{"meta":{"key":"s_in--pass-01","task":"S_IN","title":"Indiana Investigation","parent_title":"Indiana debt and debt relief law","edition":"pass-01","path":"/research/s_in--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":5,"claims":31,"sources":13,"review_status":"revise","review_complete":true,"sha256":"5d2e177902adb13a53b0ca36b0e8654ffd4df21c0795272d3043ca4814c21b98","headings":["S_IN, PASS-01: Provider market access and consumer fees","Bottom-line determination","1. Definitions and classification boundaries","1.1 Debt management, DMP, and custodial distribution services","1.2 Debt settlement and principal reduction","1.3 Principal reduction versus an incidental DMP concession","1.4 Consumer versus business-purpose debt","1.5 Indiana-resident and remote-provider nexus","1.6 Original-creditor and self-creditor activity","2. Prohibited, licensed, conditionally permitted, and exempt models","2.1 Debt-management companies: licensure, not mere registration","2.2 DMP exemptions","2.3 Debt settlement: conditional CSO access, not an ordinary DFI license","2.4 CSO exclusions","2.5 Attorney exclusion: controlling narrow construction","3. Consumer fees","3.1 Licensed DMP fees","3.2 CSO/debt-settlement fees","3.3 Regulator fees are not consumer fees","4. When fees may be requested or received","4.1 DMP state timing","4.2 CSO state timing","4.3 Current CSO contract and cancellation timing","4.4 Federal TSR context","5. Regulator permission, application, and public lookup","5.1 DMP license","5.2 CSO bond/filing","6. Fee and boundary examples","7. Pass boundary and required next investigations","Calculation conventions","Example IN-DMP-01 — ordinary monthly payment","Example IN-DMP-02 — monthly dollar cap controls","Example IN-DMP-03 — low-payment month","Example IN-DMP-04 — setup and monthly fee in first chargeable month","Example IN-DMP-05 — cancellation and close-out","Example IN-DMP-06 — previous setup/close-out fee","Example IN-DMP-07 — returned payments","Example IN-DMP-08 — proposed savings fee","Example IN-CSO-01 — enrolled-debt price is not validated by absence of a cap","Example IN-TSR-01 — proportional allocation","Example IN-TSR-02 — partial settlement and savings method","Example IN-CSO-02 — three-business-day cancellation","Example IN-BOUNDARY-01 — business-purpose debt","Component coverage and gap table","Actually read","Not successfully read or not established"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_IN/pass-01","facets":{"geography":["us","us-in"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"New active Indiana individual-state provider-access/fees component only; all remaining statecategories open.","pending_corrections":0},"markdown":"# SettleADebt.com — Indiana Investigation\n\n## S_IN, PASS-01: Provider market access and consumer fees\n\n**Research baseline:** October 22, 2026, America/Los_Angeles\n**Actual public-source access and currentness check:** October 24, 2026\n**Scope:** Indiana provider classification, market access, consumer fees, and fee timing only. This is not the complete Indiana dossier or a legal opinion.\n\n## Bottom-line determination\n\nIndiana has **two materially different consumer-debt service lanes**:\n\n| Actual operating model | Indiana classification | Market-access consequence | Consumer-fee consequence |\n| --- | --- | --- | --- |\n| A company enters a written agreement to receive, hold, transmit, or disburse the consumer’s money under a repayment plan | **Debt management company**, IC 28-1-29 | Indiana Department of Financial Institutions license required, including for many remote providers | Detailed Indiana caps: up to $50 setup, monthly formula capped at $75, up to $100 close-out, up to $25 per returned payment, and no unapproved extra charge |\n| A company, for compensation, performs, offers, or implies that it will renegotiate, settle, or alter unsecured consumer debt—including reducing principal, interest, or fees | **Credit services organization providing debt-settlement services**, IC 24-5-15 | No ordinary DFI debt-management license established; instead, a $25,000 bond or approved equivalent letter of credit must be obtained and filed with the Indiana Attorney General before doing business | IC 24-5-15 contains no numerical settlement-fee percentage or dollar cap located in this pass; contract-cost disclosure and state/federal timing rules still apply |\n| Routine convenience bill payment where the customer retains full control of the money | Express DMP exclusion if genuine and not used to evade the chapter | No DMP license under that exclusion | Other laws remain possible |\n| Individual Indiana attorney acting within the actual course and scope of legal practice | Potential statutory exclusion | The exclusion is narrow; a law firm, non-Indiana lawyer, or attorney-branded operation does not inherit it automatically | Fact-specific |\n| Business-purpose debt | Outside the express consumer definitions reviewed here | No lawful Indiana consumer-debt-service pathway should be inferred | Other commercial, collection, legal-practice, or contract law remains open |\n\nThe marketing label—“credit counseling,” “debt relief,” “law firm,” “nonprofit,” or “debt resolution”—does not decide coverage. The actual promises, debt type, money flow, customer status, and performance model do. [C001–C013]\n\n# A. Substantive answers\n\n## 1. Definitions and classification boundaries\n\n### 1.1 Debt management, DMP, and custodial distribution services\n\nIC 28-1-29-1 defines a “debt management company” as a person doing business as budget counseling, credit counseling, debt management, or debt pooling—or holding itself out in comparable terms—**and having a written agreement with the debtor to disburse money or anything of value**. It expressly includes a person that merely holds money or an instrument for transmission. A “plan” is a written repayment program containing a payment schedule. A “concession” is creditor assent to repayment terms more favorable than the original contract. [C001] [Justia Law](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/)\n\nThat definition makes the written disbursement relationship a central boundary:\n\n- A provider that takes the consumer’s monthly payment and distributes it among creditors is squarely within the DMP lane.\n- Holding a check or other payment instrument solely for onward transmission can still qualify.\n- Pure education or counseling, with no compensable settlement promise and no written disbursement agreement, is not automatically shown to be a DMP by this definition.\n- A noncustodial settlement provider does not escape regulation merely because the consumer retains the money; custody is not an element of Indiana’s separate debt-settlement definition. [C001–C002]\n\n### 1.2 Debt settlement and principal reduction\n\nIC 24-5-15-2.5 defines “debt settlement services” to include performing, offering, or representing—directly **or by implication**—that the provider will renegotiate or settle unsecured debt, or alter its payment or other terms, including reducing the balance, interest rate, or fees. A compensated person providing those services, or advice or assistance concerning them, is generally a “credit services organization.” [C002] [Justia Law+1](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2-5/)\n\nThis reaches representations, not merely completed settlements. A provider cannot avoid classification by saying that it only “facilitates,” “coaches,” “coordinates,” or “provides technology” where its actual offer implies that it will obtain creditor concessions or settlements.\n\n### 1.3 Principal reduction versus an incidental DMP concession\n\nPrincipal reduction is not, by itself, a complete classifier. Indiana expressly allows a creditor participating in a licensed DMP to reduce the amount owed during the plan, with a required tax-warning disclosure. The DMP statute also expects providers to identify creditors likely to participate and grant concessions. But a DMP may not settle a debt, or lead the consumer to believe a payment is a settlement, unless the creditor contemporaneously certifies that the payment is in full settlement. [C008] [Justia Law+1](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-7-7/)\n\nThe practical boundary is therefore:\n\n- **Repayment/distribution program:** regular consumer payments are transmitted to creditors; creditors may grant interest, fee, payment, or incidental balance concessions.\n- **Settlement program:** the offered service itself is renegotiation, settlement, or alteration of unsecured debt, particularly a promised principal reduction or lump-sum resolution.\n- **Mixed model:** held. The DMP definition excludes a “person” providing debt-settlement services, while the CSO definition excludes a statutory DMP. No controlling public interpretation resolving every mixed-program configuration was located. A mixed provider should not assume that either a DFI license or Attorney General bond filing cures the other classification. [C009]\n\n### 1.4 Consumer versus business-purpose debt\n\nThe DMP chapter defines “debt” as an obligation arising from personal, family, or household use, and “debtor” as an individual whose principal debts are not business-purpose transactions. The CSO chapter likewise defines the buyer as an individual and defines “extension of credit” around personal, family, or household debt or avoiding foreclosure on the buyer’s residence. [C003] [Justia Law+2](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/)\n\nAccordingly:\n\n- Consumer credit cards, consumer personal loans, and similar household obligations can fall within these chapters.\n- An LLC obligation, commercial line, inventory financing, or an individual’s principally business-purpose debt is not shown to fall within these consumer definitions.\n- That does **not** establish an unregulated business-debt-settlement safe harbor. Attorney-practice, collection, commercial-contract, deceptive-practice, and other laws remain for later passes.\n\n### 1.5 Indiana-resident and remote-provider nexus\n\nThe DMP statute is unusually explicit. A person operates in Indiana when the person or an employee/agent is located in Indiana, **or** when the person contracts with Indiana residents or solicits them by mail, personal delivery, telephone, radio, television, internet/electronic communications, or any other communication method. Remote internet and telephone providers are therefore expressly included. [C004] [FindLaw](https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/)\n\nThe CSO statute says that the bond or equivalent must be filed “before doing business in Indiana,” and the current contract provision requires an Indiana agent for service of process. It does not contain the DMP chapter’s detailed remote-solicitation list. Serving an Indiana consumer through an online or telephone program presents a strong Indiana nexus, but the outer limit for remote-only activity was not conclusively resolved in the public authorities read in this pass. [C013]\n\n### 1.6 Original-creditor and self-creditor activity\n\nThe CSO definition applies to services concerning an extension of credit **“by another person.”** Textually, an original creditor modifying its own debt appears different from a third-party CSO. That is a limited textual inference, not a verified blanket exemption for creditor affiliates, lead generators, servicing arrangements, or nominally separate entities. [C030] [Justia Law](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/)\n\n## 2. Prohibited, licensed, conditionally permitted, and exempt models\n\n### 2.1 Debt-management companies: licensure, not mere registration\n\nNo person may operate a debt-management company in Indiana without a DFI license. A knowing unlicensed operator’s agreements are void; the debtor owes no fees, and paid amounts may be recovered. Licenses renew annually and are not freely transferable. [C005] [FindLaw](https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/)\n\nThe current DFI licensing page identifies a **Debt Management License** as an NMLS application. DFI also says that its Consumer Credit Division regulates in-state and out-of-state entities that advertise and solicit Indiana consumers. [C026] [Indiana Government+1](https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/)\n\nOne additional market-access restriction is unusually broad: DFI may not issue a post-August 1981 DMP license to a person who is an employee, owner, or affiliate “in any way” of a collection agency or process-serving business, subject to the old grandfather clause. [C007] [Justia Law](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-4-5/)\n\n### 2.2 DMP exemptions\n\nThe DMP chapter does not apply to:\n\n1. An Indiana-authorized attorney, or persons under that attorney’s supervision and control, **only to the extent** the debt-management services are incidental to the attorney’s law practice.\n2. A statutory depository financial institution.\n3. A third-party bill-paying service used solely for the customer’s convenience, where the customer retains full control over deposited money, unless DFI determines that the structure is an evasion. [C006] [FindLaw](https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-0-5/)\n\nThere is **no blanket nonprofit exemption** in the DMP chapter. Instead, a licensee is prohibited from representing itself as nonprofit unless it is genuinely organized and operating as one, and from claiming tax-exempt status without IRS certification and proper nonprofit operation. [C031] [Justia Law](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-9-5/)\n\n### 2.3 Debt settlement: conditional CSO access, not an ordinary DFI license\n\nBefore doing business in Indiana, a covered CSO must:\n\n- Obtain a **$25,000 surety bond** from an Indiana-authorized surety, in favor of the state for persons damaged by violations; and\n- File a copy with the Indiana Attorney General.\n\nThe Attorney General may waive the bond and accept an equivalent irrevocable letter of credit, which likewise must be filed before business begins. [C010] [Justia Law](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-8/)\n\nThe Attorney General’s current operational page uses a **“Register/Submit Here”** button and restates the bond/filing process. The statute, however, does not establish an ordinary DFI license or say that the filing is an affirmative merits approval of the provider. The safest classification is **mandatory bond/letter-of-credit filing and chapter compliance**, not ordinary licensure. [Indiana Government](https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/)\n\n### 2.4 CSO exclusions\n\nThe CSO definition excludes, subject to each stated condition:\n\n- A person authorized and supervised under state or federal law to make loans/extensions of credit, and certain HUD-approved lenders.\n- An FDIC-insured bank or savings association and its subsidiary.\n- An Indiana credit union.\n- An actual Internal Revenue Code §501(c)(3) nonprofit.\n- An Indiana real-estate broker acting within the license’s scope.\n- A person admitted to practice law in Indiana acting within the course and scope of that person’s attorney practice.\n- A registered SEC/CFTC broker-dealer acting within the regulatory scope.\n- A consumer-reporting agency.\n- A loan servicer acting for the holder of a consumer loan or residential mortgage.\n- A statutory Indiana debt-management company. [C011] [Justia Law](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/)\n\nA marketing claim of nonprofit status does not prove §501(c)(3) status. A relationship with an attorney likewise does not establish the attorney exclusion.\n\n### 2.5 Attorney exclusion: controlling narrow construction\n\nIn **Consumer Attorney Services, P.A. v. State**, 71 N.E.3d 362 (Ind. 2017), the Indiana Supreme Court held that the CSO attorney exemption applies to an **individual** who is both admitted in Indiana and acting within the person’s attorney practice. It does not extend automatically to the law firm. A Florida lawyer never licensed in Indiana could not invoke it. [C012] [Justia Law](https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html)\n\nThus, “attorney-backed,” “law-firm affiliated,” fee-sharing with counsel, or retaining an Indiana lawyer for limited work is not enough by itself.\n\n## 3. Consumer fees\n\n## 3.1 Licensed DMP fees\n\nIndiana’s operative consumer-fee structure is:\n\n| Fee | Indiana limit and basis |\n| --- | --- |\n| Setup fee | Maximum **$50**, for consultation, obtaining a credit report, and establishing the account |\n| Monthly service fee | Lesser of: up to **15% of the amount received from the consumer for payment to creditors during that calendar month**, subject to a permitted $5 monthly minimum when the percentage calculation is below $5; or **$75** |\n| Close-out fee | Up to **$100** upon consumer cancellation or termination of payments |\n| Returned payment | Up to **$25 per returned payment** |\n| Other charge | Prohibited unless the provider submits a written explanation and DFI determines that it confers a benefit and is reasonable |\n| Voluntary contribution | Cannot be solicited or accepted unless the fee is specifically authorized by the chapter |\n| Settlement/savings/per-debt fee | No such fee is expressly authorized; it would require the additional-charge approval process rather than being presumed lawful |\n\nThe setup fee is excluded from the monthly percentage base. A provider may ordinarily charge only one setup and one close-out fee unless the consumer leaves the service for **more than six months**. [C014–C017] [Justia Law+1](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/)\n\nThe fee values are fixed statutory amounts. No CPI or other indexing mechanism appears in §28-1-29-8.3. The official 2026 Title 28 search result continues to surface the current returned-payment and fee section, and no conflicting 2026 amendment was located in the bounded enactment check. [C020] [Indiana General Assembly](https://iga.in.gov/laws/current/ic/titles/28?utm_source=chatgpt.com)\n\nThere is no express aggregate lifetime consumer-fee cap in §8.3. The agreement itself cannot exceed 60 months, but that duration rule should not be restated as a statutory aggregate-dollar cap because returned-payment charges and separately approved charges can vary. [FindLaw](https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-8/)\n\n### 3.2 CSO/debt-settlement fees\n\nIC 24-5-15 contains no numerical settlement-fee percentage, enrolled-debt percentage, savings percentage, per-debt amount, monthly cap, setup cap, or aggregate cap located in the complete chapter review for this pass. That means:\n\n- Indiana has not supplied a verified numerical settlement-fee ceiling in this chapter.\n- It does **not** mean any price is affirmatively authorized, reasonable, or immune from other law.\n- The provider must disclose the total cost before contract or receipt of value, and the contract must disclose the total amount of all payments and describe services, results, guarantees, and refund promises. [C021, C023] [Midpage+1](https://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c)\n\nNo statutory indexing or adjusted fee notice was found because the chapter does not state an underlying consumer-fee number to index.\n\n### 3.3 Regulator fees are not consumer fees\n\nThe current administrative rule lists DMP regulatory charges of:\n\n- $1,000 application fee.\n- $1,000 annual renewal fee, due December 31.\n- $20 per day renewal late fee.\n- $80 per examination hour.\n- $20 per day late examination-payment fee.\n\nThose are charges to the regulated entity for licensing/examination—not fees chargeable to the consumer under a DMP. [C028] [Legal Information Institute](https://www.law.cornell.edu/regulations/indiana/750-IAC-10-1-11)\n\nDFI’s current page links a Consumer Credit fee schedule for **July 1, 2026 through June 30, 2027**, but the linked DOCX was not readable through the public web reader. The prior official schedule expressly covered July 1, 2025 through June 30, 2026 and showed the same DMP amounts, but it is historical and cannot itself prove the post-June 2026 schedule. The operative administrative rule, not the expired table, supports the current amounts. [Indiana Government+1](https://www.in.gov/dfi/general-information/policies-and-guidance/)\n\n## 4. When fees may be requested or received\n\n### 4.1 DMP state timing\n\nA licensed DMP may not impose charges or receive payment for debt-management services until:\n\n1. The provider and debtor have agreed on a plan and signed a compliant agreement;\n2. At least one payment has been made to a creditor under the plan; and\n3. All creditors have been notified of the debtor-provider relationship.\n\nThe setup fee is independently subject to the first-creditor-payment trigger. [C018] [Justia Law](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/)\n\nThis is stronger than merely saying the provider has performed a consultation or opened an account. Opening the account does not by itself unlock the $50 fee.\n\n### 4.2 CSO state timing\n\nBefore entering the contract **or receiving money or other valuable consideration**, the CSO must give the statutory written statement, including a detailed service description and total cost. [Midpage](https://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c)\n\nIC 24-5-15-5 identifies charging or receiving money before complete performance as a deceptive act **unless** the CSO has obtained the §8 bond or letter of credit. [C022] [Justia Law](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-5/)\n\nThat bond exception must be handled carefully:\n\n- It removes that particular state-law deceptive-act condition when its requirements are satisfied.\n- It is not a numerical fee authorization.\n- It does not override the contract-disclosure and cancellation provisions.\n- It does not override independently applicable federal advance-fee restrictions.\n\n### 4.3 Current CSO contract and cancellation timing\n\nEffective July 1, 2026, as amended by P.L.115-2026, §24-5-15-7 requires a written, dated, signed contract; payment terms and total payments; detailed services and results; refund promises; an Indiana process agent; two cancellation forms; and delivery of the completed documents at signing. The buyer may cancel without penalty before midnight of the third business day after signing. Payments must be returned within ten days after the seller receives the cancellation notice. [C023–C024] [Bill Texts+1](https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf)\n\nThe 2026 amendment principally updated a statutory cross-reference following Indiana’s consumer-credit recodification; the enrolled act is the primary evidence of the July 1, 2026 effective text. [Bill Texts](https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf)\n\n### 4.4 Federal TSR context\n\nWhere the federal Telemarketing Sales Rule applies to the seller or telemarketer, 16 C.F.R. §310.4(a)(5) independently prohibits requesting or receiving a debt-relief fee until:\n\n1. At least one debt has actually been renegotiated, settled, reduced, or otherwise altered under a valid executed settlement, DMP, or comparable agreement;\n2. The consumer has made at least one payment under that agreement; and\n3. For debts resolved individually, the fee is allocated either proportionally by enrolled debt balance or as one consistent percentage of actual savings.\n\nThe TSR’s savings basis is the enrolled debt amount minus the amount actually paid to satisfy it. A qualifying dedicated account remains consumer-owned, and unearned funds must be returned within seven business days after withdrawal. [C025] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThis federal provision is common context only. This pass does not determine the TSR’s application to every channel, provider, or transaction. An Indiana bond filing or absence of a numerical state fee cap does not displace an applicable federal timing prohibition.\n\n## 5. Regulator permission, application, and public lookup\n\n### 5.1 DMP license\n\n**Regulator:** Indiana Department of Financial Institutions, Consumer Credit Division.\n**Application route:** NMLS, under “Debt Management License.”\n**Public status route:** DFI links “Find a License” and describes it as a listing of currently licensed or registered consumer-credit entities. [C026] [Indiana Government+1](https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/)\n\nThe current DFI pages establish the application and lookup routes. But the linked public extranet and targeted debt-management listing did not return a readable company list through the available public reader; they produced non-retryable access errors. Therefore:\n\n- The availability of a public lookup route is verified.\n- The current content of the DMP roster was not verified.\n- No named provider’s Indiana license status is established in this report.\n\nRelevant public routes:\n\nPlain text\n```\nhttps://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/\nhttps://www.in.gov/dfi/general-information/consumer-credit-division\nhttps://extranet.dfi.in.gov/\nhttps://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList\nhttps://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType\n```\n\n### 5.2 CSO bond/filing\n\n**Regulator/recipient:** Office of the Indiana Attorney General.\n**Procedure publicly verified:** Obtain the $25,000 bond or receive approval for an equivalent letter of credit; file it before doing business. The Attorney General page links a “Register/Submit Here” portal. [C027] [Indiana Government](https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/)\n\nThe linked Salesforce portal produced only a loading/CSS-error screen in the public reader. No public searchable roster, filing-acceptance list, certificate, or named-provider status was located. A portal submission procedure is not proof that a particular provider is currently compliant. [Inoag](https://inoag.my.site.com/oagcounsel/s/login/)\n\nRelevant routes:\n\nPlain text\n```\nhttps://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/\nhttps://inoag.my.site.com/oagcounsel/s/login/\n```\n\n## 6. Fee and boundary examples\n\nDetailed calculations appear in Part D. The decisive results are:\n\n- A DMP receiving $400 for creditors in a month has a maximum ordinary monthly fee of $60.\n- At $600, the $75 monthly ceiling controls.\n- At a $20 monthly creditor-payment base, the statute permits the $5 minimum even though 15% is $3.\n- A proposed percentage-of-savings or per-settlement DMP fee is not among the expressly permitted charges and remains unavailable unless DFI specifically approves it as an additional charge.\n- A debt-settlement contract charging 20% of enrolled debt cannot be validated merely because IC 24-5-15 lacks a numerical cap. Its total cost, contract terms, market-access filing, timing, and any applicable TSR formula must all be satisfied.\n- A timely CSO cancellation requires return of payments within ten days after receipt of the notice.\n- Business-purpose debt, mixed models, and original-creditor modifications should be classified before running any consumer-fee calculation.\n\n## 7. Pass boundary and required next investigations\n\nThis pass establishes the principal DMP-versus-CSO classification, the corresponding license or bond-filing route, and the verified consumer-fee rules. It does **not** establish complete Indiana compliance.\n\nThe next focused investigations are:\n\n1. Retrieve a readable current Indiana NMLS Debt Management License company checklist and renewal checklist, including every financial, bond, ownership, branch, control-person, background, and document requirement.\n2. Obtain a readable current DFI DMP license roster/detail page and verify status fields, effective dates, expiration dates, branches, and legal names before assessing any named company.\n3. Locate a public Attorney General CSO filing roster, filing-acceptance evidence, or official public-data substitute. The current submission portal alone is insufficient.\n4. Obtain a readable official copy of the July 1, 2026–June 30, 2027 Consumer Credit fee schedule and reconcile it line-by-line with 750 IAC 10-1-11.\n5. Investigate Indiana decisions or official interpretations applying “doing business in Indiana” to remote-only CSOs.\n6. Investigate DFI interpretations of the $5 DMP minimum in a month with a zero or near-zero creditor-payment base.\n7. Search public DFI orders for any approved DMP “additional charges”; none should be presumed.\n8. Complete later passes on agreements, client funds, bonds, remedies, collection/litigation, limitations, complete exemptions, secured debt, sector-specific law, local/tribal issues, contract enforceability, and broader case law.\n\n# B. Source table\n\n| Source ID | Title / issuer / authority | Direct literal URL(s) | Exact passage or pinpoint read | Version and effective status; access; limitations |\n| --- | --- | --- | --- | --- |\n| **S_IN-P1-S001** | Indiana Code 2026, Title 28 — Indiana General Assembly | https://iga.in.gov/laws/current/ic/titles/28 | Official title index and searchable current-code result for ch. 28-1-29 and §8.3 | Current 2026 official index; checked 2026-10-24. The page requires JavaScript and did not expose full section text in the reader; used for current-code identity, not as the sole passage source. [Indiana General Assembly+2](https://iga.in.gov/laws/current/ic/titles/28) |\n| **S_IN-P1-S002** | IC 28-1-29 readable section compilation — Justia/FindLaw | https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/ https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-0-5/ https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-4-5/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-7-7/ https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-8/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-8/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-9-5/ https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-17/ | Definitions §1(2), (6)–(18); exclusions §0.5; license/nexus/voidness §3; collection affiliation §4.5; concessions §7.7; agreement/cancellation §8; fees §8.3; termination §8.8; prohibited conduct §9.5; contributions §17 | Readable 2025 code/FindLaw current-as-of-Jan. 1, 2026 text; checked 2026-10-24. Currentness corroborated against official 2026 title/index and bounded 2026 enactment search. Mirrors warn that official text controls. [Justia Law+10](https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/) |\n| **S_IN-P1-S003** | Indiana Code 2026, Title 24 — Indiana General Assembly | https://iga.in.gov/laws/2026/ic/titles/24 | Official title index identifying ch. 24-5-15 | Current 2026 official index; checked 2026-10-24. JavaScript prevented full passage extraction. [Indiana General Assembly+1](https://iga.in.gov/laws/2026/ic/titles/24) |\n| **S_IN-P1-S004** | IC 24-5-15 readable chapter and section compilation — Justia/Midpage | https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/ https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/ https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/ https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2-5/ https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-3/ https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-5/ https://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c https://app.midpage.ai/laws/in-code/t24/a5/ch15/s7-e83d30 https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-8/ | Buyer §1; CSO definition/exclusions §2; settlement §2.5; credit §3; advance-fee deceptive act §5; precontract statement §6; current contract/cancellation §7; bond filing §8 | 2025 compilation except current §7 mirror effective July 1, 2026. Checked 2026-10-24. Official enrolled act separately controls the amendment. [Justia Law+7](https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/) |\n| **S_IN-P1-S005** | Senate Enrolled Act 169 / P.L.115-2026 — Indiana General Assembly | https://iga.in.gov/legislative/2026/bills/senate/169 https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf | PDF printed pp. 26–27, §28, lines 1134–1190: amendment of IC 24-5-15-7, effective July 1, 2026 | Official enrolled act; checked and page images/text read 2026-10-24. Bill-status page itself required JavaScript. [Bill Texts+2](https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf) |\n| **S_IN-P1-S006** | Consumer Attorney Services, P.A. v. State, 71 N.E.3d 362 — Indiana Supreme Court | https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html | Opinion lines 70–99 and 104; especially construction of §24-5-15-2(b)(6) | Controlling Indiana Supreme Court decision dated March 21, 2017; checked 2026-10-24. No later contrary controlling decision located in the bounded search; broader case-law pass remains open. [Justia Law](https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html) |\n| **S_IN-P1-S007** | Consumer Credit Licensing — Indiana DFI | https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/ | Lines 77–95: NMLS applications and Debt Management License | Current official operational page; checked 2026-10-24. Procedure support, not a substitute for statutory permission or proof of a provider’s status. [Indiana Government](https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/) |\n| **S_IN-P1-S008** | Consumer Credit Division and public-license route — Indiana DFI | https://www.in.gov/dfi/general-information/consumer-credit-division https://extranet.dfi.in.gov/ https://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList https://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType | DFI page lines 77–91; public listing endpoints attempted | Current DFI page read 2026-10-24. Extranet listings did not return readable results through the public reader; no company status established. [Indiana Government](https://www.in.gov/dfi/general-information/consumer-credit-division) |\n| **S_IN-P1-S009** | Credit Services Organizations/Foreclosure Consultants — Indiana Attorney General | https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/ https://inoag.my.site.com/oagcounsel/s/login/ | AG page lines 28–38; portal response lines 0–4 | Current official operational page checked 2026-10-24. Portal displayed loading/CSS error; no public roster or filing acceptance read. [Indiana Government+1](https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/) |\n| **S_IN-P1-S010** | 750 IAC 10-1-11, DFI fee schedules — Indiana Register/Cornell readable copy | https://iar.iga.in.gov/latestArticle/750/10 https://iar.iga.in.gov/register/20240424-IR-750230837FRA https://www.law.cornell.edu/regulations/indiana/750-IAC-10-1-11 | Rule §11(a), debt-management license row; notes showing filing March 26, 2024 | Current official article index plus readable rule copy; checked 2026-10-24. Provider/regulator fees only. [Indiana Register+2](https://iar.iga.in.gov/latestArticle/750/10) |\n| **S_IN-P1-S011** | Consumer-credit fee schedules — Indiana DFI | https://www.in.gov/dfi/general-information/policies-and-guidance/ https://www.in.gov/dfi/files/CC_Fees_26-27.docx https://secure.in.gov/dfi/files/CC-Fees-25-26.pdf | Current landing page lines 76–80; expired PDF p. 1, lines 0–22 | Current 2026–27 schedule link verified, but DOCX unsupported by reader. Prior schedule expressly expired June 30, 2026 and is historical only. Checked 2026-10-24. [Indiana Government+1](https://www.in.gov/dfi/general-information/policies-and-guidance/) |\n| **S_IN-P1-S012** | 16 C.F.R. §310.4(a)(5) — eCFR / FTC Telemarketing Sales Rule | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | Lines 115–131: performance/payment triggers, proportional and savings methods, dedicated account return | eCFR displayed as up to date through October 22, 2026; checked October 24, 2026. Federal common context only; applicability analysis remains transaction-specific. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_IN-P1-S013** | NMLS Checklist Compiler | https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx | Public compiler route attempted | DFI links this route, but no generated Indiana checklist content was exposed in the public reader. Checked 2026-10-24. [Indiana Government+1](https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/) |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Source IDs and pinpoint | Conditions, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_IN-P1-C001** | A custodial/distribution provider with a written agreement to disburse value is a DMP; merely holding an instrument for transmission can qualify. | S002, IC 28-1-29-1(2), lines 61–66 | High confidence; classification still depends on actual services and written arrangement. |\n| **S_IN-P1-C002** | Compensated renegotiation, settlement, or alteration of unsecured consumer debt—including balance, interest, or fee reduction—is debt-settlement activity under the CSO chapter. | S004, IC 24-5-15-2(a)(5)–(6), §2.5 | High confidence; representations and implied offers count. |\n| **S_IN-P1-C003** | Both reviewed regimes are consumer-focused; business-purpose debt is outside the express definitions. | S002, §1(6)–(7); S004, §§1, 3 | High confidence for these chapters; no conclusion about other law. |\n| **S_IN-P1-C004** | Remote DMPs contracting with or soliciting Indiana residents by internet, telephone, mail, or other communication operate in Indiana. | S002, §3(a)(2) | Express statutory rule; high confidence. |\n| **S_IN-P1-C005** | Operating a DMP without a DFI license is prohibited; knowing unlicensed agreements are void and paid fees are recoverable. | S002, §3(a), (e) | High confidence. |\n| **S_IN-P1-C006** | DMP exemptions are limited to incidental Indiana-attorney activity, depository institutions, and genuine customer-controlled routine bill payment. | S002, §0.5 | Conditions must be proven; no label-based exemption. |\n| **S_IN-P1-C007** | DFI generally may not issue a post-1981 DMP license to a collection-agency or process-server employee, owner, or affiliate. | S002, §4.5 | Grandfathered pre-Sept. 1, 1981 licenses excepted. |\n| **S_IN-P1-C008** | A licensed DMP may obtain concessions and encounter a creditor balance reduction, but may not portray a payment as settlement without creditor certification of full settlement. | S002, §§7.7(d), 9.5(a)(9) | Prevents classification solely from incidental creditor reduction. |\n| **S_IN-P1-C009** | Mixed DMP/settlement models are unresolved at the outer boundary because each statute excludes the other category. | S002, §1(2); S004, §2(b)(10) | Legal-classification hold; no universal dual/composite authorization inferred. |\n| **S_IN-P1-C010** | A covered CSO must obtain a $25,000 bond or approved equivalent LOC and file it with the AG before doing business. | S004, §8; S009, lines 28–37 | High confidence. Filing is not proven merits approval. |\n| **S_IN-P1-C011** | CSO exclusions include specified regulated lenders, banks, credit unions, actual §501(c)(3) nonprofits, scoped professionals, CRAs, servicers, and statutory DMPs. | S004, §2(b)(1)–(10) | Each activity/entity condition must independently be satisfied. |\n| **S_IN-P1-C012** | The CSO attorney exclusion covers the qualifying Indiana-admitted individual, not automatically a law firm or non-Indiana lawyer. | S006, opinion lines 90–104 | Controlling Indiana Supreme Court construction; high confidence. |\n| **S_IN-P1-C013** | The exact outer nexus for a remote-only CSO is not conclusively resolved here. | S004, §8; S005/S004, §7(a)(4) | Serving Indiana buyers likely creates risk, but controlling remote-nexus authority remains to be researched. |\n| **S_IN-P1-C014** | DMP setup fee is capped at $50 and cannot be collected before the first creditor payment. | S002, §8.3(b), (c)(1) | Requires compliant plan/agreement and creditor notice. |\n| **S_IN-P1-C015** | DMP monthly fee is the lesser of the statutory 15%-with-$5-minimum calculation and $75; setup is excluded from the base. | S002, §8.3(c)(2) | Zero-base-month treatment remains an interpretation hold. |\n| **S_IN-P1-C016** | DMP close-out fee is capped at $100; no second setup/close-out fee unless the debtor left for more than six months. | S002, §8.3(d)–(e) | “More than” six months, not six months exactly. |\n| **S_IN-P1-C017** | Additional DMP charges need DFI approval; returned payments are capped at $25 each; unauthorized voluntary contributions are prohibited. | S002, §8.3(f), (h); §17 | No savings/per-debt fee presumed. |\n| **S_IN-P1-C018** | DMP consumer fees cannot be imposed or received until a compliant plan/agreement and at least one creditor payment; all creditors must be notified. | S002, §8.3(a)–(b) | State-law timing independent of TSR. |\n| **S_IN-P1-C019** | A DMP debtor may terminate at any time; unexpended money must be refunded and trust money returned immediately, subject to the permitted close-out fee. | S002, §§8(a)(6)(I), 8(c), 8.8(c), 8.3(d) | Full funds/accounting analysis remains later. |\n| **S_IN-P1-C020** | DMP consumer caps are fixed, not indexed; no express aggregate program cap or ordinary settlement/savings fee was located. | S001–S002, §8.3 and §8(h) | High confidence from current-code and 2026 enactment check; additional DFI-approved charges could alter a specific provider’s situation. |\n| **S_IN-P1-C021** | IC 24-5-15 contains no numerical debt-settlement consumer-fee cap located in this chapter review. | S003–S004, complete ch. 15 review | Negative chapter-level finding; not a statement that every fee is lawful. |\n| **S_IN-P1-C022** | A bonded/LOC-backed CSO is outside the specific §5(1) state deceptive-act rule against pre-performance payment, but this is not blanket advance-fee authorization. | S004, §§5(1), 8 | Other Indiana and federal rules remain independently applicable. |\n| **S_IN-P1-C023** | CSO total cost must be disclosed before contract/payment; current contract must state total payments, services/results, refund promises, and cancellation rights; timely cancellation payments return within ten days. | S004–S005, §§6–7 | Current §7 effective July 1, 2026. |\n| **S_IN-P1-C024** | P.L.115-2026 amended IC 24-5-15-7 effective July 1, 2026. | S005, enrolled act pp. 26–27, §28 | Primary enactment evidence. |\n| **S_IN-P1-C025** | Where the TSR applies, debt-relief fees require actual altered debt, executed agreement, first consumer payment, and proportional or consistent-savings allocation. | S012, §310.4(a)(5)(i) | Federal scope must be analyzed separately. |\n| **S_IN-P1-C026** | DFI identifies the Debt Management License as an NMLS application and provides a public “Find a License” route. | S007–S008 | High-level procedure verified; detailed checklist/roster unavailable in reader. |\n| **S_IN-P1-C027** | AG provides a CSO “Register/Submit Here” route, but no readable public roster or filing acceptance was verified. | S009 | Portal returned loading/CSS error. |\n| **S_IN-P1-C028** | Current administrative-rule DMP provider fees are $1,000 application, $1,000 renewal, $20/day late renewal, $80/hour examination, and $20/day late examination payment. | S010, 750 IAC 10-1-11(a) | Regulatory fees, not consumer charges. Current 2026–27 schedule file remained unread. |\n| **S_IN-P1-C029** | No named provider’s Indiana authorization is established. | S008–S009 | Deliberate evidence hold; no marketing statement substituted for official status. |\n| **S_IN-P1-C030** | Original-creditor self-modification may be outside the CSO definition because the credit must be extended “by another person.” | S004, §2(a) | Textual inference only; affiliates, servicers, and structured arrangements remain open. |\n| **S_IN-P1-C031** | A nonprofit label is insufficient: DMPs have no blanket nonprofit exemption, while CSO exclusion requires actual §501(c)(3) status. | S002, §9.5(a)(12); S004, §2(b)(4) | Entity status and actual operation must be verified. |\n\n# D. Worked examples and component-coverage table\n\n## Calculation conventions\n\nAll dollar inputs and outputs are U.S. dollars. Calculations below produce exact cents or whole-dollar results; no special Indiana statutory rounding method was located. A real provider’s rounding policy may not cause the fee to exceed the statutory ceiling.\n\n## Example IN-DMP-01 — ordinary monthly payment\n\nPlain text\n```\nModel: Licensed Indiana DMP\nConsumer funds received for creditors during month: $400.00\nSetup fee included in base: No\n\nPercentage calculation:\n15% × $400.00 = $60.00\n\nDollar ceiling comparison:\nLesser of $60.00 and $75.00 = $60.00\n\nMaximum monthly service fee: $60.00\n```\n\nConditions: compliant plan and signed agreement, all creditors notified, and at least one creditor payment already made. [C015, C018]\n\n## Example IN-DMP-02 — monthly dollar cap controls\n\nPlain text\n```\nCreditor-payment base: $600.00\n15% × $600.00 = $90.00\nStatutory monthly ceiling: $75.00\n\nMaximum monthly service fee:\nmin($90.00, $75.00) = $75.00\n```\n\nThe provider may not use the $90 percentage result because the $75 ceiling is lower.\n\n## Example IN-DMP-03 — low-payment month\n\nPlain text\n```\nCreditor-payment base: $20.00\n15% × $20.00 = $3.00\nStatutory permitted minimum where calculation is below $5: $5.00\n\nMaximum monthly service fee: $5.00\nEffective fee percentage in this example: 25%\n```\n\nThe effective percentage can therefore exceed 15% in a low-payment month because the statute expressly permits the $5 minimum. A month in which the provider receives **zero** for creditor payments is held because no DFI interpretation resolving the zero-base application was located. [C015]\n\n## Example IN-DMP-04 — setup and monthly fee in first chargeable month\n\nPlain text\n```\nCreditor-payment base for month: $400.00\nMonthly maximum: $60.00\nSetup maximum: $50.00\n\nMaximum combined amount for these two expressly permitted charges:\n$60.00 + $50.00 = $110.00\n```\n\nThis is available only after the first creditor payment. The setup fee is not included in the $400 monthly base and may be charged only once unless the reentry rule applies. [C014–C016]\n\n## Example IN-DMP-05 — cancellation and close-out\n\nPlain text\n```\nConsumer money held and not yet paid to creditors: $260.00\nAssumed valid disclosed close-out fee: $100.00\nPrior close-out fee charged: No\n\nIllustrative refund:\n$260.00 - $100.00 = $160.00\n```\n\nThe consumer may terminate at any time, creditor notices must be sent, and remaining trust money must be returned immediately. The example assumes the full $100 close-out charge is validly available and no separate unresolved accounting item exists. [C016, C019]\n\n## Example IN-DMP-06 — previous setup/close-out fee\n\nPlain text\n```\nConsumer leaves program and returns after 5 months:\nSecond setup fee permitted? No\nSecond close-out fee permitted? No\n\nConsumer leaves program and returns after 7 months:\nStatute permits another setup/close-out fee? Yes\nProvider required to charge them? No\n```\n\nThe threshold is **more than six months**. Exactly six months does not satisfy “more than six months.” [C016]\n\n## Example IN-DMP-07 — returned payments\n\nPlain text\n```\nNumber of returned consumer payments: 2\nMaximum per returned payment: $25.00\n\nMaximum returned-payment charges:\n2 × $25.00 = $50.00\n```\n\nEach event must be an actual returned check, EFT, negotiable order of withdrawal, or share draft described by the statute. [C017]\n\n## Example IN-DMP-08 — proposed savings fee\n\nPlain text\n```\nOriginal debt: $10,000.00\nCreditor reduction: $4,000.00\nProposed provider fee: 20% of savings\nArithmetic result: 20% × $4,000.00 = $800.00\n\nIndiana DMP result:\n$800.00 is not an expressly authorized DMP fee.\nChargeable now? No, absent specific DFI approval as an additional charge.\n```\n\nThe arithmetic does not create legal permission. [C017, C020]\n\n## Example IN-CSO-01 — enrolled-debt price is not validated by absence of a cap\n\nPlain text\n```\nEnrolled unsecured debt: $10,000.00\nContract price: 20% of enrolled debt\n\nArithmetic:\n20% × $10,000.00 = $2,000.00\n\nIndiana conclusion:\nIC 24-5-15 supplies no verified numerical cap that validates or invalidates\n$2,000 solely by amount.\n```\n\nThe provider still needs the bond/LOC filing, precontract statement, compliant contract, cancellation rights, truthful service/result descriptions, and compliance with independently applicable fee-timing law. [C010, C021–C025]\n\n## Example IN-TSR-01 — proportional allocation\n\nPlain text\n```\nTotal debt enrolled: $10,000.00\nDebt A enrolled amount: $6,000.00\nDebt B enrolled amount: $4,000.00\nDisclosed total program fee: $2,000.00\n\nDebt B proportional share:\n$4,000.00 ÷ $10,000.00 = 0.40\n0.40 × $2,000.00 = $800.00\n\nDebt A proportional share:\n$6,000.00 ÷ $10,000.00 = 0.60\n0.60 × $2,000.00 = $1,200.00\n```\n\nFor individually resolved debts under the TSR method, the provider cannot collect Debt B’s $800 until Debt B has been altered under an executed agreement and the customer has made at least one payment under it. No fee for unresolved Debt A is unlocked merely because Debt B resolved. [C025]\n\n## Example IN-TSR-02 — partial settlement and savings method\n\nPlain text\n```\nDebt at enrollment: $10,000.00\nAmount actually paid to satisfy debt: $7,000.00\n\nSavings:\n$10,000.00 - $7,000.00 = $3,000.00\n\nContractual savings percentage: 25%\nFee:\n25% × $3,000.00 = $750.00\n```\n\nThe same savings percentage must be used from one individually resolved debt to another. The debt must be satisfied; an unaccepted offer or partial payment that does not satisfy the debt does not produce the shown TSR result. [C025]\n\n## Example IN-CSO-02 — three-business-day cancellation\n\nPlain text\n```\nAmount already paid under contract: $300.00\nConsumer sends timely cancellation before midnight of third business day\nSeller receives cancellation notice: Day 0\n\nRequired state refund:\n$300.00 within 10 days after seller receives the notice\n```\n\nWhere the TSR independently barred the original collection, the Indiana cancellation refund does not retroactively make that collection permissible. [C023, C025]\n\n## Example IN-BOUNDARY-01 — business-purpose debt\n\nPlain text\n```\nBorrower: Individual business owner\nDebt: $40,000 business inventory line\nPurpose: Primarily business\n\nDMP classification:\nOutside express personal/family/household debt and debtor definitions.\n\nCSO classification:\nOutside the reviewed personal/family/household extension-of-credit definition.\n\nResult:\nDo not invent a DMP license or CSO consumer-fee pathway.\nOther Indiana law remains uninvestigated in this pass.\n```\n\n## Component coverage and gap table\n\n| Pass component | Status | Supporting claims | Exact unresolved evidence or next action |\n| --- | --- | --- | --- |\n| DMP statutory definition | **Answered** | C001 | No material pass-one gap. |\n| Debt-settlement definition | **Answered** | C002 | No material pass-one gap. |\n| Principal reduction versus DMP concession | **Answered with factual dependency** | C008 | Apply to actual marketing, service promises, payment flow, and creditor documentation. |\n| Custodial versus noncustodial model | **Answered** | C001–C002 | Pure uncompensated counseling remains fact-specific. |\n| Mixed DMP/settlement provider | **Unresolved boundary** | C009 | Search DFI/AG interpretations and controlling cases addressing a person offering both models. |\n| Consumer/business-purpose boundary | **Answered for these chapters** | C003 | Commercial debt rules remain outside this pass. |\n| DMP remote-provider nexus | **Answered** | C004 | Express internet/telephone language. |\n| CSO remote-provider nexus | **Partial** | C013 | Locate controlling applications of “doing business in Indiana” to remote CSOs. |\n| DMP market access | **Answered at statutory level** | C005, C007 | Complete application qualifications, financial condition, bond, and control-person requirements in later pass. |\n| CSO market access | **Answered at statutory level** | C010 | Filing acceptance and public-status evidence remain unavailable. |\n| DMP exemptions | **Answered for current pass** | C006, C031 | Full exemption/circumvention case law remains later. |\n| CSO entity/professional exclusions | **Answered for current pass** | C011–C012, C031 | Each provider’s underlying license, tax, and activity facts must be verified. |\n| Original creditor/self-creditor | **Partial textual inference** | C030 | Research affiliate, servicer, and creditor-side cases. |\n| DMP setup fee | **Answered** | C014 | No gap. |\n| DMP monthly fee | **Answered except zero-base month** | C015 | Search DFI interpretation or examination guidance for a zero-receipt month. |\n| DMP close-out/reentry | **Answered** | C016 | No material pass-one gap. |\n| DMP additional/returned-payment/contribution fees | **Answered** | C017 | Search public DFI approvals for any provider-specific additional charge. |\n| DMP aggregate and indexed caps | **Answered as absence finding** | C020 | Recheck at future currentness date or following statutory amendment. |\n| CSO numerical consumer-fee caps | **Answered as absence finding** | C021 | Other statutes and unconscionability/remedies remain later. |\n| DMP state fee timing | **Answered** | C018 | No material pass-one gap. |\n| CSO state fee timing | **Answered with caution** | C022–C023 | Determine interaction with other Indiana statutes for each transaction. |\n| Federal TSR common baseline | **Answered only as common context** | C025 | Full seller, telemarketer, channel, inbound-call, face-to-face, nonprofit, and attorney scope analysis remains separate. |\n| DFI application route | **Answered** | C026 | Retrieve readable current NMLS Indiana checklists. |\n| DFI public license lookup | **Partial** | C026, C029 | Public endpoint failed; obtain readable roster/detail page before checking any provider. |\n| AG CSO submission route | **Answered at workflow level** | C027 | Portal fields, filing receipt, and public registry not read. |\n| Current DFI provider-fee rule | **Answered** | C028 | Obtain current 2026–27 DFI DOCX for administrative reconciliation. |\n| Named provider authorization | **Not determined** | C029 | Requires official current license or filing evidence; marketing statements are insufficient. |\n| Agreement content | **Touched only as needed** | C018, C023 | Full electronic-consent, mandatory-term, void-term, and creditor-participation pass remains open. |\n| Client money/trust accounts | **Touched only for cancellation** | C019, C025 | Full custody, deposit, reconciliation, account control, and disbursement pass remains open. |\n| Bonds/financial security | **Touched only for access** | C010 | Full bond form, continuation, claims, cancellation, LOC requirements, and DMP bond investigation remains open. |\n| Remedies/enforcement | **Excluded except unlicensed DMP consequence** | C005 | Complete AG, DFI, private-action, restitution, civil-penalty, criminal, and voidness pass remains open. |\n| Collection/litigation/limitations | **Open** | — | Separate required pass. |\n| Secured debts/mortgage rescue | **Open** | — | Separate required pass; no inference from unsecured-debt findings. |\n| Sector, local, tribal, contract, broader case law | **Open** | — | Separate required passes. |\n\n# E. Researcher self-check\n\n### Actually read\n\n- The operative readable passages of IC 28-1-29 covering definitions, exclusions, licensing/nexus, unlicensed consequences, collection-agency affiliation, concessions, agreement termination, fee limits, termination after missed payments, prohibited representations, and voluntary contributions.\n- The operative readable passages of IC 24-5-15 covering buyer, extension of credit, CSO definition/exclusions, debt settlement, precontract disclosures, advance-payment treatment, current contract/cancellation text, and bond/LOC filing.\n- The official enrolled text of P.L.115-2026, §28, printed pages 26–27, including page-image inspection.\n- The Indiana Supreme Court’s reasoning and holding in **Consumer Attorney Services**.\n- Current DFI licensing, division, policies/fee-schedule, and public-lookup landing pages.\n- Current Attorney General CSO filing instructions.\n- Current 750 IAC 10-1-11 readable rule text.\n- Current eCFR §310.4(a)(5), displayed up to date through October 22, 2026.\n\n### Not successfully read or not established\n\n- Full official 2026 code-section text through IGA’s JavaScript interface. The official current indexes and enrolled amendment were used to corroborate currentness; readable mirrors supplied the other passages.\n- The July 1, 2026–June 30, 2027 DFI Consumer Credit fee-schedule DOCX, because the public reader rejected the file type.\n- A current readable DFI debt-management company roster or company-detail page.\n- A public searchable Attorney General CSO filing roster or filing-acceptance record.\n- The generated current Indiana NMLS Debt Management License checklist.\n- Any named provider’s current Indiana authorization.\n- A complete mixed-model, remote-CSO-nexus, provider-specific additional-charge, or zero-base-month administrative interpretation.\n- The remaining agreement, funds, bond, remedies, litigation, limitations, secured-debt, sector, local, tribal, contract, and full case-law categories.\n\nThis was a focused researcher review, **not an independent legal review**, experimental reproduction, state acceptance, or publication-readiness determination. I did not use Chrome control, alter permissions, submit an application, contact a regulator, access private borrower data, check another conversation, or claim a local file write.\n\n**END S_IN PASS-01.**\n\n","tables":[{"headers":["Actual operating model","Indiana classification","Market-access consequence","Consumer-fee consequence"],"index":0,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Actual operating model","Indiana classification","Market-access consequence","Consumer-fee consequence"],["A company enters a written agreement to receive, hold, transmit, or disburse the consumer’s money under a repayment plan","Debt management company, IC 28-1-29","Indiana Department of Financial Institutions license required, including for many remote providers","Detailed Indiana caps: up to $50 setup, monthly formula capped at $75, up to $100 close-out, up to $25 per returned payment, and no unapproved extra charge"],["A company, for compensation, performs, offers, or implies that it will renegotiate, settle, or alter unsecured consumer debt—including reducing principal, interest, or fees","Credit services organization providing debt-settlement services, IC 24-5-15","No ordinary DFI debt-management license established; instead, a $25,000 bond or approved equivalent letter of credit must be obtained and filed with the Indiana Attorney General before doing business","IC 24-5-15 contains no numerical settlement-fee percentage or dollar cap located in this pass; contract-cost disclosure and state/federal timing rules still apply"],["Routine convenience bill payment where the customer retains full control of the money","Express DMP exclusion if genuine and not used to evade the chapter","No DMP license under that exclusion","Other laws remain possible"],["Individual Indiana attorney acting within the actual course and scope of legal practice","Potential statutory exclusion","The exclusion is narrow; a law firm, non-Indiana lawyer, or attorney-branded operation does not inherit it automatically","Fact-specific"],["Business-purpose debt","Outside the express consumer definitions reviewed here","No lawful Indiana consumer-debt-service pathway should be inferred","Other commercial, collection, legal-practice, or contract law remains open"]]},{"headers":["Fee","Indiana limit and basis"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Fee","Indiana limit and basis"],["Setup fee","Maximum $50, for consultation, obtaining a credit report, and establishing the account"],["Monthly service fee","Lesser of: up to 15% of the amount received from the consumer for payment to creditors during that calendar month, subject to a permitted $5 monthly minimum when the percentage calculation is below $5; or $75"],["Close-out fee","Up to $100 upon consumer cancellation or termination of payments"],["Returned payment","Up to $25 per returned payment"],["Other charge","Prohibited unless the provider submits a written explanation and DFI determines that it confers a benefit and is reasonable"],["Voluntary contribution","Cannot be solicited or accepted unless the fee is specifically authorized by the chapter"],["Settlement/savings/per-debt fee","No such fee is expressly authorized; it would require the additional-charge approval process rather than being presumed lawful"]]},{"headers":["Source ID","Title / issuer / authority","Direct literal URL(s)","Exact passage or pinpoint read","Version and effective status; access; limitations"],"index":2,"links":[{"href":"https://iga.in.gov/laws/current/ic/titles/28","text":"Indiana General Assembly\n+2"},{"href":"https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/","text":"Justia Law\n+10"},{"href":"https://iga.in.gov/laws/2026/ic/titles/24","text":"Indiana General Assembly\n+1"},{"href":"https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/","text":"Justia Law\n+7"},{"href":"https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf","text":"Bill Texts\n+2"},{"href":"https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html","text":"Justia Law"},{"href":"https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","text":"Indiana Government"},{"href":"https://www.in.gov/dfi/general-information/consumer-credit-division","text":"Indiana Government"},{"href":"https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/","text":"Indiana Government\n+1"},{"href":"https://iar.iga.in.gov/latestArticle/750/10","text":"Indiana Register\n+2"},{"href":"https://www.in.gov/dfi/general-information/policies-and-guidance/","text":"Indiana Government\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","text":"Indiana Government\n+1"}],"row_links":[[],[{"href":"https://iga.in.gov/laws/current/ic/titles/28","text":"Indiana General Assembly\n+2"}],[{"href":"https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/","text":"Justia Law\n+10"}],[{"href":"https://iga.in.gov/laws/2026/ic/titles/24","text":"Indiana General Assembly\n+1"}],[{"href":"https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/","text":"Justia Law\n+7"}],[{"href":"https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf","text":"Bill Texts\n+2"}],[{"href":"https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html","text":"Justia Law"}],[{"href":"https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","text":"Indiana Government"}],[{"href":"https://www.in.gov/dfi/general-information/consumer-credit-division","text":"Indiana Government"}],[{"href":"https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/","text":"Indiana Government\n+1"}],[{"href":"https://iar.iga.in.gov/latestArticle/750/10","text":"Indiana Register\n+2"}],[{"href":"https://www.in.gov/dfi/general-information/policies-and-guidance/","text":"Indiana Government\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","text":"Indiana Government\n+1"}]],"rows":[["Source ID","Title / issuer / authority","Direct literal URL(s)","Exact passage or pinpoint read","Version and effective status; access; limitations"],["S_IN-P1-S001","Indiana Code 2026, Title 28 — Indiana General Assembly","https://iga.in.gov/laws/current/ic/titles/28","Official title index and searchable current-code result for ch. 28-1-29 and §8.3","Current 2026 official index; checked 2026-10-24. The page requires JavaScript and did not expose full section text in the reader; used for current-code identity, not as the sole passage source. \nIndiana General Assembly\n+2"],["S_IN-P1-S002","IC 28-1-29 readable section compilation — Justia/FindLaw","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-0-5/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-4-5/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-7-7/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-8/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-8/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-9-5/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-17/","Definitions §1(2), (6)–(18); exclusions §0.5; license/nexus/voidness §3; collection affiliation §4.5; concessions §7.7; agreement/cancellation §8; fees §8.3; termination §8.8; prohibited conduct §9.5; contributions §17","Readable 2025 code/FindLaw current-as-of-Jan. 1, 2026 text; checked 2026-10-24. Currentness corroborated against official 2026 title/index and bounded 2026 enactment search. Mirrors warn that official text controls. \nJustia Law\n+10"],["S_IN-P1-S003","Indiana Code 2026, Title 24 — Indiana General Assembly","https://iga.in.gov/laws/2026/ic/titles/24","Official title index identifying ch. 24-5-15","Current 2026 official index; checked 2026-10-24. JavaScript prevented full passage extraction. \nIndiana General Assembly\n+1"],["S_IN-P1-S004","IC 24-5-15 readable chapter and section compilation — Justia/Midpage","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2-5/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-3/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-5/\nhttps://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c\nhttps://app.midpage.ai/laws/in-code/t24/a5/ch15/s7-e83d30\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-8/","Buyer §1; CSO definition/exclusions §2; settlement §2.5; credit §3; advance-fee deceptive act §5; precontract statement §6; current contract/cancellation §7; bond filing §8","2025 compilation except current §7 mirror effective July 1, 2026. Checked 2026-10-24. Official enrolled act separately controls the amendment. \nJustia Law\n+7"],["S_IN-P1-S005","Senate Enrolled Act 169 / P.L.115-2026 — Indiana General Assembly","https://iga.in.gov/legislative/2026/bills/senate/169\nhttps://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf","PDF printed pp. 26–27, §28, lines 1134–1190: amendment of IC 24-5-15-7, effective July 1, 2026","Official enrolled act; checked and page images/text read 2026-10-24. Bill-status page itself required JavaScript. \nBill Texts\n+2"],["S_IN-P1-S006","Consumer Attorney Services, P.A. v. State, 71 N.E.3d 362 — Indiana Supreme Court","https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html","Opinion lines 70–99 and 104; especially construction of §24-5-15-2(b)(6)","Controlling Indiana Supreme Court decision dated March 21, 2017; checked 2026-10-24. No later contrary controlling decision located in the bounded search; broader case-law pass remains open. \nJustia Law"],["S_IN-P1-S007","Consumer Credit Licensing — Indiana DFI","https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","Lines 77–95: NMLS applications and Debt Management License","Current official operational page; checked 2026-10-24. Procedure support, not a substitute for statutory permission or proof of a provider’s status. \nIndiana Government"],["S_IN-P1-S008","Consumer Credit Division and public-license route — Indiana DFI","https://www.in.gov/dfi/general-information/consumer-credit-division\nhttps://extranet.dfi.in.gov/\nhttps://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList\nhttps://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType","DFI page lines 77–91; public listing endpoints attempted","Current DFI page read 2026-10-24. Extranet listings did not return readable results through the public reader; no company status established. \nIndiana Government"],["S_IN-P1-S009","Credit Services Organizations/Foreclosure Consultants — Indiana Attorney General","https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/\nhttps://inoag.my.site.com/oagcounsel/s/login/","AG page lines 28–38; portal response lines 0–4","Current official operational page checked 2026-10-24. Portal displayed loading/CSS error; no public roster or filing acceptance read. \nIndiana Government\n+1"],["S_IN-P1-S010","750 IAC 10-1-11, DFI fee schedules — Indiana Register/Cornell readable copy","https://iar.iga.in.gov/latestArticle/750/10\nhttps://iar.iga.in.gov/register/20240424-IR-750230837FRA\nhttps://www.law.cornell.edu/regulations/indiana/750-IAC-10-1-11","Rule §11(a), debt-management license row; notes showing filing March 26, 2024","Current official article index plus readable rule copy; checked 2026-10-24. Provider/regulator fees only. \nIndiana Register\n+2"],["S_IN-P1-S011","Consumer-credit fee schedules — Indiana DFI","https://www.in.gov/dfi/general-information/policies-and-guidance/\nhttps://www.in.gov/dfi/files/CC_Fees_26-27.docx\nhttps://secure.in.gov/dfi/files/CC-Fees-25-26.pdf","Current landing page lines 76–80; expired PDF p. 1, lines 0–22","Current 2026–27 schedule link verified, but DOCX unsupported by reader. Prior schedule expressly expired June 30, 2026 and is historical only. Checked 2026-10-24. \nIndiana Government\n+1"],["S_IN-P1-S012","16 C.F.R. §310.4(a)(5) — eCFR / FTC Telemarketing Sales Rule","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Lines 115–131: performance/payment triggers, proportional and savings methods, dedicated account return","eCFR displayed as up to date through October 22, 2026; checked October 24, 2026. Federal common context only; applicability analysis remains transaction-specific. \neCFR\n+1"],["S_IN-P1-S013","NMLS Checklist Compiler","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Public compiler route attempted","DFI links this route, but no generated Indiana checklist content was exposed in the public reader. Checked 2026-10-24. \nIndiana Government\n+1"]]},{"headers":["Claim ID","Precise assertion","Source IDs and pinpoint","Conditions, exceptions, currentness, confidence"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source IDs and pinpoint","Conditions, exceptions, currentness, confidence"],["S_IN-P1-C001","A custodial/distribution provider with a written agreement to disburse value is a DMP; merely holding an instrument for transmission can qualify.","S002, IC 28-1-29-1(2), lines 61–66","High confidence; classification still depends on actual services and written arrangement."],["S_IN-P1-C002","Compensated renegotiation, settlement, or alteration of unsecured consumer debt—including balance, interest, or fee reduction—is debt-settlement activity under the CSO chapter.","S004, IC 24-5-15-2(a)(5)–(6), §2.5","High confidence; representations and implied offers count."],["S_IN-P1-C003","Both reviewed regimes are consumer-focused; business-purpose debt is outside the express definitions.","S002, §1(6)–(7); S004, §§1, 3","High confidence for these chapters; no conclusion about other law."],["S_IN-P1-C004","Remote DMPs contracting with or soliciting Indiana residents by internet, telephone, mail, or other communication operate in Indiana.","S002, §3(a)(2)","Express statutory rule; high confidence."],["S_IN-P1-C005","Operating a DMP without a DFI license is prohibited; knowing unlicensed agreements are void and paid fees are recoverable.","S002, §3(a), (e)","High confidence."],["S_IN-P1-C006","DMP exemptions are limited to incidental Indiana-attorney activity, depository institutions, and genuine customer-controlled routine bill payment.","S002, §0.5","Conditions must be proven; no label-based exemption."],["S_IN-P1-C007","DFI generally may not issue a post-1981 DMP license to a collection-agency or process-server employee, owner, or affiliate.","S002, §4.5","Grandfathered pre-Sept. 1, 1981 licenses excepted."],["S_IN-P1-C008","A licensed DMP may obtain concessions and encounter a creditor balance reduction, but may not portray a payment as settlement without creditor certification of full settlement.","S002, §§7.7(d), 9.5(a)(9)","Prevents classification solely from incidental creditor reduction."],["S_IN-P1-C009","Mixed DMP/settlement models are unresolved at the outer boundary because each statute excludes the other category.","S002, §1(2); S004, §2(b)(10)","Legal-classification hold; no universal dual/composite authorization inferred."],["S_IN-P1-C010","A covered CSO must obtain a $25,000 bond or approved equivalent LOC and file it with the AG before doing business.","S004, §8; S009, lines 28–37","High confidence. Filing is not proven merits approval."],["S_IN-P1-C011","CSO exclusions include specified regulated lenders, banks, credit unions, actual §501(c)(3) nonprofits, scoped professionals, CRAs, servicers, and statutory DMPs.","S004, §2(b)(1)–(10)","Each activity/entity condition must independently be satisfied."],["S_IN-P1-C012","The CSO attorney exclusion covers the qualifying Indiana-admitted individual, not automatically a law firm or non-Indiana lawyer.","S006, opinion lines 90–104","Controlling Indiana Supreme Court construction; high confidence."],["S_IN-P1-C013","The exact outer nexus for a remote-only CSO is not conclusively resolved here.","S004, §8; S005/S004, §7(a)(4)","Serving Indiana buyers likely creates risk, but controlling remote-nexus authority remains to be researched."],["S_IN-P1-C014","DMP setup fee is capped at $50 and cannot be collected before the first creditor payment.","S002, §8.3(b), (c)(1)","Requires compliant plan/agreement and creditor notice."],["S_IN-P1-C015","DMP monthly fee is the lesser of the statutory 15%-with-$5-minimum calculation and $75; setup is excluded from the base.","S002, §8.3(c)(2)","Zero-base-month treatment remains an interpretation hold."],["S_IN-P1-C016","DMP close-out fee is capped at $100; no second setup/close-out fee unless the debtor left for more than six months.","S002, §8.3(d)–(e)","“More than” six months, not six months exactly."],["S_IN-P1-C017","Additional DMP charges need DFI approval; returned payments are capped at $25 each; unauthorized voluntary contributions are prohibited.","S002, §8.3(f), (h); §17","No savings/per-debt fee presumed."],["S_IN-P1-C018","DMP consumer fees cannot be imposed or received until a compliant plan/agreement and at least one creditor payment; all creditors must be notified.","S002, §8.3(a)–(b)","State-law timing independent of TSR."],["S_IN-P1-C019","A DMP debtor may terminate at any time; unexpended money must be refunded and trust money returned immediately, subject to the permitted close-out fee.","S002, §§8(a)(6)(I), 8(c), 8.8(c), 8.3(d)","Full funds/accounting analysis remains later."],["S_IN-P1-C020","DMP consumer caps are fixed, not indexed; no express aggregate program cap or ordinary settlement/savings fee was located.","S001–S002, §8.3 and §8(h)","High confidence from current-code and 2026 enactment check; additional DFI-approved charges could alter a specific provider’s situation."],["S_IN-P1-C021","IC 24-5-15 contains no numerical debt-settlement consumer-fee cap located in this chapter review.","S003–S004, complete ch. 15 review","Negative chapter-level finding; not a statement that every fee is lawful."],["S_IN-P1-C022","A bonded/LOC-backed CSO is outside the specific §5(1) state deceptive-act rule against pre-performance payment, but this is not blanket advance-fee authorization.","S004, §§5(1), 8","Other Indiana and federal rules remain independently applicable."],["S_IN-P1-C023","CSO total cost must be disclosed before contract/payment; current contract must state total payments, services/results, refund promises, and cancellation rights; timely cancellation payments return within ten days.","S004–S005, §§6–7","Current §7 effective July 1, 2026."],["S_IN-P1-C024","P.L.115-2026 amended IC 24-5-15-7 effective July 1, 2026.","S005, enrolled act pp. 26–27, §28","Primary enactment evidence."],["S_IN-P1-C025","Where the TSR applies, debt-relief fees require actual altered debt, executed agreement, first consumer payment, and proportional or consistent-savings allocation.","S012, §310.4(a)(5)(i)","Federal scope must be analyzed separately."],["S_IN-P1-C026","DFI identifies the Debt Management License as an NMLS application and provides a public “Find a License” route.","S007–S008","High-level procedure verified; detailed checklist/roster unavailable in reader."],["S_IN-P1-C027","AG provides a CSO “Register/Submit Here” route, but no readable public roster or filing acceptance was verified.","S009","Portal returned loading/CSS error."],["S_IN-P1-C028","Current administrative-rule DMP provider fees are $1,000 application, $1,000 renewal, $20/day late renewal, $80/hour examination, and $20/day late examination payment.","S010, 750 IAC 10-1-11(a)","Regulatory fees, not consumer charges. Current 2026–27 schedule file remained unread."],["S_IN-P1-C029","No named provider’s Indiana authorization is established.","S008–S009","Deliberate evidence hold; no marketing statement substituted for official status."],["S_IN-P1-C030","Original-creditor self-modification may be outside the CSO definition because the credit must be extended “by another person.”","S004, §2(a)","Textual inference only; affiliates, servicers, and structured arrangements remain open."],["S_IN-P1-C031","A nonprofit label is insufficient: DMPs have no blanket nonprofit exemption, while CSO exclusion requires actual §501(c)(3) status.","S002, §9.5(a)(12); S004, §2(b)(4)","Entity status and actual operation must be verified."]]},{"headers":["Pass component","Status","Supporting claims","Exact unresolved evidence or next action"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Pass component","Status","Supporting claims","Exact unresolved evidence or next action"],["DMP statutory definition","Answered","C001","No material pass-one gap."],["Debt-settlement definition","Answered","C002","No material pass-one gap."],["Principal reduction versus DMP concession","Answered with factual dependency","C008","Apply to actual marketing, service promises, payment flow, and creditor documentation."],["Custodial versus noncustodial model","Answered","C001–C002","Pure uncompensated counseling remains fact-specific."],["Mixed DMP/settlement provider","Unresolved boundary","C009","Search DFI/AG interpretations and controlling cases addressing a person offering both models."],["Consumer/business-purpose boundary","Answered for these chapters","C003","Commercial debt rules remain outside this pass."],["DMP remote-provider nexus","Answered","C004","Express internet/telephone language."],["CSO remote-provider nexus","Partial","C013","Locate controlling applications of “doing business in Indiana” to remote CSOs."],["DMP market access","Answered at statutory level","C005, C007","Complete application qualifications, financial condition, bond, and control-person requirements in later pass."],["CSO market access","Answered at statutory level","C010","Filing acceptance and public-status evidence remain unavailable."],["DMP exemptions","Answered for current pass","C006, C031","Full exemption/circumvention case law remains later."],["CSO entity/professional exclusions","Answered for current pass","C011–C012, C031","Each provider’s underlying license, tax, and activity facts must be verified."],["Original creditor/self-creditor","Partial textual inference","C030","Research affiliate, servicer, and creditor-side cases."],["DMP setup fee","Answered","C014","No gap."],["DMP monthly fee","Answered except zero-base month","C015","Search DFI interpretation or examination guidance for a zero-receipt month."],["DMP close-out/reentry","Answered","C016","No material pass-one gap."],["DMP additional/returned-payment/contribution fees","Answered","C017","Search public DFI approvals for any provider-specific additional charge."],["DMP aggregate and indexed caps","Answered as absence finding","C020","Recheck at future currentness date or following statutory amendment."],["CSO numerical consumer-fee caps","Answered as absence finding","C021","Other statutes and unconscionability/remedies remain later."],["DMP state fee timing","Answered","C018","No material pass-one gap."],["CSO state fee timing","Answered with caution","C022–C023","Determine interaction with other Indiana statutes for each transaction."],["Federal TSR common baseline","Answered only as common context","C025","Full seller, telemarketer, channel, inbound-call, face-to-face, nonprofit, and attorney scope analysis remains separate."],["DFI application route","Answered","C026","Retrieve readable current NMLS Indiana checklists."],["DFI public license lookup","Partial","C026, C029","Public endpoint failed; obtain readable roster/detail page before checking any provider."],["AG CSO submission route","Answered at workflow level","C027","Portal fields, filing receipt, and public registry not read."],["Current DFI provider-fee rule","Answered","C028","Obtain current 2026–27 DFI DOCX for administrative reconciliation."],["Named provider authorization","Not determined","C029","Requires official current license or filing evidence; marketing statements are insufficient."],["Agreement content","Touched only as needed","C018, C023","Full electronic-consent, mandatory-term, void-term, and creditor-participation pass remains open."],["Client money/trust accounts","Touched only for cancellation","C019, C025","Full custody, deposit, reconciliation, account control, and disbursement pass remains open."],["Bonds/financial security","Touched only for access","C010","Full bond form, continuation, claims, cancellation, LOC requirements, and DMP bond investigation remains open."],["Remedies/enforcement","Excluded except unlicensed DMP consequence","C005","Complete AG, DFI, private-action, restitution, civil-penalty, criminal, and voidness pass remains open."],["Collection/litigation/limitations","Open","—","Separate required pass."],["Secured debts/mortgage rescue","Open","—","Separate required pass; no inference from unsecured-debt findings."],["Sector, local, tribal, contract, broader case law","Open","—","Separate required passes."]]}],"claims":[{"claim_id":"S_IN-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C001","Precise assertion":"A custodial/distribution provider with a written agreement to disburse value is a DMP; merely holding an instrument for transmission can qualify.","Source IDs and pinpoint":"S002, IC 28-1-29-1(2), lines 61–66","Conditions, exceptions, currentness, confidence":"High confidence; classification still depends on actual services and written arrangement."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C002","Precise assertion":"Compensated renegotiation, settlement, or alteration of unsecured consumer debt—including balance, interest, or fee reduction—is debt-settlement activity under the CSO chapter.","Source IDs and pinpoint":"S004, IC 24-5-15-2(a)(5)–(6), §2.5","Conditions, exceptions, currentness, confidence":"High confidence; representations and implied offers count."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C003","Precise assertion":"Both reviewed regimes are consumer-focused; business-purpose debt is outside the express definitions.","Source IDs and pinpoint":"S002, §1(6)–(7); S004, §§1, 3","Conditions, exceptions, currentness, confidence":"High confidence for these chapters; no conclusion about other law."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C004","Precise assertion":"Remote DMPs contracting with or soliciting Indiana residents by internet, telephone, mail, or other communication operate in Indiana.","Source IDs and pinpoint":"S002, §3(a)(2)","Conditions, exceptions, currentness, confidence":"Express statutory rule; high confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C005","Precise assertion":"Operating a DMP without a DFI license is prohibited; knowing unlicensed agreements are void and paid fees are recoverable.","Source IDs and pinpoint":"S002, §3(a), (e)","Conditions, exceptions, currentness, confidence":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C006","Precise assertion":"DMP exemptions are limited to incidental Indiana-attorney activity, depository institutions, and genuine customer-controlled routine bill payment.","Source IDs and pinpoint":"S002, §0.5","Conditions, exceptions, currentness, confidence":"Conditions must be proven; no label-based exemption."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C007","Precise assertion":"DFI generally may not issue a post-1981 DMP license to a collection-agency or process-server employee, owner, or affiliate.","Source IDs and pinpoint":"S002, §4.5","Conditions, exceptions, currentness, confidence":"Grandfathered pre-Sept. 1, 1981 licenses excepted."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C008","Precise assertion":"A licensed DMP may obtain concessions and encounter a creditor balance reduction, but may not portray a payment as settlement without creditor certification of full settlement.","Source IDs and pinpoint":"S002, §§7.7(d), 9.5(a)(9)","Conditions, exceptions, currentness, confidence":"Prevents classification solely from incidental creditor reduction."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C009","Precise assertion":"Mixed DMP/settlement models are unresolved at the outer boundary because each statute excludes the other category.","Source IDs and pinpoint":"S002, §1(2); S004, §2(b)(10)","Conditions, exceptions, currentness, confidence":"Legal-classification hold; no universal dual/composite authorization inferred."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C010","Precise assertion":"A covered CSO must obtain a $25,000 bond or approved equivalent LOC and file it with the AG before doing business.","Source IDs and pinpoint":"S004, §8; S009, lines 28–37","Conditions, exceptions, currentness, confidence":"High confidence. Filing is not proven merits approval."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C011","Precise assertion":"CSO exclusions include specified regulated lenders, banks, credit unions, actual §501(c)(3) nonprofits, scoped professionals, CRAs, servicers, and statutory DMPs.","Source IDs and pinpoint":"S004, §2(b)(1)–(10)","Conditions, exceptions, currentness, confidence":"Each activity/entity condition must independently be satisfied."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C012","Precise assertion":"The CSO attorney exclusion covers the qualifying Indiana-admitted individual, not automatically a law firm or non-Indiana lawyer.","Source IDs and pinpoint":"S006, opinion lines 90–104","Conditions, exceptions, currentness, confidence":"Controlling Indiana Supreme Court construction; high confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C013","Precise assertion":"The exact outer nexus for a remote-only CSO is not conclusively resolved here.","Source IDs and pinpoint":"S004, §8; S005/S004, §7(a)(4)","Conditions, exceptions, currentness, confidence":"Serving Indiana buyers likely creates risk, but controlling remote-nexus authority remains to be researched."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C014","Precise assertion":"DMP setup fee is capped at $50 and cannot be collected before the first creditor payment.","Source IDs and pinpoint":"S002, §8.3(b), (c)(1)","Conditions, exceptions, currentness, confidence":"Requires compliant plan/agreement and creditor notice."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C015","Precise assertion":"DMP monthly fee is the lesser of the statutory 15%-with-$5-minimum calculation and $75; setup is excluded from the base.","Source IDs and pinpoint":"S002, §8.3(c)(2)","Conditions, exceptions, currentness, confidence":"Zero-base-month treatment remains an interpretation hold."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C016","Precise assertion":"DMP close-out fee is capped at $100; no second setup/close-out fee unless the debtor left for more than six months.","Source IDs and pinpoint":"S002, §8.3(d)–(e)","Conditions, exceptions, currentness, confidence":"“More than” six months, not six months exactly."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C017","Precise assertion":"Additional DMP charges need DFI approval; returned payments are capped at $25 each; unauthorized voluntary contributions are prohibited.","Source IDs and pinpoint":"S002, §8.3(f), (h); §17","Conditions, exceptions, currentness, confidence":"No savings/per-debt fee presumed."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C018","Precise assertion":"DMP consumer fees cannot be imposed or received until a compliant plan/agreement and at least one creditor payment; all creditors must be notified.","Source IDs and pinpoint":"S002, §8.3(a)–(b)","Conditions, exceptions, currentness, confidence":"State-law timing independent of TSR."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C019","Precise assertion":"A DMP debtor may terminate at any time; unexpended money must be refunded and trust money returned immediately, subject to the permitted close-out fee.","Source IDs and pinpoint":"S002, §§8(a)(6)(I), 8(c), 8.8(c), 8.3(d)","Conditions, exceptions, currentness, confidence":"Full funds/accounting analysis remains later."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C020","Precise assertion":"DMP consumer caps are fixed, not indexed; no express aggregate program cap or ordinary settlement/savings fee was located.","Source IDs and pinpoint":"S001–S002, §8.3 and §8(h)","Conditions, exceptions, currentness, confidence":"High confidence from current-code and 2026 enactment check; additional DFI-approved charges could alter a specific provider’s situation."},"coordinator_verification_status":"clarification_required_currentness_or_schedule_condition","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C021","Precise assertion":"IC 24-5-15 contains no numerical debt-settlement consumer-fee cap located in this chapter review.","Source IDs and pinpoint":"S003–S004, complete ch. 15 review","Conditions, exceptions, currentness, confidence":"Negative chapter-level finding; not a statement that every fee is lawful."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C022","Precise assertion":"A bonded/LOC-backed CSO is outside the specific §5(1) state deceptive-act rule against pre-performance payment, but this is not blanket advance-fee authorization.","Source IDs and pinpoint":"S004, §§5(1), 8","Conditions, exceptions, currentness, confidence":"Other Indiana and federal rules remain independently applicable."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C023","Precise assertion":"CSO total cost must be disclosed before contract/payment; current contract must state total payments, services/results, refund promises, and cancellation rights; timely cancellation payments return within ten days.","Source IDs and pinpoint":"S004–S005, §§6–7","Conditions, exceptions, currentness, confidence":"Current §7 effective July 1, 2026."},"coordinator_verification_status":"clarification_required_currentness_or_schedule_condition","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C024","Precise assertion":"P.L.115-2026 amended IC 24-5-15-7 effective July 1, 2026.","Source IDs and pinpoint":"S005, enrolled act pp. 26–27, §28","Conditions, exceptions, currentness, confidence":"Primary enactment evidence."},"coordinator_verification_status":"clarification_required_currentness_or_schedule_condition","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C025","Precise assertion":"Where the TSR applies, debt-relief fees require actual altered debt, executed agreement, first consumer payment, and proportional or consistent-savings allocation.","Source IDs and pinpoint":"S012, §310.4(a)(5)(i)","Conditions, exceptions, currentness, confidence":"Federal scope must be analyzed separately."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C026","Precise assertion":"DFI identifies the Debt Management License as an NMLS application and provides a public “Find a License” route.","Source IDs and pinpoint":"S007–S008","Conditions, exceptions, currentness, confidence":"High-level procedure verified; detailed checklist/roster unavailable in reader."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C027","Precise assertion":"AG provides a CSO “Register/Submit Here” route, but no readable public roster or filing acceptance was verified.","Source IDs and pinpoint":"S009","Conditions, exceptions, currentness, confidence":"Portal returned loading/CSS error."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C028","Precise assertion":"Current administrative-rule DMP provider fees are $1,000 application, $1,000 renewal, $20/day late renewal, $80/hour examination, and $20/day late examination payment.","Source IDs and pinpoint":"S010, 750 IAC 10-1-11(a)","Conditions, exceptions, currentness, confidence":"Regulatory fees, not consumer charges. Current 2026–27 schedule file remained unread."},"coordinator_verification_status":"clarification_required_currentness_or_schedule_condition","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C029","Precise assertion":"No named provider’s Indiana authorization is established.","Source IDs and pinpoint":"S008–S009","Conditions, exceptions, currentness, confidence":"Deliberate evidence hold; no marketing statement substituted for official status."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C030","Precise assertion":"Original-creditor self-modification may be outside the CSO definition because the credit must be extended “by another person.”","Source IDs and pinpoint":"S004, §2(a)","Conditions, exceptions, currentness, confidence":"Textual inference only; affiliates, servicers, and structured arrangements remain open."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_IN-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_IN-P1-C031","Precise assertion":"A nonprofit label is insufficient: DMPs have no blanket nonprofit exemption, while CSO exclusion requires actual §501(c)(3) status.","Source IDs and pinpoint":"S002, §9.5(a)(12); S004, §2(b)(4)","Conditions, exceptions, currentness, confidence":"Entity status and actual operation must be verified."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_IN-P1-S001","urls":["https://iga.in.gov/laws/current/ic/titles/28"],"researcher_record":{"Source ID":"S_IN-P1-S001","Title / issuer / authority":"Indiana Code 2026, Title 28 — Indiana General Assembly","Direct literal URL(s)":"https://iga.in.gov/laws/current/ic/titles/28","Exact passage or pinpoint read":"Official title index and searchable current-code result for ch. 28-1-29 and §8.3","Version and effective status; access; limitations":"Current 2026 official index; checked 2026-10-24. The page requires JavaScript and did not expose full section text in the reader; used for current-code identity, not as the sole passage source. \nIndiana General Assembly\n+2"},"coordinator_verification_status":"held_official_current_full_text_not_read","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S002","urls":["https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/","https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-0-5/","https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-4-5/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-7-7/","https://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-8/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-8/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-9-5/","https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-17/"],"researcher_record":{"Source ID":"S_IN-P1-S002","Title / issuer / authority":"IC 28-1-29 readable section compilation — Justia/FindLaw","Direct literal URL(s)":"https://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-1/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-0-5/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-3/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-4-5/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-7-7/\nhttps://codes.findlaw.com/in/title-28-financial-institutions/in-code-sect-28-1-29-8/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-3/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-8-8/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-9-5/\nhttps://law.justia.com/codes/indiana/title-28/article-1/chapter-29/section-28-1-29-17/","Exact passage or pinpoint read":"Definitions §1(2), (6)–(18); exclusions §0.5; license/nexus/voidness §3; collection affiliation §4.5; concessions §7.7; agreement/cancellation §8; fees §8.3; termination §8.8; prohibited conduct §9.5; contributions §17","Version and effective status; access; limitations":"Readable 2025 code/FindLaw current-as-of-Jan. 1, 2026 text; checked 2026-10-24. Currentness corroborated against official 2026 title/index and bounded 2026 enactment search. Mirrors warn that official text controls. \nJustia Law\n+10"},"coordinator_verification_status":"not_all_passages_freshly_verified","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S003","urls":["https://iga.in.gov/laws/2026/ic/titles/24"],"researcher_record":{"Source ID":"S_IN-P1-S003","Title / issuer / authority":"Indiana Code 2026, Title 24 — Indiana General Assembly","Direct literal URL(s)":"https://iga.in.gov/laws/2026/ic/titles/24","Exact passage or pinpoint read":"Official title index identifying ch. 24-5-15","Version and effective status; access; limitations":"Current 2026 official index; checked 2026-10-24. JavaScript prevented full passage extraction. \nIndiana General Assembly\n+1"},"coordinator_verification_status":"held_official_current_full_text_not_read","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S004","urls":["https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2-5/","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-3/","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-5/","https://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c","https://app.midpage.ai/laws/in-code/t24/a5/ch15/s7-e83d30","https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-8/"],"researcher_record":{"Source ID":"S_IN-P1-S004","Title / issuer / authority":"IC 24-5-15 readable chapter and section compilation — Justia/Midpage","Direct literal URL(s)":"https://law.justia.com/codes/indiana/title-24/article-5/chapter-15/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-1/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-2-5/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-3/\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-5/\nhttps://app.midpage.ai/laws/in-code/t24/a5/ch15/s6-94179c\nhttps://app.midpage.ai/laws/in-code/t24/a5/ch15/s7-e83d30\nhttps://law.justia.com/codes/indiana/title-24/article-5/chapter-15/section-24-5-15-8/","Exact passage or pinpoint read":"Buyer §1; CSO definition/exclusions §2; settlement §2.5; credit §3; advance-fee deceptive act §5; precontract statement §6; current contract/cancellation §7; bond filing §8","Version and effective status; access; limitations":"2025 compilation except current §7 mirror effective July 1, 2026. Checked 2026-10-24. Official enrolled act separately controls the amendment. \nJustia Law\n+7"},"coordinator_verification_status":"not_all_passages_freshly_verified","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S005","urls":["https://iga.in.gov/legislative/2026/bills/senate/169","https://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf"],"researcher_record":{"Source ID":"S_IN-P1-S005","Title / issuer / authority":"Senate Enrolled Act 169 / P.L.115-2026 — Indiana General Assembly","Direct literal URL(s)":"https://iga.in.gov/legislative/2026/bills/senate/169\nhttps://billtexts.s3.amazonaws.com/_data/in/https-iga-in-gov-pdf-documents-124-2026-senate-bills-SB0169-SB0169-04-ENRH-pdf.pdf","Exact passage or pinpoint read":"PDF printed pp. 26–27, §28, lines 1134–1190: amendment of IC 24-5-15-7, effective July 1, 2026","Version and effective status; access; limitations":"Official enrolled act; checked and page images/text read 2026-10-24. Bill-status page itself required JavaScript. \nBill Texts\n+2"},"coordinator_verification_status":"held_enactment_not_authenticated_by_coordinator","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S006","urls":["https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html"],"researcher_record":{"Source ID":"S_IN-P1-S006","Title / issuer / authority":"Consumer Attorney Services, P.A. v. State, 71 N.E.3d 362 — Indiana Supreme Court","Direct literal URL(s)":"https://law.justia.com/cases/indiana/supreme-court/2017/49s05-1703-pl-161.html","Exact passage or pinpoint read":"Opinion lines 70–99 and 104; especially construction of §24-5-15-2(b)(6)","Version and effective status; access; limitations":"Controlling Indiana Supreme Court decision dated March 21, 2017; checked 2026-10-24. No later contrary controlling decision located in the bounded search; broader case-law pass remains open. \nJustia Law"},"coordinator_verification_status":"selected_holding_checked_primary_court_no_complete_later_history","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S007","urls":["https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/"],"researcher_record":{"Source ID":"S_IN-P1-S007","Title / issuer / authority":"Consumer Credit Licensing — Indiana DFI","Direct literal URL(s)":"https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/","Exact passage or pinpoint read":"Lines 77–95: NMLS applications and Debt Management License","Version and effective status; access; limitations":"Current official operational page; checked 2026-10-24. Procedure support, not a substitute for statutory permission or proof of a provider’s status. \nIndiana Government"},"coordinator_verification_status":"selected_operational_route_checked","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S008","urls":["https://www.in.gov/dfi/general-information/consumer-credit-division","https://extranet.dfi.in.gov/","https://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList","https://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType"],"researcher_record":{"Source ID":"S_IN-P1-S008","Title / issuer / authority":"Consumer Credit Division and public-license route — Indiana DFI","Direct literal URL(s)":"https://www.in.gov/dfi/general-information/consumer-credit-division\nhttps://extranet.dfi.in.gov/\nhttps://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList\nhttps://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType","Exact passage or pinpoint read":"DFI page lines 77–91; public listing endpoints attempted","Version and effective status; access; limitations":"Current DFI page read 2026-10-24. Extranet listings did not return readable results through the public reader; no company status established. \nIndiana Government"},"coordinator_verification_status":"not_all_passages_freshly_verified","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S009","urls":["https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/","https://inoag.my.site.com/oagcounsel/s/login/"],"researcher_record":{"Source ID":"S_IN-P1-S009","Title / issuer / authority":"Credit Services Organizations/Foreclosure Consultants — Indiana Attorney General","Direct literal URL(s)":"https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/\nhttps://inoag.my.site.com/oagcounsel/s/login/","Exact passage or pinpoint read":"AG page lines 28–38; portal response lines 0–4","Version and effective status; access; limitations":"Current official operational page checked 2026-10-24. Portal displayed loading/CSS error; no public roster or filing acceptance read. \nIndiana Government\n+1"},"coordinator_verification_status":"selected_bond_filing_instructions_checked_no_named_status","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S010","urls":["https://iar.iga.in.gov/latestArticle/750/10","https://iar.iga.in.gov/register/20240424-IR-750230837FRA","https://www.law.cornell.edu/regulations/indiana/750-IAC-10-1-11"],"researcher_record":{"Source ID":"S_IN-P1-S010","Title / issuer / authority":"750 IAC 10-1-11, DFI fee schedules — Indiana Register/Cornell readable copy","Direct literal URL(s)":"https://iar.iga.in.gov/latestArticle/750/10\nhttps://iar.iga.in.gov/register/20240424-IR-750230837FRA\nhttps://www.law.cornell.edu/regulations/indiana/750-IAC-10-1-11","Exact passage or pinpoint read":"Rule §11(a), debt-management license row; notes showing filing March 26, 2024","Version and effective status; access; limitations":"Current official article index plus readable rule copy; checked 2026-10-24. Provider/regulator fees only. \nIndiana Register\n+2"},"coordinator_verification_status":"not_all_passages_freshly_verified","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S011","urls":["https://www.in.gov/dfi/general-information/policies-and-guidance/","https://www.in.gov/dfi/files/CC_Fees_26-27.docx","https://secure.in.gov/dfi/files/CC-Fees-25-26.pdf"],"researcher_record":{"Source ID":"S_IN-P1-S011","Title / issuer / authority":"Consumer-credit fee schedules — Indiana DFI","Direct literal URL(s)":"https://www.in.gov/dfi/general-information/policies-and-guidance/\nhttps://www.in.gov/dfi/files/CC_Fees_26-27.docx\nhttps://secure.in.gov/dfi/files/CC-Fees-25-26.pdf","Exact passage or pinpoint read":"Current landing page lines 76–80; expired PDF p. 1, lines 0–22","Version and effective status; access; limitations":"Current 2026–27 schedule link verified, but DOCX unsupported by reader. Prior schedule expressly expired June 30, 2026 and is historical only. Checked 2026-10-24. \nIndiana Government\n+1"},"coordinator_verification_status":"current_official_schedule_read_rule_reconciliation_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S012","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_IN-P1-S012","Title / issuer / authority":"16 C.F.R. §310.4(a)(5) — eCFR / FTC Telemarketing Sales Rule","Direct literal URL(s)":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact passage or pinpoint read":"Lines 115–131: performance/payment triggers, proportional and savings methods, dedicated account return","Version and effective status; access; limitations":"eCFR displayed as up to date through October 22, 2026; checked October 24, 2026. Federal common context only; applicability analysis remains transaction-specific. \neCFR\n+1"},"coordinator_verification_status":"selected_federal_text_checked_scope_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_IN-P1-S013","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/"],"researcher_record":{"Source ID":"S_IN-P1-S013","Title / issuer / authority":"NMLS Checklist Compiler","Direct literal URL(s)":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Exact passage or pinpoint read":"Public compiler route attempted","Version and effective status; access; limitations":"DFI links this route, but no generated Indiana checklist content was exposed in the public reader. Checked 2026-10-24. \nIndiana Government\n+1"},"coordinator_verification_status":"not_all_passages_freshly_verified","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"}],"coverage":[{"topic":"DMP statutory definition","researcher_record":{"Pass component":"DMP statutory definition","Status":"Answered","Supporting claims":"C001","Exact unresolved evidence or next action":"No material pass-one gap."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-settlement definition","researcher_record":{"Pass component":"Debt-settlement definition","Status":"Answered","Supporting claims":"C002","Exact unresolved evidence or next action":"No material pass-one gap."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Principal reduction versus DMP concession","researcher_record":{"Pass component":"Principal reduction versus DMP concession","Status":"Answered with factual dependency","Supporting claims":"C008","Exact unresolved evidence or next action":"Apply to actual marketing, service promises, payment flow, and creditor documentation."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial versus noncustodial model","researcher_record":{"Pass component":"Custodial versus noncustodial model","Status":"Answered","Supporting claims":"C001–C002","Exact unresolved evidence or next action":"Pure uncompensated counseling remains fact-specific."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Mixed DMP/settlement provider","researcher_record":{"Pass component":"Mixed DMP/settlement provider","Status":"Unresolved boundary","Supporting claims":"C009","Exact unresolved evidence or next action":"Search DFI/AG interpretations and controlling cases addressing a person offering both models."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business-purpose boundary","researcher_record":{"Pass component":"Consumer/business-purpose boundary","Status":"Answered for these chapters","Supporting claims":"C003","Exact unresolved evidence or next action":"Commercial debt rules remain outside this pass."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP remote-provider nexus","researcher_record":{"Pass component":"DMP remote-provider nexus","Status":"Answered","Supporting claims":"C004","Exact unresolved evidence or next action":"Express internet/telephone language."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO remote-provider nexus","researcher_record":{"Pass component":"CSO remote-provider nexus","Status":"Partial","Supporting claims":"C013","Exact unresolved evidence or next action":"Locate controlling applications of “doing business in Indiana” to remote CSOs."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP market access","researcher_record":{"Pass component":"DMP market access","Status":"Answered at statutory level","Supporting claims":"C005, C007","Exact unresolved evidence or next action":"Complete application qualifications, financial condition, bond, and control-person requirements in later pass."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO market access","researcher_record":{"Pass component":"CSO market access","Status":"Answered at statutory level","Supporting claims":"C010","Exact unresolved evidence or next action":"Filing acceptance and public-status evidence remain unavailable."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP exemptions","researcher_record":{"Pass component":"DMP exemptions","Status":"Answered for current pass","Supporting claims":"C006, C031","Exact unresolved evidence or next action":"Full exemption/circumvention case law remains later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO entity/professional exclusions","researcher_record":{"Pass component":"CSO entity/professional exclusions","Status":"Answered for current pass","Supporting claims":"C011–C012, C031","Exact unresolved evidence or next action":"Each provider’s underlying license, tax, and activity facts must be verified."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Original creditor/self-creditor","researcher_record":{"Pass component":"Original creditor/self-creditor","Status":"Partial textual inference","Supporting claims":"C030","Exact unresolved evidence or next action":"Research affiliate, servicer, and creditor-side cases."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP setup fee","researcher_record":{"Pass component":"DMP setup fee","Status":"Answered","Supporting claims":"C014","Exact unresolved evidence or next action":"No gap."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP monthly fee","researcher_record":{"Pass component":"DMP monthly fee","Status":"Answered except zero-base month","Supporting claims":"C015","Exact unresolved evidence or next action":"Search DFI interpretation or examination guidance for a zero-receipt month."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP close-out/reentry","researcher_record":{"Pass component":"DMP close-out/reentry","Status":"Answered","Supporting claims":"C016","Exact unresolved evidence or next action":"No material pass-one gap."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP additional/returned-payment/contribution fees","researcher_record":{"Pass component":"DMP additional/returned-payment/contribution fees","Status":"Answered","Supporting claims":"C017","Exact unresolved evidence or next action":"Search public DFI approvals for any provider-specific additional charge."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP aggregate and indexed caps","researcher_record":{"Pass component":"DMP aggregate and indexed caps","Status":"Answered as absence finding","Supporting claims":"C020","Exact unresolved evidence or next action":"Recheck at future currentness date or following statutory amendment."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO numerical consumer-fee caps","researcher_record":{"Pass component":"CSO numerical consumer-fee caps","Status":"Answered as absence finding","Supporting claims":"C021","Exact unresolved evidence or next action":"Other statutes and unconscionability/remedies remain later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP state fee timing","researcher_record":{"Pass component":"DMP state fee timing","Status":"Answered","Supporting claims":"C018","Exact unresolved evidence or next action":"No material pass-one gap."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO state fee timing","researcher_record":{"Pass component":"CSO state fee timing","Status":"Answered with caution","Supporting claims":"C022–C023","Exact unresolved evidence or next action":"Determine interaction with other Indiana statutes for each transaction."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR common baseline","researcher_record":{"Pass component":"Federal TSR common baseline","Status":"Answered only as common context","Supporting claims":"C025","Exact unresolved evidence or next action":"Full seller, telemarketer, channel, inbound-call, face-to-face, nonprofit, and attorney scope analysis remains separate."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DFI application route","researcher_record":{"Pass component":"DFI application route","Status":"Answered","Supporting claims":"C026","Exact unresolved evidence or next action":"Retrieve readable current NMLS Indiana checklists."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DFI public license lookup","researcher_record":{"Pass component":"DFI public license lookup","Status":"Partial","Supporting claims":"C026, C029","Exact unresolved evidence or next action":"Public endpoint failed; obtain readable roster/detail page before checking any provider."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"AG CSO submission route","researcher_record":{"Pass component":"AG CSO submission route","Status":"Answered at workflow level","Supporting claims":"C027","Exact unresolved evidence or next action":"Portal fields, filing receipt, and public registry not read."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Current DFI provider-fee rule","researcher_record":{"Pass component":"Current DFI provider-fee rule","Status":"Answered","Supporting claims":"C028","Exact unresolved evidence or next action":"Obtain current 2026–27 DFI DOCX for administrative reconciliation."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Pass component":"Named provider authorization","Status":"Not determined","Supporting claims":"C029","Exact unresolved evidence or next action":"Requires official current license or filing evidence; marketing statements are insufficient."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement content","researcher_record":{"Pass component":"Agreement content","Status":"Touched only as needed","Supporting claims":"C018, C023","Exact unresolved evidence or next action":"Full electronic-consent, mandatory-term, void-term, and creditor-participation pass remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Client money/trust accounts","researcher_record":{"Pass component":"Client money/trust accounts","Status":"Touched only for cancellation","Supporting claims":"C019, C025","Exact unresolved evidence or next action":"Full custody, deposit, reconciliation, account control, and disbursement pass remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Bonds/financial security","researcher_record":{"Pass component":"Bonds/financial security","Status":"Touched only for access","Supporting claims":"C010","Exact unresolved evidence or next action":"Full bond form, continuation, claims, cancellation, LOC requirements, and DMP bond investigation remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Remedies/enforcement","researcher_record":{"Pass component":"Remedies/enforcement","Status":"Excluded except unlicensed DMP consequence","Supporting claims":"C005","Exact unresolved evidence or next action":"Complete AG, DFI, private-action, restitution, civil-penalty, criminal, and voidness pass remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Collection/litigation/limitations","researcher_record":{"Pass component":"Collection/litigation/limitations","Status":"Open","Supporting claims":"—","Exact unresolved evidence or next action":"Separate required pass."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debts/mortgage rescue","researcher_record":{"Pass component":"Secured debts/mortgage rescue","Status":"Open","Supporting claims":"—","Exact unresolved evidence or next action":"Separate required pass; no inference from unsecured-debt findings."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Sector, local, tribal, contract, broader case law","researcher_record":{"Pass component":"Sector, local, tribal, contract, broader case law","Status":"Open","Supporting claims":"—","Exact unresolved evidence or next action":"Separate required passes."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}