{"meta":{"key":"s_ky--pass-01","task":"S_KY","title":"Kentucky provider market access and consumer fees","parent_title":"Kentucky debt and debt relief law","edition":"pass-01","path":"/research/s_ky--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":6,"claims":37,"sources":18,"review_status":"revise","review_complete":true,"sha256":"7d87f4531ffa12dc50814a27f92de19dd8f32861f5040c8f5d5303a323c29e1c","headings":["Kentucky provider market access and consumer fees","Executive disposition","1. Current Kentucky classification and coverage","1.1 Activity-based definition","1.2 Model-by-model classification","1.3 Consumer versus business purpose","2. Prohibited, registered, authorized, and exempt models","2.1 Ordinary covered businesses: registration, not blanket prohibition","2.2 Express statutory exemptions","2.3 Attorney and nonprofit boundaries","3. Applicable consumer fee structures","3.1 Verified Kentucky fee matrix","3.2 CPI adjustment: exact current amount held","3.3 Additional fee boundaries","4. When fees may be requested or received","4.1 Kentucky timing","4.2 Federal TSR baseline—separate from Kentucky permission","5. Current regulator process, permission, lookup, and effective status","5.1 Current verified route","5.2 Current versus proposed procedure","5.3 Public lookup limitation","6. Worked examples","7. Component coverage and next investigations","D.1 Custodial DMP—lower monthly distribution","D.2 Custodial DMP—higher distribution","D.3 Very low distribution","D.4 Bad-check charge","Scenario A","Scenario B","D.5 Kentucky setup ceiling versus federal timing","D.6 Fourteen-day cancellation","D.7 Residential-mortgage assistance fee","D.8 Fifty-percent settlement authorization boundary","Settlement A","Settlement B","D.9 Federal partial settlement—proportional allocation","D.10 Federal savings method","D.11 Termination after a previously earned fee","D.12 Full scope-coverage and gap table","Actually read and used","Not verified or not treated as 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_KY/pass-01","facets":{"geography":["us","us-ky"],"debt_type":[],"stage":["repossession"],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Kentucky provider-access/fees component; all other individual-state categories remain required","pending_corrections":0},"markdown":"# SettleADebt.com — S_KY PASS-01\n\n## Kentucky provider market access and consumer fees\n\n**Actual public-source research date:** October 24, 2026, Pacific Time.\n**Requested baseline:** October 22, 2026. The baseline is not treated as the current-verification date.\n\n**Component status:** This is the Kentucky provider-access and consumer-fee component only. It does not complete the Kentucky dossier, does not resolve every contract, client-funds, remedies, litigation, secured-debt, sector, local, tribal, limitations, or case-law issue, and does not imply Kentucky-state or A066 acceptance.\n\n## Executive disposition\n\nKentucky does **not** impose a blanket prohibition on ordinary debt-settlement or debt-management businesses. It uses a broad, activity-based **debt-adjuster registration** regime administered by the Kentucky Attorney General. “Debt adjusting” expressly includes budget counseling, debt management, debt modification or settlement, foreclosure assistance, debt pooling, creditor intermediation, receiving and distributing debtor funds, and soliciting or advertising as a debt adjuster. The definition therefore reaches principal-reduction settlement as well as concession/payment-distribution plans, and it reaches noncustodial as well as custodial models. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378)\n\nA covered person must register annually. Under the currently effective regulation, filing alone is not enough: the registration must be complete, accurate, and **confirmed in writing** by the Consumer Protection Division before the person engages in debt adjusting. Kentucky calls this registration, not licensing. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nKentucky’s verified printed fee provisions are:\n\n- initial setup: not more than **$75**;\n- consultation: not more than **$50 per calendar year**;\n- custodial unsecured-creditor periodic fee: not more than the **greater of 8.5% of the monthly amount paid for distribution to creditors or $30**;\n- bad-check charge: **$20 or the amount passed through by the bank, whichever is greater**;\n- for a defined category of residential-mortgage-secured consumer debt, no “other” fee may be accepted—or even escrowed—before complete performance of all promised services. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nKRS 380.040(4) permits annual CPI-related adjustment, but this investigation did **not** locate a current official adjustment schedule, order, bulletin, methodology, base period, or authoritative current adjusted amount. The Attorney General’s dated operational table still displays the printed amounts, but the page is identified as updated in November 2010 and even uses an obsolete subsection reference for the mortgage rule. Accordingly, no CPI uplift is calculated or asserted in this pass. [Kentucky Agriculture+1](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx)\n\nFor a noncustodial unsecured-debt-settlement performance fee, no express Kentucky percentage, per-debt, savings-based, or aggregate amount cap was found in the current Chapter 380 provisions reviewed. That is an **absence finding, not affirmative authorization to charge any amount**. All fees must be itemized in the contract, conduct may not be unconscionable, unrelated add-ons are barred, the debtor must receive the full benefit of a compromise, and independently applicable federal timing restrictions may prohibit requesting or receiving the fee before performance. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387)\n\n# A. Substantive answers to the numbered scope questions\n\n## 1. Current Kentucky classification and coverage\n\n### 1.1 Activity-based definition\n\nKRS 380.010 defines “debt adjusting” through the activity performed, not the business’s chosen label. It covers doing business in Kentucky in:\n\n- debt adjusting;\n- budget counseling;\n- debt management;\n- debt modification or settlement;\n- foreclosure assistance; or\n- debt pooling.\n\nIt also covers holding oneself out, offering, or attempting to act as an intermediary between a debtor and creditors for a fee, contribution, or other consideration to adjust, compromise, settle, modify, or discharge debt; receive and distribute debtor funds; or solicit and advertise as a debt adjuster. A “person” includes individuals, partnerships, associations, corporations, LLCs, trusts, and other legal entities. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378)\n\n### 1.2 Model-by-model classification\n\n| Model or conduct | Kentucky Chapter 380 classification | Custody relevance | PASS-01 disposition |\n| --- | --- | --- | --- |\n| Principal-reduction debt settlement or negotiation | Expressly within “modification or settlement” and adjustment, compromise, settlement, modification, or discharge of indebtedness | Custody is not required for coverage | Covered unless a specific KRS 380.030 exemption applies. **C002-C004** |\n| DMP involving creditor concessions and regular creditor payments | Expressly within debt management and creditor intermediation | If the provider receives and holds money for unsecured-creditor distribution, the trust, 30-day disbursement, and periodic-fee rules apply | Covered; registration required. **C002, C004, C018, C027** |\n| Credit or budget counseling | “Budget counseling” is expressly named | No custody prerequisite in the general definition | Commercial counseling directed at debt management is covered. A genuinely education-only service with no debt-management or creditor-intermediary function remains fact-dependent. **C002, C004** |\n| Noncustodial settlement using a consumer-owned third-party account | Settlement/intermediation remains covered even if the provider never holds creditor money | The special custodial periodic-fee formula may not apply if the debt adjuster does not receive and hold funds for creditor distribution | Registration remains required; state performance-fee amount cap is unresolved. **C004, C022** |\n| Custodial debt management or pooling | Expressly covered by receiving debtor money and disbursing it to creditors | Triggers trust-account and 30-day-disbursement requirements | Covered; registration plus custodial duties. **C004, C027** |\n| Foreclosure or residential-mortgage assistance | “Foreclosure assistance” is expressly named | Special advance-fee prohibition and enhanced insurance/bond requirements can apply to the defined residential-mortgage-secured consumer debt | Covered, with additional restrictions. Other mortgage-assistance laws remain open. **C002, C021, C028** |\n| Solicitation or advertising | Soliciting business and advertising as a debt adjuster is expressly included | No custody required | A seller cannot avoid coverage merely by outsourcing negotiations or funds handling if it holds itself out as providing the covered service. Pure publisher/referral facts remain unresolved. **C005** |\n| Corporate or LLC borrower debt | “Debtor” is defined as an **individual** residing in Kentucky | Not relevant if there is no statutory “debtor” | A corporation or LLC, in its own capacity, falls outside that definition. **C008** |\n| Individual’s business-purpose debt | “Debtor” is an individual Kentucky resident; the general definition does not expressly require personal, family, or household purpose | Some mortgage-specific provisions separately contain a consumer-purpose limitation | A sole proprietor’s, guarantor’s, or other individual’s business-purpose debt is potentially covered. No controlling appellate construction was located; hold fact-specific. **C008, C037** |\n| Remote or out-of-state provider | Custodial KRS 380.040 expressly says “whether or not located in this state”; the rule and form focus on services to Kentucky residents | Remote location does not create a custodial safe harbor | Strong coverage conclusion where the provider contracts with or serves a Kentucky resident. Passive-site or de minimis-contact limits remain unresolved. **C006-C007** |\n\nThe statutory “debtor” is an individual who resides in Kentucky, with “reside” including temporary or permanent residence. That makes Kentucky residency the clearest consumer-side nexus. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378)\n\n### 1.3 Consumer versus business purpose\n\nChapter 380’s general debtor definition is tied to an **individual resident**, not expressly to “consumer debt.” By contrast, several special mortgage provisions expressly apply only where the debt is primarily for personal, family, or household use and is secured by residential real property or related collateral. That contrast supports the cautious conclusion that an individual’s business-purpose debt is not automatically excluded from the chapter, while an entity’s own debt is outside the defined “debtor.” This is a textual inference, not a reported Kentucky appellate holding. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378)\n\n## 2. Prohibited, registered, authorized, and exempt models\n\n### 2.1 Ordinary covered businesses: registration, not blanket prohibition\n\nKRS 380.040(5) requires **any person that engages in debt adjusting** to file an initial registration and renew annually, with a $250 filing fee each time. The currently effective regulation provides that:\n\n1. the initial filing must occur before the provider begins;\n2. registration is not effective until all required information and materials are filed;\n3. the Division provides written confirmation;\n4. a person may not engage in debt adjusting before a complete and accurate registration has been confirmed; and\n5. registration is valid for one year from the effective date in the written confirmation. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nThus:\n\n- ordinary for-profit debt settlement is **conditionally market-accessible through confirmed registration**, not generally prohibited;\n- custodial DMP activity is **conditionally market-accessible through confirmed registration**, subject to additional trust and fee rules;\n- mortgage/foreclosure-assistance activity is not converted into ordinary advance-fee authority merely by registration; the activity-specific fee prohibition still applies;\n- registration is not a determination that every contract, fee, marketing representation, or servicing model complies with law.\n\n### 2.2 Express statutory exemptions\n\n| Exemption | Exact conditions | What is not enough |\n| --- | --- | --- |\n| Kentucky attorney | Admitted to practice in Kentucky; not principally engaged in debt adjusting; services rendered in the course of law practice | Attorney affiliation, an attorney-owned company, an out-of-state lawyer, or a Kentucky lawyer principally engaged in debt adjusting is not automatically exempt |\n| Regular employee | Regular, full-time employee adjusting the employer’s debts | Independent contractor or outsourced vendor |\n| Court or statutory authority | Acting under court order or judgment, or authority conferred by Kentucky or federal law | General assertion that conduct is “legal” |\n| Creditor or creditor agent | Creditor or agent of one or more creditors, with adjustment services rendered **without cost to the debtor** | Creditor-side compensation does not cure a debtor charge; a debtor fee defeats this particular condition |\n| Loan-disbursement model | Makes or arranges a loan and, with debtor authorization, disburses proceeds to adjust debts, without debtor compensation for the adjustment service | Charging the debtor for the adjustment component |\n| Section 501(c)(3) organization | Charitable, religious, or educational organization determined exempt under §501(c)(3), and **not in the business of debt adjusting** | Merely being nonprofit, tax-exempt, or charitable in name |\n| Self-creditor | Creditor adjusting debts owed to itself | Adjusting unrelated third-party debts |\n| Chapter 286 financial institution collecting own debt | Chapter 380 does not limit a KRS Chapter 286 licensed institution’s collection of debts owed to it | This is not a blanket exemption for third-party debt-adjusting services |\n\nThe conditions come directly from KRS 380.030 and 380.130. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380)\n\n### 2.3 Attorney and nonprofit boundaries\n\nThe attorney exemption is narrower than a generic “attorney model.” It requires Kentucky admission, nonprincipal engagement in debt adjusting, and provision of the services in the attorney’s law practice. A company cannot safely infer exemption because a lawyer reviews files or appears in the corporate structure. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380)\n\nLikewise, the nonprofit exemption is conjunctive: the organization must have the specified §501(c)(3) status **and** must not be in the business of debt adjusting. Nonprofit status by itself does not establish exemption. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380)\n\n## 3. Applicable consumer fee structures\n\n### 3.1 Verified Kentucky fee matrix\n\nThe figures below are the amounts and formula printed in the current KRS text. Because the CPI-adjustment issue is unresolved, they should not be restated as proven CPI-adjusted 2026 figures.\n\n| Fee or charge | Statutory base | Verified printed ceiling or rule | Important conditions |\n| --- | --- | --- | --- |\n| Initial setup | Fee, contribution, or other consideration from a Kentucky-resident debtor for initial setup | **$75 maximum** | Exact CPI-adjusted ceiling, if any, held. **C016, C020** |\n| Consultation | Fee, contribution, or other consideration from a Kentucky-resident debtor for consultation | **$50 maximum per calendar year** | Exact CPI-adjusted ceiling, if any, held. **C017, C020** |\n| Custodial periodic fee for unsecured creditors | Amount paid by the debtor each month **for distribution to the debtor’s creditors** | Maximum is the **greater of 8.5% of that monthly distribution amount or $30** | Applies when the debt adjuster receives and holds money or value for distribution to unsecured creditors. **C018** |\n| Bad-check charge | Returned/bad-payment event | **$20 or the amount passed through by the debt adjuster’s bank, whichever is greater** | In addition to otherwise nonprohibited fees. **C019** |\n| “Other” fee connected with defined secured debt | Debt primarily for personal, family, or household use, secured by a residential mortgage, deed of trust, equivalent consensual interest, or collateral having a residential mortgage lien | **No acceptance before complete performance of all promised services** | Escrowing the fee for later payment is expressly prohibited. Exact postperformance amount cap not specified in this paragraph. **C021** |\n| Noncustodial unsecured settlement performance fee | Provider negotiates but does not receive and hold money for creditor distribution | No express Kentucky percentage or dollar amount cap located | This is not an “unlimited fee” finding. Contract disclosure, unconscionability, cancellation, federal timing, and other law remain applicable. **C022-C024** |\n| Kentucky per-debt allocation rule | Settlement of individual unsecured debts | No Kentucky formula found equivalent to the federal proportional or savings formula | Federal TSR formula applies only when federal coverage exists. **C023, C032** |\n| Kentucky savings-percentage cap | Savings produced by settlement | No state percentage ceiling found in the reviewed provisions | Absence is not affirmative approval of a percentage. **C022-C023** |\n| Kentucky aggregate settlement-fee cap | Entire enrolled debt portfolio | No express state aggregate cap found | Contract and unconscionability constraints remain. **C022-C024** |\n| Provider registration fee | Initial and annual filing with Attorney General | **$250 initial; $250 annual** | This is a provider regulatory filing fee, not a consumer fee. **C009** |\n\nThe operative fee text is in KRS 380.040(2)-(4). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n### 3.2 CPI adjustment: exact current amount held\n\nKRS 380.040(4) says the fees, contributions, or consideration permitted in subsections (1), (2), and (3) “may be adjusted” annually by an amount equivalent to any CPI increase published by BLS. The provision does not itself state a base year, a particular CPI series, a rounding method, a required publication instrument, or an adjusted table. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nThe Attorney General’s fee page continues to display $75, $50, 8.5%/$30, and $20/bank pass-through. But the landing page identifies that guidance as updated in November 2010, and the fee page labels the mortgage rule as “380.040(4)” even though current KRS places that rule at §380.040(2)(d), while current subsection (4) is the CPI provision. The page therefore corroborates the nominal figures but is not sufficient evidence of a legally operative 2026 CPI adjustment—or of the absence of one. [Kentucky Agriculture+1](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx)\n\n**PASS-01 hold:** No official adjustment order, bulletin, fee schedule, administrative regulation, or other primary Kentucky instrument establishing a different current amount was located. No CPI calculation is supplied.\n\n### 3.3 Additional fee boundaries\n\nThe following provisions further constrain fees even where no numerical performance-fee cap was identified:\n\n- all fees or their determination method must be individually itemized in the agreement;\n- the total amount and terms of compensation must be disclosed;\n- unrelated insurance, club memberships, coupons, internet access, and similar add-ons may not be charged as part of debt-adjusting services;\n- the debtor must receive the full benefit of a compromise arranged by the adjuster;\n- unfair conduct is prohibited, with “unfair” defined as unconscionable;\n- Kentucky permits a settlement fee to be deferred only at no additional expense to the debtor. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383)\n\n## 4. When fees may be requested or received\n\n## 4.1 Kentucky timing\n\nKentucky creates one clear activity-specific performance trigger:\n\nFor the defined residential-mortgage-secured consumer debt, no other fee may be accepted before **complete performance of all promised services**, and putting the fee into escrow for later release is expressly prohibited. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nFor ordinary unsecured settlement, the Kentucky provisions reviewed do not state a comparable universal performance trigger for setup, consultation, or performance fees. That does **not** mean that a Kentucky amount ceiling authorizes advance collection. Timing remains subject to:\n\n- the specific service model;\n- contract and cancellation rights;\n- unconscionability and misrepresentation prohibitions;\n- independently applicable federal law; and\n- other unreviewed state or federal laws.\n\nFor custodial models, debtor funds received for creditor distribution generally must be distributed, less lawful fees, within 30 days unless the debtor specifically instructs otherwise, and must be maintained in a separate trust account. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\nKentucky also prohibits representing a payment as a settlement unless the debtor receives creditor certification that the payment is a full settlement or part of a certified payment plan that will lead to full settlement. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## 4.2 Federal TSR baseline—separate from Kentucky permission\n\nThe federal TSR defines a debt-relief service as a program represented to renegotiate, settle, or alter payment or other terms with unsecured creditors or debt collectors, including balance, interest-rate, or fee reductions. “Telemarketing” generally means a plan, program, or campaign using one or more telephones and involving more than one interstate call. A full federal coverage and exemption analysis is outside this state component. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\nWhere the TSR applies, a seller or telemarketer may not request or receive **any fee or consideration for the debt-relief service** until:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under an agreement executed by the customer; and\n2. the customer has made at least one payment under that agreement. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nWhere debts are altered individually, the fee must either:\n\n- bear the same proportional relationship to the total fee as that debt’s enrolled amount bears to the total enrolled amount; or\n- be the same percentage of savings for each debt. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nA qualifying dedicated account must be at an insured institution, remain owned by the customer, be administered by an unaffiliated entity that does not exchange referral compensation, and return all funds other than properly earned fees within seven business days after withdrawal. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n**Critical reconciliation:** A Kentucky setup ceiling of $75 is an amount restriction. It is not permission to collect $75 before the federal performance trigger where the TSR applies.\n\n## 5. Current regulator process, permission, lookup, and effective status\n\n### 5.1 Current verified route\n\nThe current operative route is:\n\n1. complete the Commonwealth of Kentucky Debt Adjuster Registration Statement, Form DA-1;\n2. supply the required organizational, authority-to-transact, service-model, fee-schedule, agreement, trust-account, insurance, and bond/letter-of-credit information;\n3. file the original documentation with the Kentucky Attorney General, Consumer Protection Division;\n4. pay the $250 filing fee;\n5. file before beginning Kentucky debt-adjusting activity;\n6. obtain written confirmation of an effective registration; and\n7. renew annually, with the renewal filed at least four weeks before expiration and accompanied by required audit material. [Legislative Research Commission+3](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/)\n\nThe current form requires, among other things:\n\n- evidence of authority to transact business in Kentucky;\n- a description of services offered to Kentucky residents;\n- identification of residential-mortgage-secured activity;\n- separate disclosure of setup, consultation, service/periodic, bad-check, and “other” fees;\n- sample Kentucky consumer agreements;\n- trust-account information;\n- insurance details; and\n- a bond or approved letter-of-credit submission. [Kentucky Agriculture+3](https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf)\n\n### 5.2 Current versus proposed procedure\n\nThe currently effective 40 KAR 12:400 retains the paper-form process, written confirmation, one-year registration period, and current July 2010 forms. It was recodified as 40 KAR 12:400 effective July 18, 2025, and the LRC page shows a seven-year expiration date of February 21, 2027. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/)\n\nA separate 2026 amendment would institute an online registration and renewal portal. The LRC page expressly labels that amendment **“PROPOSED”** and **“not yet current.”** It was filed with LRC on July 8, 2026, and the displayed proposed page was generated August 28, 2026. It is not used here as current operative law. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/)\n\n### 5.3 Public lookup limitation\n\nThe Attorney General provides a “registered debt adjusters” PDF and expressly says the list is not an endorsement. [Kentucky Agriculture](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx)\n\nHowever, the file has a material internal integrity problem:\n\n- the extracted text layer says “Updated: 10/19/2026” and presents a list inconsistent with the rendered pages; [Kentucky Agriculture](https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf)\n- rendered page 1 says “Updated: 3/30/2026”; [Kentucky Agriculture](https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf)\n- rendered page 2 says “Updated: 8/24/2026,” reports 36 adjusters, and visually contains a duplicated entry. [Kentucky Agriculture](https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf)\n\nTherefore the public PDF is useful as a discovery or screening tool but, standing alone, is insufficient to establish:\n\n- a named provider’s registration expiration date;\n- whether registration remained effective on a particular transaction date;\n- the exact model or fee schedule approved or disclosed;\n- whether a provider’s legal entity, DBA, or affiliate is covered;\n- whether a registration was later suspended, withdrawn, or rendered incomplete; or\n- whether the provider complied with nonregistration obligations.\n\nNo named-provider authorization finding is made in this pass.\n\n## 6. Worked examples\n\nThe required examples appear in Section D below. They distinguish the statutory base, operator, intermediate calculation, result, units, rounding, legal conditions, and unresolved assumptions.\n\n## 7. Component coverage and next investigations\n\nThe full coverage and gap table appears in Section D. Agreement form, client-money operations, bond claims, remedies, full enforcement history, collections, litigation, limitations, secured-debt overlays, sector-specific law, local law, tribal issues, contract enforceability, and exhaustive case law remain later passes except to the limited extent needed here.\n\n# B. Source table\n\n| Source ID | Title, issuer, and direct literal URL | Exact pinpoint/version/effective status | Actual check and limitations |\n| --- | --- | --- | --- |\n| **S_KY-P1-S001** | KRS Chapter 380 index, Kentucky Legislative Research Commission. https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145 | Lines 90-120: includes enactments through 2026 Regular Session; database updated 10/24/2026 | Accessed 10/24/2026. Currentness index, not substantive text. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145) |\n| **S_KY-P1-S002** | KRS 380.010, Definitions. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378 | §380.010(1)-(5), PDF pp.1-2; effective 7/15/2010 | Accessed/read 10/24/2026. Primary statutory definition. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) |\n| **S_KY-P1-S003** | KRS 380.030, Exempt persons. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380 | §380.030(1)-(7), PDF p.1; effective 7/15/2010 | Accessed/read 10/24/2026. Express exemptions only; entity structuring facts may require later analysis. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380) |\n| **S_KY-P1-S004** | KRS 380.040, powers, prohibitions, fees, registration, audit, insurance, bond. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571 | §380.040(1)-(10), PDF pp.1-5; effective 4/5/2024 | Accessed/read 10/24/2026. Principal substantive source for this pass. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) |\n| **S_KY-P1-S005** | KRS 380.060, contract disclosure and 14-day cancellation. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383 | §380.060(1)-(7), PDF pp.1-2; effective 7/15/2010 | Accessed/read 10/24/2026. Used only for compensation disclosure and cancellation/refund boundaries. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383) |\n| **S_KY-P1-S006** | KRS 380.100, agreement contents and termination. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387 | §380.100(1)-(5), PDF pp.1-3; effective 7/15/2010 | Accessed/read 10/24/2026. Used for itemized fees, unexpended-funds refund, and settlement authorization boundaries. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387) |\n| **S_KY-P1-S007** | KRS 380.110, private action. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388 | §380.110(1)-(4), PDF p.1; effective 7/15/2010 | Accessed/read 10/24/2026. Detailed remedies reserved for later pass. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388) |\n| **S_KY-P1-S008** | KRS 380.120, nonwaiver. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389 | Entire section; effective 7/15/2010 | Accessed/read 10/24/2026. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389) |\n| **S_KY-P1-S009** | KRS 380.130, financial institution own-debt provision. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390 | Entire section; effective 7/15/2010 | Accessed/read 10/24/2026. Not a blanket third-party-service exemption. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390) |\n| **S_KY-P1-S010** | KRS 380.990, penalties and KCPA treatment. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391 | §380.990(1)-(4), PDF p.1; effective 7/15/2010 | Accessed/read 10/24/2026. Enforcement details remain later-pass material. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391) |\n| **S_KY-P1-S011** | Current 40 KAR 12:400, Kentucky LRC. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/ | Sections 1-7; registration effective only after complete filing and written confirmation; history shows recodification effective 7/18/2025; expiration 2/21/2027 | Accessed/read 10/24/2026. Current operative regulation; separate proposed version exists. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/) |\n| **S_KY-P1-S012** | Proposed 40 KAR 12:400 amendment. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/ | Page labels: “PROPOSED—This document is not yet current”; filed 7/8/2026; page generated 8/28/2026; proposed online application | Accessed/read 10/24/2026. Not current law and not used as operative procedure. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/) |\n| **S_KY-P1-S013** | Kentucky AG, Information for Adjusters. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx | Definition, fee table, registration instructions, mail address | Accessed 10/24/2026. Operational guidance; landing page identifies it as updated Nov. 2010. Its mortgage-rule subsection citation is stale. [Kentucky Agriculture+1](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx) |\n| **S_KY-P1-S014** | Kentucky AG, Debt Adjusters landing page. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx | Lines 36-51: list not endorsement; links to list and Nov. 2010 guidance | Accessed 10/24/2026. Procedure/lookup aid, not legal authorization. [Kentucky Agriculture](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx) |\n| **S_KY-P1-S015** | Kentucky AG, Registered Debt Adjusters PDF. https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf | Parsed layer says updated 10/19/2026; rendered pp.1-2 say 3/30/2026 and 8/24/2026; visual total 36 | Accessed, parsed, and visually inspected 10/24/2026. Internal inconsistency prevents treating it as conclusive named-provider proof. [Kentucky Agriculture+2](https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf) |\n| **S_KY-P1-S016** | Form DA-1, Debt Adjuster Registration Statement. https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf | July 2010, pp.1-7; fee schedule p.5; insurance/bond pp.6-7 | Accessed/read 10/24/2026. Current rule incorporates the July 2010 form, although it contains legacy URLs and old rule-number references. [Kentucky Agriculture+2](https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf) |\n| **S_KY-P1-S017** | eCFR, 16 CFR Part 310, definitions. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310 | §§310.2(o), 310.2(ii); displayed federal text current through 10/22/2026 | Accessed 10/24/2026. eCFR is continuously updated and authoritative but unofficial. Federal common context only. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) |\n| **S_KY-P1-S018** | eCFR, 16 CFR 310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | §310.4(a)(5)(i)-(ii); displayed current through 10/22/2026 | Accessed/read 10/24/2026. Federal trigger/allocation/account rules; federal coverage remains separately fact-dependent. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, currentness, confidence limits |\n| --- | --- | --- | --- |\n| **S_KY-P1-C001** | Chapter 380’s official index includes 2026 Regular Session enactments and was updated 10/24/2026. | S001, lines 90-95. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145) | High confidence as codification-currentness statement, not assurance against uncodified orders or litigation. |\n| **S_KY-P1-C002** | Debt adjusting expressly includes budget counseling, debt management, debt modification or settlement, foreclosure assistance, and debt pooling. | S002, §380.010(3), p.1. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence. |\n| **S_KY-P1-C003** | Principal-reduction settlement is covered because adjustment, compromise, settlement, modification, and discharge are expressly included. | S002, §380.010(3)(a). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence; exemption analysis remains separate. |\n| **S_KY-P1-C004** | Chapter 380 covers both noncustodial intermediation and custodial receipt/distribution models. | S002, §380.010(3)(a)-(b). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence. Custodial status changes some duties and fee rules, not base classification. |\n| **S_KY-P1-C005** | Soliciting and advertising as a debt adjuster is itself included in the definition. | S002, §380.010(3)(c). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence for holding out as the covered provider; pure independent publishing/referral requires facts. |\n| **S_KY-P1-C006** | A statutory debtor is an individual residing temporarily or permanently in Kentucky. | S002, §380.010(4)-(5). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence. |\n| **S_KY-P1-C007** | Out-of-state location does not avoid coverage where the provider serves Kentucky residents; custodial §380.040 expressly reaches a person whether or not located in Kentucky. | S004, §380.040(1); S011 §2; S016 items 11 and 13. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence for actual Kentucky-resident service; passive-web/minimum-contact boundary unresolved. |\n| **S_KY-P1-C008** | An entity borrower is outside “debtor,” but an individual’s business-purpose debt is not expressly excluded by the general definition. | S002, §380.010(5); compare S004 mortgage-specific consumer-purpose language. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378) | High confidence for entity/individual distinction; moderate for individual business-purpose application absent controlling case. |\n| **S_KY-P1-C009** | Every covered person must file an initial registration and renew annually, with $250 each time. | S004, §380.040(5). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence. |\n| **S_KY-P1-C010** | A provider may not engage before a complete, accurate registration is confirmed by the Division; filing alone is insufficient. | S011 §§2(4), 3. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/) | High confidence under current rule. |\n| **S_KY-P1-C011** | The verified current route is the paper/form process; the 2026 online amendment remains proposed and not current. | S011 §§2, 7; S012 status and proposed §1. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/) | High confidence as of 10/24/2026. |\n| **S_KY-P1-C012** | The attorney exemption requires Kentucky admission, nonprincipal engagement in debt adjusting, and services in the course of law practice. | S003, §380.030(1). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380) | High confidence. Attorney affiliation alone is insufficient. |\n| **S_KY-P1-C013** | The nonprofit exemption requires §501(c)(3) status and that the organization not be in the business of debt adjusting. | S003, §380.030(6). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380) | High confidence. |\n| **S_KY-P1-C014** | Employee, court/statutory-authority, creditor-agent, loan-disbursement, and self-creditor exemptions are conditional, not categorical industry exemptions. | S003, §380.030(2)-(5), (7). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380) | High confidence; facts must satisfy every condition. |\n| **S_KY-P1-C015** | KRS Chapter 286 institutions retain the right to collect debts owed to themselves; this is not a broad third-party debt-adjusting exemption. | S009, §380.130. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390) | High confidence. |\n| **S_KY-P1-C016** | Printed initial-setup ceiling is $75. | S004, §380.040(2)(a). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence as printed figure; exact CPI-adjusted ceiling held under C020. |\n| **S_KY-P1-C017** | Printed consultation ceiling is $50 per calendar year. | S004, §380.040(2)(b). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence as printed figure; exact CPI-adjusted ceiling held. |\n| **S_KY-P1-C018** | For money held for unsecured-creditor distribution, periodic fee may not exceed the greater of 8.5% of the monthly distribution amount or $30. | S004, §380.040(2)(c). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence for covered custodial facts. Gross debit versus creditor-distribution base must be identified. |\n| **S_KY-P1-C019** | Bad-check charge is $20 or the bank pass-through, whichever is greater. | S004, §380.040(3). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence as printed rule; CPI issue held. |\n| **S_KY-P1-C020** | Chapter 380 permits annual CPI adjustment, but no exact current adjusted amount or authoritative adjustment instrument was verified. | S004, §380.040(4); S013 fee table. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | Statutory authorization high confidence; exact 2026 adjusted amounts unresolved. |\n| **S_KY-P1-C021** | For defined residential-mortgage-secured consumer debt, no other fee may be accepted or escrowed before complete performance. | S004, §380.040(2)(d). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence. Postperformance amount ceiling and other mortgage laws remain open. |\n| **S_KY-P1-C022** | No express Kentucky dollar or percentage cap was located for a noncustodial unsecured settlement performance fee. | S004 §§380.040(2), (9)-(10); S006 §380.100(1)(f). [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence as scoped absence finding, not authorization or “unlimited fee” conclusion. |\n| **S_KY-P1-C023** | No express Kentucky per-debt, uniform-savings-percentage, or aggregate settlement-fee formula was located. | S004 and S006 reviewed; compare federal S018. [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | Scoped absence finding; later case/interpretive research remains open. |\n| **S_KY-P1-C024** | Fees must be disclosed and itemized; unconscionable conduct, unrelated add-ons, and withholding part of the creditor compromise are prohibited. | S005 §380.060(1); S006 §380.100(1)(f); S004 §380.040(9)(o)-(p), (10). [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383) | High confidence. |\n| **S_KY-P1-C025** | Debtor may cancel through midnight of the fourteenth day after signing without penalty or monetary obligation; omitted notice extends the cancellation right. | S005 §380.060(2)-(7). [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383) | High confidence. |\n| **S_KY-P1-C026** | Debtor may terminate at any time without penalty or obligation and receive all unexpended money held for debt reduction or satisfaction. | S006 §380.100(1)(g). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387) | High confidence. This provision does not expressly require refund of every previously earned lawful fee. |\n| **S_KY-P1-C027** | A custodial provider generally must use a separate trust account and distribute funds within 30 days unless specifically instructed otherwise. | S004 §380.040(1). [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence; full client-money administration remains later scope. |\n| **S_KY-P1-C028** | Registration also requires annual audit, insurance, and a $25,000 bond or approved letter of credit, with mortgage-related increases. | S004 §380.040(6)-(8); S011 §4; S016 pp.6-7. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence for statutory amounts and access conditions; full bond/claims pass remains open. |\n| **S_KY-P1-C029** | A Kentucky fee ceiling is not affirmative permission to collect the fee in advance. | S004 §380.040; federal S018 §310.4(a)(5). [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | Legal reconciliation; high confidence where federal coverage exists. |\n| **S_KY-P1-C030** | Federal “debt relief service” concerns represented alteration of unsecured-debt terms; federal telemarketing generally requires a telephone campaign with more than one interstate call. | S017 §§310.2(o), (ii). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | High confidence as common baseline; exemptions and application require separate facts. |\n| **S_KY-P1-C031** | Under the covered TSR rule, no fee may be requested or received until at least one debt is altered under an executed agreement and the customer makes a payment under it. | S018 §310.4(a)(5)(i)(A)-(B). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High confidence where TSR coverage exists. |\n| **S_KY-P1-C032** | Covered federal individual-debt fees must be proportional to enrolled debt or use a uniform savings percentage. | S018 §310.4(a)(5)(i)(C). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High confidence; this is allocation/timing, not a federal percentage ceiling. |\n| **S_KY-P1-C033** | Covered dedicated accounts must satisfy insured-institution, ownership, independence, referral-compensation, and seven-business-day refund conditions. | S018 §310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High confidence where this federal account provision applies. |\n| **S_KY-P1-C034** | Kentucky’s public registry is a lookup aid but has conflicting rendered and extracted dates/counts and cannot alone prove current named-provider authorization. | S014-S015. [Kentucky Agriculture+3](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx) | High confidence regarding the observed conflict; current individual files were not obtained. |\n| **S_KY-P1-C035** | A settlement leaving 50% or more owed requires creditor assent followed by debtor assent; POA authority may cover only a settlement below 50%, and never the defined mortgage-secured consumer debt. | S004 §380.040(9)(b)-(c); S006 §380.100(2). [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571) | High confidence. |\n| **S_KY-P1-C036** | Violations can support civil penalties, misdemeanor treatment for §380.040 violations, KCPA remedies, injunction, restoration, and receivership. | S010 §380.990. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391) | High confidence at statutory level; full remedies/enforcement-history pass remains open. |\n| **S_KY-P1-C037** | No controlling published Kentucky appellate decision resolving the identified business-purpose, CPI, or noncustodial-fee-cap issues was located in the targeted searches performed. | Research-search result; statutory sources S002-S006 remain controlling evidence for this pass. | Moderate confidence only; not an exhaustive paid-citator or every-docket conclusion. |\n\n# D. Worked examples and scope/gap table\n\n## D.1 Custodial DMP—lower monthly distribution\n\n**Facts and assumptions**\n\nPlain text\n```\nMonthly amount designated for distribution to unsecured creditors: $200.00\nPeriodic provider fee is separate from that distribution amount.\nNo CPI uplift is assumed.\nNo federal timing conclusion is embedded in this amount calculation.\n```\n\n**Calculation**\n\nPlain text\n```\nBase:                         $200.00 per month for creditor distribution\nPercentage operator:          8.5% × $200.00\nPercentage result:            $17.00\nDollar alternative:           $30.00\nStatutory comparison:         greater of $17.00 or $30.00\nMaximum printed periodic fee: $30.00\n```\n\n**Cash-flow illustration**\n\nPlain text\n```\nAmount reaching creditors:    $200.00\nSeparate periodic fee:         $30.00\nTotal consumer debit:          $230.00\n```\n\nCurrency is shown to the nearest cent. No Kentucky statutory rounding rule was located. If the consumer makes a single gross $200 payment that includes the fee, the amount “paid … for distribution” must first be identified from the contract and accounting records; it should not automatically be treated as $200. **C018, C020.** [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.2 Custodial DMP—higher distribution\n\nPlain text\n```\nBase:                         $500.00 per month\n8.5% operator:                0.085 × $500.00\nPercentage result:            $42.50\nDollar alternative:           $30.00\nGreater amount:               $42.50\nMaximum printed periodic fee: $42.50\n```\n\nThe result is a monthly fee ceiling for the described custodial unsecured-creditor facts, not permission to collect it at any time forbidden by other law. **C018, C029.** [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.3 Very low distribution\n\nPlain text\n```\nBase:                         $100.00 per month\n8.5% operator:                0.085 × $100.00\nPercentage result:            $8.50\nDollar alternative:           $30.00\nGreater amount:               $30.00\nMaximum printed periodic fee: $30.00\n```\n\nThe statutory word is “greater,” not “lesser.” Therefore the printed formula produces a $30 ceiling in this example. No view is expressed here on whether charging the full ceiling would be unconscionable in particular circumstances. **C018, C024.** [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.4 Bad-check charge\n\n### Scenario A\n\nPlain text\n```\nBank amount passed through:   $12.00\nStatutory dollar amount:       $20.00\nOperator:                      greater of $12.00 or $20.00\nMaximum printed charge:        $20.00\n```\n\n### Scenario B\n\nPlain text\n```\nBank amount passed through:   $35.00\nStatutory dollar amount:       $20.00\nOperator:                      greater of $35.00 or $20.00\nMaximum printed charge:        $35.00\n```\n\nNo unsupported markup over the actual bank pass-through is introduced. Exact CPI adjustment, if any, remains held. **C019-C020.** [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.5 Kentucky setup ceiling versus federal timing\n\nPlain text\n```\nProposed setup fee:            $75.00\nKentucky printed ceiling:      $75.00\nKentucky amount comparison:    $75.00 ≤ $75.00\nState amount result:           Within printed Kentucky amount ceiling\n```\n\nAssume, however, that the seller operates a covered interstate telephone debt-relief campaign and no enrolled debt has yet been altered under an executed creditor agreement and no payment has been made under that agreement:\n\nPlain text\n```\nFederal trigger A met?         No\nFederal trigger B met?         No\nFee may be requested/received? No, under the covered TSR facts\n```\n\nThe state amount result does not override federal timing. **C016, C029-C031.** [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.6 Fourteen-day cancellation\n\nPlain text\n```\nContract signed:               October 1, 2026\nFirst day after signing:       October 2, 2026\nFourteenth day after signing:  October 15, 2026\nDeadline:                      Midnight, October 15, 2026\nMethod assumed:                Email sent to address stated in contract\nResult:                        Timely cancellation\nConsumer obligation:           No penalty or monetary obligation\n```\n\nThe email is effective when sent. If the required cancellation notice was never properly given, the statutory cancellation right continues until compliance. **C025.** [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383)\n\n## D.7 Residential-mortgage assistance fee\n\nPlain text\n```\nPromised fee:                  $1,500.00\nDebt:                          Personal/family/household debt secured by residential mortgage\nService completion status:     Not completely performed\nProposed collection method:    Direct charge or escrow\nAmount collectible now:        $0.00\n```\n\nBoth direct acceptance and placement in escrow for later release are prohibited before complete performance. After complete performance, this paragraph no longer bars collection solely on timing grounds, but it does not itself establish that $1,500 is a lawful amount or resolve other mortgage-assistance law. **C021.** [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.8 Fifty-percent settlement authorization boundary\n\n### Settlement A\n\nPlain text\n```\nPre-settlement debt:           $10,000.00\nAmount remaining/payable:      $6,000.00\nOperator:                      $6,000 ÷ $10,000\nResult:                        60%\nBoundary:                      Equal to or more than 50%\nRequired sequence:             Creditor assents, then debtor separately assents\nPOA alone sufficient?          No\n```\n\n### Settlement B\n\nPlain text\n```\nPre-settlement debt:           $10,000.00\nAmount remaining/payable:      $4,000.00\nOperator:                      $4,000 ÷ $10,000\nResult:                        40%\nBoundary:                      Less than 50%\nPOA potentially usable?        Yes, if expressly limited and otherwise valid\nMortgage-secured exception:    POA still prohibited for defined residential-mortgage debt\n```\n\n**C035.** [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571)\n\n## D.9 Federal partial settlement—proportional allocation\n\nThis example uses a hypothetical total fee formula solely to illustrate federal allocation. It does not represent a Kentucky-approved fee percentage.\n\nPlain text\n```\nDebt A enrolled balance:       $5,000.00\nDebt B enrolled balance:       $15,000.00\nTotal enrolled balance:        $20,000.00\n\nHypothetical total fee:        20% × $20,000.00\nTotal fee result:              $4,000.00\n\nDebt A allocation fraction:    $5,000 ÷ $20,000 = 0.25\nDebt A allocated fee:          0.25 × $4,000 = $1,000.00\n\nDebt B allocation fraction:    $15,000 ÷ $20,000 = 0.75\nDebt B allocated fee:          0.75 × $4,000 = $3,000.00\n```\n\nAssume only Debt A has been settled under an executed agreement and the consumer has made the first payment under that agreement. Under the covered TSR facts, up to the allocated Debt A fee could meet the timing structure; the Debt B fee remains untriggered until Debt B separately satisfies the rule. **C031-C032.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## D.10 Federal savings method\n\nPlain text\n```\nDebt at enrollment:            $10,000.00\nAmount actually paid:          $6,000.00\nSavings base:                  $10,000.00 − $6,000.00 = $4,000.00\nIllustrative savings rate:     25%\nFee:                           0.25 × $4,000.00 = $1,000.00\n```\n\nThe same savings percentage must be used for each individually resolved debt. The 25% is illustrative and is not established here as a lawful Kentucky amount. Federal and state performance/timing conditions must independently be satisfied. **C022, C032.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## D.11 Termination after a previously earned fee\n\nPlain text\n```\nUnexpended money held for debt reduction:    $2,400.00\nPreviously charged fee:                        $600.00\nAssumption: fee was already lawfully earned,\n            properly disclosed, and not otherwise refundable\nMinimum refund expressly required by\nKRS 380.100(1)(g):                            $2,400.00\n```\n\nKRS 380.100 expressly requires return of all **unexpended debt-reduction money**. It does not, by that clause alone, expressly require refund of the hypothetical $600 previously earned fee. A cancellation within the initial 14-day window is different because that cancellation is without penalty or monetary obligation. Other facts could make the $600 refundable. **C025-C026.** [Legislative Research Commission+1](https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383)\n\n## D.12 Full scope-coverage and gap table\n\n| Component | Status in PASS-01 | Supporting claims | Exact remaining evidence or next action |\n| --- | --- | --- | --- |\n| Current Chapter 380 codification | **Answered** | C001 | Recheck for later special-session or post-10/24/2026 enactments in any future update. |\n| Core debt-adjusting definition | **Answered** | C002-C005 | Later apply to each actual SettleADebt operating role, affiliate, advertiser, negotiator, and account administrator. |\n| Principal-reduction settlement classification | **Answered** | C003-C004 | Contract-specific application later. |\n| DMP/concession/payment-distribution classification | **Answered** | C002, C004, C018, C027 | Full funds-flow and trust-account pass remains open. |\n| Credit/budget counseling | **Substantially answered** | C002, C004 | Resolve edge cases involving education-only, free, employer, or software-only services. |\n| Advertising/lead generation | **Partial** | C005 | Determine when a publisher, marketplace, lead generator, white-label front end, or referral entity is “advertising as” or holding itself out as the adjuster. |\n| Kentucky-resident nexus | **Answered for actual service** | C006-C007 | Passive-site, transient-resident, relocation, and multistate contract conflicts remain open. |\n| Entity and business-purpose debt | **Partial** | C008, C037 | Search exhaustive Kentucky appellate/federal applications; analyze guarantor, sole-proprietor, mixed-purpose, and entity/individual co-obligor facts. |\n| Ordinary market access | **Answered** | C009-C011 | Obtain and inspect an actual written confirmation only if a named-provider review is later authorized. |\n| Attorney exemption | **Answered textually; factual application open** | C012 | Later examine law-firm ownership, nonlawyer marketing, fee sharing, principal-business test, and professional-conduct law. |\n| Nonprofit exemption | **Answered textually; factual application open** | C013 | Verify IRS determination and whether actual operations constitute the business of debt adjusting. |\n| Creditor/lender/employee/court exemptions | **Answered textually** | C014-C015 | Apply to actual compensation and agency relationships later. |\n| Setup fee | **Answered subject to CPI hold** | C016, C020 | Locate official CPI adjustment instrument or authoritative AG interpretation. |\n| Consultation fee | **Answered subject to CPI hold** | C017, C020 | Same. |\n| Custodial periodic fee | **Answered subject to CPI/base facts** | C018, C020 | Determine creditor-distribution base where fee and creditor funds share one debit; locate any adjustment instrument. |\n| Bad-check charge | **Answered subject to CPI hold** | C019-C020 | Verify actual bank pass-through and any official adjustment. |\n| CPI adjustment | **Unresolved exact amount** | C020 | Search Attorney General orders, archived fee bulletins, Register notices, open-record materials, and controlling interpretations; no invented calculation. |\n| Noncustodial unsecured settlement-fee amount | **Unresolved exact ceiling; scoped absence found** | C022-C024 | Exhaustive citator, AG opinions/enforcement settlements, KCPA unconscionability cases, and actual confirmed fee schedules. |\n| State per-debt/savings/aggregate cap | **No express formula located; later interpretation open** | C023 | Same interpretive and enforcement research. |\n| Mortgage-secured advance-fee timing | **Answered under Chapter 380** | C021 | Full MARS, foreclosure-consultant, mortgage-service, federal/state overlap, and exact postperformance amount pass remains open. |\n| State fee timing for unsecured models | **Partial** | C025-C029 | Investigate AG interpretations, enforcement pleadings/orders, and any case construing setup/consultation timing. |\n| Federal TSR timing baseline | **Answered as common context** | C030-C033 | Full coverage/exemption analysis by marketing channel, seller, telemarketer, attorney, nonprofit, and call flow remains separate. |\n| Cancellation and unexpended-funds refund | **Answered for fee boundary** | C025-C026 | Full agreement/delivery/e-sign and disputed-earned-fee analysis later. |\n| Trust and 30-day disbursement | **Answered only to market-access boundary** | C027 | Full account ownership, reconciliation, authorized instructions, commingling, administrator, insolvency, and records pass later. |\n| Audit, insurance, bond/LOC | **Answered only as access conditions** | C028 | Full forms DA-2/DA-3/DA-4, cancellation notices, bond claims, insurance exclusions, and proof-of-continuity pass later. |\n| Current application route | **Answered** | C010-C011 | Monitor proposed regulation for final effective date and operative portal migration. |\n| Public provider lookup | **Partial/unreliable for conclusive status** | C034 | Obtain current written confirmation, registration file, or authoritative agency record for any named provider; do not rely solely on PDF. |\n| Settlement assent/POA boundary | **Answered where needed** | C035 | Full settlement-document and agency-authority pass later. |\n| Enforcement/remedies | **Boundary only** | C036 | Full AG actions, private actions, damages, penalties, receiverships, criminal cases, and limitation periods later. |\n| Controlling case law | **Unresolved/exhaustiveness hold** | C037 | Formal citator and docket search using KRS 380.010, .030, .040, .060, .100, and Chapter 380; review unpublished and federal diversity decisions. |\n| Collections and litigation consequences | **Excluded from this pass** | — | Dedicated later pass. |\n| Statutes of limitation and repose | **Excluded except citation to §380.110** | — | Dedicated remedies/limitations pass. |\n| Secured debt outside the defined residential-mortgage category | **Open** | — | Classify auto, UCC, judgment lien, tax lien, business real-estate, and mixed-collateral debt. |\n| Sector-specific laws | **Open** | — | Mortgage, student loan, tax, medical, payday, bank, collection-agency, and legal-services overlays. |\n| Local and tribal law | **Open** | — | Kentucky local-authority and tribal-jurisdiction research. |\n| Complete consumer-agreement duties | **Open except fee/cancellation provisions used here** | C024-C026 | Full contract pass covering form, delivery, disclosures, prohibited terms, electronic consent, and creditor participation. |\n| Publication or state acceptance | **Not determined** | — | Coordinator/legal review remains separate; no acceptance implication. |\n\n# E. Researcher self-check\n\n## Actually read and used\n\nI read the operative text of KRS 380.010, 380.030, 380.040, 380.060, 380.100, 380.110, 380.120, 380.130, and 380.990 from the Kentucky Legislative Research Commission sources. The Chapter 380 index was checked for its October 24, 2026 database date and 2026-session statement. [Legislative Research Commission](https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145)\n\nI read the current 40 KAR 12:400 operative registration provisions, incorporation-by-reference section, history, and expiration statement. I separately read the proposed 2026 amendment and preserved its “not yet current” status rather than treating its online portal process as operative. [Legislative Research Commission+2](https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/)\n\nI read the Attorney General’s adjuster instructions, fee table, registration landing page, and DA-1 form. The operational guidance was not substituted for the current statute where its subsection numbering or update date was stale. [Kentucky Agriculture+2](https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx)\n\nI inspected both the extracted text and rendered page images of the registered-adjusters PDF and preserved the conflict rather than selecting the most convenient update date or count. [Kentucky Agriculture+2](https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf)\n\nI read the current eCFR definitions and exact federal fee-trigger, allocation, and dedicated-account provisions used for the separate federal baseline. The eCFR page displayed Title 16 as current through October 22, 2026. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## Not verified or not treated as established\n\n- No current official Kentucky CPI adjustment notice, order, schedule, bulletin, base-year methodology, or adjusted fee amount was verified.\n- No provider’s individual registration file, written confirmation, expiration notice, audit, fee schedule, insurance, bond, or disciplinary status was obtained.\n- The public registry PDF was not treated as conclusive named-provider authorization because of its internal visual/text-layer conflict.\n- The proposed online application amendment was not treated as current.\n- No exhaustive paid citator, every-docket search, or comprehensive unpublished-case review was performed. Targeted searches did not locate a controlling published Kentucky appellate construction resolving the CPI, individual business-purpose, or noncustodial performance-fee issues.\n- No conclusion was drawn that the absence of an express state settlement-fee cap affirmatively approves a particular fee amount or percentage.\n- No full federal TSR exemption analysis was performed.\n- No full mortgage, foreclosure-assistance, MARS, collection-agency, legal-services, professional-conduct, secured-debt, local, tribal, or sector-specific analysis was performed.\n- No applications were filed, no agency or provider was contacted, no account or permission was changed, no private borrower information was used, and no publication or local-write claim is made.\n- This self-check describes the research performed in this pass. It is not labeled an independent review.\n\n**PASS-01 conclusion:** Kentucky presents a verified registration pathway for covered debt-adjusting models, with narrow conditional exemptions, model-specific fee rules, and a particularly clear complete-performance bar for defined residential-mortgage-secured consumer debt. The printed custodial fee formula is verifiable; the exact CPI-adjusted amounts and the state amount ceiling for noncustodial unsecured settlement performance fees remain explicit evidence holds. Federal timing must be overlaid separately whenever its coverage elements are met.\n\nEND S_KY PASS-01.\n\n","tables":[{"headers":["Model or conduct","Kentucky Chapter 380 classification","Custody relevance","PASS-01 disposition"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or conduct","Kentucky Chapter 380 classification","Custody relevance","PASS-01 disposition"],["Principal-reduction debt settlement or negotiation","Expressly within “modification or settlement” and adjustment, compromise, settlement, modification, or discharge of indebtedness","Custody is not required for coverage","Covered unless a specific KRS 380.030 exemption applies. C002-C004"],["DMP involving creditor concessions and regular creditor payments","Expressly within debt management and creditor intermediation","If the provider receives and holds money for unsecured-creditor distribution, the trust, 30-day disbursement, and periodic-fee rules apply","Covered; registration required. C002, C004, C018, C027"],["Credit or budget counseling","“Budget counseling” is expressly named","No custody prerequisite in the general definition","Commercial counseling directed at debt management is covered. A genuinely education-only service with no debt-management or creditor-intermediary function remains fact-dependent. C002, C004"],["Noncustodial settlement using a consumer-owned third-party account","Settlement/intermediation remains covered even if the provider never holds creditor money","The special custodial periodic-fee formula may not apply if the debt adjuster does not receive and hold funds for creditor distribution","Registration remains required; state performance-fee amount cap is unresolved. C004, C022"],["Custodial debt management or pooling","Expressly covered by receiving debtor money and disbursing it to creditors","Triggers trust-account and 30-day-disbursement requirements","Covered; registration plus custodial duties. C004, C027"],["Foreclosure or residential-mortgage assistance","“Foreclosure assistance” is expressly named","Special advance-fee prohibition and enhanced insurance/bond requirements can apply to the defined residential-mortgage-secured consumer debt","Covered, with additional restrictions. Other mortgage-assistance laws remain open. C002, C021, C028"],["Solicitation or advertising","Soliciting business and advertising as a debt adjuster is expressly included","No custody required","A seller cannot avoid coverage merely by outsourcing negotiations or funds handling if it holds itself out as providing the covered service. Pure publisher/referral facts remain unresolved. C005"],["Corporate or LLC borrower debt","“Debtor” is defined as an individual residing in Kentucky","Not relevant if there is no statutory “debtor”","A corporation or LLC, in its own capacity, falls outside that definition. C008"],["Individual’s business-purpose debt","“Debtor” is an individual Kentucky resident; the general definition does not expressly require personal, family, or household purpose","Some mortgage-specific provisions separately contain a consumer-purpose limitation","A sole proprietor’s, guarantor’s, or other individual’s business-purpose debt is potentially covered. No controlling appellate construction was located; hold fact-specific. C008, C037"],["Remote or out-of-state provider","Custodial KRS 380.040 expressly says “whether or not located in this state”; the rule and form focus on services to Kentucky residents","Remote location does not create a custodial safe harbor","Strong coverage conclusion where the provider contracts with or serves a Kentucky resident. Passive-site or de minimis-contact limits remain unresolved. C006-C007"]]},{"headers":["Exemption","Exact conditions","What is not enough"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Exemption","Exact conditions","What is not enough"],["Kentucky attorney","Admitted to practice in Kentucky; not principally engaged in debt adjusting; services rendered in the course of law practice","Attorney affiliation, an attorney-owned company, an out-of-state lawyer, or a Kentucky lawyer principally engaged in debt adjusting is not automatically exempt"],["Regular employee","Regular, full-time employee adjusting the employer’s debts","Independent contractor or outsourced vendor"],["Court or statutory authority","Acting under court order or judgment, or authority conferred by Kentucky or federal law","General assertion that conduct is “legal”"],["Creditor or creditor agent","Creditor or agent of one or more creditors, with adjustment services rendered without cost to the debtor","Creditor-side compensation does not cure a debtor charge; a debtor fee defeats this particular condition"],["Loan-disbursement model","Makes or arranges a loan and, with debtor authorization, disburses proceeds to adjust debts, without debtor compensation for the adjustment service","Charging the debtor for the adjustment component"],["Section 501(c)(3) organization","Charitable, religious, or educational organization determined exempt under §501(c)(3), and not in the business of debt adjusting","Merely being nonprofit, tax-exempt, or charitable in name"],["Self-creditor","Creditor adjusting debts owed to itself","Adjusting unrelated third-party debts"],["Chapter 286 financial institution collecting own debt","Chapter 380 does not limit a KRS Chapter 286 licensed institution’s collection of debts owed to it","This is not a blanket exemption for third-party debt-adjusting services"]]},{"headers":["Fee or charge","Statutory base","Verified printed ceiling or rule","Important conditions"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Fee or charge","Statutory base","Verified printed ceiling or rule","Important conditions"],["Initial setup","Fee, contribution, or other consideration from a Kentucky-resident debtor for initial setup","$75 maximum","Exact CPI-adjusted ceiling, if any, held. C016, C020"],["Consultation","Fee, contribution, or other consideration from a Kentucky-resident debtor for consultation","$50 maximum per calendar year","Exact CPI-adjusted ceiling, if any, held. C017, C020"],["Custodial periodic fee for unsecured creditors","Amount paid by the debtor each month for distribution to the debtor’s creditors","Maximum is the greater of 8.5% of that monthly distribution amount or $30","Applies when the debt adjuster receives and holds money or value for distribution to unsecured creditors. C018"],["Bad-check charge","Returned/bad-payment event","$20 or the amount passed through by the debt adjuster’s bank, whichever is greater","In addition to otherwise nonprohibited fees. C019"],["“Other” fee connected with defined secured debt","Debt primarily for personal, family, or household use, secured by a residential mortgage, deed of trust, equivalent consensual interest, or collateral having a residential mortgage lien","No acceptance before complete performance of all promised services","Escrowing the fee for later payment is expressly prohibited. Exact postperformance amount cap not specified in this paragraph. C021"],["Noncustodial unsecured settlement performance fee","Provider negotiates but does not receive and hold money for creditor distribution","No express Kentucky percentage or dollar amount cap located","This is not an “unlimited fee” finding. Contract disclosure, unconscionability, cancellation, federal timing, and other law remain applicable. C022-C024"],["Kentucky per-debt allocation rule","Settlement of individual unsecured debts","No Kentucky formula found equivalent to the federal proportional or savings formula","Federal TSR formula applies only when federal coverage exists. C023, C032"],["Kentucky savings-percentage cap","Savings produced by settlement","No state percentage ceiling found in the reviewed provisions","Absence is not affirmative approval of a percentage. C022-C023"],["Kentucky aggregate settlement-fee cap","Entire enrolled debt portfolio","No express state aggregate cap found","Contract and unconscionability constraints remain. C022-C024"],["Provider registration fee","Initial and annual filing with Attorney General","$250 initial; $250 annual","This is a provider regulatory filing fee, not a consumer fee. C009"]]},{"headers":["Source ID","Title, issuer, and direct literal URL","Exact pinpoint/version/effective status","Actual check and limitations"],"index":3,"links":[{"href":"https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","text":"Legislative Research Commission\n+1"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","text":"Legislative Research Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/","text":"Legislative Research Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/","text":"Legislative Research Commission\n+2"},{"href":"https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx","text":"Kentucky Agriculture\n+1"},{"href":"https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","text":"Kentucky Agriculture"},{"href":"https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf","text":"Kentucky Agriculture\n+2"},{"href":"https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf","text":"Kentucky Agriculture\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],"row_links":[[],[{"href":"https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+2"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","text":"Legislative Research Commission\n+1"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","text":"Legislative Research Commission\n+2"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/","text":"Legislative Research Commission\n+2"}],[{"href":"https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/","text":"Legislative Research Commission\n+2"}],[{"href":"https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx","text":"Kentucky Agriculture\n+1"}],[{"href":"https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","text":"Kentucky Agriculture"}],[{"href":"https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf","text":"Kentucky Agriculture\n+2"}],[{"href":"https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf","text":"Kentucky Agriculture\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}]],"rows":[["Source ID","Title, issuer, and direct literal URL","Exact pinpoint/version/effective status","Actual check and limitations"],["S_KY-P1-S001","KRS Chapter 380 index, Kentucky Legislative Research Commission. https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145","Lines 90-120: includes enactments through 2026 Regular Session; database updated 10/24/2026","Accessed 10/24/2026. Currentness index, not substantive text. \nLegislative Research Commission"],["S_KY-P1-S002","KRS 380.010, Definitions. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","§380.010(1)-(5), PDF pp.1-2; effective 7/15/2010","Accessed/read 10/24/2026. Primary statutory definition. \nLegislative Research Commission"],["S_KY-P1-S003","KRS 380.030, Exempt persons. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380","§380.030(1)-(7), PDF p.1; effective 7/15/2010","Accessed/read 10/24/2026. Express exemptions only; entity structuring facts may require later analysis. \nLegislative Research Commission"],["S_KY-P1-S004","KRS 380.040, powers, prohibitions, fees, registration, audit, insurance, bond. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","§380.040(1)-(10), PDF pp.1-5; effective 4/5/2024","Accessed/read 10/24/2026. Principal substantive source for this pass. \nLegislative Research Commission\n+2"],["S_KY-P1-S005","KRS 380.060, contract disclosure and 14-day cancellation. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","§380.060(1)-(7), PDF pp.1-2; effective 7/15/2010","Accessed/read 10/24/2026. Used only for compensation disclosure and cancellation/refund boundaries. \nLegislative Research Commission\n+1"],["S_KY-P1-S006","KRS 380.100, agreement contents and termination. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","§380.100(1)-(5), PDF pp.1-3; effective 7/15/2010","Accessed/read 10/24/2026. Used for itemized fees, unexpended-funds refund, and settlement authorization boundaries. \nLegislative Research Commission\n+2"],["S_KY-P1-S007","KRS 380.110, private action. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388","§380.110(1)-(4), PDF p.1; effective 7/15/2010","Accessed/read 10/24/2026. Detailed remedies reserved for later pass. \nLegislative Research Commission"],["S_KY-P1-S008","KRS 380.120, nonwaiver. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389","Entire section; effective 7/15/2010","Accessed/read 10/24/2026. \nLegislative Research Commission"],["S_KY-P1-S009","KRS 380.130, financial institution own-debt provision. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390","Entire section; effective 7/15/2010","Accessed/read 10/24/2026. Not a blanket third-party-service exemption. \nLegislative Research Commission"],["S_KY-P1-S010","KRS 380.990, penalties and KCPA treatment. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391","§380.990(1)-(4), PDF p.1; effective 7/15/2010","Accessed/read 10/24/2026. Enforcement details remain later-pass material. \nLegislative Research Commission"],["S_KY-P1-S011","Current 40 KAR 12:400, Kentucky LRC. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/","Sections 1-7; registration effective only after complete filing and written confirmation; history shows recodification effective 7/18/2025; expiration 2/21/2027","Accessed/read 10/24/2026. Current operative regulation; separate proposed version exists. \nLegislative Research Commission\n+2"],["S_KY-P1-S012","Proposed 40 KAR 12:400 amendment. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/","Page labels: “PROPOSED—This document is not yet current”; filed 7/8/2026; page generated 8/28/2026; proposed online application","Accessed/read 10/24/2026. Not current law and not used as operative procedure. \nLegislative Research Commission\n+2"],["S_KY-P1-S013","Kentucky AG, Information for Adjusters. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx","Definition, fee table, registration instructions, mail address","Accessed 10/24/2026. Operational guidance; landing page identifies it as updated Nov. 2010. Its mortgage-rule subsection citation is stale. \nKentucky Agriculture\n+1"],["S_KY-P1-S014","Kentucky AG, Debt Adjusters landing page. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","Lines 36-51: list not endorsement; links to list and Nov. 2010 guidance","Accessed 10/24/2026. Procedure/lookup aid, not legal authorization. \nKentucky Agriculture"],["S_KY-P1-S015","Kentucky AG, Registered Debt Adjusters PDF. https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf","Parsed layer says updated 10/19/2026; rendered pp.1-2 say 3/30/2026 and 8/24/2026; visual total 36","Accessed, parsed, and visually inspected 10/24/2026. Internal inconsistency prevents treating it as conclusive named-provider proof. \nKentucky Agriculture\n+2"],["S_KY-P1-S016","Form DA-1, Debt Adjuster Registration Statement. https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf","July 2010, pp.1-7; fee schedule p.5; insurance/bond pp.6-7","Accessed/read 10/24/2026. Current rule incorporates the July 2010 form, although it contains legacy URLs and old rule-number references. \nKentucky Agriculture\n+2"],["S_KY-P1-S017","eCFR, 16 CFR Part 310, definitions. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","§§310.2(o), 310.2(ii); displayed federal text current through 10/22/2026","Accessed 10/24/2026. eCFR is continuously updated and authoritative but unofficial. Federal common context only. \neCFR\n+1"],["S_KY-P1-S018","eCFR, 16 CFR 310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§310.4(a)(5)(i)-(ii); displayed current through 10/22/2026","Accessed/read 10/24/2026. Federal trigger/allocation/account rules; federal coverage remains separately fact-dependent. \neCFR\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, confidence limits"],"index":4,"links":[{"href":"https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","text":"Legislative Research 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Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+1"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","text":"Legislative Research Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","text":"Legislative Research Commission\n+1"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+2"},{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research 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Commission\n+1"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+2"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","text":"Kentucky Agriculture\n+3"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","text":"Legislative Research Commission\n+2"}],[{"href":"https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391","text":"Legislative Research Commission"}],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, currentness, confidence limits"],["S_KY-P1-C001","Chapter 380’s official index includes 2026 Regular Session enactments and was updated 10/24/2026.","S001, lines 90-95. \nLegislative Research Commission","High confidence as codification-currentness statement, not assurance against uncodified orders or litigation."],["S_KY-P1-C002","Debt adjusting expressly includes budget counseling, debt management, debt modification or settlement, foreclosure assistance, and debt pooling.","S002, §380.010(3), p.1. \nLegislative Research Commission","High confidence."],["S_KY-P1-C003","Principal-reduction settlement is covered because adjustment, compromise, settlement, modification, and discharge are expressly included.","S002, §380.010(3)(a). \nLegislative Research Commission","High confidence; exemption analysis remains separate."],["S_KY-P1-C004","Chapter 380 covers both noncustodial intermediation and custodial receipt/distribution models.","S002, §380.010(3)(a)-(b). \nLegislative Research Commission","High confidence. Custodial status changes some duties and fee rules, not base classification."],["S_KY-P1-C005","Soliciting and advertising as a debt adjuster is itself included in the definition.","S002, §380.010(3)(c). \nLegislative Research Commission","High confidence for holding out as the covered provider; pure independent publishing/referral requires facts."],["S_KY-P1-C006","A statutory debtor is an individual residing temporarily or permanently in Kentucky.","S002, §380.010(4)-(5). \nLegislative Research Commission","High confidence."],["S_KY-P1-C007","Out-of-state location does not avoid coverage where the provider serves Kentucky residents; custodial §380.040 expressly reaches a person whether or not located in Kentucky.","S004, §380.040(1); S011 §2; S016 items 11 and 13. \nLegislative Research Commission\n+1","High confidence for actual Kentucky-resident service; passive-web/minimum-contact boundary unresolved."],["S_KY-P1-C008","An entity borrower is outside “debtor,” but an individual’s business-purpose debt is not expressly excluded by the general definition.","S002, §380.010(5); compare S004 mortgage-specific consumer-purpose language. \nLegislative Research Commission\n+1","High confidence for entity/individual distinction; moderate for individual business-purpose application absent controlling case."],["S_KY-P1-C009","Every covered person must file an initial registration and renew annually, with $250 each time.","S004, §380.040(5). \nLegislative Research Commission","High confidence."],["S_KY-P1-C010","A provider may not engage before a complete, accurate registration is confirmed by the Division; filing alone is insufficient.","S011 §§2(4), 3. \nLegislative Research Commission\n+1","High confidence under current rule."],["S_KY-P1-C011","The verified current route is the paper/form process; the 2026 online amendment remains proposed and not current.","S011 §§2, 7; S012 status and proposed §1. \nLegislative Research Commission\n+2","High confidence as of 10/24/2026."],["S_KY-P1-C012","The attorney exemption requires Kentucky admission, nonprincipal engagement in debt adjusting, and services in the course of law practice.","S003, §380.030(1). \nLegislative Research Commission","High confidence. Attorney affiliation alone is insufficient."],["S_KY-P1-C013","The nonprofit exemption requires §501(c)(3) status and that the organization not be in the business of debt adjusting.","S003, §380.030(6). \nLegislative Research Commission","High confidence."],["S_KY-P1-C014","Employee, court/statutory-authority, creditor-agent, loan-disbursement, and self-creditor exemptions are conditional, not categorical industry exemptions.","S003, §380.030(2)-(5), (7). \nLegislative Research Commission","High confidence; facts must satisfy every condition."],["S_KY-P1-C015","KRS Chapter 286 institutions retain the right to collect debts owed to themselves; this is not a broad third-party debt-adjusting exemption.","S009, §380.130. \nLegislative Research Commission","High confidence."],["S_KY-P1-C016","Printed initial-setup ceiling is $75.","S004, §380.040(2)(a). \nLegislative Research Commission","High confidence as printed figure; exact CPI-adjusted ceiling held under C020."],["S_KY-P1-C017","Printed consultation ceiling is $50 per calendar year.","S004, §380.040(2)(b). \nLegislative Research Commission","High confidence as printed figure; exact CPI-adjusted ceiling held."],["S_KY-P1-C018","For money held for unsecured-creditor distribution, periodic fee may not exceed the greater of 8.5% of the monthly distribution amount or $30.","S004, §380.040(2)(c). \nLegislative Research Commission","High confidence for covered custodial facts. Gross debit versus creditor-distribution base must be identified."],["S_KY-P1-C019","Bad-check charge is $20 or the bank pass-through, whichever is greater.","S004, §380.040(3). \nLegislative Research Commission","High confidence as printed rule; CPI issue held."],["S_KY-P1-C020","Chapter 380 permits annual CPI adjustment, but no exact current adjusted amount or authoritative adjustment instrument was verified.","S004, §380.040(4); S013 fee table. \nLegislative Research Commission\n+1","Statutory authorization high confidence; exact 2026 adjusted amounts unresolved."],["S_KY-P1-C021","For defined residential-mortgage-secured consumer debt, no other fee may be accepted or escrowed before complete performance.","S004, §380.040(2)(d). \nLegislative Research Commission","High confidence. Postperformance amount ceiling and other mortgage laws remain open."],["S_KY-P1-C022","No express Kentucky dollar or percentage cap was located for a noncustodial unsecured settlement performance fee.","S004 §§380.040(2), (9)-(10); S006 §380.100(1)(f). \nLegislative Research Commission\n+2","High confidence as scoped absence finding, not authorization or “unlimited fee” conclusion."],["S_KY-P1-C023","No express Kentucky per-debt, uniform-savings-percentage, or aggregate settlement-fee formula was located.","S004 and S006 reviewed; compare federal S018. \nLegislative Research Commission\n+1","Scoped absence finding; later case/interpretive research remains open."],["S_KY-P1-C024","Fees must be disclosed and itemized; unconscionable conduct, unrelated add-ons, and withholding part of the creditor compromise are prohibited.","S005 §380.060(1); S006 §380.100(1)(f); S004 §380.040(9)(o)-(p), (10). \nLegislative Research Commission\n+2","High confidence."],["S_KY-P1-C025","Debtor may cancel through midnight of the fourteenth day after signing without penalty or monetary obligation; omitted notice extends the cancellation right.","S005 §380.060(2)-(7). \nLegislative Research Commission\n+1","High confidence."],["S_KY-P1-C026","Debtor may terminate at any time without penalty or obligation and receive all unexpended money held for debt reduction or satisfaction.","S006 §380.100(1)(g). \nLegislative Research Commission","High confidence. This provision does not expressly require refund of every previously earned lawful fee."],["S_KY-P1-C027","A custodial provider generally must use a separate trust account and distribute funds within 30 days unless specifically instructed otherwise.","S004 §380.040(1). \nLegislative Research Commission","High confidence; full client-money administration remains later scope."],["S_KY-P1-C028","Registration also requires annual audit, insurance, and a $25,000 bond or approved letter of credit, with mortgage-related increases.","S004 §380.040(6)-(8); S011 §4; S016 pp.6-7. \nLegislative Research Commission\n+2","High confidence for statutory amounts and access conditions; full bond/claims pass remains open."],["S_KY-P1-C029","A Kentucky fee ceiling is not affirmative permission to collect the fee in advance.","S004 §380.040; federal S018 §310.4(a)(5). \nLegislative Research Commission\n+1","Legal reconciliation; high confidence where federal coverage exists."],["S_KY-P1-C030","Federal “debt relief service” concerns represented alteration of unsecured-debt terms; federal telemarketing generally requires a telephone campaign with more than one interstate call.","S017 §§310.2(o), (ii). \neCFR\n+1","High confidence as common baseline; exemptions and application require separate facts."],["S_KY-P1-C031","Under the covered TSR rule, no fee may be requested or received until at least one debt is altered under an executed agreement and the customer makes a payment under it.","S018 §310.4(a)(5)(i)(A)-(B). \neCFR","High confidence where TSR coverage exists."],["S_KY-P1-C032","Covered federal individual-debt fees must be proportional to enrolled debt or use a uniform savings percentage.","S018 §310.4(a)(5)(i)(C). \neCFR","High confidence; this is allocation/timing, not a federal percentage ceiling."],["S_KY-P1-C033","Covered dedicated accounts must satisfy insured-institution, ownership, independence, referral-compensation, and seven-business-day refund conditions.","S018 §310.4(a)(5)(ii). \neCFR","High confidence where this federal account provision applies."],["S_KY-P1-C034","Kentucky’s public registry is a lookup aid but has conflicting rendered and extracted dates/counts and cannot alone prove current named-provider authorization.","S014-S015. \nKentucky Agriculture\n+3","High confidence regarding the observed conflict; current individual files were not obtained."],["S_KY-P1-C035","A settlement leaving 50% or more owed requires creditor assent followed by debtor assent; POA authority may cover only a settlement below 50%, and never the defined mortgage-secured consumer debt.","S004 §380.040(9)(b)-(c); S006 §380.100(2). \nLegislative Research Commission\n+2","High confidence."],["S_KY-P1-C036","Violations can support civil penalties, misdemeanor treatment for §380.040 violations, KCPA remedies, injunction, restoration, and receivership.","S010 §380.990. \nLegislative Research Commission","High confidence at statutory level; full remedies/enforcement-history pass remains open."],["S_KY-P1-C037","No controlling published Kentucky appellate decision resolving the identified business-purpose, CPI, or noncustodial-fee-cap issues was located in the targeted searches performed.","Research-search result; statutory sources S002-S006 remain controlling evidence for this pass.","Moderate confidence only; not an exhaustive paid-citator or every-docket conclusion."]]},{"headers":["Component","Status in PASS-01","Supporting claims","Exact remaining evidence or next action"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status in PASS-01","Supporting claims","Exact remaining evidence or next action"],["Current Chapter 380 codification","Answered","C001","Recheck for later special-session or post-10/24/2026 enactments in any future update."],["Core debt-adjusting definition","Answered","C002-C005","Later apply to each actual SettleADebt operating role, affiliate, advertiser, negotiator, and account administrator."],["Principal-reduction settlement classification","Answered","C003-C004","Contract-specific application later."],["DMP/concession/payment-distribution classification","Answered","C002, C004, C018, C027","Full funds-flow and trust-account pass remains open."],["Credit/budget counseling","Substantially answered","C002, C004","Resolve edge cases involving education-only, free, employer, or software-only services."],["Advertising/lead generation","Partial","C005","Determine when a publisher, marketplace, lead generator, white-label front end, or referral entity is “advertising as” or holding itself out as the adjuster."],["Kentucky-resident nexus","Answered for actual service","C006-C007","Passive-site, transient-resident, relocation, and multistate contract conflicts remain open."],["Entity and business-purpose debt","Partial","C008, C037","Search exhaustive Kentucky appellate/federal applications; analyze guarantor, sole-proprietor, mixed-purpose, and entity/individual co-obligor facts."],["Ordinary market access","Answered","C009-C011","Obtain and inspect an actual written confirmation only if a named-provider review is later authorized."],["Attorney exemption","Answered textually; factual application open","C012","Later examine law-firm ownership, nonlawyer marketing, fee sharing, principal-business test, and professional-conduct law."],["Nonprofit exemption","Answered textually; factual application open","C013","Verify IRS determination and whether actual operations constitute the business of debt adjusting."],["Creditor/lender/employee/court exemptions","Answered textually","C014-C015","Apply to actual compensation and agency relationships later."],["Setup fee","Answered subject to CPI hold","C016, C020","Locate official CPI adjustment instrument or authoritative AG interpretation."],["Consultation fee","Answered subject to CPI hold","C017, C020","Same."],["Custodial periodic fee","Answered subject to CPI/base facts","C018, C020","Determine creditor-distribution base where fee and creditor funds share one debit; locate any adjustment instrument."],["Bad-check charge","Answered subject to CPI hold","C019-C020","Verify actual bank pass-through and any official adjustment."],["CPI adjustment","Unresolved exact amount","C020","Search Attorney General orders, archived fee bulletins, Register notices, open-record materials, and controlling interpretations; no invented calculation."],["Noncustodial unsecured settlement-fee amount","Unresolved exact ceiling; scoped absence found","C022-C024","Exhaustive citator, AG opinions/enforcement settlements, KCPA unconscionability cases, and actual confirmed fee schedules."],["State per-debt/savings/aggregate cap","No express formula located; later interpretation open","C023","Same interpretive and enforcement research."],["Mortgage-secured advance-fee timing","Answered under Chapter 380","C021","Full MARS, foreclosure-consultant, mortgage-service, federal/state overlap, and exact postperformance amount pass remains open."],["State fee timing for unsecured models","Partial","C025-C029","Investigate AG interpretations, enforcement pleadings/orders, and any case construing setup/consultation timing."],["Federal TSR timing baseline","Answered as common context","C030-C033","Full coverage/exemption analysis by marketing channel, seller, telemarketer, attorney, nonprofit, and call flow remains separate."],["Cancellation and unexpended-funds refund","Answered for fee boundary","C025-C026","Full agreement/delivery/e-sign and disputed-earned-fee analysis later."],["Trust and 30-day disbursement","Answered only to market-access boundary","C027","Full account ownership, reconciliation, authorized instructions, commingling, administrator, insolvency, and records pass later."],["Audit, insurance, bond/LOC","Answered only as access conditions","C028","Full forms DA-2/DA-3/DA-4, cancellation notices, bond claims, insurance exclusions, and proof-of-continuity pass later."],["Current application route","Answered","C010-C011","Monitor proposed regulation for final effective date and operative portal migration."],["Public provider lookup","Partial/unreliable for conclusive status","C034","Obtain current written confirmation, registration file, or authoritative agency record for any named provider; do not rely solely on PDF."],["Settlement assent/POA boundary","Answered where needed","C035","Full settlement-document and agency-authority pass later."],["Enforcement/remedies","Boundary only","C036","Full AG actions, private actions, damages, penalties, receiverships, criminal cases, and limitation periods later."],["Controlling case law","Unresolved/exhaustiveness hold","C037","Formal citator and docket search using KRS 380.010, .030, .040, .060, .100, and Chapter 380; review unpublished and federal diversity decisions."],["Collections and litigation consequences","Excluded from this pass","—","Dedicated later pass."],["Statutes of limitation and repose","Excluded except citation to §380.110","—","Dedicated remedies/limitations pass."],["Secured debt outside the defined residential-mortgage category","Open","—","Classify auto, UCC, judgment lien, tax lien, business real-estate, and mixed-collateral debt."],["Sector-specific laws","Open","—","Mortgage, student loan, tax, medical, payday, bank, collection-agency, and legal-services overlays."],["Local and tribal law","Open","—","Kentucky local-authority and tribal-jurisdiction research."],["Complete consumer-agreement duties","Open except fee/cancellation provisions used here","C024-C026","Full contract pass covering form, delivery, disclosures, prohibited terms, electronic consent, and creditor participation."],["Publication or state acceptance","Not determined","—","Coordinator/legal review remains separate; no acceptance implication."]]}],"claims":[{"claim_id":"S_KY-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C001","Precise assertion":"Chapter 380’s official index includes 2026 Regular Session enactments and was updated 10/24/2026.","Sources and pinpoints":"S001, lines 90-95. \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence as codification-currentness statement, not assurance against uncodified orders or litigation."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C002","Precise assertion":"Debt adjusting expressly includes budget counseling, debt management, debt modification or settlement, foreclosure assistance, and debt pooling.","Sources and pinpoints":"S002, §380.010(3), p.1. \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C003","Precise assertion":"Principal-reduction settlement is covered because adjustment, compromise, settlement, modification, and discharge are expressly included.","Sources and pinpoints":"S002, §380.010(3)(a). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence; exemption analysis remains separate."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C004","Precise assertion":"Chapter 380 covers both noncustodial intermediation and custodial receipt/distribution models.","Sources and pinpoints":"S002, §380.010(3)(a)-(b). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence. Custodial status changes some duties and fee rules, not base classification."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C005","Precise assertion":"Soliciting and advertising as a debt adjuster is itself included in the definition.","Sources and pinpoints":"S002, §380.010(3)(c). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence for holding out as the covered provider; pure independent publishing/referral requires facts."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C006","Precise assertion":"A statutory debtor is an individual residing temporarily or permanently in Kentucky.","Sources and pinpoints":"S002, §380.010(4)-(5). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C007","Precise assertion":"Out-of-state location does not avoid coverage where the provider serves Kentucky residents; custodial §380.040 expressly reaches a person whether or not located in Kentucky.","Sources and pinpoints":"S004, §380.040(1); S011 §2; S016 items 11 and 13. \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"High confidence for actual Kentucky-resident service; passive-web/minimum-contact boundary unresolved."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C008","Precise assertion":"An entity borrower is outside “debtor,” but an individual’s business-purpose debt is not expressly excluded by the general definition.","Sources and pinpoints":"S002, §380.010(5); compare S004 mortgage-specific consumer-purpose language. \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"High confidence for entity/individual distinction; moderate for individual business-purpose application absent controlling case."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C009","Precise assertion":"Every covered person must file an initial registration and renew annually, with $250 each time.","Sources and pinpoints":"S004, §380.040(5). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C010","Precise assertion":"A provider may not engage before a complete, accurate registration is confirmed by the Division; filing alone is insufficient.","Sources and pinpoints":"S011 §§2(4), 3. \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"High confidence under current rule."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C011","Precise assertion":"The verified current route is the paper/form process; the 2026 online amendment remains proposed and not current.","Sources and pinpoints":"S011 §§2, 7; S012 status and proposed §1. \nLegislative Research Commission\n+2","Conditions, currentness, confidence limits":"High confidence as of 10/24/2026."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C012","Precise assertion":"The attorney exemption requires Kentucky admission, nonprincipal engagement in debt adjusting, and services in the course of law practice.","Sources and pinpoints":"S003, §380.030(1). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence. Attorney affiliation alone is insufficient."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C013","Precise assertion":"The nonprofit exemption requires §501(c)(3) status and that the organization not be in the business of debt adjusting.","Sources and pinpoints":"S003, §380.030(6). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C014","Precise assertion":"Employee, court/statutory-authority, creditor-agent, loan-disbursement, and self-creditor exemptions are conditional, not categorical industry exemptions.","Sources and pinpoints":"S003, §380.030(2)-(5), (7). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence; facts must satisfy every condition."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C015","Precise assertion":"KRS Chapter 286 institutions retain the right to collect debts owed to themselves; this is not a broad third-party debt-adjusting exemption.","Sources and pinpoints":"S009, §380.130. \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C016","Precise assertion":"Printed initial-setup ceiling is $75.","Sources and pinpoints":"S004, §380.040(2)(a). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence as printed figure; exact CPI-adjusted ceiling held under C020."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C017","Precise assertion":"Printed consultation ceiling is $50 per calendar year.","Sources and pinpoints":"S004, §380.040(2)(b). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence as printed figure; exact CPI-adjusted ceiling held."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C018","Precise assertion":"For money held for unsecured-creditor distribution, periodic fee may not exceed the greater of 8.5% of the monthly distribution amount or $30.","Sources and pinpoints":"S004, §380.040(2)(c). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence for covered custodial facts. Gross debit versus creditor-distribution base must be identified."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C019","Precise assertion":"Bad-check charge is $20 or the bank pass-through, whichever is greater.","Sources and pinpoints":"S004, §380.040(3). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence as printed rule; CPI issue held."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C020","Precise assertion":"Chapter 380 permits annual CPI adjustment, but no exact current adjusted amount or authoritative adjustment instrument was verified.","Sources and pinpoints":"S004, §380.040(4); S013 fee table. \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"Statutory authorization high confidence; exact 2026 adjusted amounts unresolved."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C021","Precise assertion":"For defined residential-mortgage-secured consumer debt, no other fee may be accepted or escrowed before complete performance.","Sources and pinpoints":"S004, §380.040(2)(d). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence. Postperformance amount ceiling and other mortgage laws remain open."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C022","Precise assertion":"No express Kentucky dollar or percentage cap was located for a noncustodial unsecured settlement performance fee.","Sources and pinpoints":"S004 §§380.040(2), (9)-(10); S006 §380.100(1)(f). \nLegislative Research Commission\n+2","Conditions, currentness, confidence limits":"High confidence as scoped absence finding, not authorization or “unlimited fee” conclusion."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C023","Precise assertion":"No express Kentucky per-debt, uniform-savings-percentage, or aggregate settlement-fee formula was located.","Sources and pinpoints":"S004 and S006 reviewed; compare federal S018. \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"Scoped absence finding; later case/interpretive research remains open."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C024","Precise assertion":"Fees must be disclosed and itemized; unconscionable conduct, unrelated add-ons, and withholding part of the creditor compromise are prohibited.","Sources and pinpoints":"S005 §380.060(1); S006 §380.100(1)(f); S004 §380.040(9)(o)-(p), (10). \nLegislative Research Commission\n+2","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C025","Precise assertion":"Debtor may cancel through midnight of the fourteenth day after signing without penalty or monetary obligation; omitted notice extends the cancellation right.","Sources and pinpoints":"S005 §380.060(2)-(7). \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C026","Precise assertion":"Debtor may terminate at any time without penalty or obligation and receive all unexpended money held for debt reduction or satisfaction.","Sources and pinpoints":"S006 §380.100(1)(g). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence. This provision does not expressly require refund of every previously earned lawful fee."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C027","Precise assertion":"A custodial provider generally must use a separate trust account and distribute funds within 30 days unless specifically instructed otherwise.","Sources and pinpoints":"S004 §380.040(1). \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence; full client-money administration remains later scope."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C028","Precise assertion":"Registration also requires annual audit, insurance, and a $25,000 bond or approved letter of credit, with mortgage-related increases.","Sources and pinpoints":"S004 §380.040(6)-(8); S011 §4; S016 pp.6-7. \nLegislative Research Commission\n+2","Conditions, currentness, confidence limits":"High confidence for statutory amounts and access conditions; full bond/claims pass remains open."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C029","Precise assertion":"A Kentucky fee ceiling is not affirmative permission to collect the fee in advance.","Sources and pinpoints":"S004 §380.040; federal S018 §310.4(a)(5). \nLegislative Research Commission\n+1","Conditions, currentness, confidence limits":"Legal reconciliation; high confidence where federal coverage exists."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C030","Precise assertion":"Federal “debt relief service” concerns represented alteration of unsecured-debt terms; federal telemarketing generally requires a telephone campaign with more than one interstate call.","Sources and pinpoints":"S017 §§310.2(o), (ii). \neCFR\n+1","Conditions, currentness, confidence limits":"High confidence as common baseline; exemptions and application require separate facts."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C031","Precise assertion":"Under the covered TSR rule, no fee may be requested or received until at least one debt is altered under an executed agreement and the customer makes a payment under it.","Sources and pinpoints":"S018 §310.4(a)(5)(i)(A)-(B). \neCFR","Conditions, currentness, confidence limits":"High confidence where TSR coverage exists."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C032","Precise assertion":"Covered federal individual-debt fees must be proportional to enrolled debt or use a uniform savings percentage.","Sources and pinpoints":"S018 §310.4(a)(5)(i)(C). \neCFR","Conditions, currentness, confidence limits":"High confidence; this is allocation/timing, not a federal percentage ceiling."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C033","Precise assertion":"Covered dedicated accounts must satisfy insured-institution, ownership, independence, referral-compensation, and seven-business-day refund conditions.","Sources and pinpoints":"S018 §310.4(a)(5)(ii). \neCFR","Conditions, currentness, confidence limits":"High confidence where this federal account provision applies."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C034","Precise assertion":"Kentucky’s public registry is a lookup aid but has conflicting rendered and extracted dates/counts and cannot alone prove current named-provider authorization.","Sources and pinpoints":"S014-S015. \nKentucky Agriculture\n+3","Conditions, currentness, confidence limits":"High confidence regarding the observed conflict; current individual files were not obtained."},"coordinator_verification_status":"clarification_required_registry_retrieval_provenance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C035","Precise assertion":"A settlement leaving 50% or more owed requires creditor assent followed by debtor assent; POA authority may cover only a settlement below 50%, and never the defined mortgage-secured consumer debt.","Sources and pinpoints":"S004 §380.040(9)(b)-(c); S006 §380.100(2). \nLegislative Research Commission\n+2","Conditions, currentness, confidence limits":"High confidence."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C036","Precise assertion":"Violations can support civil penalties, misdemeanor treatment for §380.040 violations, KCPA remedies, injunction, restoration, and receivership.","Sources and pinpoints":"S010 §380.990. \nLegislative Research Commission","Conditions, currentness, confidence limits":"High confidence at statutory level; full remedies/enforcement-history pass remains open."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_KY-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_KY-P1-C037","Precise assertion":"No controlling published Kentucky appellate decision resolving the identified business-purpose, CPI, or noncustodial-fee-cap issues was located in the targeted searches performed.","Sources and pinpoints":"Research-search result; statutory sources S002-S006 remain controlling evidence for this pass.","Conditions, currentness, confidence limits":"Moderate confidence only; not an exhaustive paid-citator or every-docket conclusion."},"coordinator_verification_status":"scoped_review_not_unqualified_claim_acceptance","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_KY-P1-S001","urls":["https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145"],"researcher_record":{"Source ID":"S_KY-P1-S001","Title, issuer, and direct literal URL":"KRS Chapter 380 index, Kentucky Legislative Research Commission. https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=39145","Exact pinpoint/version/effective status":"Lines 90-120: includes enactments through 2026 Regular Session; database updated 10/24/2026","Actual check and limitations":"Accessed 10/24/2026. Currentness index, not substantive text. \nLegislative Research Commission"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S002","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378"],"researcher_record":{"Source ID":"S_KY-P1-S002","Title, issuer, and direct literal URL":"KRS 380.010, Definitions. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35378","Exact pinpoint/version/effective status":"§380.010(1)-(5), PDF pp.1-2; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Primary statutory definition. \nLegislative Research Commission"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S003","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380"],"researcher_record":{"Source ID":"S_KY-P1-S003","Title, issuer, and direct literal URL":"KRS 380.030, Exempt persons. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35380","Exact pinpoint/version/effective status":"§380.030(1)-(7), PDF p.1; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Express exemptions only; entity structuring facts may require later analysis. \nLegislative Research Commission"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S004","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571"],"researcher_record":{"Source ID":"S_KY-P1-S004","Title, issuer, and direct literal URL":"KRS 380.040, powers, prohibitions, fees, registration, audit, insurance, bond. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=54571","Exact pinpoint/version/effective status":"§380.040(1)-(10), PDF pp.1-5; effective 4/5/2024","Actual check and limitations":"Accessed/read 10/24/2026. Principal substantive source for this pass. \nLegislative Research Commission\n+2"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S005","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383"],"researcher_record":{"Source ID":"S_KY-P1-S005","Title, issuer, and direct literal URL":"KRS 380.060, contract disclosure and 14-day cancellation. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35383","Exact pinpoint/version/effective status":"§380.060(1)-(7), PDF pp.1-2; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Used only for compensation disclosure and cancellation/refund boundaries. \nLegislative Research Commission\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S006","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387"],"researcher_record":{"Source ID":"S_KY-P1-S006","Title, issuer, and direct literal URL":"KRS 380.100, agreement contents and termination. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35387","Exact pinpoint/version/effective status":"§380.100(1)-(5), PDF pp.1-3; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Used for itemized fees, unexpended-funds refund, and settlement authorization boundaries. \nLegislative Research Commission\n+2"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S007","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388"],"researcher_record":{"Source ID":"S_KY-P1-S007","Title, issuer, and direct literal URL":"KRS 380.110, private action. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35388","Exact pinpoint/version/effective status":"§380.110(1)-(4), PDF p.1; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Detailed remedies reserved for later pass. \nLegislative Research Commission"},"coordinator_verification_status":"not_all_researcher_sources_freshly_checked","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S008","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389"],"researcher_record":{"Source ID":"S_KY-P1-S008","Title, issuer, and direct literal URL":"KRS 380.120, nonwaiver. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35389","Exact pinpoint/version/effective status":"Entire section; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. \nLegislative Research Commission"},"coordinator_verification_status":"not_all_researcher_sources_freshly_checked","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S009","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390"],"researcher_record":{"Source ID":"S_KY-P1-S009","Title, issuer, and direct literal URL":"KRS 380.130, financial institution own-debt provision. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35390","Exact pinpoint/version/effective status":"Entire section; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Not a blanket third-party-service exemption. \nLegislative Research Commission"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S010","urls":["https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391"],"researcher_record":{"Source ID":"S_KY-P1-S010","Title, issuer, and direct literal URL":"KRS 380.990, penalties and KCPA treatment. https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=35391","Exact pinpoint/version/effective status":"§380.990(1)-(4), PDF p.1; effective 7/15/2010","Actual check and limitations":"Accessed/read 10/24/2026. Enforcement details remain later-pass material. \nLegislative Research Commission"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S011","urls":["https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/"],"researcher_record":{"Source ID":"S_KY-P1-S011","Title, issuer, and direct literal URL":"Current 40 KAR 12:400, Kentucky LRC. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/16374/","Exact pinpoint/version/effective status":"Sections 1-7; registration effective only after complete filing and written confirmation; history shows recodification effective 7/18/2025; expiration 2/21/2027","Actual check and limitations":"Accessed/read 10/24/2026. Current operative regulation; separate proposed version exists. \nLegislative Research Commission\n+2"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_additional_locator":{"url":"https://apps.legislature.ky.gov/law/kar/titles/040/012/400/","basis":"OfficialproposalViewCurrentRegulationlink; actualpostedtextread; no byteidentityassumptionwitholdnumericURL"}},{"source_id":"S_KY-P1-S012","urls":["https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/"],"researcher_record":{"Source ID":"S_KY-P1-S012","Title, issuer, and direct literal URL":"Proposed 40 KAR 12:400 amendment. https://apps.legislature.ky.gov/law/kar/titles/040/012/400/REG/","Exact pinpoint/version/effective status":"Page labels: “PROPOSED—This document is not yet current”; filed 7/8/2026; page generated 8/28/2026; proposed online application","Actual check and limitations":"Accessed/read 10/24/2026. Not current law and not used as operative procedure. \nLegislative Research Commission\n+2"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S013","urls":["https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx","https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx"],"researcher_record":{"Source ID":"S_KY-P1-S013","Title, issuer, and direct literal URL":"Kentucky AG, Information for Adjusters. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/adjusters.aspx","Exact pinpoint/version/effective status":"Definition, fee table, registration instructions, mail address","Actual check and limitations":"Accessed 10/24/2026. Operational guidance; landing page identifies it as updated Nov. 2010. Its mortgage-rule subsection citation is stale. \nKentucky Agriculture\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S014","urls":["https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","https://ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx"],"researcher_record":{"Source ID":"S_KY-P1-S014","Title, issuer, and direct literal URL":"Kentucky AG, Debt Adjusters landing page. https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Debt-Adjusters/Pages/default.aspx","Exact pinpoint/version/effective status":"Lines 36-51: list not endorsement; links to list and Nov. 2010 guidance","Actual check and limitations":"Accessed 10/24/2026. Procedure/lookup aid, not legal authorization. \nKentucky Agriculture"},"coordinator_verification_status":"selected_primary_passages_checked_with_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S015","urls":["https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf"],"researcher_record":{"Source ID":"S_KY-P1-S015","Title, issuer, and direct literal URL":"Kentucky AG, Registered Debt Adjusters PDF. https://www.ag.ky.gov/Resources/Consumer-Resources/charity/Documents/debtAdjusters.pdf","Exact pinpoint/version/effective status":"Parsed layer says updated 10/19/2026; rendered pp.1-2 say 3/30/2026 and 8/24/2026; visual total 36","Actual check and limitations":"Accessed, parsed, and visually inspected 10/24/2026. Internal inconsistency prevents treating it as conclusive named-provider proof. \nKentucky Agriculture\n+2"},"coordinator_verification_status":"clarification_required_registry_representation_version_identity_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S016","urls":["https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf"],"researcher_record":{"Source ID":"S_KY-P1-S016","Title, issuer, and direct literal URL":"Form DA-1, Debt Adjuster Registration Statement. https://www.ag.ky.gov/AG%20Business%20Forms/DA_registration_form.pdf","Exact pinpoint/version/effective status":"July 2010, pp.1-7; fee schedule p.5; insurance/bond pp.6-7","Actual check and limitations":"Accessed/read 10/24/2026. Current rule incorporates the July 2010 form, although it contains legacy URLs and old rule-number references. \nKentucky Agriculture\n+2"},"coordinator_verification_status":"not_all_researcher_sources_freshly_checked","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S017","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310"],"researcher_record":{"Source ID":"S_KY-P1-S017","Title, issuer, and direct literal URL":"eCFR, 16 CFR Part 310, definitions. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","Exact pinpoint/version/effective status":"§§310.2(o), 310.2(ii); displayed federal text current through 10/22/2026","Actual check and limitations":"Accessed 10/24/2026. eCFR is continuously updated and authoritative but unofficial. Federal common context only. \neCFR\n+1"},"coordinator_verification_status":"not_all_researcher_sources_freshly_checked","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_KY-P1-S018","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_KY-P1-S018","Title, issuer, and direct literal URL":"eCFR, 16 CFR 310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact pinpoint/version/effective status":"§310.4(a)(5)(i)-(ii); displayed current through 10/22/2026","Actual check and limitations":"Accessed/read 10/24/2026. Federal trigger/allocation/account rules; federal coverage remains separately fact-dependent. \neCFR\n+1"},"coordinator_verification_status":"prior_federal_actual_text_reuse_scope_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]"}],"coverage":[{"topic":"Current Chapter 380 codification","researcher_record":{"Component":"Current Chapter 380 codification","Status in PASS-01":"Answered","Supporting claims":"C001","Exact remaining evidence or next action":"Recheck for later special-session or post-10/24/2026 enactments in any future update."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Core debt-adjusting definition","researcher_record":{"Component":"Core debt-adjusting definition","Status in PASS-01":"Answered","Supporting claims":"C002-C005","Exact remaining evidence or next action":"Later apply to each actual SettleADebt operating role, affiliate, advertiser, negotiator, and account administrator."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Principal-reduction settlement classification","researcher_record":{"Component":"Principal-reduction settlement classification","Status in PASS-01":"Answered","Supporting claims":"C003-C004","Exact remaining evidence or next action":"Contract-specific application later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"DMP/concession/payment-distribution classification","researcher_record":{"Component":"DMP/concession/payment-distribution classification","Status in PASS-01":"Answered","Supporting claims":"C002, C004, C018, C027","Exact remaining evidence or next action":"Full funds-flow and trust-account pass remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Credit/budget counseling","researcher_record":{"Component":"Credit/budget counseling","Status in PASS-01":"Substantially answered","Supporting claims":"C002, C004","Exact remaining evidence or next action":"Resolve edge cases involving education-only, free, employer, or software-only services."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Advertising/lead generation","researcher_record":{"Component":"Advertising/lead generation","Status in PASS-01":"Partial","Supporting claims":"C005","Exact remaining evidence or next action":"Determine when a publisher, marketplace, lead generator, white-label front end, or referral entity is “advertising as” or holding itself out as the adjuster."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Kentucky-resident nexus","researcher_record":{"Component":"Kentucky-resident nexus","Status in PASS-01":"Answered for actual service","Supporting claims":"C006-C007","Exact remaining evidence or next action":"Passive-site, transient-resident, relocation, and multistate contract conflicts remain open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Entity and business-purpose debt","researcher_record":{"Component":"Entity and business-purpose debt","Status in PASS-01":"Partial","Supporting claims":"C008, C037","Exact remaining evidence or next action":"Search exhaustive Kentucky appellate/federal applications; analyze guarantor, sole-proprietor, mixed-purpose, and entity/individual co-obligor facts."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary market access","researcher_record":{"Component":"Ordinary market access","Status in PASS-01":"Answered","Supporting claims":"C009-C011","Exact remaining evidence or next action":"Obtain and inspect an actual written confirmation only if a named-provider review is later authorized."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exemption","researcher_record":{"Component":"Attorney exemption","Status in PASS-01":"Answered textually; factual application open","Supporting claims":"C012","Exact remaining evidence or next action":"Later examine law-firm ownership, nonlawyer marketing, fee sharing, principal-business test, and professional-conduct law."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit exemption","researcher_record":{"Component":"Nonprofit exemption","Status in PASS-01":"Answered textually; factual application open","Supporting claims":"C013","Exact remaining evidence or next action":"Verify IRS determination and whether actual operations constitute the business of debt adjusting."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor/lender/employee/court exemptions","researcher_record":{"Component":"Creditor/lender/employee/court exemptions","Status in PASS-01":"Answered textually","Supporting claims":"C014-C015","Exact remaining evidence or next action":"Apply to actual compensation and agency relationships later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Setup fee","researcher_record":{"Component":"Setup fee","Status in PASS-01":"Answered subject to CPI hold","Supporting claims":"C016, C020","Exact remaining evidence or next action":"Locate official CPI adjustment instrument or authoritative AG interpretation."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Consultation fee","researcher_record":{"Component":"Consultation fee","Status in PASS-01":"Answered subject to CPI hold","Supporting claims":"C017, C020","Exact remaining evidence or next action":"Same."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial periodic fee","researcher_record":{"Component":"Custodial periodic fee","Status in PASS-01":"Answered subject to CPI/base facts","Supporting claims":"C018, C020","Exact remaining evidence or next action":"Determine creditor-distribution base where fee and creditor funds share one debit; locate any adjustment instrument."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Bad-check charge","researcher_record":{"Component":"Bad-check charge","Status in PASS-01":"Answered subject to CPI hold","Supporting claims":"C019-C020","Exact remaining evidence or next action":"Verify actual bank pass-through and any official adjustment."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CPI adjustment","researcher_record":{"Component":"CPI adjustment","Status in PASS-01":"Unresolved exact amount","Supporting claims":"C020","Exact remaining evidence or next action":"Search Attorney General orders, archived fee bulletins, Register notices, open-record materials, and controlling interpretations; no invented calculation."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial unsecured settlement-fee amount","researcher_record":{"Component":"Noncustodial unsecured settlement-fee amount","Status in PASS-01":"Unresolved exact ceiling; scoped absence found","Supporting claims":"C022-C024","Exact remaining evidence or next action":"Exhaustive citator, AG opinions/enforcement settlements, KCPA unconscionability cases, and actual confirmed fee schedules."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State per-debt/savings/aggregate cap","researcher_record":{"Component":"State per-debt/savings/aggregate cap","Status in PASS-01":"No express formula located; later interpretation open","Supporting claims":"C023","Exact remaining evidence or next action":"Same interpretive and enforcement research."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Mortgage-secured advance-fee timing","researcher_record":{"Component":"Mortgage-secured advance-fee timing","Status in PASS-01":"Answered under Chapter 380","Supporting claims":"C021","Exact remaining evidence or next action":"Full MARS, foreclosure-consultant, mortgage-service, federal/state overlap, and exact postperformance amount pass remains open."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State fee timing for unsecured models","researcher_record":{"Component":"State fee timing for unsecured models","Status in PASS-01":"Partial","Supporting claims":"C025-C029","Exact remaining evidence or next action":"Investigate AG interpretations, enforcement pleadings/orders, and any case construing setup/consultation timing."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR timing baseline","researcher_record":{"Component":"Federal TSR timing baseline","Status in PASS-01":"Answered as common context","Supporting claims":"C030-C033","Exact remaining evidence or next action":"Full coverage/exemption analysis by marketing channel, seller, telemarketer, attorney, nonprofit, and call flow remains separate."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation and unexpended-funds refund","researcher_record":{"Component":"Cancellation and unexpended-funds refund","Status in PASS-01":"Answered for fee boundary","Supporting claims":"C025-C026","Exact remaining evidence or next action":"Full agreement/delivery/e-sign and disputed-earned-fee analysis later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Trust and 30-day disbursement","researcher_record":{"Component":"Trust and 30-day disbursement","Status in PASS-01":"Answered only to market-access boundary","Supporting claims":"C027","Exact remaining evidence or next action":"Full account ownership, reconciliation, authorized instructions, commingling, administrator, insolvency, and records pass later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Audit, insurance, bond/LOC","researcher_record":{"Component":"Audit, insurance, bond/LOC","Status in PASS-01":"Answered only as access conditions","Supporting claims":"C028","Exact remaining evidence or next action":"Full forms DA-2/DA-3/DA-4, cancellation notices, bond claims, insurance exclusions, and proof-of-continuity pass later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Current application route","researcher_record":{"Component":"Current application route","Status in PASS-01":"Answered","Supporting claims":"C010-C011","Exact remaining evidence or next action":"Monitor proposed regulation for final effective date and operative portal migration."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Public provider lookup","researcher_record":{"Component":"Public provider lookup","Status in PASS-01":"Partial/unreliable for conclusive status","Supporting claims":"C034","Exact remaining evidence or next action":"Obtain current written confirmation, registration file, or authoritative agency record for any named provider; do not rely solely on PDF."},"coordinator_acceptance":"partial_provider_registry_provenance_correction_required","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement assent/POA boundary","researcher_record":{"Component":"Settlement assent/POA boundary","Status in PASS-01":"Answered where needed","Supporting claims":"C035","Exact remaining evidence or next action":"Full settlement-document and agency-authority pass later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Enforcement/remedies","researcher_record":{"Component":"Enforcement/remedies","Status in PASS-01":"Boundary only","Supporting claims":"C036","Exact remaining evidence or next action":"Full AG actions, private actions, damages, penalties, receiverships, criminal cases, and limitation periods later."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling case law","researcher_record":{"Component":"Controlling case law","Status in PASS-01":"Unresolved/exhaustiveness hold","Supporting claims":"C037","Exact remaining evidence or next action":"Formal citator and docket search using KRS 380.010, .030, .040, .060, .100, and Chapter 380; review unpublished and federal diversity decisions."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Collections and litigation consequences","researcher_record":{"Component":"Collections and litigation consequences","Status in PASS-01":"Excluded from this pass","Supporting claims":"—","Exact remaining evidence or next action":"Dedicated later pass."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Statutes of limitation and repose","researcher_record":{"Component":"Statutes of limitation and repose","Status in PASS-01":"Excluded except citation to §380.110","Supporting claims":"—","Exact remaining evidence or next action":"Dedicated remedies/limitations pass."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt outside the defined residential-mortgage category","researcher_record":{"Component":"Secured debt outside the defined residential-mortgage category","Status in PASS-01":"Open","Supporting claims":"—","Exact remaining evidence or next action":"Classify auto, UCC, judgment lien, tax lien, business real-estate, and mixed-collateral debt."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Sector-specific laws","researcher_record":{"Component":"Sector-specific laws","Status in PASS-01":"Open","Supporting claims":"—","Exact remaining evidence or next action":"Mortgage, student loan, tax, medical, payday, bank, collection-agency, and legal-services overlays."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Local and tribal law","researcher_record":{"Component":"Local and tribal law","Status in PASS-01":"Open","Supporting claims":"—","Exact remaining evidence or next action":"Kentucky local-authority and tribal-jurisdiction research."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Complete consumer-agreement duties","researcher_record":{"Component":"Complete consumer-agreement duties","Status in PASS-01":"Open except fee/cancellation provisions used here","Supporting claims":"C024-C026","Exact remaining evidence or next action":"Full contract pass covering form, delivery, disclosures, prohibited terms, electronic consent, and creditor participation."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Publication or state acceptance","researcher_record":{"Component":"Publication or state acceptance","Status in PASS-01":"Not determined","Supporting claims":"—","Exact remaining evidence or next action":"Coordinator/legal review remains separate; no acceptance implication."},"coordinator_acceptance":"partial_component_review_remaining_state_source_and_interpretation_holds","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}