S014** | **Illinois Debt Settlement New Application Checklist route** — NMLS, linked by IDFPR; IL | [https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf](https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf?utm_source=chatgpt.com) | **Followed, not readable:** redirected to resource center; checklist version/content unknown. |\n| **S_IL-P1-S015** | **Consumer Credit license-lookup endpoint** — IDFPR-linked service; IL | [https://online-obre.micropact.com/Lookup/LicenseLookup.aspx](https://online-obre.micropact.com/Lookup/LicenseLookup.aspx) | **Failed/restricted:** no result set read and no provider status established. |\n| **S_IL-P1-S016** | **Illinois Register archive** — SOS; IL | [https://www.ilsos.gov/departments/index/register.html](https://www.ilsos.gov/departments/index/register.html?utm_source=chatgpt.com) | **Read:** latest listed issue42 at access; electronic-copy disclaimer. Publisher says electronic copies are not the official authoritative print publication. |\n| **S_IL-P1-S017** | **Illinois Register 50, issue39** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf?utm_source=chatgpt.com) | **9/25/2026**; contents and relevant text-find checks read; no debt-management/settlement amendment identified. Not a claim to have read every unrelated rule. |\n| **S_IL-P1-S018** | **Illinois Register 50, issue40** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf?utm_source=chatgpt.com) | **10/2/2026**; same bounded contents/text check; no relevant amendment identified. |\n| **S_IL-P1-S019** | **Illinois Register 50, issue41** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf?utm_source=chatgpt.com) | **10/9/2026**; same bounded check; no relevant amendment identified. |\n| **S_IL-P1-S020** | **Illinois Register 50, issue42** — SOS; IL | [https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf](https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf?utm_source=chatgpt.com) | **10/16/2026**; same bounded check; no relevant amendment identified. |\n| **S_IL-P1-S021** | **16 CFR Part310, Telemarketing Sales Rule** — eCFR/FTC; federal | [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com) | **Read:** §310.2 debt-relief/telemarketing definitions; **§310.4(a)(5)(i)(A)–(C), (ii)(A)–(E)**; relevant §310.6 exemptions. Current retrieved regulation; exact federal baseline, not Illinois permission. |\n| **S_IL-P1-S022** | **Debt Relief Services & the TSR: A Guide for Business** — FTC; federal | [https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com) | **Read:** “Who’s Covered,” fee collection, nonprofit/attorney discussion. **Staff guidance, nonbinding**, subordinate to regulation and jurisdictional law. |\n| **S_IL-P1-S023** | **2025 Illinois Code reproduction, 225 ILCS429** — Justia; secondary IL reproduction | [https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/](https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/?utm_source=chatgpt.com) | **Read as secondary cross-check:** especially §135(a)–(d). Version lacks new2026§78. Not sufficient alone to establish current law; five-day/retention details held. |\n| **S_IL-P1-S024** | **P.A.104-520 full-text route** — ILGA; IL | [https://my.ilga.gov/Legislation/PublicActs/View/104-0520](https://my.ilga.gov/Legislation/PublicActs/View/104-0520?utm_source=chatgpt.com) ; [https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf](https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf) | **Failed:** HTML/PDF routes unavailable. Enactment supported by S002/S007; complete enacted text and exact settlement§78 clauses not read. |\n| **S_IL-P1-S025** | **Current 38 Ill. Adm. Code Part140** — ILGA/JCAR; IL | [https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140](https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140&utm_source=chatgpt.com) | **Failed:** current whole-Part and individual legacy routes returned502/inaccessible responses. §§140.60/.70 indexed text was discovery, not a direct read. S003/S004 supply only the actually retrieved adoption/amendment text. |\n| **S_IL-P1-S026** | **Credit Services Organizations Act, 815 ILCS605** — ILGA; IL adjacent boundary | [https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True](https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True&utm_source=chatgpt.com) | **Failed:** current Act/individual-section routes unavailable. Definitions, exclusions, registration, and credit-repair fee permission not established in this pass. |\n\n# C. Claim table\n\n“High” below means strong support for the stated, bounded proposition from the actually read source. It does not imply completion of every related legal issue.\n\n| Claim ID | Precise assertion | Sources / pinpoints | Conditions, currentness, and confidence limits |\n| --- | --- | --- | --- |\n| **S_IL-P1-C001** | Compensated unsecured-debt reduction/intermediation and settlement-fund accumulation assistance can be settlement services; soliciting for or acting on behalf of a provider can be covered. | S001 §10, “debt settlement provider/service.” | **High—text.** Primary purpose and enumerated exclusions matter; custody unnecessary. |\n| **S_IL-P1-C002** | DMSA coverage includes the financial-planning/payment-distribution definition and its express solicitation-of-creditor-contributions language; defined settlement services are excluded. | S002 §2. | **High—text.** Preserve statutory syntax; no categorical noncustody escape. |\n| **S_IL-P1-C003** | Defined credit counseling is excluded only while performing the defined counseling activities; that exclusion does not establish credit-repair or loan-procurement fee permission. | S002 §2, “credit counselor,” exclusion(g); S026. | Counseling exclusion verified; current adjacent CSO rules **held**. |\n| **S_IL-P1-C004** | DMSA expressly reaches Illinois location or solicitation/contracts with Illinois debtors; settlement licensing addresses locations doing business with Illinois residents. | S002 §2; S001 §25. | **High—text.** Passive-site and disputed nexus applications unresolved. |\n| **S_IL-P1-C005** | The reviewed definitions contain no simple household-purpose-only limitation; DMSA expressly includes business entities as persons. | S001 §10; S002 §2. | **High—text; limited application confidence.** No blanket business-debt exemption approved. |\n| **S_IL-P1-C006** | Federal student-loan relief can be covered without principal reduction, and its fees must comply with §125. | S001 §10; §125(e). | **High.** Lower monthly payments alone do not establish the defined savings/full-satisfaction trigger. |\n| **S_IL-P1-C007** | Attorney exclusions require Illinois authorization and actual law practice; specified settlement professional exclusions require ordinary professional activity/entity conditions. | S001 §10; S002 §2(a). | **High—conditions.** Entity-specific attorney affiliation model not approved. |\n| **S_IL-P1-C008** | Institutional exclusions are limited to enumerated institutions and their statutory authorization/ordinary-business conditions. | S001 §10, provider exclusion(3); S002 §2(b)–(c). | **High.** A bank relationship does not automatically transfer an exclusion. |\n| **S_IL-P1-C009** | Settlement nonprofit exclusion requires the cumulative tax-status/501(q)/DMSA conditions; DMSA has no blanket nonprofit exclusion. | S001 §10, exclusion(6); S002 §§2,5. | **High.** Nonprofit marketing or incorporation alone insufficient. |\n| **S_IL-P1-C010** | Settlement has conditional employee, licensed-collector, official/court, business-liquidation, real-estate, higher-education, and education-loan-service exclusions. | S001 §10. | **High—text.** Each actor must satisfy its specific activity conditions. |\n| **S_IL-P1-C011** | DMP exclusions include specified attorneys/institutions/escrow actors, court actors, employers, bill-payment services, and credit counselors; outside employee-benefit DMP vendors must be licensed. | S002 §2(a)–(g). | **High.** Money-transmission cross-reference reconciliation remains open. |\n| **S_IL-P1-C012** | No unlimited standalone self-creditor exemption was established; actual service definition and specific lender/collector exclusions control. | S001 §10; S002 §2. | Text-based boundary; own-receivable and separate paid-adviser facts must be distinguished. |\n| **S_IL-P1-C013** | Covered settlement and DMP businesses have statutory licensing pathways and must obtain the required license before operating; an unlicensed DMP contract is void under §16(b). | S001 §15; S002 §§3,16(b). | **High.** Permission is activity-specific, not inferred from a regulator directory. |\n| **S_IL-P1-C014** | Settlement entry requires application/fitness/location conditions; retrieved rules impose $100,000 bond floor, $30,000 net worth, six months’ experience, $350 application and $1,000 annual agency fees. | S001 §§20,25,30; S003 §§145.40–.50, pp.6373–6376. | **High for retrieved schedule.** Higher bond possible; NMLS extras/current checkout not verified. |\n| **S_IL-P1-C015** | DMP entry requires application/fitness/location conditions, $25,000 bond floor, positive net worth and six months’ experience; statute states $30 investigation/$100 license and renewal fees. | S002 §§4–6; S003 §140.40, p.6355. | **High for retrieved schedule.** Full bond formula and checklist remain later/held. |\n| **S_IL-P1-C016** | Noncustodial settlement may avoid establishing a trust account under §65(d), but remains subject to licensing when otherwise covered. | S001 §§15,65(d); S003 §145.105. | **High.** Exception concerns funds, not provider status. |\n| **S_IL-P1-C017** | Settlement savings use contract-entry outstanding balance less creditor payment for full satisfaction; settlement fee cannot exceed15% of that savings. | S001 §10, principal/savings; §125(c). | **High.** No later balance inflation; zero/negative savings yields no success fee. |\n| **S_IL-P1-C018** | Only one enrollment charge up to$50 is permitted under the stated exception; additional setup/upfront/maintenance fees are barred. | S001 §125(a)–(b); S003 §145.5. | **High.** Old generic fee-definition language does not override the prohibition; federal timing separate. |\n| **S_IL-P1-C019** | Settlement-fee collection requires the enforceable full-satisfaction agreement and provision of its specified funds to the creditor. | S001 §125(d). | **High—text.** First-installment-only permission **not established**; controlling construction held. |\n| **S_IL-P1-C020** | No separate fixed per-debt fee, further program-dollar cap, or mandatory enrollment credit was found; statements/proof/receipts cannot generate extra charges. | S001 §125; S003 §§145.70(i),145.120(b), pp.6378,6382. | Negative findings limited to retrieved provisions. Prior fees count within the relevant ceiling; federal allocation still applies. |\n| **S_IL-P1-C021** | DMP initial counseling is capped at$50 per debtor; additional fees after completion of initial counseling are capped at$50/month. | S002 §12(1)–(2). | **High.** No current creditor-count or disbursement-percentage alternative established. |\n| **S_IL-P1-C022** | One DMP monthly service fee may be earned per defined anniversary month; stopped-payment earning is limited by the rule’s30-day/next-contract-date language. | S003 §140.50(c)(1),(i), pp.6356–6357. | **High for retrieved rule.** No invented daily-proration or future-month precollection permission. |\n| **S_IL-P1-C023** | Written DMP cancellation takes effect first day of following month; no separate exit penalty is authorized by current§12. | S003 §140.50(b)(2)–(3),(c)(2); S002 §12. | **High.** General refund deadline and automatic earned-fee reversal not established. |\n| **S_IL-P1-C024** | Settlement disclosures/contracts must recognize cancellation and refund of unearned fees and funds not paid to creditors. | S001 §§115(c),120(c)(14). | **High—primary read.** Detailed §135 mechanics separately held. |\n| **S_IL-P1-C025** | Five-business-day refund/accounting, material-violation trigger, and “application fee” retention are reported by the read2025§135 reproduction. | S023 §135(a)–(d); current S001§135 route failed. | **Provisional/held.** Not asserted as freshly primary-verified current permission or deadline. |\n| **S_IL-P1-C026** | No CPI formula or adjusted consumer-fee figure was established; retrieved statutes/rules support the stated fixed caps, with no relevant intervening amendment found in the bounded check. | S001§125; S002§12; S003–S006; S016–S020. | **High for retrieved amounts; bounded currentness.** No invented CPI adjustment. |\n| **S_IL-P1-C027** | Fee-amendment rulemaking authority was enacted effective6/26/2026; it does not itself change a numerical fee. | S002§6.5; S007 HB5384; S024. | Enactment verified. Exact settlement§78/full Public Act language **held**. |\n| **S_IL-P1-C028** | HB4814’s proposed percentage/tier fees and HB1289’s replacement scheme were not established as enacted law; November2026 agenda is planning only. | S006 pp.8977–8978; S008–S009. | **High for observed status.** Proposed numbers excluded from operative examples. |\n| **S_IL-P1-C029** | Covered settlement and DMP providers are prohibited from the specified receipt/payment of customer-referral consideration. | S003§145.70(d)–(e), p.6378; S002§13(3). | **High.** Actual advertising-versus-referral characterization remains fact dependent. |\n| **S_IL-P1-C030** | DMP licensees face prohibitions on loans, loan brokerage, specified credit-card/customer procurement, compulsory ancillary purchases, and another business at the licensed location. | S002§13(2),(4)–(7). | **High.** A license is not authorization for those prohibited combinations. |\n| **S_IL-P1-C031** | IDFPR publicly provides both application routes through NMLS; current checklist contents were not retrievable. | S010; S013–S014. | Route verified; procedure details **partial**. No submission or license grant. |\n| **S_IL-P1-C032** | IDFPR’s lookup directory includes both license categories, but no named provider’s status was established. | S011; S015. | Directory verified; endpoint/results **unresolved**. |\n| **S_IL-P1-C033** | TSR debt-relief coverage includes relevant telemarketing/inbound-ad-response activity; attorney/nonprofit labels do not by themselves establish exclusion. | S021§§310.2,310.6; S022 “Who’s Covered.” | **High—bounded federal context.** Entity jurisdiction/exemptions require actual facts. |\n| **S_IL-P1-C034** | Covered TSR fees may not be requested or received before a qualifying customer-executed agreement, at least one customer payment, and applicable allocation compliance. | S021§310.4(a)(5)(i)(A)–(C). | **High—regulation.** State conditions also apply. |\n| **S_IL-P1-C035** | Individual-debt fees must satisfy TSR proportional allocation or consistent savings-percentage rules; dedicated-account deposits are subject to separate ownership/independence/return conditions. | S021§310.4(a)(5)(i)(C),(ii). | **High.** Account placement does not make provider fees earned. |\n| **S_IL-P1-C036** | Illinois’s enrollment/counseling ceilings do not excuse a covered federal advance fee; federal first payment does not override the Illinois settlement trigger. | S001§125; S002§12; S021§310.4(a)(5). | **High—combined application.** Examples expressly assume or hold the relevant conditions. |\n| **S_IL-P1-C037** | Additional settlement§145 third-party-compensation/gift provisions were located in secondary text, but the current operative primary passage was not reached. | S023§145(9)–(10); S001 current§145 failed. | **Held.** No third-party-funded workaround approved. Verified referral prohibitions remain independently applicable. |\n| **S_IL-P1-C038** | Exclusion from one of these Acts does not establish unrestricted fees under other applicable law. | S001§10; S002§2; S021; S026. | Legal boundary inference. Actual attorney, credit-services, lending, and federal analyses remain necessary where implicated. |\n\n# D. Worked examples and coverage/gap table\n\n## Worked examples\n\nAll examples use **U.S. dollars**. Arithmetic is exact to cents; no rounding is needed. No statutory rounding rule is inferred. Unless the example identifies a failure, assume the correct license, a lawful agreed fee, required disclosures and contract, and all applicable state and federal conditions.\n\n### E1 — Later balance growth does not enlarge settlement savings\n\n**Claims:** C017–C019.\n\nPlain text\n```\nInputs:\nBalance at service-contract entry = $10,000.00\nLater balance = $12,000.00\nAmount paid for full creditor satisfaction = $7,000.00\nEnrollment fee = $0.00\n\nBase:\n$10,000.00 - $7,000.00 = $3,000.00 statutory savings\n\nOperator:\n$3,000.00 x 0.15 = $450.00\n\nResult:\nMaximum settlement fee = $450.00, after all earning/payment conditions.\nUsing the later balance would produce $750.00; that is the wrong base.\n```\n\n### E2 — One debt settled; another unresolved; earlier fee already paid\n\n**Claims:** C017, C019–C020, C035.\n\nPlain text\n```\nInputs:\nDebt A enrollment balance = $10,000.00\nDebt B enrollment balance = $20,000.00\nDebt A fully settled and paid = $4,000.00\nDebt B remains unresolved.\nPrior lawful fee paid for Debt A, after its earning conditions = $400.00\nAgreed fee percentage = 15%; enrollment fee = $0.00\n\nDebt A savings:\n$10,000.00 - $4,000.00 = $6,000.00\n\nDebt A total fee ceiling:\n$6,000.00 x 0.15 = $900.00\n\nRemaining ceiling:\n$900.00 - $400.00 = $500.00\n\nResult:\nAt most $500.00 further for Debt A, subject to the agreement.\nCurrent success fee for unresolved Debt B = $0.00.\nThe full $30,000.00 enrolled balance is not a savings base.\n```\n\n### E3 — Installment settlement: federal first payment does not settle the state issue\n\n**Claims:** C019, C034, C036.\n\nPlain text\n```\nInputs:\nEnrollment balance = $10,000.00\nCreditor agrees to $4,000.00 in four $1,000.00 installments.\nThe agreement requires all four installments for full satisfaction.\nOnly one installment has been paid.\n\nProjected savings if completed:\n$10,000.00 - $4,000.00 = $6,000.00\n\nProjected fee ceiling:\n$6,000.00 x 0.15 = $900.00\n\nCurrent approved collection in this investigation:\n$0.00; hold the $900.00 pending the Illinois condition or authoritative\ninterpretation.\n\nReason:\nA first payment can satisfy one TSR condition, but does not establish\nthat Illinois's specified settlement funds have been provided.\n```\n\nThis is a text-based hold, not a claim that a controlling court has decided every installment arrangement.\n\n### E4 — Lower debt and zero/negative savings\n\n**Claim:** C017.\n\nPlain text\n```\nCase A:\nEnrollment balance = $600.00\nFull settlement payment = $500.00\nSavings = $600.00 - $500.00 = $100.00\nFee ceiling = $100.00 x 0.15 = $15.00\nEnrollment fee assumed waived.\nResult: $15.00 maximum success fee; no $50 minimum success fee.\n\nCase B:\nEnrollment balance = $8,000.00\nLater balance = $9,500.00\nFull settlement payment = $8,300.00\nBaseline difference = $8,000.00 - $8,300.00 = -$300.00\nResult: success fee = $0.00.\nReduction below the later balance may still be covered settlement activity.\n```\n\n### E5 — State enrollment ceiling with an unmet federal trigger\n\n**Claims:** C018, C034–C036.\n\nPlain text\n```\nInputs:\nFor-profit provider; covered debt-relief telemarketing transaction.\nRequested enrollment charge = $50.00.\nNo debt terms changed; no qualifying customer payment.\n\nState enrollment ceiling = $50.00.\nFederal fee amount requestable/receivable at this stage = $0.00.\n\nResult:\nThe provider may not request or receive the $50.00 now.\nThe state ceiling supplies no federal advance-fee exception.\n```\n\n### E6 — DMP ordinary fees after required performance\n\n**Claims:** C021–C022, C036.\n\nPlain text\n```\nInputs:\nOne debtor; initial counseling completed.\nAgreed initial counseling fee = $40.00.\nAgreed monthly fee = $35.00.\nThree eligible, earned service months; federal conditions satisfied.\n\nInitial:\nmin($40.00, $50.00) = $40.00\n\nMonthly:\nmin($35.00, $50.00) = $35.00\n\nTotal:\n$40.00 + (3 x $35.00) = $145.00\n\nResult:\n$145.00 across the completed services.\nThis is not permission to collect future months upfront.\n```\n\n### E7 — DMP additional processing charge and small-debt boundary\n\n**Claims:** C021–C022.\n\nPlain text\n```\nInputs:\n$35.00 monthly fee already charged in the same applicable month.\nProposed additional processing charge = $25.00.\n\nCombined:\n$35.00 + $25.00 = $60.00\n\nExcess above monthly ceiling:\n$60.00 - $50.00 = $10.00\n\nResult:\nThe proposed combined charge exceeds the limit by $10.00.\nThe remaining $15.00 of numerical headroom is not automatically earned\nor contractually authorized.\n\nSmall-debt variation:\nA single $600.00 debt does not authorize a $60.00 monthly fee.\nThe same proposed excess is $10.00 per month.\n```\n\n### E8 — DMP cancellation\n\n**Claim:** C023.\n\nPlain text\n```\nInputs:\nWritten cancellation received October 20.\nProvider demands a separate $100.00 exit charge.\n\nRule effective date:\nFirst day of the following month = November 1.\n\nAuthorized separate cancellation penalty under the read §12:\n$0.00.\n\nResult:\nThe $100.00 exit charge is not authorized.\nNo automatic refund of all properly earned prior fees is assumed.\nNo daily-proration formula is invented.\n```\n\n### E9 — Settlement cancellation with unearned money\n\n**Claims:** C024–C025.\n\nPlain text\n```\nInputs:\nUnused consumer settlement funds held = $1,200.00.\nUnearned fees erroneously collected = $200.00.\nEnrollment fee = $0.00; earned settlement fees = $0.00.\n\nRefund components:\n$1,200.00 + $200.00 = $1,400.00.\n\nResult:\n$1,400.00 falls within the verified unspent-funds/unearned-fees refund right.\n\nDeadline:\nThe reported five-business-day §135 deadline remains held for a current\nprimary read; this example does not certify that deadline.\n```\n\n### E10 — Paid-referral and student-payment-reduction boundaries\n\n**Claims:** C006, C029, C037.\n\nPlain text\n```\nReferral case:\nA covered provider proposes paying $150.00 for each referred customer.\nThe verified referral prohibition applies.\nPermitted payment for that prohibited referral arrangement = $0.00.\nLicensing does not make the $150.00 payment permissible.\nA different advertising arrangement requires its own factual classification.\n\nStudent-loan case:\nMonthly payment changes from $400.00 to $150.00.\nMonthly difference = $250.00.\nNo debt has been paid in full satisfaction.\n\nResult:\n$250.00 is not the verified statutory savings base.\nNo 15%-of-monthly-payment-reduction success fee is established.\nDo not invent a licensed fee scenario from that calculation.\n```\n\n## Component coverage and exact next investigations\n\n| Component | Status | Claims | Missing evidence / exact next investigation |\n| --- | --- | --- | --- |\n| Ordinary settlement versus DMP classification | **Answered**, with hybrid boundary | C001–C002 | For a hybrid model, obtain actual representations, agreement, compensation terms, and fund flows; determine primary purpose and which statutory definition applies. |\n| Custodial/noncustodial distinction | **Answered for license boundary** | C001, C002, C016 | Full trust/account-control obligations remain later. Noncustody does not establish settlement-license exemption. |\n| Remote/resident nexus | **Answered textually; application partial** | C004 | Establish actual Illinois solicitation/contracts and locations. Research controlling nexus interpretation if a passive-site-only theory is proposed. |\n| Consumer/business purpose | **Partial** | C005, C010 | Obtain official interpretation or controlling decisions for the specific commercial/corporate model; test liquidation exception on facts. |\n| Attorney/nonprofit/institutional exclusions | **Answered as conditional statutory tests** | C007–C012, C038 | Verify the actual entity, licenses, professional conduct, tax status, and ordinary-business conditions before approving a particular exemption. |\n| Core licensing pathways | **Answered** | C013–C016 | Complete current application checklist and actual provider/location status before any market-entry determination. |\n| Consumer cap amounts and bases | **Answered from retrieved law** | C017–C022, C026 | No adjusted CPI figure established. Any claimed different amount must be supported by an effective amending rule or statute. |\n| Settlement installment-fee maturity | **Unresolved interpretation** | C019, C036 | Locate controlling judicial or formal agency interpretation of §125(d)’s funding condition for installment settlements; examine the actual creditor release terms. |\n| Settlement basic cancellation/refund | **Answered** | C024 | §§115/120 support the basic right. |\n| Detailed settlement refund/retention rules | **Held** | C025 | Recover current **§135**, or enacted P.A.96-1420 plus amendment history. Failed route: [https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html](https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html). Resolve five-day deadline, material violation, and “application fee” wording. |\n| Additional settlement compensation prohibitions | **Partial** | C029, C037 | Recover current **§145(9)–(10)** or readable enacted P.A.102-298 pages. Failed route: [https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html](https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html). Verified referral rules already apply. |\n| Full relevant DMP rule text | **Partial** | C021–C023, C029; S025 | Obtain current **§§140.60 and140.70**, or official1998 adoption **22 Ill.Reg.12550**, and reconcile with later amendments. Do not count indexed excerpts as the missing read. |\n| 2026 fee-rulemaking authority | **Enactment answered; full text partial** | C027 | Recover complete **P.A.104-520** and settlement **§78**; verify exact scope. Inspect any subsequent first-notice/adoption before using a changed fee. |\n| Proposed/historical material | **Answered for identified conflicts** | C026–C028 | Do not apply HB4814/HB1289 proposals, November agenda, or2011 transition language as current permission. |\n| Current application procedure | **Partial** | C031 | Recover dated, readable Illinois DMP and settlement NMLS checklists, including any current filing-system charges and entity/branch instructions. |\n| Named provider authorization | **Unresolved; not asserted** | C032 | Obtain actual lookup results for legal entity and locations; inspect status, dates, restrictions, and relevant orders. No marketing statement substitutes for this. |\n| Federal TSR timing interface | **Answered as common baseline** | C033–C036 | Determine actual telemarketing campaign, jurisdiction, exemption facts, and fee allocation for the proposed model. Full federal compliance review remains open. |\n| Pure counseling/credit repair/credit procurement | **Partial adjacent boundary** | C003, C030, C038 | Recover **815 ILCS605 §§3,5,9,10**, amendment history and current registration instructions; then examine independently applicable federal credit-repair timing. No fee pathway approved here. |\n| Agreements, funds, bonds, and remedies | **Later required pass; narrow provisions only here** | C014–C016, C023–C025, C035 | Read complete operative agreement/disclosure, trust/dedicated-account, disbursement, bond, cancellation, enforcement, and remedy provisions; reconcile statute/rule conflicts. |\n| Collection, litigation, limitations, property exemptions | **Open; excluded from this component** | — | Separate statutory and controlling-case investigations required. No conclusions carried over by implication. |\n| Secured debt, sector-specific, local, tribal, full contract and case-law coverage | **Open; excluded except necessary boundaries** | C001, C006, C038 | Separate investigations required. Student-loan classification here does not complete the student-loan sector pass. |\n| Illinois-wide / A066 acceptance | **Not granted** | — | Remaining evidence holds and later required passes must be resolved under their own acceptance criteria. |\n\n# E. Researcher self-check\n\n**Actually read:** The statute passages listed in S001–S002; the original Part145 adoption and its 2022 amendments; the retrieved DMP adoption/amendment passages, including §§140.40–.50; the official rule index, agenda, and bounded post-index Register checks; IDFPR’s actual licensing/application and lookup-directory pages; the exact TSR fee provision and relevant coverage provisions; and the Governor’s actual HB5384 signing announcement.\n\n**Not represented as read:** The full current Part140, especially §§140.60/.70; current settlement §§78,135,145 and other later-pass provisions that could not be reached; the complete P.A.104-520 text; readable current NMLS checklists; a functioning provider-specific lookup result; or controlling merits decisions resolving the installment and entity-exemption questions. Some official PDFs opened only their initial displayed passages, while attempts to reach later sections failed. Those initial opens were not counted as reading the missing provisions.\n\n**Secondary and discovery handling:** Justia’s 2025 §135 text was actually read but remains secondary corroboration. Search excerpts, proposed bills, historical transition language, and regulator titles were not substituted for operative permission. No controlling decision is relied upon, and the limited unsuccessful case search is not a conclusion that no relevant case exists.\n\n**Research mode:** This was ordinary conversational research with primary web browsing, not Deep Research. Parallel research streams were used within the investigation; they are not labeled independent review or separate regular-Chat conversations. The chatgpt.com UI model selector was not observable here, so I do not certify the requested “actualGPT6Pro” setting.\n\nEND S_IL PASS-01\n\n","tables":[{"headers":["Actual conduct","Illinois classification and consequence","Claims"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Actual conduct","Illinois classification and consequence","Claims"],["Compensated advice, negotiation, or intermediation whose primary purpose is to settle, adjust, or satisfy unsecured debt below its defined principal amount or current outstanding balance","Falls within the ordinary debt-settlement definition, unless a specified exclusion applies. Calling it “negotiation,” “consulting,” or “debt adjustment” does not establish an exemption.","C001"],["Helping, encouraging, or counseling a consumer to accumulate money for such settlements","Expressly within settlement services. The provider need not possess the settlement money.","C001, C016"],["Planning and managing a debtor’s financial affairs for a fee, receiving money for distribution to creditors in full or partial payment, or conduct involving the definition’s express creditor-contribution limb","Analyze under the Debt Management Service Act. Its definition includes soliciting financial contributions from creditors; it should not be rewritten as an invariably custody-only test.","C002"],["A repayment/distribution plan that repays the relevant debt balance while obtaining concessions on future interest or payment terms","A typical DMP candidate, subject to the actual statutory definition. A concession reducing an existing balance can instead implicate settlement coverage when that reduction is the service’s primary purpose.","C001–C002"],["Budgeting, financial-literacy, saving/spending, or personal-finance counseling without performing covered DMP or settlement activity","The DMSA defines and conditionally excludes a “credit counselor” providing those services. This does not establish unrestricted permission to charge for credit repair, credit improvement, or loan procurement.","C003"],["Federal student-loan assistance involving repayment-plan enrollment, forbearance, deferment, consolidation, or changes to rates, payments, or fees","Special statutory student-loan-relief coverage can apply without a principal reduction. Its fees remain subject to §125; a lower monthly payment is not itself the statutory savings base.","C006"],["A compensated business soliciting for or acting on behalf of a settlement provider","The settlement-provider definition can reach the intermediary. A referral or marketing label is not a reliable coverage exclusion, and separate referral-payment prohibitions apply.","C001, C029"]]},{"headers":["Model","Governing permission","Entry conditions material to this pass"],"index":1,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Model","Governing permission","Entry conditions material to this pass"],["Covered debt settlement","225 ILCS 429/15, 20, 25; IDFPR Secretary; 38 Ill. Adm. Code Part 145","License before acting; sworn application; financial and character fitness; location-specific licensing; statutory bond floor of $100,000, potentially higher; rule-based net worth of at least $30,000 and at least six months’ relevant experience."],["Covered debt management","205 ILCS 665/3–5; IDFPR Secretary; 38 Ill. Adm. Code Part 140","License before covered business; sworn application; financial and character fitness; location-specific licensing; bond floor of $25,000, potentially higher; positive net worth and at least six months’ relevant experience under the rule."],["Noncustodial settlement","Same settlement license pathway","Section 65(d)’s exception from establishing a trust account, where the provider holds or controls no consumer funds other than earned settlement fees, is not a license exemption."],["Paid customer referrals involving covered providers","Subject to the prohibitions described below","A license does not authorize compensation that the statute or rule prohibits."]]},{"headers":["Actor or model","Settlement Act","Debt Management Service Act"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Actor or model","Settlement Act","Debt Management Service Act"],["Attorney","Illinois licensure or authorization and actual practice of law are required. An attorney’s ownership, affiliation, referral, or nominal participation alone does not establish the exclusion.","Likewise requires Illinois authorization and actual practice of law, within the regular course of the profession."],["Nonprofit","The specified exclusion is cumulative: 501(c)(3) status, being subject to 501(q), exemption under 501(a), and being governed by the DMSA.","No blanket nonprofit exclusion. Nonprofits are included in the Act’s entity definitions and licensing provisions."],["Banks and other financial institutions","Enumerated banks, bank agents/operating subsidiaries/affiliates, trust companies, savings institutions, credit unions, specified credit/development entities, title insurers/agents, independent escrowees, insurers, and authorized lenders have stated statutory conditions, including operation under applicable law and ordinary-business limitations.","Enumerated banks, operating subsidiaries/affiliates, fiduciaries, credit unions, and savings institutions must be authorized/admitted to transact Illinois business and perform the relevant adjusting services in their ordinary principal business."],["Escrow, accounting, securities professionals","Specified professionals must act in their ordinary profession through the ordinary professional entity.","Title insurers, agents, independent escrowees, and abstract companies are excluded while doing escrow business; no general exclusion for every accountant or financial adviser was established."],["Employer/employee arrangements","Regular salaried or wage employees performing credit services for an employer that is not in the settlement business are excluded.","Employers acting for employees are excluded. An outside DMP vendor serving the employer’s employees must be licensed."],["Collection agency","A collection agency licensed under the Collection Agency Act, collecting its own or third-party debt, is expressly excluded.","No comparable general collection-agency exclusion was established from §2."],["Public/court actors","Public officers acting officially and persons acting under court order.","Judicial officers and persons acting under court order."],["Other specified actors","Services incidental to business dissolution/winding up/liquidation; real-estate licensees acting ordinarily without holding out as settlement providers; qualifying higher-education institutions. Defined student-loan servicers and other education-loan originators, guarantors, or servicers also receive service-definition exclusions.","Defined bill-payment services and defined credit counselors, while performing the excluded activities. The bill-payment cross-reference needs reconciliation with the newer money-transmission framework in a later pass."]]},{"headers":["Fee","Verified Illinois rule","Base and limits"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Fee","Verified Illinois rule","Base and limits"],["Settlement enrollment","§125(b): one-time enrollment fee up to $50","Not $50 per creditor, settlement, or month. Federal timing remains separate."],["Settlement success fee","§125(c): up to 15% of savings","Savings use the debt balance at contract entry, less the amount actually paid to the creditor for full and complete satisfaction."],["Settlement monthly maintenance, additional setup, or other upfront fees","§125(b) prohibits these outside the limited enrollment exception","A generic rule definition mentioning a fee does not authorize a fee prohibited by the statute."],["Settlement statements, proof of payment, receipts","Rules 145.70(i), 145.120(b) prohibit these charges","They cannot be added as independent administrative fees."],["DMP initial counseling","§12(1): up to $50 per debtor counseled","A fee for the initial counseling, not a repeated setup charge for each debt."],["DMP additional fees","§12(2): up to $50 per month, at completion of initial counseling","No verified per-creditor supplement or current percentage-of-disbursement formula. All additional monthly charges must fit the limit and other conditions."]]},{"headers":["Material","Status and consequence"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Material","Status and consequence"],["Current §125 and §12","Support the $50 / 15%-of-savings settlement structure and $50 / $50-monthly DMP structure."],["2011 adopted rules","Effective March 29, 2011. They establish relevant licensing, earning, cancellation, and prohibited-fee rules. Their historical transition deadline is not current permission to operate before licensing."],["2022 adopted amendments","Effective July 8, 2022. The retrieved amendments concern hearing/procedure provisions, not new consumer-fee amounts."],["September 18, 2026 Title 38 index","Lists the 2022 amendments as the latest amendments to Parts 140 and 145. The index-update date is not a legal effective date."],["Register issues 39–42, September 25–October 16, 2026","Contents and relevant text searches did not identify intervening Part 140/145 fee amendments. This is a bounded published-record check, not a guarantee about an unlocated filing."],["P.A. 104-520 / HB5384","New fee-amendment rulemaking authority is enacted. DMSA §6.5 was actually read; the Governor’s June 26, 2026 announcement confirms signing and immediate effectiveness. Full Public Act text and exact settlement §78 language remain held. Authority to amend fees is not itself a changed fee amount."],["July 2026 regulatory agenda","Anticipates first notice in November 2026 for Parts 140/145. It is planning material, not an adopted fee change. Its “if signed” wording does not override the actual June 26 signing."],["HB4814","Proposed DMP percentage/creditor-tier fees—15% of monthly disbursements, with proposed $75/$100 caps—were not established as enacted law. They must not replace current §12."],["HB1289","Proposed replacement Debt Resolution Services Act; the retrieved status does not establish enactment. Its prospective provisions are not current authorization."]]},{"headers":["Source ID","Title / issuer / jurisdiction","Direct literal URL(s)","Exact pinpoint, version, legal status, and access limitation"],"index":5,"links":[{"href":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS,+OCCUPATIONS,+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION"},{"href":"https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm","text":"https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm"},{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html?utm_source=chatgpt.com","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html"},{"href":"https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm","text":"https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm"},{"href":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION&utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION"},{"href":"https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12&utm_source=chatgpt.com","text":"https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12"},{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html?utm_source=chatgpt.com","text":"https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf"},{"href":"https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz?utm_source=chatgpt.com","text":"https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz"},{"href":"https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114&utm_source=chatgpt.com","text":"https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114"},{"href":"https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114","text":"https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114"},{"href":"https://idfpr.illinois.gov/dfi/ccd/ccd-main.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/dfi/ccd/ccd-main.html"},{"href":"https://idfpr.illinois.gov/dfi/dfilicenselookup.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/dfi/dfilicenselookup.html"},{"href":"https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html"},{"href":"https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL&utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL"},{"href":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf?utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf"},{"href":"https://online-obre.micropact.com/Lookup/LicenseLookup.aspx","text":"https://online-obre.micropact.com/Lookup/LicenseLookup.aspx"},{"href":"https://www.ilsos.gov/departments/index/register.html?utm_source=chatgpt.com","text":"https://www.ilsos.gov/departments/index/register.html"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf"},{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"},{"href":"https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/"},{"href":"https://my.ilga.gov/Legislation/PublicActs/View/104-0520?utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/PublicActs/View/104-0520"},{"href":"https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf","text":"https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf"},{"href":"https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140&utm_source=chatgpt.com","text":"https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140"},{"href":"https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True&utm_source=chatgpt.com","text":"https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True"}],"row_links":[[],[{"href":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS,+OCCUPATIONS,+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION"},{"href":"https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm","text":"https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm"},{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html?utm_source=chatgpt.com","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html"},{"href":"https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm","text":"https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm"}],[{"href":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION&utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION"},{"href":"https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12&utm_source=chatgpt.com","text":"https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12"},{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html?utm_source=chatgpt.com","text":"https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf"}],[{"href":"https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz?utm_source=chatgpt.com","text":"https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz"}],[{"href":"https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114&utm_source=chatgpt.com","text":"https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114"}],[{"href":"https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114","text":"https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114"}],[{"href":"https://idfpr.illinois.gov/dfi/ccd/ccd-main.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/dfi/ccd/ccd-main.html"}],[{"href":"https://idfpr.illinois.gov/dfi/dfilicenselookup.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/dfi/dfilicenselookup.html"}],[{"href":"https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html?utm_source=chatgpt.com","text":"https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL&utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf?utm_source=chatgpt.com","text":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf"}],[{"href":"https://online-obre.micropact.com/Lookup/LicenseLookup.aspx","text":"https://online-obre.micropact.com/Lookup/LicenseLookup.aspx"}],[{"href":"https://www.ilsos.gov/departments/index/register.html?utm_source=chatgpt.com","text":"https://www.ilsos.gov/departments/index/register.html"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf"}],[{"href":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf?utm_source=chatgpt.com","text":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"}],[{"href":"https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/?utm_source=chatgpt.com","text":"https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/"}],[{"href":"https://my.ilga.gov/Legislation/PublicActs/View/104-0520?utm_source=chatgpt.com","text":"https://my.ilga.gov/Legislation/PublicActs/View/104-0520"},{"href":"https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf","text":"https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf"}],[{"href":"https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140&utm_source=chatgpt.com","text":"https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140"}],[{"href":"https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True&utm_source=chatgpt.com","text":"https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True"}]],"rows":[["Source ID","Title / issuer / jurisdiction","Direct literal URL(s)","Exact pinpoint, version, legal status, and access limitation"],["S_IL-P1-S001","Debt Settlement Consumer Protection Act, 225 ILCS 429 — Illinois General Assembly; IL","https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION ; https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm ; https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html ; https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm","Partial current-code read: §10 definitions/exclusions; §§15, 20, 25, 30, 65; full relevant §§115, 120, 125. §§10/115/125 carry P.A.102-298, effective 8/6/2021; §120 source P.A.96-1420, effective 8/3/2010. Full current §§78, 110, 135, 145, 150 not successfully read. Later reopen failures do not erase earlier successful reads."],["S_IL-P1-S002","Debt Management Service Act, 205 ILCS 665 — ILGA; IL","https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION ; https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12 ; https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html","Read: relevant §§1–16.6, including §§2–6.5, 12, 13, 14, 16(b). Independent successful section reads for §§12–13. §2 source P.A.100-201, effective 8/18/2017; §§12–13 P.A.96-1420, 8/3/2010; §6.5 P.A.104-520, 6/26/2026. Whole-Act later reopen failed."],["S_IL-P1-S003","Illinois Register 35, issue 16 — Illinois Secretary of State; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf","Read: DMP adoption pp.6350–6363, especially §§140.40–.50, pp.6355–6357; full original Part145 adoption pp.6364–6385, including .40/.45/.50/.70/.105/.120. Published 4/15/2011, effective 3/29/2011. State-hosted reproduction; not a certified print copy."],["S_IL-P1-S004","Illinois Register 46, issue 30 — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf","Read: Part140 amendment pp.12514–12521, §§140.120/.140; Part145 amendment pp.12522–12528, §§145.80/.125. Effective 7/8/2022, published 7/22/2022. Operative additions/deletions checked; no consumer-fee change in these amendments."],["S_IL-P1-S005","Illinois Administrative Code, Title 38 index — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf","Read: document pp.5–6, Parts140/145; index updated 9/18/2026. Latest listed amendments: 46 Ill.Reg.12514 and 12522, effective 7/8/2022. Index is a currentness aid, not operative text."],["S_IL-P1-S006","Illinois Register 50, issue 27; IDFPR regulatory agenda — SOS/IDFPR; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf","Read: pp.8977–8978, items II(c)–(d), Parts140/145. Published 7/6/2026; anticipated first notice November2026. Planning, not adopted law."],["S_IL-P1-S007","“Gov. Pritzker Takes Bill Action” — Illinois Office of the Governor; IL","https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz","Read: dated 6/26/2026, HB5384 entry, lines343–348: signed, effective immediately; describes fee-rulemaking amendments. Confirms executive action, not the full statutory clauses or a changed fee schedule."],["S_IL-P1-S008","HB1289 bill status, 104th GA — ILGA; IL","https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114","Read: synopsis and actions; displayed referral to House Rules 1/28/2025. Replacement-act proposal; enactment not established."],["S_IL-P1-S009","HB4814 bill status, 104th GA — ILGA; IL","https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114","Read in parallel research: synopsis/actions; House passage4/14/2026, Senate actions through displayed7/2/2026; no Public Act established. Proposed DMP fee changes remain proposed. Subsequent reopen failed."],["S_IL-P1-S010","Consumer Credit Section — IDFPR; IL","https://idfpr.illinois.gov/dfi/ccd/ccd-main.html","Read: “Debt Management Services,” “Debt Settlement,” application links, governing Acts/rules. Current operational routing; not proof of an applicant’s authority."],["S_IL-P1-S011","DFI License Lookup — IDFPR; IL","https://idfpr.illinois.gov/dfi/dfilicenselookup.html","Read: Consumer Credit categories include both license types and link to lookup. Directory route only."],["S_IL-P1-S012","Consumer Credit FAQ/brochure — IDFPR; IL","https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html","Read: DMP fee FAQ and licensing references. Corroborates $50 initial/$50 monthly; undated operational explanation does not establish legal effective date."],["S_IL-P1-S013","Illinois NMLS application routing — NMLS, linked by IDFPR; IL application procedure","https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL","Followed, not readable: redirected to State Resource Center; no current DMP checklist text returned."],["S_IL-P1-S014","Illinois Debt Settlement New Application Checklist route — NMLS, linked by IDFPR; IL","https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf","Followed, not readable: redirected to resource center; checklist version/content unknown."],["S_IL-P1-S015","Consumer Credit license-lookup endpoint — IDFPR-linked service; IL","https://online-obre.micropact.com/Lookup/LicenseLookup.aspx","Failed/restricted: no result set read and no provider status established."],["S_IL-P1-S016","Illinois Register archive — SOS; IL","https://www.ilsos.gov/departments/index/register.html","Read: latest listed issue42 at access; electronic-copy disclaimer. Publisher says electronic copies are not the official authoritative print publication."],["S_IL-P1-S017","Illinois Register 50, issue39 — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf","9/25/2026; contents and relevant text-find checks read; no debt-management/settlement amendment identified. Not a claim to have read every unrelated rule."],["S_IL-P1-S018","Illinois Register 50, issue40 — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf","10/2/2026; same bounded contents/text check; no relevant amendment identified."],["S_IL-P1-S019","Illinois Register 50, issue41 — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf","10/9/2026; same bounded check; no relevant amendment identified."],["S_IL-P1-S020","Illinois Register 50, issue42 — SOS; IL","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf","10/16/2026; same bounded check; no relevant amendment identified."],["S_IL-P1-S021","16 CFR Part310, Telemarketing Sales Rule — eCFR/FTC; federal","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","Read: §310.2 debt-relief/telemarketing definitions; §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E); relevant §310.6 exemptions. Current retrieved regulation; exact federal baseline, not Illinois permission."],["S_IL-P1-S022","Debt Relief Services & the TSR: A Guide for Business — FTC; federal","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Read: “Who’s Covered,” fee collection, nonprofit/attorney discussion. Staff guidance, nonbinding, subordinate to regulation and jurisdictional law."],["S_IL-P1-S023","2025 Illinois Code reproduction, 225 ILCS429 — Justia; secondary IL reproduction","https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/","Read as secondary cross-check: especially §135(a)–(d). Version lacks new2026§78. Not sufficient alone to establish current law; five-day/retention details held."],["S_IL-P1-S024","P.A.104-520 full-text route — ILGA; IL","https://my.ilga.gov/Legislation/PublicActs/View/104-0520 ; https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf","Failed: HTML/PDF routes unavailable. Enactment supported by S002/S007; complete enacted text and exact settlement§78 clauses not read."],["S_IL-P1-S025","Current 38 Ill. Adm. Code Part140 — ILGA/JCAR; IL","https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140","Failed: current whole-Part and individual legacy routes returned502/inaccessible responses. §§140.60/.70 indexed text was discovery, not a direct read. S003/S004 supply only the actually retrieved adoption/amendment text."],["S_IL-P1-S026","Credit Services Organizations Act, 815 ILCS605 — ILGA; IL adjacent boundary","https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True","Failed: current Act/individual-section routes unavailable. Definitions, exclusions, registration, and credit-repair fee permission not established in this pass."]]},{"headers":["Claim ID","Precise assertion","Sources / pinpoints","Conditions, currentness, and confidence limits"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources / pinpoints","Conditions, currentness, and confidence limits"],["S_IL-P1-C001","Compensated unsecured-debt reduction/intermediation and settlement-fund accumulation assistance can be settlement services; soliciting for or acting on behalf of a provider can be covered.","S001 §10, “debt settlement provider/service.”","High—text. Primary purpose and enumerated exclusions matter; custody unnecessary."],["S_IL-P1-C002","DMSA coverage includes the financial-planning/payment-distribution definition and its express solicitation-of-creditor-contributions language; defined settlement services are excluded.","S002 §2.","High—text. Preserve statutory syntax; no categorical noncustody escape."],["S_IL-P1-C003","Defined credit counseling is excluded only while performing the defined counseling activities; that exclusion does not establish credit-repair or loan-procurement fee permission.","S002 §2, “credit counselor,” exclusion(g); S026.","Counseling exclusion verified; current adjacent CSO rules held."],["S_IL-P1-C004","DMSA expressly reaches Illinois location or solicitation/contracts with Illinois debtors; settlement licensing addresses locations doing business with Illinois residents.","S002 §2; S001 §25.","High—text. Passive-site and disputed nexus applications unresolved."],["S_IL-P1-C005","The reviewed definitions contain no simple household-purpose-only limitation; DMSA expressly includes business entities as persons.","S001 §10; S002 §2.","High—text; limited application confidence. No blanket business-debt exemption approved."],["S_IL-P1-C006","Federal student-loan relief can be covered without principal reduction, and its fees must comply with §125.","S001 §10; §125(e).","High. Lower monthly payments alone do not establish the defined savings/full-satisfaction trigger."],["S_IL-P1-C007","Attorney exclusions require Illinois authorization and actual law practice; specified settlement professional exclusions require ordinary professional activity/entity conditions.","S001 §10; S002 §2(a).","High—conditions. Entity-specific attorney affiliation model not approved."],["S_IL-P1-C008","Institutional exclusions are limited to enumerated institutions and their statutory authorization/ordinary-business conditions.","S001 §10, provider exclusion(3); S002 §2(b)–(c).","High. A bank relationship does not automatically transfer an exclusion."],["S_IL-P1-C009","Settlement nonprofit exclusion requires the cumulative tax-status/501(q)/DMSA conditions; DMSA has no blanket nonprofit exclusion.","S001 §10, exclusion(6); S002 §§2,5.","High. Nonprofit marketing or incorporation alone insufficient."],["S_IL-P1-C010","Settlement has conditional employee, licensed-collector, official/court, business-liquidation, real-estate, higher-education, and education-loan-service exclusions.","S001 §10.","High—text. Each actor must satisfy its specific activity conditions."],["S_IL-P1-C011","DMP exclusions include specified attorneys/institutions/escrow actors, court actors, employers, bill-payment services, and credit counselors; outside employee-benefit DMP vendors must be licensed.","S002 §2(a)–(g).","High. Money-transmission cross-reference reconciliation remains open."],["S_IL-P1-C012","No unlimited standalone self-creditor exemption was established; actual service definition and specific lender/collector exclusions control.","S001 §10; S002 §2.","Text-based boundary; own-receivable and separate paid-adviser facts must be distinguished."],["S_IL-P1-C013","Covered settlement and DMP businesses have statutory licensing pathways and must obtain the required license before operating; an unlicensed DMP contract is void under §16(b).","S001 §15; S002 §§3,16(b).","High. Permission is activity-specific, not inferred from a regulator directory."],["S_IL-P1-C014","Settlement entry requires application/fitness/location conditions; retrieved rules impose $100,000 bond floor, $30,000 net worth, six months’ experience, $350 application and $1,000 annual agency fees.","S001 §§20,25,30; S003 §§145.40–.50, pp.6373–6376.","High for retrieved schedule. Higher bond possible; NMLS extras/current checkout not verified."],["S_IL-P1-C015","DMP entry requires application/fitness/location conditions, $25,000 bond floor, positive net worth and six months’ experience; statute states $30 investigation/$100 license and renewal fees.","S002 §§4–6; S003 §140.40, p.6355.","High for retrieved schedule. Full bond formula and checklist remain later/held."],["S_IL-P1-C016","Noncustodial settlement may avoid establishing a trust account under §65(d), but remains subject to licensing when otherwise covered.","S001 §§15,65(d); S003 §145.105.","High. Exception concerns funds, not provider status."],["S_IL-P1-C017","Settlement savings use contract-entry outstanding balance less creditor payment for full satisfaction; settlement fee cannot exceed15% of that savings.","S001 §10, principal/savings; §125(c).","High. No later balance inflation; zero/negative savings yields no success fee."],["S_IL-P1-C018","Only one enrollment charge up to$50 is permitted under the stated exception; additional setup/upfront/maintenance fees are barred.","S001 §125(a)–(b); S003 §145.5.","High. Old generic fee-definition language does not override the prohibition; federal timing separate."],["S_IL-P1-C019","Settlement-fee collection requires the enforceable full-satisfaction agreement and provision of its specified funds to the creditor.","S001 §125(d).","High—text. First-installment-only permission not established; controlling construction held."],["S_IL-P1-C020","No separate fixed per-debt fee, further program-dollar cap, or mandatory enrollment credit was found; statements/proof/receipts cannot generate extra charges.","S001 §125; S003 §§145.70(i),145.120(b), pp.6378,6382.","Negative findings limited to retrieved provisions. Prior fees count within the relevant ceiling; federal allocation still applies."],["S_IL-P1-C021","DMP initial counseling is capped at$50 per debtor; additional fees after completion of initial counseling are capped at$50/month.","S002 §12(1)–(2).","High. No current creditor-count or disbursement-percentage alternative established."],["S_IL-P1-C022","One DMP monthly service fee may be earned per defined anniversary month; stopped-payment earning is limited by the rule’s30-day/next-contract-date language.","S003 §140.50(c)(1),(i), pp.6356–6357.","High for retrieved rule. No invented daily-proration or future-month precollection permission."],["S_IL-P1-C023","Written DMP cancellation takes effect first day of following month; no separate exit penalty is authorized by current§12.","S003 §140.50(b)(2)–(3),(c)(2); S002 §12.","High. General refund deadline and automatic earned-fee reversal not established."],["S_IL-P1-C024","Settlement disclosures/contracts must recognize cancellation and refund of unearned fees and funds not paid to creditors.","S001 §§115(c),120(c)(14).","High—primary read. Detailed §135 mechanics separately held."],["S_IL-P1-C025","Five-business-day refund/accounting, material-violation trigger, and “application fee” retention are reported by the read2025§135 reproduction.","S023 §135(a)–(d); current S001§135 route failed.","Provisional/held. Not asserted as freshly primary-verified current permission or deadline."],["S_IL-P1-C026","No CPI formula or adjusted consumer-fee figure was established; retrieved statutes/rules support the stated fixed caps, with no relevant intervening amendment found in the bounded check.","S001§125; S002§12; S003–S006; S016–S020.","High for retrieved amounts; bounded currentness. No invented CPI adjustment."],["S_IL-P1-C027","Fee-amendment rulemaking authority was enacted effective6/26/2026; it does not itself change a numerical fee.","S002§6.5; S007 HB5384; S024.","Enactment verified. Exact settlement§78/full Public Act language held."],["S_IL-P1-C028","HB4814’s proposed percentage/tier fees and HB1289’s replacement scheme were not established as enacted law; November2026 agenda is planning only.","S006 pp.8977–8978; S008–S009.","High for observed status. Proposed numbers excluded from operative examples."],["S_IL-P1-C029","Covered settlement and DMP providers are prohibited from the specified receipt/payment of customer-referral consideration.","S003§145.70(d)–(e), p.6378; S002§13(3).","High. Actual advertising-versus-referral characterization remains fact dependent."],["S_IL-P1-C030","DMP licensees face prohibitions on loans, loan brokerage, specified credit-card/customer procurement, compulsory ancillary purchases, and another business at the licensed location.","S002§13(2),(4)–(7).","High. A license is not authorization for those prohibited combinations."],["S_IL-P1-C031","IDFPR publicly provides both application routes through NMLS; current checklist contents were not retrievable.","S010; S013–S014.","Route verified; procedure details partial. No submission or license grant."],["S_IL-P1-C032","IDFPR’s lookup directory includes both license categories, but no named provider’s status was established.","S011; S015.","Directory verified; endpoint/results unresolved."],["S_IL-P1-C033","TSR debt-relief coverage includes relevant telemarketing/inbound-ad-response activity; attorney/nonprofit labels do not by themselves establish exclusion.","S021§§310.2,310.6; S022 “Who’s Covered.”","High—bounded federal context. Entity jurisdiction/exemptions require actual facts."],["S_IL-P1-C034","Covered TSR fees may not be requested or received before a qualifying customer-executed agreement, at least one customer payment, and applicable allocation compliance.","S021§310.4(a)(5)(i)(A)–(C).","High—regulation. State conditions also apply."],["S_IL-P1-C035","Individual-debt fees must satisfy TSR proportional allocation or consistent savings-percentage rules; dedicated-account deposits are subject to separate ownership/independence/return conditions.","S021§310.4(a)(5)(i)(C),(ii).","High. Account placement does not make provider fees earned."],["S_IL-P1-C036","Illinois’s enrollment/counseling ceilings do not excuse a covered federal advance fee; federal first payment does not override the Illinois settlement trigger.","S001§125; S002§12; S021§310.4(a)(5).","High—combined application. Examples expressly assume or hold the relevant conditions."],["S_IL-P1-C037","Additional settlement§145 third-party-compensation/gift provisions were located in secondary text, but the current operative primary passage was not reached.","S023§145(9)–(10); S001 current§145 failed.","Held. No third-party-funded workaround approved. Verified referral prohibitions remain independently applicable."],["S_IL-P1-C038","Exclusion from one of these Acts does not establish unrestricted fees under other applicable law.","S001§10; S002§2; S021; S026.","Legal boundary inference. Actual attorney, credit-services, lending, and federal analyses remain necessary where implicated."]]},{"headers":["Component","Status","Claims","Missing evidence / exact next investigation"],"index":7,"links":[{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html"},{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html"}],"row_links":[[],[],[],[],[],[],[],[],[],[],[{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html"}],[{"href":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html","text":"https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html"}],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Missing evidence / exact next investigation"],["Ordinary settlement versus DMP classification","Answered, with hybrid boundary","C001–C002","For a hybrid model, obtain actual representations, agreement, compensation terms, and fund flows; determine primary purpose and which statutory definition applies."],["Custodial/noncustodial distinction","Answered for license boundary","C001, C002, C016","Full trust/account-control obligations remain later. Noncustody does not establish settlement-license exemption."],["Remote/resident nexus","Answered textually; application partial","C004","Establish actual Illinois solicitation/contracts and locations. Research controlling nexus interpretation if a passive-site-only theory is proposed."],["Consumer/business purpose","Partial","C005, C010","Obtain official interpretation or controlling decisions for the specific commercial/corporate model; test liquidation exception on facts."],["Attorney/nonprofit/institutional exclusions","Answered as conditional statutory tests","C007–C012, C038","Verify the actual entity, licenses, professional conduct, tax status, and ordinary-business conditions before approving a particular exemption."],["Core licensing pathways","Answered","C013–C016","Complete current application checklist and actual provider/location status before any market-entry determination."],["Consumer cap amounts and bases","Answered from retrieved law","C017–C022, C026","No adjusted CPI figure established. Any claimed different amount must be supported by an effective amending rule or statute."],["Settlement installment-fee maturity","Unresolved interpretation","C019, C036","Locate controlling judicial or formal agency interpretation of §125(d)’s funding condition for installment settlements; examine the actual creditor release terms."],["Settlement basic cancellation/refund","Answered","C024","§§115/120 support the basic right."],["Detailed settlement refund/retention rules","Held","C025","Recover current §135, or enacted P.A.96-1420 plus amendment history. Failed route: https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html. Resolve five-day deadline, material violation, and “application fee” wording."],["Additional settlement compensation prohibitions","Partial","C029, C037","Recover current §145(9)–(10) or readable enacted P.A.102-298 pages. Failed route: https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html. Verified referral rules already apply."],["Full relevant DMP rule text","Partial","C021–C023, C029; S025","Obtain current §§140.60 and140.70, or official1998 adoption 22 Ill.Reg.12550, and reconcile with later amendments. Do not count indexed excerpts as the missing read."],["2026 fee-rulemaking authority","Enactment answered; full text partial","C027","Recover complete P.A.104-520 and settlement §78; verify exact scope. Inspect any subsequent first-notice/adoption before using a changed fee."],["Proposed/historical material","Answered for identified conflicts","C026–C028","Do not apply HB4814/HB1289 proposals, November agenda, or2011 transition language as current permission."],["Current application procedure","Partial","C031","Recover dated, readable Illinois DMP and settlement NMLS checklists, including any current filing-system charges and entity/branch instructions."],["Named provider authorization","Unresolved; not asserted","C032","Obtain actual lookup results for legal entity and locations; inspect status, dates, restrictions, and relevant orders. No marketing statement substitutes for this."],["Federal TSR timing interface","Answered as common baseline","C033–C036","Determine actual telemarketing campaign, jurisdiction, exemption facts, and fee allocation for the proposed model. Full federal compliance review remains open."],["Pure counseling/credit repair/credit procurement","Partial adjacent boundary","C003, C030, C038","Recover 815 ILCS605 §§3,5,9,10, amendment history and current registration instructions; then examine independently applicable federal credit-repair timing. No fee pathway approved here."],["Agreements, funds, bonds, and remedies","Later required pass; narrow provisions only here","C014–C016, C023–C025, C035","Read complete operative agreement/disclosure, trust/dedicated-account, disbursement, bond, cancellation, enforcement, and remedy provisions; reconcile statute/rule conflicts."],["Collection, litigation, limitations, property exemptions","Open; excluded from this component","—","Separate statutory and controlling-case investigations required. No conclusions carried over by implication."],["Secured debt, sector-specific, local, tribal, full contract and case-law coverage","Open; excluded except necessary boundaries","C001, C006, C038","Separate investigations required. Student-loan classification here does not complete the student-loan sector pass."],["Illinois-wide / A066 acceptance","Not granted","—","Remaining evidence holds and later required passes must be resolved under their own acceptance criteria."]]}],"claims":[{"claim_id":"S_IL-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C001","Precise assertion":"Compensated unsecured-debt reduction/intermediation and settlement-fund accumulation assistance can be settlement services; soliciting for or acting on behalf of a provider can be covered.","Sources / pinpoints":"S001 §10, “debt settlement provider/service.”","Conditions, currentness, and confidence limits":"High—text. Primary purpose and enumerated exclusions matter; custody unnecessary."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C002","Precise assertion":"DMSA coverage includes the financial-planning/payment-distribution definition and its express solicitation-of-creditor-contributions language; defined settlement services are excluded.","Sources / pinpoints":"S002 §2.","Conditions, currentness, and confidence limits":"High—text. Preserve statutory syntax; no categorical noncustody escape."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C003","Precise assertion":"Defined credit counseling is excluded only while performing the defined counseling activities; that exclusion does not establish credit-repair or loan-procurement fee permission.","Sources / pinpoints":"S002 §2, “credit counselor,” exclusion(g); S026.","Conditions, currentness, and confidence limits":"Counseling exclusion verified; current adjacent CSO rules held."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C004","Precise assertion":"DMSA expressly reaches Illinois location or solicitation/contracts with Illinois debtors; settlement licensing addresses locations doing business with Illinois residents.","Sources / pinpoints":"S002 §2; S001 §25.","Conditions, currentness, and confidence limits":"High—text. Passive-site and disputed nexus applications unresolved."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C005","Precise assertion":"The reviewed definitions contain no simple household-purpose-only limitation; DMSA expressly includes business entities as persons.","Sources / pinpoints":"S001 §10; S002 §2.","Conditions, currentness, and confidence limits":"High—text; limited application confidence. No blanket business-debt exemption approved."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C006","Precise assertion":"Federal student-loan relief can be covered without principal reduction, and its fees must comply with §125.","Sources / pinpoints":"S001 §10; §125(e).","Conditions, currentness, and confidence limits":"High. Lower monthly payments alone do not establish the defined savings/full-satisfaction trigger."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C007","Precise assertion":"Attorney exclusions require Illinois authorization and actual law practice; specified settlement professional exclusions require ordinary professional activity/entity conditions.","Sources / pinpoints":"S001 §10; S002 §2(a).","Conditions, currentness, and confidence limits":"High—conditions. Entity-specific attorney affiliation model not approved."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C008","Precise assertion":"Institutional exclusions are limited to enumerated institutions and their statutory authorization/ordinary-business conditions.","Sources / pinpoints":"S001 §10, provider exclusion(3); S002 §2(b)–(c).","Conditions, currentness, and confidence limits":"High. A bank relationship does not automatically transfer an exclusion."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C009","Precise assertion":"Settlement nonprofit exclusion requires the cumulative tax-status/501(q)/DMSA conditions; DMSA has no blanket nonprofit exclusion.","Sources / pinpoints":"S001 §10, exclusion(6); S002 §§2,5.","Conditions, currentness, and confidence limits":"High. Nonprofit marketing or incorporation alone insufficient."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C010","Precise assertion":"Settlement has conditional employee, licensed-collector, official/court, business-liquidation, real-estate, higher-education, and education-loan-service exclusions.","Sources / pinpoints":"S001 §10.","Conditions, currentness, and confidence limits":"High—text. Each actor must satisfy its specific activity conditions."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C011","Precise assertion":"DMP exclusions include specified attorneys/institutions/escrow actors, court actors, employers, bill-payment services, and credit counselors; outside employee-benefit DMP vendors must be licensed.","Sources / pinpoints":"S002 §2(a)–(g).","Conditions, currentness, and confidence limits":"High. Money-transmission cross-reference reconciliation remains open."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C012","Precise assertion":"No unlimited standalone self-creditor exemption was established; actual service definition and specific lender/collector exclusions control.","Sources / pinpoints":"S001 §10; S002 §2.","Conditions, currentness, and confidence limits":"Text-based boundary; own-receivable and separate paid-adviser facts must be distinguished."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C013","Precise assertion":"Covered settlement and DMP businesses have statutory licensing pathways and must obtain the required license before operating; an unlicensed DMP contract is void under §16(b).","Sources / pinpoints":"S001 §15; S002 §§3,16(b).","Conditions, currentness, and confidence limits":"High. Permission is activity-specific, not inferred from a regulator directory."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C014","Precise assertion":"Settlement entry requires application/fitness/location conditions; retrieved rules impose $100,000 bond floor, $30,000 net worth, six months’ experience, $350 application and $1,000 annual agency fees.","Sources / pinpoints":"S001 §§20,25,30; S003 §§145.40–.50, pp.6373–6376.","Conditions, currentness, and confidence limits":"High for retrieved schedule. Higher bond possible; NMLS extras/current checkout not verified."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C015","Precise assertion":"DMP entry requires application/fitness/location conditions, $25,000 bond floor, positive net worth and six months’ experience; statute states $30 investigation/$100 license and renewal fees.","Sources / pinpoints":"S002 §§4–6; S003 §140.40, p.6355.","Conditions, currentness, and confidence limits":"High for retrieved schedule. Full bond formula and checklist remain later/held."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C016","Precise assertion":"Noncustodial settlement may avoid establishing a trust account under §65(d), but remains subject to licensing when otherwise covered.","Sources / pinpoints":"S001 §§15,65(d); S003 §145.105.","Conditions, currentness, and confidence limits":"High. Exception concerns funds, not provider status."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C017","Precise assertion":"Settlement savings use contract-entry outstanding balance less creditor payment for full satisfaction; settlement fee cannot exceed15% of that savings.","Sources / pinpoints":"S001 §10, principal/savings; §125(c).","Conditions, currentness, and confidence limits":"High. No later balance inflation; zero/negative savings yields no success fee."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C018","Precise assertion":"Only one enrollment charge up to$50 is permitted under the stated exception; additional setup/upfront/maintenance fees are barred.","Sources / pinpoints":"S001 §125(a)–(b); S003 §145.5.","Conditions, currentness, and confidence limits":"High. Old generic fee-definition language does not override the prohibition; federal timing separate."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C019","Precise assertion":"Settlement-fee collection requires the enforceable full-satisfaction agreement and provision of its specified funds to the creditor.","Sources / pinpoints":"S001 §125(d).","Conditions, currentness, and confidence limits":"High—text. First-installment-only permission not established; controlling construction held."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C020","Precise assertion":"No separate fixed per-debt fee, further program-dollar cap, or mandatory enrollment credit was found; statements/proof/receipts cannot generate extra charges.","Sources / pinpoints":"S001 §125; S003 §§145.70(i),145.120(b), pp.6378,6382.","Conditions, currentness, and confidence limits":"Negative findings limited to retrieved provisions. Prior fees count within the relevant ceiling; federal allocation still applies."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C021","Precise assertion":"DMP initial counseling is capped at$50 per debtor; additional fees after completion of initial counseling are capped at$50/month.","Sources / pinpoints":"S002 §12(1)–(2).","Conditions, currentness, and confidence limits":"High. No current creditor-count or disbursement-percentage alternative established."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C022","Precise assertion":"One DMP monthly service fee may be earned per defined anniversary month; stopped-payment earning is limited by the rule’s30-day/next-contract-date language.","Sources / pinpoints":"S003 §140.50(c)(1),(i), pp.6356–6357.","Conditions, currentness, and confidence limits":"High for retrieved rule. No invented daily-proration or future-month precollection permission."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C023","Precise assertion":"Written DMP cancellation takes effect first day of following month; no separate exit penalty is authorized by current§12.","Sources / pinpoints":"S003 §140.50(b)(2)–(3),(c)(2); S002 §12.","Conditions, currentness, and confidence limits":"High. General refund deadline and automatic earned-fee reversal not established."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]","coordinator_addenda":[{"file":"[internal evidence reference]","clarification":"Cancellation date is attributed to prior Rule140.50(b), not all mechanics to DMSA12. Prior no-separate-exit-penalty inference depends on DMSA12 together with Rule140.50(c)(2); fresh current clause verification remains held. Original P.A.96-1420 refund wording is historical researcher evidence: five business days after notice of cancellation; do not invent a violation-discovery clock, receipt gloss, second application fee or automatic fee retention. Coordinator ILGA retrieval failed; this addendum does not newly authenticate those clauses.","no_current_law_clearance":true}]},{"claim_id":"S_IL-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C024","Precise assertion":"Settlement disclosures/contracts must recognize cancellation and refund of unearned fees and funds not paid to creditors.","Sources / pinpoints":"S001 §§115(c),120(c)(14).","Conditions, currentness, and confidence limits":"High—primary read. Detailed §135 mechanics separately held."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C025","Precise assertion":"Five-business-day refund/accounting, material-violation trigger, and “application fee” retention are reported by the read2025§135 reproduction.","Sources / pinpoints":"S023 §135(a)–(d); current S001§135 route failed.","Conditions, currentness, and confidence limits":"Provisional/held. Not asserted as freshly primary-verified current permission or deadline."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]","coordinator_addenda":[{"file":"[internal evidence reference]","clarification":"Cancellation date is attributed to prior Rule140.50(b), not all mechanics to DMSA12. Prior no-separate-exit-penalty inference depends on DMSA12 together with Rule140.50(c)(2); fresh current clause verification remains held. Original P.A.96-1420 refund wording is historical researcher evidence: five business days after notice of cancellation; do not invent a violation-discovery clock, receipt gloss, second application fee or automatic fee retention. Coordinator ILGA retrieval failed; this addendum does not newly authenticate those clauses.","no_current_law_clearance":true}]},{"claim_id":"S_IL-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C026","Precise assertion":"No CPI formula or adjusted consumer-fee figure was established; retrieved statutes/rules support the stated fixed caps, with no relevant intervening amendment found in the bounded check.","Sources / pinpoints":"S001§125; S002§12; S003–S006; S016–S020.","Conditions, currentness, and confidence limits":"High for retrieved amounts; bounded currentness. No invented CPI adjustment."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C027","Precise assertion":"Fee-amendment rulemaking authority was enacted effective6/26/2026; it does not itself change a numerical fee.","Sources / pinpoints":"S002§6.5; S007 HB5384; S024.","Conditions, currentness, and confidence limits":"Enactment verified. Exact settlement§78/full Public Act language held."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C028","Precise assertion":"HB4814’s proposed percentage/tier fees and HB1289’s replacement scheme were not established as enacted law; November2026 agenda is planning only.","Sources / pinpoints":"S006 pp.8977–8978; S008–S009.","Conditions, currentness, and confidence limits":"High for observed status. Proposed numbers excluded from operative examples."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C029","Precise assertion":"Covered settlement and DMP providers are prohibited from the specified receipt/payment of customer-referral consideration.","Sources / pinpoints":"S003§145.70(d)–(e), p.6378; S002§13(3).","Conditions, currentness, and confidence limits":"High. Actual advertising-versus-referral characterization remains fact dependent."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C030","Precise assertion":"DMP licensees face prohibitions on loans, loan brokerage, specified credit-card/customer procurement, compulsory ancillary purchases, and another business at the licensed location.","Sources / pinpoints":"S002§13(2),(4)–(7).","Conditions, currentness, and confidence limits":"High. A license is not authorization for those prohibited combinations."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C031","Precise assertion":"IDFPR publicly provides both application routes through NMLS; current checklist contents were not retrievable.","Sources / pinpoints":"S010; S013–S014.","Conditions, currentness, and confidence limits":"Route verified; procedure details partial. No submission or license grant."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C032","Precise assertion":"IDFPR’s lookup directory includes both license categories, but no named provider’s status was established.","Sources / pinpoints":"S011; S015.","Conditions, currentness, and confidence limits":"Directory verified; endpoint/results unresolved."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C033","Precise assertion":"TSR debt-relief coverage includes relevant telemarketing/inbound-ad-response activity; attorney/nonprofit labels do not by themselves establish exclusion.","Sources / pinpoints":"S021§§310.2,310.6; S022 “Who’s Covered.”","Conditions, currentness, and confidence limits":"High—bounded federal context. Entity jurisdiction/exemptions require actual facts."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C034","Precise assertion":"Covered TSR fees may not be requested or received before a qualifying customer-executed agreement, at least one customer payment, and applicable allocation compliance.","Sources / pinpoints":"S021§310.4(a)(5)(i)(A)–(C).","Conditions, currentness, and confidence limits":"High—regulation. State conditions also apply."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C035","Precise assertion":"Individual-debt fees must satisfy TSR proportional allocation or consistent savings-percentage rules; dedicated-account deposits are subject to separate ownership/independence/return conditions.","Sources / pinpoints":"S021§310.4(a)(5)(i)(C),(ii).","Conditions, currentness, and confidence limits":"High. Account placement does not make provider fees earned."},"coordinator_verification_status":"selected_support_checked_with_recorded_scope_limits","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C036","Precise assertion":"Illinois’s enrollment/counseling ceilings do not excuse a covered federal advance fee; federal first payment does not override the Illinois settlement trigger.","Sources / pinpoints":"S001§125; S002§12; S021§310.4(a)(5).","Conditions, currentness, and confidence limits":"High—combined application. Examples expressly assume or hold the relevant conditions."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C037","Precise assertion":"Additional settlement§145 third-party-compensation/gift provisions were located in secondary text, but the current operative primary passage was not reached.","Sources / pinpoints":"S023§145(9)–(10); S001 current§145 failed.","Conditions, currentness, and confidence limits":"Held. No third-party-funded workaround approved. Verified referral prohibitions remain independently applicable."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IL-P1-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IL-P1-C038","Precise assertion":"Exclusion from one of these Acts does not establish unrestricted fees under other applicable law.","Sources / pinpoints":"S001§10; S002§2; S021; S026.","Conditions, currentness, and confidence limits":"Legal boundary inference. Actual attorney, credit-services, lending, and federal analyses remain necessary where implicated."},"coordinator_verification_status":"held_for_additional_source_verification","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_IL-P1-S001","urls":["https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION","https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm","https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html","https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm","https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS,+OCCUPATIONS,+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION&utm_source=chatgpt.com","https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S001","Title / issuer / jurisdiction":"Debt Settlement Consumer Protection Act, 225 ILCS 429 — Illinois General Assembly; IL","Direct literal URL(s)":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=3276&Chapter=PROFESSIONS%2C+OCCUPATIONS%2C+AND+BUSINESS+OPERATIONS&ChapterID=24&MajorTopic=REGULATION ; https://www.ilga.gov/Documents/legislation/ilcs/documents/022504290K125.htm ; https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K115.html ; https://www.ilga.gov/documents/legislation/ilcs/documents/022504290K120.htm","Exact pinpoint, version, legal status, and access limitation":"Partial current-code read: §10 definitions/exclusions; §§15, 20, 25, 30, 65; full relevant §§115, 120, 125. §§10/115/125 carry P.A.102-298, effective 8/6/2021; §120 source P.A.96-1420, effective 8/3/2010. Full current §§78, 110, 135, 145, 150 not successfully read. Later reopen failures do not erase earlier successful reads."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S002","urls":["https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION","https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12","https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html","https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION&utm_source=chatgpt.com","https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12&utm_source=chatgpt.com","https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S002","Title / issuer / jurisdiction":"Debt Management Service Act, 205 ILCS 665 — ILGA; IL","Direct literal URL(s)":"https://my.ilga.gov/Legislation/ILCS/Articles?ActID=1203&Chapter=FINANCIAL+REGULATION&ChapterID=20&MajorTopic=REGULATION ; https://my.ilga.gov/legislation/ilcs/fulltext?DocName=020506650K12 ; https://www.ilga.gov/ftp/ILCS/Ch%200205/Act%200665/020506650K13.html","Exact pinpoint, version, legal status, and access limitation":"Read: relevant §§1–16.6, including §§2–6.5, 12, 13, 14, 16(b). Independent successful section reads for §§12–13. §2 source P.A.100-201, effective 8/18/2017; §§12–13 P.A.96-1420, 8/3/2010; §6.5 P.A.104-520, 6/26/2026. Whole-Act later reopen failed."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S003","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S003","Title / issuer / jurisdiction":"Illinois Register 35, issue 16 — Illinois Secretary of State; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume35/register_volume35_issue16.pdf","Exact pinpoint, version, legal status, and access limitation":"Read: DMP adoption pp.6350–6363, especially §§140.40–.50, pp.6355–6357; full original Part145 adoption pp.6364–6385, including .40/.45/.50/.70/.105/.120. Published 4/15/2011, effective 3/29/2011. State-hosted reproduction; not a certified print copy."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S004","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S004","Title / issuer / jurisdiction":"Illinois Register 46, issue 30 — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume46/register_volume46_issue_30.pdf","Exact pinpoint, version, legal status, and access limitation":"Read: Part140 amendment pp.12514–12521, §§140.120/.140; Part145 amendment pp.12522–12528, §§145.80/.125. Effective 7/8/2022, published 7/22/2022. Operative additions/deletions checked; no consumer-fee change in these amendments."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S005","urls":["https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf","https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S005","Title / issuer / jurisdiction":"Illinois Administrative Code, Title 38 index — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/codification_indexes/title38.pdf","Exact pinpoint, version, legal status, and access limitation":"Read: document pp.5–6, Parts140/145; index updated 9/18/2026. Latest listed amendments: 46 Ill.Reg.12514 and 12522, effective 7/8/2022. Index is a currentness aid, not operative text."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S006","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S006","Title / issuer / jurisdiction":"Illinois Register 50, issue 27; IDFPR regulatory agenda — SOS/IDFPR; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_27.pdf","Exact pinpoint, version, legal status, and access limitation":"Read: pp.8977–8978, items II(c)–(d), Parts140/145. Published 7/6/2026; anticipated first notice November2026. Planning, not adopted law."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S007","urls":["https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz","https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S007","Title / issuer / jurisdiction":"“Gov. Pritzker Takes Bill Action” — Illinois Office of the Governor; IL","Direct literal URL(s)":"https://gov-pritzker-newsroom.prezly.com/gov-pritzker-takes-bill-action-d45ziz","Exact pinpoint, version, legal status, and access limitation":"Read: dated 6/26/2026, HB5384 entry, lines343–348: signed, effective immediately; describes fee-rulemaking amendments. Confirms executive action, not the full statutory clauses or a changed fee schedule."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S008","urls":["https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114","https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S008","Title / issuer / jurisdiction":"HB1289 bill status, 104th GA — ILGA; IL","Direct literal URL(s)":"https://www.ilga.gov/Legislation/BillStatus?DocNum=1289&DocTypeID=HB&GAID=18&LegId=0&Print=1&SessionID=114","Exact pinpoint, version, legal status, and access limitation":"Read: synopsis and actions; displayed referral to House Rules 1/28/2025. Replacement-act proposal; enactment not established."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S009","urls":["https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114"],"researcher_record":{"Source ID":"S_IL-P1-S009","Title / issuer / jurisdiction":"HB4814 bill status, 104th GA — ILGA; IL","Direct literal URL(s)":"https://www.ilga.gov/Legislation/BillStatus?DocNum=4814&DocTypeID=HB&GAID=18&LegId=166008&Print=1&SessionID=114","Exact pinpoint, version, legal status, and access limitation":"Read in parallel research: synopsis/actions; House passage4/14/2026, Senate actions through displayed7/2/2026; no Public Act established. Proposed DMP fee changes remain proposed. Subsequent reopen failed."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S010","urls":["https://idfpr.illinois.gov/dfi/ccd/ccd-main.html","https://idfpr.illinois.gov/dfi/ccd/ccd-main.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S010","Title / issuer / jurisdiction":"Consumer Credit Section — IDFPR; IL","Direct literal URL(s)":"https://idfpr.illinois.gov/dfi/ccd/ccd-main.html","Exact pinpoint, version, legal status, and access limitation":"Read: “Debt Management Services,” “Debt Settlement,” application links, governing Acts/rules. Current operational routing; not proof of an applicant’s authority."},"coordinator_verification_status":"selected_passages_checked_only_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IL-P1-S011","urls":["https://idfpr.illinois.gov/dfi/dfilicenselookup.html","https://idfpr.illinois.gov/dfi/dfilicenselookup.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S011","Title / issuer / jurisdiction":"DFI License Lookup — IDFPR; IL","Direct literal URL(s)":"https://idfpr.illinois.gov/dfi/dfilicenselookup.html","Exact pinpoint, version, legal status, and access limitation":"Read: Consumer Credit categories include both license types and link to lookup. Directory route only."},"coordinator_verification_status":"selected_passages_checked_only_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_IL-P1-S012","urls":["https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html","https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S012","Title / issuer / jurisdiction":"Consumer Credit FAQ/brochure — IDFPR; IL","Direct literal URL(s)":"https://idfpr.illinois.gov/about/brochures/dfibrochures/consumer-credit.html","Exact pinpoint, version, legal status, and access limitation":"Read: DMP fee FAQ and licensing references. Corroborates $50 initial/$50 monthly; undated operational explanation does not establish legal effective date."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S013","urls":["https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL","https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S013","Title / issuer / jurisdiction":"Illinois NMLS application routing — NMLS, linked by IDFPR; IL application procedure","Direct literal URL(s)":"https://mortgage.nationwidelicensingsystem.org/slr/SitePages/DynamicLicenses.aspx?StateID=IL","Exact pinpoint, version, legal status, and access limitation":"Followed, not readable: redirected to State Resource Center; no current DMP checklist text returned."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S014","urls":["https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf","https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S014","Title / issuer / jurisdiction":"Illinois Debt Settlement New Application Checklist route — NMLS, linked by IDFPR; IL","Direct literal URL(s)":"https://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/IL_Debt_Settlement_Consumer_Protection_License-New_App-Checklist.pdf","Exact pinpoint, version, legal status, and access limitation":"Followed, not readable: redirected to resource center; checklist version/content unknown."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S015","urls":["https://online-obre.micropact.com/Lookup/LicenseLookup.aspx"],"researcher_record":{"Source ID":"S_IL-P1-S015","Title / issuer / jurisdiction":"Consumer Credit license-lookup endpoint — IDFPR-linked service; IL","Direct literal URL(s)":"https://online-obre.micropact.com/Lookup/LicenseLookup.aspx","Exact pinpoint, version, legal status, and access limitation":"Failed/restricted: no result set read and no provider status established."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S016","urls":["https://www.ilsos.gov/departments/index/register.html","https://www.ilsos.gov/departments/index/register.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S016","Title / issuer / jurisdiction":"Illinois Register archive — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/departments/index/register.html","Exact pinpoint, version, legal status, and access limitation":"Read: latest listed issue42 at access; electronic-copy disclaimer. Publisher says electronic copies are not the official authoritative print publication."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S017","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S017","Title / issuer / jurisdiction":"Illinois Register 50, issue39 — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_39.pdf","Exact pinpoint, version, legal status, and access limitation":"9/25/2026; contents and relevant text-find checks read; no debt-management/settlement amendment identified. Not a claim to have read every unrelated rule."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S018","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S018","Title / issuer / jurisdiction":"Illinois Register 50, issue40 — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_40.pdf","Exact pinpoint, version, legal status, and access limitation":"10/2/2026; same bounded contents/text check; no relevant amendment identified."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S019","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S019","Title / issuer / jurisdiction":"Illinois Register 50, issue41 — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_41.pdf","Exact pinpoint, version, legal status, and access limitation":"10/9/2026; same bounded check; no relevant amendment identified."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S020","urls":["https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf","https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S020","Title / issuer / jurisdiction":"Illinois Register 50, issue42 — SOS; IL","Direct literal URL(s)":"https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_42.pdf","Exact pinpoint, version, legal status, and access limitation":"10/16/2026; same bounded check; no relevant amendment identified."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S021","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S021","Title / issuer / jurisdiction":"16 CFR Part310, Telemarketing Sales Rule — eCFR/FTC; federal","Direct literal URL(s)":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","Exact pinpoint, version, legal status, and access limitation":"Read: §310.2 debt-relief/telemarketing definitions; §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E); relevant §310.6 exemptions. Current retrieved regulation; exact federal baseline, not Illinois permission."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S022","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S022","Title / issuer / jurisdiction":"Debt Relief Services & the TSR: A Guide for Business — FTC; federal","Direct literal URL(s)":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact pinpoint, version, legal status, and access limitation":"Read: “Who’s Covered,” fee collection, nonprofit/attorney discussion. Staff guidance, nonbinding, subordinate to regulation and jurisdictional law."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S023","urls":["https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/","https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S023","Title / issuer / jurisdiction":"2025 Illinois Code reproduction, 225 ILCS429 — Justia; secondary IL reproduction","Direct literal URL(s)":"https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-429/","Exact pinpoint, version, legal status, and access limitation":"Read as secondary cross-check: especially §135(a)–(d). Version lacks new2026§78. Not sufficient alone to establish current law; five-day/retention details held."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S024","urls":["https://my.ilga.gov/Legislation/PublicActs/View/104-0520","https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf","https://my.ilga.gov/Legislation/PublicActs/View/104-0520?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S024","Title / issuer / jurisdiction":"P.A.104-520 full-text route — ILGA; IL","Direct literal URL(s)":"https://my.ilga.gov/Legislation/PublicActs/View/104-0520 ; https://www.ilga.gov/legislation/publicacts/104/PDF/104-0520.pdf","Exact pinpoint, version, legal status, and access limitation":"Failed: HTML/PDF routes unavailable. Enactment supported by S002/S007; complete enacted text and exact settlement§78 clauses not read."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S025","urls":["https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140","https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S025","Title / issuer / jurisdiction":"Current 38 Ill. Adm. Code Part140 — ILGA/JCAR; IL","Direct literal URL(s)":"https://my.ilga.gov/agencies/JCAR/EntirePart?titlepart=03800140","Exact pinpoint, version, legal status, and access limitation":"Failed: current whole-Part and individual legacy routes returned502/inaccessible responses. §§140.60/.70 indexed text was discovery, not a direct read. S003/S004 supply only the actually retrieved adoption/amendment text."},"coordinator_verification_status":"unverified_in_current_scoped_review"},{"source_id":"S_IL-P1-S026","urls":["https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True","https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_IL-P1-S026","Title / issuer / jurisdiction":"Credit Services Organizations Act, 815 ILCS605 — ILGA; IL adjacent boundary","Direct literal URL(s)":"https://ilga.gov/Legislation/ILCS/Articles?ActID=2365&ChapterID=67&Print=True","Exact pinpoint, version, legal status, and access limitation":"Failed: current Act/individual-section routes unavailable. Definitions, exclusions, registration, and credit-repair fee permission not established in this pass."},"coordinator_verification_status":"unverified_in_current_scoped_review"}],"coverage":[{"topic":"Ordinary settlement versus DMP classification","researcher_record":{"Component":"Ordinary settlement versus DMP classification","Status":"Answered, with hybrid boundary","Claims":"C001–C002","Missing evidence / exact next investigation":"For a hybrid model, obtain actual representations, agreement, compensation terms, and fund flows; determine primary purpose and which statutory definition applies."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial/noncustodial distinction","researcher_record":{"Component":"Custodial/noncustodial distinction","Status":"Answered for license boundary","Claims":"C001, C002, C016","Missing evidence / exact next investigation":"Full trust/account-control obligations remain later. Noncustody does not establish settlement-license exemption."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Remote/resident nexus","researcher_record":{"Component":"Remote/resident nexus","Status":"Answered textually; application partial","Claims":"C004","Missing evidence / exact next investigation":"Establish actual Illinois solicitation/contracts and locations. Research controlling nexus interpretation if a passive-site-only theory is proposed."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business purpose","researcher_record":{"Component":"Consumer/business purpose","Status":"Partial","Claims":"C005, C010","Missing evidence / exact next investigation":"Obtain official interpretation or controlling decisions for the specific commercial/corporate model; test liquidation exception on facts."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney/nonprofit/institutional exclusions","researcher_record":{"Component":"Attorney/nonprofit/institutional exclusions","Status":"Answered as conditional statutory tests","Claims":"C007–C012, C038","Missing evidence / exact next investigation":"Verify the actual entity, licenses, professional conduct, tax status, and ordinary-business conditions before approving a particular exemption."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Core licensing pathways","researcher_record":{"Component":"Core licensing pathways","Status":"Answered","Claims":"C013–C016","Missing evidence / exact next investigation":"Complete current application checklist and actual provider/location status before any market-entry determination."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer cap amounts and bases","researcher_record":{"Component":"Consumer cap amounts and bases","Status":"Answered from retrieved law","Claims":"C017–C022, C026","Missing evidence / exact next investigation":"No adjusted CPI figure established. Any claimed different amount must be supported by an effective amending rule or statute."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement installment-fee maturity","researcher_record":{"Component":"Settlement installment-fee maturity","Status":"Unresolved interpretation","Claims":"C019, C036","Missing evidence / exact next investigation":"Locate controlling judicial or formal agency interpretation of §125(d)’s funding condition for installment settlements; examine the actual creditor release terms."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement basic cancellation/refund","researcher_record":{"Component":"Settlement basic cancellation/refund","Status":"Answered","Claims":"C024","Missing evidence / exact next investigation":"§§115/120 support the basic right."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Detailed settlement refund/retention rules","researcher_record":{"Component":"Detailed settlement refund/retention rules","Status":"Held","Claims":"C025","Missing evidence / exact next investigation":"Recover current §135, or enacted P.A.96-1420 plus amendment history. Failed route: https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K135.html. Resolve five-day deadline, material violation, and “application fee” wording."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Additional settlement compensation prohibitions","researcher_record":{"Component":"Additional settlement compensation prohibitions","Status":"Partial","Claims":"C029, C037","Missing evidence / exact next investigation":"Recover current §145(9)–(10) or readable enacted P.A.102-298 pages. Failed route: https://www.ilga.gov/ftp/ILCS/Ch%200225/Act%200429/022504290K145.html. Verified referral rules already apply."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Full relevant DMP rule text","researcher_record":{"Component":"Full relevant DMP rule text","Status":"Partial","Claims":"C021–C023, C029; S025","Missing evidence / exact next investigation":"Obtain current §§140.60 and140.70, or official1998 adoption 22 Ill.Reg.12550, and reconcile with later amendments. Do not count indexed excerpts as the missing read."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"2026 fee-rulemaking authority","researcher_record":{"Component":"2026 fee-rulemaking authority","Status":"Enactment answered; full text partial","Claims":"C027","Missing evidence / exact next investigation":"Recover complete P.A.104-520 and settlement §78; verify exact scope. Inspect any subsequent first-notice/adoption before using a changed fee."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Proposed/historical material","researcher_record":{"Component":"Proposed/historical material","Status":"Answered for identified conflicts","Claims":"C026–C028","Missing evidence / exact next investigation":"Do not apply HB4814/HB1289 proposals, November agenda, or2011 transition language as current permission."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Current application procedure","researcher_record":{"Component":"Current application procedure","Status":"Partial","Claims":"C031","Missing evidence / exact next investigation":"Recover dated, readable Illinois DMP and settlement NMLS checklists, including any current filing-system charges and entity/branch instructions."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Component":"Named provider authorization","Status":"Unresolved; not asserted","Claims":"C032","Missing evidence / exact next investigation":"Obtain actual lookup results for legal entity and locations; inspect status, dates, restrictions, and relevant orders. No marketing statement substitutes for this."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR timing interface","researcher_record":{"Component":"Federal TSR timing interface","Status":"Answered as common baseline","Claims":"C033–C036","Missing evidence / exact next investigation":"Determine actual telemarketing campaign, jurisdiction, exemption facts, and fee allocation for the proposed model. Full federal compliance review remains open."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Pure counseling/credit repair/credit procurement","researcher_record":{"Component":"Pure counseling/credit repair/credit procurement","Status":"Partial adjacent boundary","Claims":"C003, C030, C038","Missing evidence / exact next investigation":"Recover 815 ILCS605 §§3,5,9,10, amendment history and current registration instructions; then examine independently applicable federal credit-repair timing. No fee pathway approved here."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Agreements, funds, bonds, and remedies","researcher_record":{"Component":"Agreements, funds, bonds, and remedies","Status":"Later required pass; narrow provisions only here","Claims":"C014–C016, C023–C025, C035","Missing evidence / exact next investigation":"Read complete operative agreement/disclosure, trust/dedicated-account, disbursement, bond, cancellation, enforcement, and remedy provisions; reconcile statute/rule conflicts."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, litigation, limitations, property exemptions","researcher_record":{"Component":"Collection, litigation, limitations, property exemptions","Status":"Open; excluded from this component","Claims":"—","Missing evidence / exact next investigation":"Separate statutory and controlling-case investigations required. No conclusions carried over by implication."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt, sector-specific, local, tribal, full contract and case-law coverage","researcher_record":{"Component":"Secured debt, sector-specific, local, tribal, full contract and case-law coverage","Status":"Open; excluded except necessary boundaries","Claims":"C001, C006, C038","Missing evidence / exact next investigation":"Separate investigations required. Student-loan classification here does not complete the student-loan sector pass."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"},{"topic":"Illinois-wide / A066 acceptance","researcher_record":{"Component":"Illinois-wide / A066 acceptance","Status":"Not granted","Claims":"—","Missing evidence / exact next investigation":"Remaining evidence holds and later required passes must be resolved under their own acceptance criteria."},"coordinator_acceptance":"reviewed_component_only_not_accepted_remaining_gaps_open","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}