{"meta":{"key":"s_me--pass-01","task":"S_ME","title":"Maine provider market access and consumer fees","parent_title":"Maine debt and debt relief law","edition":"pass-01","path":"/research/s_me--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":8,"claims":37,"sources":17,"review_status":"revise","review_complete":true,"sha256":"41d447390ae02e6581d79324e78a66fbb616c4024314221311696c1a12ee565d","headings":["Maine provider market access and consumer fees","Executive determination","1. How Maine classifies the relevant conduct","1.1 The four statutory activity categories","1.2 Model-by-model classification","1.3 Consumer versus business purpose","1.4 Remote-provider and geographic nexus","2. Whether each model is prohibited, registered, authorized, or exempt","2.1 General registration requirement","2.2 Traditional budget planning is affirmatively prohibited unless an exception applies","2.3 Debt settlement and noncustodial services","2.4 Nonprofit status","2.5 Attorney exclusion","2.6 Financial-institution and lender exclusions","2.7 Self-creditor activity","2.8 Other prohibited combinations","3. Legally applicable consumer-fee structures","3.1 Current fee table","3.2 “Reasonable” is an independent limitation","3.3 Alternative service-fee tracks","3.4 Settlement-fee base","3.5 Partial settlements and multiple debts","3.6 Interest, waived fees, and prospective concessions","3.7 Noncustodial arranger with no reduction","3.8 Creditor-paid and third-party compensation","3.9 Refunds and credits","4. When fees may be requested or received","4.1 Maine law by itself","4.2 Federal TSR overlay when applicable","4.3 Dedicated accounts under the TSR","4.4 Maine creditor-payment funds","5. Regulator permission, registration procedure, and public lookup","5.1 Regulator and legal authority","5.2 Current operational path","5.3 Registration periods require current NMLS inspection","5.4 NMLS transition and electronic surety bond","5.5 Public authorization verification","5.6 Rule status and possible future changes","6. Worked-example conclusion","7. Immediate implementation implications for SettleADebt.com","D1. Plain-text worked examples","Example 1 — Ordinary settlement","Example 2 — Lower-balance debt","Example 3 — Partial reduction without full discharge","Example 4 — Two debts and a previously assessed fee","Example 5 — Conservative cent rounding","Example 6 — Six-month custodial DMP","Example 7 — Joint obligations of spouses","Example 8 — Interest-rate reduction only","Example 9 — Cancellation after two actual DMP months","Example 10 — Noncustodial arranger, no distribution and no result","Example 11 — Covered but unregistered provider","D2. Component coverage and gap table","Actually read","Not fully read or not independently verified","Judicial search boundary","Arithmetic and process controls"],"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_ME/pass-01","facets":{"geography":["us","us-me"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Maine provider-access/fees component; every broader state category remains required","pending_corrections":0},"markdown":"# S_ME — PASS-01\n\n## Maine provider market access and consumer fees\n\n**Actual research/access date:** October 24, 2026, Pacific Time.\n**Baseline supplied:** October 22, 2026.\n**Actual model/mode:** GPT-5.6 Sol Pro in regular Chat; the owner-authorized quality-first fallback was used because GPT-6 Pro was not the selected/available model.\n**Scope:** Provider classification, market access, consumer fees, fee timing, current public registration procedure, bounded examples, and exact remaining gaps. This is **not** whole-state acceptance, publication approval, an A066 acceptance, or a completed Maine dossier.\n\n## Executive determination\n\n1. **Maine uses a broad, conduct-based debt-management definition.** It reaches receiving or controlling consumer funds, arranging distributions without taking custody, and acting or offering to act as an intermediary to adjust, settle, compromise, discharge, or otherwise alter payment terms. A company cannot avoid coverage by calling itself a “financial coach,” “law firm partner,” “negotiator,” “software platform,” or “credit-counseling service” when its actual conduct falls within those activities. [C001–C006] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n2. **Covered organizations generally must obtain a Maine debt-management-service-provider registration.** Traditional custodial budget planning is additionally subject to a separate statute that affirmatively prohibits the business unless the actor falls within a narrow exclusion or is registered under Title 32, chapter 80-A. Thus, registration is the statutory exception to an express prohibition for classic budget planning—not merely an optional operational credential. [C004, C007] [Maine State Legislature+1](https://www.legislature.maine.gov/statutes/17/title17sec701.html)\n3. **For-profit providers may register.** Maine repealed its nonprofit-only restriction effective September 20, 2007. A nonprofit label is not a present exemption from registration. [C008] [Maine Legislature](https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp)\n4. **Current Maine consumer-fee ceilings are:**reasonable one-time setup fee: **no more than $75**;then **either**:reasonable monthly fee: **no more than $40**, for a provider that actually distributes monthly payments; **or**reasonable settlement/term-alteration fee: **no more than 15% of the amount by which debt is reduced as part of each settlement**;reasonable approved consumer-education-program fee: **no more than $50**.\nThese are ceilings, not automatic entitlements, and the operative consumer-fee statute contains no CPI/indexing mechanism. [C013–C019, C035] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n5. **Maine’s statute does not establish a complete standalone fee-collection timetable.** It does not say that the $75 fee may be taken in advance. The 15% formula is outcome-dependent, but Maine does not separately prescribe the exact request/receipt event. When the federal Telemarketing Sales Rule applies, no fee or consideration for the debt-relief service may be requested or received until at least one debt has been altered under an executed agreement and the consumer has made at least one payment under that creditor agreement. [C020, C023–C025] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n6. **Public market access currently runs through NMLS under Maine Bureau of Consumer Credit Protection oversight.** The operative rule states a $500 company application fee, $250 branch application fee, and $250 company and branch renewal fees, plus NMLS processing costs. Each business location requires a separate registration. Those company-registration fees must not be confused with the consumer-fee ceilings. [C026–C030] [Midpage+1](https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f)\n\n# A. Substantive answers to the seven assigned questions\n\n## 1. How Maine classifies the relevant conduct\n\n### 1.1 The four statutory activity categories\n\nMaine defines “debt management service” through four alternative forms of conduct:\n\n| Activity | Statutory classification | Practical consequence |\n| --- | --- | --- |\n| Receiving consumer money to distribute to one or more creditors | §6172(2)(A) | Covers traditional custodial debt-management plans. |\n| Arranging or assisting the consumer to arrange creditor distributions | §6172(2)(B) | Custody is not required. A provider cannot avoid coverage merely by having the consumer, processor, or account administrator transmit payments. |\n| Directly or indirectly controlling, or arranging control over, consumer funds for creditor payments | §6172(2)(C) | Reaches functional control and arranged control, not only possession of a check or bank account. |\n| Acting or offering to act as intermediary to adjust, settle, discharge, compromise, or otherwise alter payment terms | §6172(2)(D) | Covers principal-reduction settlement, payment concessions, and other negotiated term alterations. |\n\nThe definition is written around actual functions, including an **offer** to perform the service. It does not depend on whether the provider calls the product “debt settlement,” “credit counseling,” “debt resolution,” “hardship assistance,” “legal support,” or another marketing label. [C001] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 1.2 Model-by-model classification\n\n| Business model | Maine classification | Registration/access conclusion | Fee-path conclusion |\n| --- | --- | --- | --- |\n| **Custodial DMP:** provider receives periodic consumer payments and remits them to creditors | §6172(2)(A) and usually (C); also “budget planning” under Title 17, §702 | Explicitly prohibited under Title 17, §701 unless registered or within a narrow exclusion | Up to $75 setup plus the alternative §6174-A(2)(A) monthly fee, capped at $40, assuming actual monthly distributions and reasonableness |\n| **Noncustodial DMP:** provider negotiates concessions and arranges consumer or third-party payment delivery | §6172(2)(B), potentially (C) and (D) | Registration still required; lack of custody does not defeat coverage | A recurring $40 fee is not clearly established unless the provider “distributes monthly payments”; if there is no debt reduction, the 15% base is also absent |\n| **Principal-reduction settlement:** provider negotiates a creditor’s acceptance of less than the debt | §6172(2)(D) | Registration required | Up to 15% of actual debt reduction as part of each settlement, not 15% of enrolled debt |\n| **Interest-rate, fee, payment-date, or term concession** | §6172(2)(D), because “otherwise altering the terms of payment” is broad | Registration required even if principal is not reduced | Coverage and compensation are separate. If no present debt reduction exists, the Maine 15% base is unresolved and may be zero |\n| **Pure financial education with no A–D activity and no fee or other consideration** | Likely outside chapter 80-A | This is a textual inference, not an express education exemption | Once education is offered by a covered provider, §6174-B requires an approved program and caps the consumer program fee at $50 |\n| **Commercial/business-debt program** | Outside the defined “consumer’s obligation” | Chapter 80-A does not cover the obligation merely because an individual guarantees it; exact mixed-purpose treatment remains for later research | No chapter 80-A fee conclusion; other Maine law remains open |\n| **Creditor negotiating its own debt** | No express self-creditor exemption | Paragraph (D)’s “intermediary” wording ordinarily does not fit the creditor itself, but paragraphs (A)–(C), affiliate structures, or third-party fee arrangements could change the result | Held; do not rely on an assumed self-creditor exemption |\n| **Lead generator or referral site** | Fact-dependent | Merely publishing neutral information differs from offering the service as one’s own. Representations, compensation, intake, matching, control, and agency relationships matter | Referral compensation is not affirmatively approved by the consumer-fee provisions; the registration rule requires disclosure of referral relationships |\n| **Debt collector offering settlement to collect another’s debt** | Collection law and DMS functions may overlap factually | A registered debt-management provider is affirmatively prohibited from operating as a debt collector; registration does not authorize collection activity | Collection compensation and creditor-side recovery remain outside this pass |\n\nThe underlying statutory definitions support the classifications above. The traditional budget-planning prohibition and its definition are separate from, but operate alongside, chapter 80-A. [C001–C006, C031–C034] [Maine State Legislature+3](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 1.3 Consumer versus business purpose\n\nA “consumer’s obligation” is debt incurred for **personal, family, or household purposes** and expressly excludes debt incurred for business or commercial purposes. Maine’s chapter does not resolve mixed-purpose debt, business cards used personally, personal cards used for a business, personal guarantees of business debt, or post-origination changes in use. Those require transaction-level facts and later interpretive research. [C002] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 1.4 Remote-provider and geographic nexus\n\nA provider includes a person **“wherever located”** that provides or offers debt-management services to a consumer “in this State” for a fee or other consideration. It also includes a person located in Maine that serves a nonresident for consideration. This expressly reaches ordinary telephone and online delivery into Maine. [C003] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nTwo nexus details remain unresolved:\n\n- “Consumer in this State” is not separately defined as exclusively residence, physical presence, domicile, or contract location.\n- The fee and education sections use the narrower phrase “consumer who is a resident of this State” in their Maine-outbound-provider carveouts. That wording difference means residence should not automatically be substituted for every occurrence of “in this State.”\n\nA Maine-located provider serving **no Maine residents** remains within the provider definition, but §§6174-A(4) and 6174-B(3) say those fee and counselor/education provisions do not apply. Registration and the destination consumer’s state law remain distinct. [C012] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n## 2. Whether each model is prohibited, registered, authorized, or exempt\n\n### 2.1 General registration requirement\n\nAn organization desiring to act or continue acting as a debt-management-service provider must apply for registration or reregistration. Registration cannot issue unless the administrator finds that financial soundness and responsibility, insurance, consumer education and services, character, and fitness support a belief that the business will be operated honestly and fairly. A separate registration is required for each business location. [C007] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nThe statute defines “person” to include an individual or organization, but §6173(2) literally directs an **“organization”** to register. Rule 706, by contrast, expressly contemplates sole proprietors and individual applicants. Operationally, Maine provides a sole-proprietor registration route, but the statute/rule wording tension has not been resolved by a controlling decision found in this pass. [C036] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 2.2 Traditional budget planning is affirmatively prohibited unless an exception applies\n\nTitle 17, §701 states that a person, firm, association, or corporation may not engage in budget planning for a consumer except for:\n\n- the grandfathered attorney category;\n- a supervised financial organization;\n- a supervised lender; or\n- an organization registered as a debt-management-service provider.\n\n“Budget planning” is a contract under which the debtor periodically pays the provider, which distributes the money to specified creditors under an agreed plan. [C004] [Maine State Legislature+1](https://www.legislature.maine.gov/statutes/17/title17sec701.html)\n\nAccordingly, a regulator webpage describing how to register does **not** transform unregistered budget planning into generally permissible activity. Registration is the statutory exception to the prohibition.\n\n### 2.3 Debt settlement and noncustodial services\n\nDebt settlement and noncustodial payment-arrangement services fall within chapter 80-A even when they are not “budget planning” under Title 17. Chapter 80-A’s mandatory registration language and enforcement provisions govern them. Registration is a conditional authorization to perform covered debt-management services; it is not a license to collect debts, lend money, purchase consumer debt, or take security interests. [C005–C007, C034] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 2.4 Nonprofit status\n\nMaine’s original 2000 law permitted only qualifying §501(c)(3) organizations to register. Public Law 2007, chapter 36 repealed that restriction and expressly allocated funds for the additional costs of permitting for-profit companies to obtain registrations. The amendment became effective September 20, 2007. Current §6173 contains no nonprofit-only condition. [C008] [Maine Legislature+1](https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm)\n\nTherefore:\n\n- a for-profit provider is not prohibited merely because it is for-profit;\n- a nonprofit provider is not exempt merely because it is nonprofit;\n- either must satisfy the current registration regime unless a different statutory exclusion applies.\n\n### 2.5 Attorney exclusion\n\nThe attorney language is unusually narrow. It excludes only:\n\na person admitted to practice law in Maine **as of the chapter’s effective date**, except to the extent debt-management services constitute that attorney’s exclusive activity.\n\nThe chapter took effect March 15, 2000. The text does not create a general exemption for:\n\n- lawyers admitted after March 15, 2000;\n- an out-of-state attorney;\n- a law firm merely employing or partnering with a Maine attorney;\n- a nonlawyer debt-settlement company operating under an attorney’s name;\n- an attorney whose exclusive activity is debt management.\n\nThe Granite Law administrative matter is a historical indication that the Bureau did not accept a mere Maine-attorney connection as sufficient, but the full official order was inaccessible in this session and it is not controlling appellate precedent. [C009] [Maine Legislature+2](https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm)\n\n### 2.6 Financial-institution and lender exclusions\n\nA “supervised financial organization” is a defined financial institution or specified supervised entity authorized to make loans and receive deposits, or a qualifying limited-purpose institution. A “supervised lender” is a person authorized to make, take assignments of, or service supervised loans under the Maine Consumer Credit Code or as a supervised financial organization. [C010] [Maine State Legislature](https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html)\n\nThese are entity-status exclusions. A parent, affiliate, vendor, lead generator, or separately incorporated settlement provider should not be assumed to inherit the exclusion from a bank or lender merely through a contract or common ownership.\n\n### 2.7 Self-creditor activity\n\nMaine does not provide an express “creditor collecting or modifying its own debt” exclusion in chapter 80-A. Paragraph (D)’s requirement that the provider act as an **intermediary** normally points away from a creditor dealing directly with its own borrower. But a creditor affiliate, separate servicing entity, common payment pool, or third-party fee-taker could implicate paragraphs (A) through (C). [C011]\n\n**Result:** self-creditor treatment is a held issue. It should not be represented as a verified exemption without facts and an interpretive source.\n\n### 2.8 Other prohibited combinations\n\nA debt-management-service provider may not:\n\n- purchase a consumer’s debt;\n- lend money or provide credit to the consumer;\n- obtain a mortgage or other security interest in consumer property;\n- operate as a debt collector in Maine; or\n- design an agreement that produces negative amortization at the end of the projected term.\n\nThese provisions are market-boundary rules, not a complete collection or secured-debt analysis. [C034] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n## 3. Legally applicable consumer-fee structures\n\n### 3.1 Current fee table\n\n| Fee | Current Maine ceiling | Eligible activity/base | Important conditions |\n| --- | --- | --- | --- |\n| Initial or setup fee | **$75 once** | A covered debt-management provider | Must be reasonable; statute does not state that it may be collected before performance |\n| Monthly service fee | **$40 per month** | Provider **that distributes monthly payments** to creditor(s) | Alternative to the settlement-fee track; reasonableness remains independently required |\n| Settlement or term-alteration fee | **15% of debt reduction per settlement** | Amount by which the consumer’s debt is reduced as part of each settlement | Not enrolled debt, original balance, deposited funds, or projected savings |\n| Approved consumer-education-program fee | **$50** | An administrator-approved consumer education program actually offered by the provider | Must be reasonable; program submission and approval requirements apply |\n| Duplicate fee for joint household obligations | **Prohibited** | Joint debts of consumer and spouse/household member | Provider may not multiply the §6174-A fees merely because obligations are joint |\n\nThe current consolidated chapter, generated October 5, 2026 and current through October 1, 2026, carries the same consumer-fee figures enacted in 2007. The section history identifies no later amendment to §6174-A, and the statute contains no indexing or annual-adjustment clause. [C013–C019] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 3.2 “Reasonable” is an independent limitation\n\nEach consumer fee is described as **reasonable** and then assigned a maximum. Charging the maximum is not automatically lawful merely because the arithmetic falls at or below the ceiling. The provider must still have an applicable service, agreement, registration, and lawful timing basis. [C035] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 3.3 Alternative service-fee tracks\n\nSection 6174-A(2) says the provider may assess **“either”** the monthly-distribution fee **or** the settlement/reduction fee. The stronger textual reading is that these are alternative compensation tracks for the relevant consumer service, not cumulative monthly-plus-settlement compensation for the same program. [C017] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nThere is no controlling Maine appellate interpretation located in this pass. A hybrid model should therefore not stack the $40 and 15% fees for the same consumer without a specific legal basis and regulator/counsel confirmation.\n\n### 3.4 Settlement-fee base\n\nThe Maine base is:\n\nactual debt before the settlement − debt remaining/payable under the settlement\n\nThe ceiling is:\n\n15% × actual debt reduction\n\nMaine does **not** say the fee is 15% of:\n\n- total enrolled debt;\n- original portfolio balance;\n- monthly savings-account contributions;\n- the settlement payment;\n- estimated future interest avoided;\n- the consumer’s total program savings; or\n- the amount paid to a dedicated account.\n\n[C015] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 3.5 Partial settlements and multiple debts\n\nThe statute applies the 15% calculation to the amount reduced “as part of **each settlement**.” Therefore:\n\n- a partial reduction can create a fee base even when the debt is not fully extinguished;\n- each separately settled debt has its own reduction and cap;\n- a fee already charged for Debt A does not enlarge the reduction base for Debt B;\n- there is no separate lifetime dollar cap in the statute, but the sum of settlement fees remains bounded by the reduction calculations and reasonableness.\n\n[C015] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 3.6 Interest, waived fees, and prospective concessions\n\nMaine does not define whether “debt” for §6174-A(2)(B) includes:\n\n- accrued interest already included in the legal balance;\n- contingent collection charges;\n- late fees;\n- future interest that has not yet accrued;\n- savings produced only if a consumer completes a long payment plan.\n\nA settlement forgiving presently owed principal, accrued interest, or posted fees may create a measurable reduction. A prospective APR decrease with unchanged present balance does not clearly create a present “amount by which debt is reduced.” [C032]\n\n**Held conclusion:** no fee should be modeled on projected future-interest savings as though Maine expressly authorized it.\n\n### 3.7 Noncustodial arranger with no reduction\n\nParagraph §6172(2)(B) can cover a provider that merely arranges payment distributions, but §6174-A(2)(A) describes the $40 fee for a provider **that distributes monthly payments**. If the provider neither distributes payments nor achieves a measurable debt reduction:\n\n- coverage may still exist;\n- the $75 setup ceiling may be relevant under state law;\n- no recurring $40 or 15% compensation pathway was verified;\n- if the TSR applies and no debt was altered and paid, even the setup fee cannot yet be requested or received.\n\n[C031] [Maine State Legislature+2](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 3.8 Creditor-paid and third-party compensation\n\nProvider status is triggered by a “fee or other consideration,” without saying the consideration must come from the consumer. By contrast, §6174-A is drafted around charges to the consumer. [C003, C033] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nThis pass did **not** establish whether creditor “fair-share” payments, grants, referral compensation, affiliate revenue, or lead fees:\n\n- count against consumer fee caps;\n- are independently permitted;\n- create conflicts or disclosure duties;\n- cause a referral entity itself to become a provider.\n\nSilence in the consumer-fee section is not affirmative permission.\n\n### 3.9 Refunds and credits\n\nThe agreement must state that either party may cancel by written notice. The chapter text reviewed does not supply a universal pro-rata fee-refund formula, a fixed refund deadline, or an express rule declaring when each type of fee becomes nonrefundable. [C021, C037] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nThat is distinct from:\n\n- consumer funds held for creditors, which remain subject to statutory trust-account rules;\n- unlawful or unearned fees that an agency or court may order refunded;\n- federal dedicated-account funds, which may have to be returned within seven business days after withdrawal when the TSR applies.\n\n## 4. When fees may be requested or received\n\n### 4.1 Maine law by itself\n\n| Fee | What Maine expressly says | What Maine does not expressly say |\n| --- | --- | --- |\n| $75 setup | Provider may charge a reasonable one-time initial/setup fee | No specific collection date; no express advance-fee authorization |\n| $40 monthly | Provider that distributes monthly payments may assess a reasonable monthly fee | No exact day of month; no explicit treatment of a month in which no distribution occurs |\n| 15% settlement | Fee may not exceed 15% of actual debt reduction as part of each settlement | No standalone request/receipt event; no explicit treatment of failed or rescinded settlements |\n| $50 education | Reasonable fee for an approved program | No express payment date or blanket refund formula |\n\nMaine also requires the provider and consumer to execute a written agreement **before the provider performs debt-management services**. The agreement must describe services and fees and include the provider’s registration number and a written-cancellation right. That performance prerequisite does not itself answer when money may be collected. [C020–C021] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 4.2 Federal TSR overlay when applicable\n\nThe federal rule defines a debt-relief service as a program represented to renegotiate, settle, or otherwise alter terms of unsecured debt, including balance, interest-rate, or fee reductions. “Telemarketing” generally requires a campaign involving more than one interstate telephone call. Calls initiated by consumers in response to general or direct-mail debt-relief advertising are specifically excluded from the ordinary inbound-call exemptions, so “the customer called us” does not by itself avoid the rule. [C023] [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\nFor a covered debt-relief service, the seller or telemarketer may not request or receive **any fee or consideration** until:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid agreement executed by the customer; and\n2. the customer has made at least one payment under the agreement between the customer and creditor or debt collector.\n\nWhen debts are handled individually, the provider must then use one of the federal individual-debt allocation methods. Under the savings method, the percentage charged cannot change from one debt to another. [C024] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nConsequently, when the TSR applies:\n\n- Maine’s $75 ceiling does not authorize collecting $75 at enrollment;\n- relabeling the fee as “setup,” “legal,” “membership,” or “monthly” does not avoid the federal timing rule when it remains consideration for the debt-relief service;\n- a genuinely optional and separate education product would require its own analysis;\n- the federal rule cannot raise Maine’s lower fee ceiling.\n\nThe TSR is not necessarily applicable to every provider or transaction. Purely online programs without a covered telephone campaign, secured debts, exempt entities, and FTC-jurisdiction questions require separate analysis.\n\n### 4.3 Dedicated accounts under the TSR\n\nThe TSR permits the consumer to place money in an account before a fee is earned only if, among other things:\n\n- the account is at an insured financial institution;\n- the consumer owns the funds and receives any accrued interest;\n- the administrator is not owned, controlled by, or affiliated with the debt-relief service;\n- the administrator does not pay or accept referral compensation involving the debt-relief service; and\n- the consumer can withdraw without penalty and receive all unearned funds within seven business days after requesting withdrawal.\n\n[C025] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThat federal dedicated account is analytically distinct from Maine’s trust-account requirements for money received for payment to creditors.\n\n### 4.4 Maine creditor-payment funds\n\nWhen a Maine debt-management provider receives consumer funds for payment to creditors, it must:\n\n- deposit them within two business days in a federally insured trust account for the consumer’s benefit;\n- maintain separate consumer records;\n- remit them to creditors within 15 business days;\n- avoid commingling with operating accounts; and\n- correct provider-caused misdirected payments and reimburse resulting actual creditor costs or fees.\n\n[C022] [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\nThose creditor-payment funds are not provider fees and should not be included in fee calculations.\n\n## 5. Regulator permission, registration procedure, and public lookup\n\n### 5.1 Regulator and legal authority\n\nThe administrator is the Superintendent of Consumer Credit Protection within Maine’s Department of Professional and Financial Regulation, operating through the Bureau of Consumer Credit Protection. Chapter 80-A supplies the registration authority; Rule 706 implements NMLS filing, fees, and application requirements. [C007, C026–C029] [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 5.2 Current operational path\n\n| Market-access item | Current finding | Limitation |\n| --- | --- | --- |\n| Filing platform | All current applications are directed through NMLS | The official BCCP page was discoverable but returned 403 when opened in this session |\n| Company application fee | $500 | NMLS processing charges are additional |\n| Branch application fee | $250 per branch | Separate registration for each place of business |\n| Company renewal | $250 | Late renewal adds $100 under the rule/statute |\n| Branch renewal | $250 per branch | NMLS procedures and status control current processing |\n| Statutory maximum | Initial application no more than $800; renewal no more than $600 | These are statutory ceilings on regulator fees, not the amounts currently charged and not consumer fees |\n| Bond | $50,000 for each office/location under Rule 706 | Full bond-form and claim analysis remains a later pass |\n| Foreign entity | Maine authority to do business and Maine service-of-process agent required | Additional Secretary of State requirements may apply |\n| Background information | Resumes plus consumer and criminal background reports for specified control persons | NMLS may impose additional current system fields |\n| Consumer documents | Sample Maine contract, fee schedule, education program, periodic report | Filing these documents does not guarantee approval |\n| Referral relationships | Applicant must identify referral companies and explain relationships or affiliations | This is disclosure, not affirmative permission for every payment arrangement |\n| Approval timing | Statute requires action within 30 days after the application is accepted as complete | “Accepted as complete” is the operative starting point |\n\n[C026–C029] [Maine State Legislature+3](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### 5.3 Registration periods require current NMLS inspection\n\nRule 706 contains overlapping provisions:\n\n- §IV(2) states registrations run January 1 through December 31;\n- §IV(5)(b) says a new registration issued November 1 or later is valid through December 31 of the following year;\n- §IV(7)(b) says registrations issued after the transition are valid for periods established by NMLS.\n\nAccordingly, a provider should not infer its current expiration date from one generic rule sentence. The actual NMLS authority record and renewal status must be inspected. [C029] [Midpage+2](https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f)\n\n### 5.4 NMLS transition and electronic surety bond\n\nRule 706 required the earlier transition of registrations into NMLS beginning in 2023. Separately, the current BCCP operational page states that businesses with existing Maine registrations were required to convert their surety bonds to electronic surety bonds through NMLS by January 31, 2026. These are two different transitions and should not be conflated. [Midpage+2](https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f)\n\n### 5.5 Public authorization verification\n\nMaine’s official license-search page directs debt-management-service-provider searches to NMLS. CSBS identifies NMLS as the system of record and describes NMLS Consumer Access as a free service for confirming whether a company or professional is authorized in the relevant state. [C028] [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/license_search.htm)\n\nA defensible provider-status check should use:\n\n- exact legal entity name;\n- every DBA used with consumers;\n- NMLS ID;\n- Maine authority type;\n- current approved/active status;\n- issue and expiration dates;\n- branch/location authority where applicable; and\n- any public regulatory actions.\n\nNo SettleADebt.com legal entity, DBA, or named provider was checked in this pass. A website or marketing statement is not proof of registration.\n\n### 5.6 Rule status and possible future changes\n\nChapter 706 is listed in the Maine Secretary of State’s official rule inventory. Cornell’s current reproduction reports an effective date of September 2, 2023 and filing number 2023-139. The official Maine Word document could not be fetched because the state page returned 403, so the full rule text in this report was read from two matching third-party reproductions rather than from the official downloadable file. [C029] [Maine.gov+2](https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules)\n\nThe Bureau’s 2025–2026 regulatory agenda says the Bureau **may** update Rule 706 based on experience and to correct errors. An agenda statement is neither a proposed rule nor an adopted amendment. No later effective amendment was verified in the accessible sources. [C030] [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf)\n\n## 6. Worked-example conclusion\n\nThe complete examples appear in Part D. They demonstrate:\n\n- lower-balance settlement;\n- partial settlement;\n- multiple debts and a previously charged debt fee;\n- conservative cent rounding;\n- six-month DMP;\n- joint household obligations;\n- prospective interest-rate concessions;\n- cancellation;\n- a noncustodial/no-outcome model; and\n- an unregistered-provider classification hold.\n\nNo example assumes that satisfying a mathematical ceiling establishes registration, reasonableness, fee timing, or federal compliance.\n\n## 7. Immediate implementation implications for SettleADebt.com\n\nFor a conventional for-profit, telephone-assisted unsecured-debt-settlement model marketed to Maine consumers, the most defensible present working classification is:\n\n- covered intermediary service under §6172(2)(D);\n- Maine debt-management-service-provider registration required before offering or providing the service;\n- 15% of actual reduction per settlement as the relevant Maine service-fee ceiling;\n- no additional $40 monthly-distribution fee for the same settlement program;\n- $75 setup ceiling under state law, but no advance collection when the TSR applies;\n- written Maine agreement and registration number before performance;\n- approved consumer-education program and counselor-certification process;\n- NMLS company and applicable branch authority;\n- required bond and application materials; and\n- fee collection only after all independently applicable state and federal conditions are satisfied.\n\nThis is a component-level implementation conclusion, not a determination that any particular operating agreement, payment processor, attorney model, dedicated account, lead arrangement, or provider is lawful.\n\n# B. Source table\n\n| Source ID | Title / issuer | Direct literal URL | Pinpoint, version, and legal status | Actual access/check and limitations |\n| --- | --- | --- | --- | --- |\n| **S_ME-P1-S001** | Maine Revised Statutes, Title 32, Chapter 80-A, Debt Management Services — Maine Revisor of Statutes | https://legislature.maine.gov/statutes/32/title32ch80-A.pdf | §§6172–6176 and 6179; pp. 1–7. Generated Oct. 5, 2026; states current through Oct. 1, 2026. Consolidated official Revisor text, with uncertified-text disclaimer. | Freshly read parsed text and page images for relevant pages. Principal current state-law source. [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) |\n| **S_ME-P1-S002** | Title 17, §701, Business prohibited — Maine Revisor | https://www.legislature.maine.gov/statutes/17/title17sec701.html | §701(1)–(2). Current webpage extracted Oct. 5, 2026. | Fresh official read. Establishes express budget-planning prohibition and exceptions. [Maine State Legislature](https://www.legislature.maine.gov/statutes/17/title17sec701.html) |\n| **S_ME-P1-S003** | Title 17, §702, Budget planning defined — Maine Revisor | https://www.legislature.maine.gov/statutes/17/title17sec702.html | §702. Current webpage extracted Oct. 5, 2026. | Fresh official read. [Maine State Legislature](https://www.legislature.maine.gov/statutes/17/title17sec702.html) |\n| **S_ME-P1-S004** | Title 9-A, §1-301, General definitions — Maine Revisor | https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html | Subsections 38-A and 39. Current webpage extracted Oct. 5, 2026. | Fresh official read; used only for institutional exclusions. [Maine State Legislature](https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html) |\n| **S_ME-P1-S005** | Public Law 1999, chapter 560 — Maine Legislature | https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm | Original chapter enactment; emergency effective March 15, 2000. | Fresh official historical read. Establishes attorney grandfather date and original nonprofit-only architecture. [Maine Legislature](https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm) |\n| **S_ME-P1-S006** | Public Law 2007, chapter 36, An Act To Amend the Debt Management Services Laws — Maine Legislature | https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp | §§5–9, 13; effective Sept. 20, 2007. | Fresh official historical read. Repealed nonprofit restriction and enacted current consumer-fee framework. [Maine Legislature](https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp) |\n| **S_ME-P1-S007** | Department of Professional and Financial Regulation Rules — Maine Secretary of State | https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules | Official inventory listing for 02-030 C.M.R. ch. 706. | Search result freshly checked; direct page returned 403. Supports official existence/title, not the full rule wording. [Maine.gov](https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules) |\n| **S_ME-P1-S008** | 02-030 C.M.R. ch. 706, debt-management registration/NMLS rule | https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706; https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f | §§I–IV; reported effective Sept. 2, 2023, filing 2023-139. | Full matching reproductions freshly read. Not official/certified Maine-hosted text; official downloadable Word route inaccessible. [Legal Information Institute+2](https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706) |\n| **S_ME-P1-S009** | Debt Management Service Providers — Maine BCCP | https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm | Current operational registration page; search index identifies who must register and NMLS filing. | Discovery/search-index text only; direct fetch returned 403. Procedure support only, not substitute for statute/rule. [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm) |\n| **S_ME-P1-S010** | Licensee Search — Maine BCCP | https://www.maine.gov/pfr/consumercredit/license_search.htm | Current public lookup route identifying NMLS for debt-management registrations. | Search-index text read; direct fetch returned 403. No named-provider lookup performed. [Maine.gov](https://www.maine.gov/pfr/consumercredit/license_search.htm) |\n| **S_ME-P1-S011** | Electronic Surety Bonds — Maine BCCP | https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html | Operational ESB instructions; DMS providers included. | Search-index text read; direct fetch returned 403. Bond-form details not independently inspected. [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html) |\n| **S_ME-P1-S012** | Nationwide Multistate Licensing System — CSBS | https://www.csbs.org/nationwide-multistate-licensing-system-nmls | System-of-record and Consumer Access descriptions. | Fresh primary operational read; not state substantive-law authority. [CSBS](https://www.csbs.org/nationwide-multistate-licensing-system-nmls) |\n| **S_ME-P1-S013** | NMLS Licensing Checklists, Requirements, and Fees | https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx | Dynamic checklist compiler. | Route opened with no exposed checklist text. Exact current Maine generated checklist remains unverified. [Nationwide Licensing System](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx) |\n| **S_ME-P1-S014** | Legal Solutions Debt, LLC enforcement order — Maine BCCP | https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983 | Dec. 6, 2013 administrative order. | Official-page search excerpts read; direct full order inaccessible. Historical agency action, not controlling judicial precedent. [Maine.gov+2](https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983) |\n| **S_ME-P1-S015** | Granite Law California LLP enforcement order — Maine BCCP | https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984 | Historical administrative order involving attorney-connected mortgage-relief activity. | Official-page search excerpts read; direct full order inaccessible. Not relied on as a complete or controlling interpretation. [Maine.gov+2](https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984) |\n| **S_ME-P1-S016** | Telemarketing Sales Rule — eCFR, 16 CFR Part 310 | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6 | §§310.2(o), 310.2(ii), 310.4(a)(5), 310.6(b)(5)–(6). Title 16 up to date through Oct. 22, 2026. | Fresh primary federal regulatory read. eCFR is authoritative but unofficial. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_ME-P1-S017** | BCCP 2025–2026 Regulatory Agenda — Maine BCCP | https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf | Rule 706 agenda entry states Bureau may update the rule based on operational experience and to correct errors. | Search-index passage read. Full PDF route could not be opened/rendered. Agenda is planning material, not an adopted or proposed rule by itself. [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf) |\n\n# C. Material claim table\n\n| Claim ID | Precise assertion | Sources and exact pinpoint | Conditions, exceptions, currentness | Confidence |\n| --- | --- | --- | --- | --- |\n| **S_ME-P1-C001** | Maine’s DMS definition reaches receipt, arrangement, direct/indirect control, and settlement or term-alteration intermediation. | S001, §6172(2)(A)–(D), pp. 1–2. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Conduct controls; an offer to act can suffice. | High |\n| **S_ME-P1-C002** | Covered obligations are personal, family, or household debts; business/commercial debts are excluded. | S001, §6172(1-C), p. 1. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Mixed-purpose debts unresolved. | High |\n| **S_ME-P1-C003** | A provider may be located anywhere; service offered to a consumer in Maine for fee or other consideration creates statutory nexus. Maine-based outbound providers are also included. | S001, §6172(3), p. 2. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | “In this State” is not separately defined; consideration need not expressly be consumer-paid. | High on text; medium on edge nexus |\n| **S_ME-P1-C004** | Traditional custodial budget planning is prohibited unless an enumerated exception applies, including registration under chapter 80-A. | S002, §701(1)–(2); S003, §702. [Maine State Legislature+1](https://www.legislature.maine.gov/statutes/17/title17sec701.html) | Applies to periodic debtor payment followed by provider distribution under a plan. | High |\n| **S_ME-P1-C005** | Noncustodial payment-arrangement assistance can be covered. | S001, §6172(2)(B), and potentially (C). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Actual facts about control and arrangement matter. | High |\n| **S_ME-P1-C006** | Principal reduction and other payment-term modification are covered intermediary activities. | S001, §6172(2)(D). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Compensation may still lack a fee base if no debt reduction occurs. | High |\n| **S_ME-P1-C007** | Covered organizations must apply for registration; separate registration is required for each place of business; issuance is conditional on specified fitness factors. | S001, §6173(2), (2-A), (3). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Registration is not automatic upon filing. | High |\n| **S_ME-P1-C008** | Current Maine law permits for-profit registration and provides no nonprofit exemption. | S006, §§6–7 and appropriation language; effective Sept. 20, 2007. [Maine Legislature](https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp) | Other entity exclusions may still apply. | High |\n| **S_ME-P1-C009** | Attorney exclusion is limited to a person admitted in Maine as of March 15, 2000 and does not apply to the extent DMS is that attorney’s exclusive activity. | S001, §6172(3)(C); S005 effective clause. [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | No blanket law-firm, partner, or post-2000 attorney exemption. | High on text |\n| **S_ME-P1-C010** | Supervised financial organization and supervised lender exclusions depend on their Title 9-A defined status. | S001, §6172(3), (5), (6); S004, §1-301(38-A), (39). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Affiliate status is not automatically inherited. | High |\n| **S_ME-P1-C011** | Maine provides no express self-creditor exemption. | S001, §6172. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | A creditor may not fit “intermediary,” but A–C, affiliate, and payment-control facts remain unresolved. | Held / medium-low |\n| **S_ME-P1-C012** | §§6174-A and 6174-B do not apply to a Maine-located provider serving no Maine resident. | S001, §§6174-A(4), 6174-B(3). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Registration definition still reaches Maine-based outbound activity; destination-state law remains. | High |\n| **S_ME-P1-C013** | Initial/setup fee must be reasonable and no more than $75 once. | S001, §6174-A(1). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Does not establish advance collection date. | High |\n| **S_ME-P1-C014** | Monthly fee must be reasonable, no more than $40, and applies to a provider that distributes monthly creditor payments. | S001, §6174-A(2)(A). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Exact monthly earning date not stated. | High |\n| **S_ME-P1-C015** | Settlement fee must be reasonable and no more than 15% of actual debt reduction as part of each settlement. | S001, §6174-A(2)(B). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Composition of “debt” and failed-settlement treatment not fully defined. | High on formula |\n| **S_ME-P1-C016** | Covered providers must offer an approved education program and may charge a reasonable fee up to $50; counselor certification evidence is due within 12 months of initial employment. | S001, §6174-B(1)–(2). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Maine-outbound-only carveout applies. | High |\n| **S_ME-P1-C017** | Monthly-distribution and settlement fees are alternative service-fee tracks. | S001, §6174-A(2), “either … or.” [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | No controlling opinion located; hybrid arrangements need confirmation. | Medium-high |\n| **S_ME-P1-C018** | Fees may not be duplicated merely because obligations are joint with a spouse or household member. | S001, §6174-A(3). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Applies to fees authorized under §6174-A(1)–(2). | High |\n| **S_ME-P1-C019** | The current consumer-fee amounts are unchanged from the 2007 enactment and have no statutory indexing provision. | S001, §6174-A and section history; S006, §8. [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Current consolidated text through Oct. 1, 2026. | High |\n| **S_ME-P1-C020** | Maine does not expressly state a collection date for the setup, monthly, or education fee; the settlement formula is outcome-dependent but lacks a separate request/receipt rule. | S001, §§6174-A, 6174-B. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Absence in chapter text is not advance-fee permission. | High on textual absence; medium overall |\n| **S_ME-P1-C021** | Written agreement must precede performance and disclose services, fees, registration number, and written-cancellation right. | S001, §6176(1)–(2)(A), (B), (E). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Full contract-law and electronic-signature analysis remains open. | High |\n| **S_ME-P1-C022** | Creditor-payment funds must be deposited within two business days, separately recorded, remitted within 15 business days, and not commingled. | S001, §6175. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Applies to funds received for creditor payment, not necessarily noncustodial models. | High |\n| **S_ME-P1-C023** | TSR debt-relief coverage includes unsecured debt term alteration; covered telemarketing generally involves more than one interstate call, and inbound debt-relief ad responses are not within ordinary inbound exemptions. | S016, §§310.2(o), 310.2(ii), 310.6(b)(5)–(6). [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310) | Entity and jurisdictional exclusions not completed here. | High |\n| **S_ME-P1-C024** | Under covered TSR activity, no debt-relief fee may be requested or received until one debt is altered under an executed agreement and the customer makes one payment under that creditor agreement. | S016, §310.4(a)(5)(i)(A)–(C). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | Federal rule does not increase Maine fee ceilings. | High |\n| **S_ME-P1-C025** | TSR dedicated accounts require insured institution, consumer ownership, independent administration, no referral compensation, free withdrawal, and return of unearned funds within seven business days. | S016, §310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | Only when TSR applies and account is used. | High |\n| **S_ME-P1-C026** | Statute permits regulator initial fees up to $800, renewal up to $600, NMLS processing fees, and $100 late fee; Rule 706 currently sets lower state fees. | S001, §6173(2-B)(B); S008, §IV(4)–(5). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | These are provider application fees, not consumer charges. | High |\n| **S_ME-P1-C027** | Rule 706 sets company application $500, branch application $250, and company/branch renewal $250. | S008, §IV(4)(e), (5)(c). [Midpage](https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f) | NMLS fees additional; possible future rule update not adopted in sources read. | High subject to official-text gap |\n| **S_ME-P1-C028** | NMLS is the current filing/system-of-record route, and Consumer Access is the public authorization-check route. | S009–S012. [Maine.gov+2](https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm) | No named provider checked. | High operationally |\n| **S_ME-P1-C029** | Rule 706 is reported effective Sept. 2, 2023; its text contains overlapping registration-period provisions. | S008, note and §IV(2), (5)(b), (7)(b). [Legal Information Institute+2](https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706) | Official Maine downloadable text inaccessible; use live NMLS status. | Medium-high |\n| **S_ME-P1-C030** | The 2025–2026 agenda’s “may update” statement is not an effective or proposed amendment by itself. | S017. [Maine.gov+1](https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf) | Full agenda PDF was inaccessible. | High on legal-status distinction |\n| **S_ME-P1-C031** | A noncustodial arranger that neither distributes monthly payments nor achieves debt reduction lacks a verified recurring Maine fee pathway. | S001, §§6172(2)(B), 6174-A(2). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Setup fee and federal timing still require separate treatment. | Medium-high |\n| **S_ME-P1-C032** | A prospective rate reduction with no present balance reduction has no clearly verified Maine settlement-fee base. | S001, §6174-A(2)(B). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Accrued-interest and fee forgiveness remain unresolved. | Held / medium |\n| **S_ME-P1-C033** | Provider coverage may be triggered by “other consideration,” but chapter 80-A does not clearly resolve creditor-paid or referral compensation. | S001, §§6172(3), 6174-A; S008, §IV(6)(q). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | No affirmative permission inferred. | Held |\n| **S_ME-P1-C034** | A debt-management provider may not purchase debt, lend, take security, operate as debt collector, or structure negative amortization. | S001, §6179. [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Full collection and secured-debt treatment remains open. | High |\n| **S_ME-P1-C035** | Each enumerated consumer fee remains independently subject to reasonableness. | S001, §§6174-A(1), (2), 6174-B(2). [Maine State Legislature](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Maximum is not automatic entitlement. | High |\n| **S_ME-P1-C036** | Statute/rule wording is not perfectly aligned for natural persons: statute says organization applies; rule contemplates sole proprietors and individuals. | S001, §§6172(4), 6173(2); S008, §IV(6)(a), (c), (h). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Operational route exists; controlling construction not located. | Medium |\n| **S_ME-P1-C037** | No general chapter-80-A pro-rata refund formula or fee-refund deadline was found; cancellation, creditor funds, unlawful fees, and TSR funds are separate questions. | S001, §§6175–6176; S016, §310.4(a)(5)(ii)(E). [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf) | Negative finding limited to sources and scope actually read. | Medium |\n\n# D. Worked examples and scope coverage\n\n## D1. Plain-text worked examples\n\nAll examples assume a Maine-resident consumer, a properly registered provider, a personal/family/household unsecured obligation, an executed written agreement, a reasonable fee, and no other legal bar. They show arithmetic ceilings—not automatic earning or collection authority. The Maine formula is from §6174-A; federal timing is separately controlled by 16 CFR 310.4(a)(5) when applicable. [Maine State Legislature+1](https://legislature.maine.gov/statutes/32/title32ch80-A.pdf)\n\n### Example 1 — Ordinary settlement\n\nPlain text\n```\nDebt immediately before settlement:       $10,000.00\nAmount remaining/payable in settlement:     7,000.00\nDebt reduction:                           $10,000.00 - $7,000.00\nDebt reduction:                            $3,000.00\n\nMaine percentage ceiling:                         15%\nMaximum settlement fee:                   $3,000.00 × 0.15\nMaximum settlement fee:                     $450.00\n```\n\nA separate setup fee could have a state arithmetic ceiling of $75, and an actually provided approved education program could have a separate $50 ceiling. Neither figure is automatically collectible at enrollment. Under the covered TSR, the settlement-fee timing conditions must occur first.\n\n### Example 2 — Lower-balance debt\n\nPlain text\n```\nDebt before settlement:                     $300.00\nSettlement amount:                          $240.00\nReduction:                                   $60.00\n\nMaximum Maine settlement fee:\n$60.00 × 15% =                                $9.00\n```\n\nThe fact that the maximum fee is small does not permit replacing it with a flat per-debt minimum.\n\n### Example 3 — Partial reduction without full discharge\n\nPlain text\n```\nDebt before modification:                $10,000.00\nDebt remaining after binding settlement:   8,000.00\nReduction:                                 2,000.00\n\nMaximum Maine settlement fee:\n$2,000.00 × 15% =                            $300.00\n```\n\nThis assumes the transaction legally constitutes a settlement reducing the debt by $2,000. A temporary payment pause or merely projected future savings does not establish that base.\n\n### Example 4 — Two debts and a previously assessed fee\n\nPlain text\n```\nDebt A:\nEnrolled/owed amount:                      $8,000.00\nSettlement amount:                          5,000.00\nReduction:                                  3,000.00\nMaximum fee:                              $3,000 × 15% = $450.00\n\nDebt B:\nEnrolled/owed amount:                      $4,000.00\nSettlement amount:                          3,700.00\nReduction:                                    300.00\nMaximum fee:                                $300 × 15% =  $45.00\n\nCombined reductions:                       $3,300.00\nCombined Maine settlement-fee ceiling:       $495.00\n```\n\nThe $450 already attributable to Debt A does not increase or decrease Debt B’s Maine reduction base. If the federal savings method is used, the percentage cannot change from one individually resolved debt to another.\n\n### Example 5 — Conservative cent rounding\n\nPlain text\n```\nVerified debt reduction:                  $1,234.57\nExact 15% product:                        $1,234.57 × 0.15\nExact product:                              $185.1855\n```\n\nMaine supplies no rounding rule. The conservative whole-cent amount that does not exceed the exact ceiling is **$185.18**. Rounding to $185.19 would exceed the mathematical 15% ceiling by $0.0045.\n\n### Example 6 — Six-month custodial DMP\n\nPlain text\n```\nOne-time setup ceiling:                      $75.00\nSix monthly fees:                     6 × $40.00\nSix monthly fees:                           $240.00\n\nState arithmetic total:\n$75.00 + $240.00 =                          $315.00\n```\n\nThis assumes the provider actually distributes monthly creditor payments and a $40 fee is reasonable for every month. An approved education program could add no more than $50 if actually provided, producing a theoretical state arithmetic total of $365. The TSR may still delay the setup and service fees if the program is a covered telemarketing debt-relief service.\n\n### Example 7 — Joint obligations of spouses\n\nPlain text\n```\nOne setup fee:                               $75.00\nSix monthly fees:                           $240.00\nMaximum arithmetic total:                   $315.00\n```\n\nThe provider may not double the total to $630 merely because the agreement covers joint debts of both spouses.\n\n### Example 8 — Interest-rate reduction only\n\nPlain text\n```\nPresent debt balance before agreement:     $8,000.00\nPresent debt balance after agreement:      $8,000.00\nAPR before agreement:                            24%\nAPR after agreement:                              8%\nAccrued interest or fees expressly waived:       $0\nPresent verified debt reduction:             $0.00\n```\n\nThe service is covered term-alteration activity, but the current Maine 15% base is not established by projected future interest avoidance. The conservative present fee calculation is:\n\nPlain text\n```\n$0.00 × 15% = $0.00\n```\n\nA different result requires authority defining future avoided interest as “debt reduced.”\n\n### Example 9 — Cancellation after two actual DMP months\n\nPlain text\n```\nSetup ceiling:                               $75.00\nTwo monthly fees:                      2 × $40.00\nTwo monthly fees:                            $80.00\nState arithmetic ceiling to date:           $155.00\nFuture monthly fees after cancellation:       $0.00\n```\n\nThis does **not** conclude that the $155 was earned or nonrefundable. Maine requires a written-cancellation right but does not supply a universal pro-rata refund rule in the chapter text reviewed. Unsent creditor funds remain separate trust funds. If a TSR-compliant dedicated account is involved, unearned account funds are subject to the federal seven-business-day return rule.\n\n### Example 10 — Noncustodial arranger, no distribution and no result\n\nPlain text\n```\nMonthly creditor payments distributed by provider:   none\nExecuted settlements reducing debt:                  none\nVerified debt reduction:                             $0.00\n```\n\nState classification may still exist under §6172(2)(B) or (D), but:\n\nPlain text\n```\nVerified monthly-distribution fee pathway:           none\nVerified settlement-fee base:                        $0.00\nState setup-fee ceiling:                              $75.00\n```\n\nIf the TSR applies, no fee can yet be requested or received because no debt was altered and no first creditor payment occurred.\n\n### Example 11 — Covered but unregistered provider\n\nPlain text\n```\nConsumer debt:                             $20,000.00\nProposed settlement reduction:              8,000.00\nArithmetic 15% figure:                      1,200.00\nMaine registration status:                 not established\n```\n\nThe $1,200 calculation does not create a lawful fee pathway. An unregistered covered provider cannot use the fee ceiling as permission to operate.\n\n## D2. Component coverage and gap table\n\n| Topic | Pass status | Claim IDs | Exact remaining evidence / next investigation |\n| --- | --- | --- | --- |\n| Four-part DMS definition | **Answered** | C001 | Apply to final operating facts and contracts in a later implementation pass |\n| Consumer versus business purpose | **Answered at statutory level** | C002 | Mixed-purpose debt, personal guarantees, and use changes need cases/guidance |\n| Custodial DMP / budget planning | **Answered** | C004, C022 | Full trust-account audit, reports, examinations, and remedies remain open |\n| Noncustodial payment arrangement | **Answered on coverage; partial on fees** | C005, C031 | Obtain Maine interpretation of “distributes monthly payments” |\n| Principal-reduction settlement | **Answered** | C006, C015 | Agreement-specific fee trigger and rescinded-settlement treatment remain open |\n| Interest and term concessions | **Partial** | C006, C032 | Need authoritative definition of “debt reduced,” especially future interest |\n| Remote provider nexus | **Partial** | C003 | Determine meaning of “consumer in this State” versus resident, domicile, and physical presence |\n| Maine outbound-only provider | **Answered on express carveout; partial on reach** | C012 | Determine transaction-by-transaction effect if provider serves both Maine and non-Maine consumers |\n| Registration requirement | **Answered for organizations** | C007 | Resolve natural-person/sole-proprietor wording tension through agency interpretation or case law |\n| For-profit/nonprofit status | **Answered** | C008 | Federal nonprofit/FTC status remains separate |\n| Attorney exclusion | **Answered textually; application partial** | C009 | Full Granite Law order, later agency interpretations, firm/entity treatment, and current-good-standing question |\n| Financial institution/lender exclusions | **Answered textually** | C010 | Entity-by-entity authority and affiliate separateness must be verified |\n| Self-creditor treatment | **Unresolved** | C011 | Search formal advisory rulings and cases; analyze creditor/affiliate facts |\n| Setup fee | **Ceiling answered; timing partial** | C013, C020, C024 | Maine earning/refund interpretation and federal coverage |\n| Monthly fee | **Ceiling answered; trigger partial** | C014, C020, C031 | Determine fee treatment for skipped months, partial distributions, and third-party processors |\n| Settlement fee | **Formula answered; components partial** | C015, C032 | Accrued interest, posted fees, failed settlements, and prospective savings |\n| Education fee | **Ceiling answered; timing partial** | C016, C020 | Obtain approved-program standards and separate/bundled federal treatment |\n| Fee-track stacking | **Textual answer; no controlling opinion** | C017 | Seek written agency interpretation or controlling authority |\n| Joint obligations | **Answered** | C018 | Reenrollment and successive agreements not studied |\n| Indexing/current amounts | **Answered through Oct. 1, 2026 consolidated statute** | C019 | Monitor later session-law changes; no invented CPI amount |\n| Creditor-paid/fair-share/referral compensation | **Unresolved** | C033 | Formal guidance, examination manuals, and enforcement decisions |\n| State fee collection timing | **Partial** | C020–C021 | Search additional administrative orders and cases for earning/refund rules |\n| Federal TSR timing | **Answered as common context** | C023–C025 | Provider-specific jurisdiction, entity exclusions, and call-flow audit remain open |\n| Current NMLS process | **Answered operationally** | C026–C029 | Generate and read current Maine checklist from NMLS; inspect live application fields |\n| Current company/branch fees | **Answered subject to official-rule-text limitation** | C026–C027 | Confirm current generated NMLS fee chart at filing |\n| Registration periods | **Partial due rule overlap** | C029 | Rely on live NMLS authority dates; seek BCCP interpretation |\n| Current public lookup | **Answered procedurally** | C028 | Check exact legal entity/DBA/NMLS ID when supplied |\n| Electronic surety bond | **Partially answered** | C027–C029 | Read current bond form, cancellation notice, claims, and replacement rules |\n| Rule 706 official text | **Partial** | C029 | Retrieve official Word/adoption filing through an accessible public route |\n| Possible rule update | **Unresolved—not effective law** | C030 | Check Maine rulemaking notices and adopted-rule filings after agenda entry |\n| Controlling court interpretation | **Unresolved** | — | Full citator, Maine Superior Court dockets, Law Court opinions, and federal Maine cases |\n| Cancellation/refund | **Partial** | C021, C025, C037 | State fee refund, credit, chargeback, termination, and failed-settlement rules |\n| Lead generator/marketing platform | **Partial** | C001, C003, C033 | Analyze representations, agency, intake, transfer, compensation, and referrals |\n| Debt collector overlap | **Boundary answered only** | C034 | Full Title 32 collection licensing and litigation pass remains open |\n| Residential mortgage/secured debt | **Excluded from this pass** | — | §6183 and all mortgage-relief-specific conditions require a separate pass |\n| Full agreement requirements | **Only provisions needed for fee timing covered** | C021 | Electronic consent, signatures, disclosures, modification, assignment, governing law |\n| Full funds/account regime | **Only core timing covered** | C022, C025 | Audits, account title, processor roles, insolvency, reconciliation, reporting |\n| Bond and remedies | **Only access gate mentioned** | C027 | Bond claims, penalties, private actions, restitution, limitations, administrative procedure |\n| Collection, litigation, limitation periods | **Open** | — | Separate component required |\n| Sector, local, tribal, contract, and preemption issues | **Open** | — | Separate component required |\n| Whole-state/A066 acceptance | **Expressly not reached** | — | All remaining Maine components and coordinator review required |\n\n# E. Researcher self-check\n\n### Actually read\n\n- The current Maine chapter 80-A PDF, including definitions, registration, consumer fees, education, handling of funds, written agreements, prohibited activities, and current-through date.\n- Current official Maine webpages for Title 17 §§701–702 and Title 9-A §1-301.\n- The official 1999 and 2007 Maine session laws.\n- Two matching full reproductions of Rule 706 and its reported effective-date metadata.\n- Current eCFR provisions for TSR definitions, fee timing, dedicated accounts, telemarketing definition, and inbound-call exceptions.\n- Current public-search descriptions of Maine’s NMLS filing and public-lookup routes.\n- Search-index passages from the two historical Maine administrative orders.\n\n### Not fully read or not independently verified\n\n- The official Maine-hosted Word copy of Rule 706: official rule-list page returned 403.\n- A separate official Rule 706 adoption order beyond filing/effective-date metadata.\n- The complete BCCP debt-management licensing, license-search, and ESB webpages: direct fetches returned 403.\n- The dynamically generated Maine NMLS checklist: compiler exposed no checklist text.\n- The full 2025–2026 regulatory-agenda PDF: search passages were available, but the PDF could not be opened/rendered.\n- The full Legal Solutions Debt and Granite Law orders: only official-page indexed passages were available.\n- A comprehensive paid citator or all Maine trial-court dockets.\n- Any named provider’s current registration status.\n- Private analytics, borrower records, contracts, payment files, or internal regulator systems.\n\n### Judicial search boundary\n\nTargeted public searches for Maine appellate opinions using “Debt Management Services Act,” “32 M.R.S. §6174-A,” “debt management service provider,” and related terms did not locate a controlling interpretation of the material fee provisions. That is a bounded search result, not a representation that no such trial-level, unpublished, federal, or otherwise unindexed decision exists.\n\n### Arithmetic and process controls\n\n- Worked calculations use the literal statutory bases and exact decimal arithmetic.\n- No CPI adjustment was invented because no consumer-fee indexing mechanism was found.\n- Regulator application fees were kept separate from consumer charges.\n- State fee ceilings were kept separate from federal fee timing.\n- Creditor-payment trust funds were kept separate from provider fees and TSR dedicated-account funds.\n- Historical agency enforcement was not represented as controlling court precedent.\n- Search snippets were used only where the underlying official route was inaccessible and were identified as such.\n- No Chrome control, new browser tabs, other chats, Deep Research, Work, APIs, purchases, CAPTCHA workarounds, account or permission changes, contacts, applications, private borrower data, local writes, or publication actions were used.\n- This report is not labeled an independent review and is not represented as publication-ready legal advice.\n\n**END S_ME PASS-01**\n\n","tables":[{"headers":["Activity","Statutory classification","Practical consequence"],"index":0,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Activity","Statutory classification","Practical consequence"],["Receiving consumer money to distribute to one or more creditors","§6172(2)(A)","Covers traditional custodial debt-management plans."],["Arranging or assisting the consumer to arrange creditor distributions","§6172(2)(B)","Custody is not required. A provider cannot avoid coverage merely by having the consumer, processor, or account administrator transmit payments."],["Directly or indirectly controlling, or arranging control over, consumer funds for creditor payments","§6172(2)(C)","Reaches functional control and arranged control, not only possession of a check or bank account."],["Acting or offering to act as intermediary to adjust, settle, discharge, compromise, or otherwise alter payment terms","§6172(2)(D)","Covers principal-reduction settlement, payment concessions, and other negotiated term alterations."]]},{"headers":["Business model","Maine classification","Registration/access conclusion","Fee-path conclusion"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Maine classification","Registration/access conclusion","Fee-path conclusion"],["Custodial DMP: provider receives periodic consumer payments and remits them to creditors","§6172(2)(A) and usually (C); also “budget planning” under Title 17, §702","Explicitly prohibited under Title 17, §701 unless registered or within a narrow exclusion","Up to $75 setup plus the alternative §6174-A(2)(A) monthly fee, capped at $40, assuming actual monthly distributions and reasonableness"],["Noncustodial DMP: provider negotiates concessions and arranges consumer or third-party payment delivery","§6172(2)(B), potentially (C) and (D)","Registration still required; lack of custody does not defeat coverage","A recurring $40 fee is not clearly established unless the provider “distributes monthly payments”; if there is no debt reduction, the 15% base is also absent"],["Principal-reduction settlement: provider negotiates a creditor’s acceptance of less than the debt","§6172(2)(D)","Registration required","Up to 15% of actual debt reduction as part of each settlement, not 15% of enrolled debt"],["Interest-rate, fee, payment-date, or term concession","§6172(2)(D), because “otherwise altering the terms of payment” is broad","Registration required even if principal is not reduced","Coverage and compensation are separate. If no present debt reduction exists, the Maine 15% base is unresolved and may be zero"],["Pure financial education with no A–D activity and no fee or other consideration","Likely outside chapter 80-A","This is a textual inference, not an express education exemption","Once education is offered by a covered provider, §6174-B requires an approved program and caps the consumer program fee at $50"],["Commercial/business-debt program","Outside the defined “consumer’s obligation”","Chapter 80-A does not cover the obligation merely because an individual guarantees it; exact mixed-purpose treatment remains for later research","No chapter 80-A fee conclusion; other Maine law remains open"],["Creditor negotiating its own debt","No express self-creditor exemption","Paragraph (D)’s “intermediary” wording ordinarily does not fit the creditor itself, but paragraphs (A)–(C), affiliate structures, or third-party fee arrangements could change the result","Held; do not rely on an assumed self-creditor exemption"],["Lead generator or referral site","Fact-dependent","Merely publishing neutral information differs from offering the service as one’s own. Representations, compensation, intake, matching, control, and agency relationships matter","Referral compensation is not affirmatively approved by the consumer-fee provisions; the registration rule requires disclosure of referral relationships"],["Debt collector offering settlement to collect another’s debt","Collection law and DMS functions may overlap factually","A registered debt-management provider is affirmatively prohibited from operating as a debt collector; registration does not authorize collection activity","Collection compensation and creditor-side recovery remain outside this pass"]]},{"headers":["Fee","Current Maine ceiling","Eligible activity/base","Important conditions"],"index":2,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Fee","Current Maine ceiling","Eligible activity/base","Important conditions"],["Initial or setup fee","$75 once","A covered debt-management provider","Must be reasonable; statute does not state that it may be collected before performance"],["Monthly service fee","$40 per month","Provider that distributes monthly payments to creditor(s)","Alternative to the settlement-fee track; reasonableness remains independently required"],["Settlement or term-alteration fee","15% of debt reduction per settlement","Amount by which the consumer’s debt is reduced as part of each settlement","Not enrolled debt, original balance, deposited funds, or projected savings"],["Approved consumer-education-program fee","$50","An administrator-approved consumer education program actually offered by the provider","Must be reasonable; program submission and approval requirements apply"],["Duplicate fee for joint household obligations","Prohibited","Joint debts of consumer and spouse/household member","Provider may not multiply the §6174-A fees merely because obligations are joint"]]},{"headers":["Fee","What Maine expressly says","What Maine does not expressly say"],"index":3,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Fee","What Maine expressly says","What Maine does not expressly say"],["$75 setup","Provider may charge a reasonable one-time initial/setup fee","No specific collection date; no express advance-fee authorization"],["$40 monthly","Provider that distributes monthly payments may assess a reasonable monthly fee","No exact day of month; no explicit treatment of a month in which no distribution occurs"],["15% settlement","Fee may not exceed 15% of actual debt reduction as part of each settlement","No standalone request/receipt event; no explicit treatment of failed or rescinded settlements"],["$50 education","Reasonable fee for an approved program","No express payment date or blanket refund formula"]]},{"headers":["Market-access item","Current finding","Limitation"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Market-access item","Current finding","Limitation"],["Filing platform","All current applications are directed through NMLS","The official BCCP page was discoverable but returned 403 when opened in this session"],["Company application fee","$500","NMLS processing charges are additional"],["Branch application fee","$250 per branch","Separate registration for each place of business"],["Company renewal","$250","Late renewal adds $100 under the rule/statute"],["Branch renewal","$250 per branch","NMLS procedures and status control current processing"],["Statutory maximum","Initial application no more than $800; renewal no more than $600","These are statutory ceilings on regulator fees, not the amounts currently charged and not consumer fees"],["Bond","$50,000 for each office/location under Rule 706","Full bond-form and claim analysis remains a later pass"],["Foreign entity","Maine authority to do business and Maine service-of-process agent required","Additional Secretary of State requirements may apply"],["Background information","Resumes plus consumer and criminal background reports for specified control persons","NMLS may impose additional current system fields"],["Consumer documents","Sample Maine contract, fee schedule, education program, periodic report","Filing these documents does not guarantee approval"],["Referral relationships","Applicant must identify referral companies and explain relationships or affiliations","This is disclosure, not affirmative permission for every payment arrangement"],["Approval timing","Statute requires action within 30 days after the application is accepted as complete","“Accepted as complete” is the operative starting point"]]},{"headers":["Source ID","Title / issuer","Direct literal URL","Pinpoint, version, and legal status","Actual access/check and limitations"],"index":5,"links":[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://www.legislature.maine.gov/statutes/17/title17sec701.html","text":"Maine State Legislature"},{"href":"https://www.legislature.maine.gov/statutes/17/title17sec702.html","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html","text":"Maine State Legislature"},{"href":"https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm","text":"Maine Legislature"},{"href":"https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp","text":"Maine Legislature"},{"href":"https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules","text":"Maine.gov"},{"href":"https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706","text":"Legal Information Institute\n+2"},{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","text":"Maine.gov\n+1"},{"href":"https://www.maine.gov/pfr/consumercredit/license_search.htm","text":"Maine.gov"},{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html","text":"Maine.gov\n+1"},{"href":"https://www.csbs.org/nationwide-multistate-licensing-system-nmls","text":"CSBS"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"},{"href":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983","text":"Maine.gov\n+2"},{"href":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984","text":"Maine.gov\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"},{"href":"https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","text":"Maine.gov\n+1"}],"row_links":[[],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],[{"href":"https://www.legislature.maine.gov/statutes/17/title17sec701.html","text":"Maine State Legislature"}],[{"href":"https://www.legislature.maine.gov/statutes/17/title17sec702.html","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html","text":"Maine State Legislature"}],[{"href":"https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm","text":"Maine Legislature"}],[{"href":"https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp","text":"Maine Legislature"}],[{"href":"https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules","text":"Maine.gov"}],[{"href":"https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706","text":"Legal Information Institute\n+2"}],[{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","text":"Maine.gov\n+1"}],[{"href":"https://www.maine.gov/pfr/consumercredit/license_search.htm","text":"Maine.gov"}],[{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html","text":"Maine.gov\n+1"}],[{"href":"https://www.csbs.org/nationwide-multistate-licensing-system-nmls","text":"CSBS"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System"}],[{"href":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983","text":"Maine.gov\n+2"}],[{"href":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984","text":"Maine.gov\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"}],[{"href":"https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","text":"Maine.gov\n+1"}]],"rows":[["Source ID","Title / issuer","Direct literal URL","Pinpoint, version, and legal status","Actual access/check and limitations"],["S_ME-P1-S001","Maine Revised Statutes, Title 32, Chapter 80-A, Debt Management Services — Maine Revisor of Statutes","https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","§§6172–6176 and 6179; pp. 1–7. Generated Oct. 5, 2026; states current through Oct. 1, 2026. Consolidated official Revisor text, with uncertified-text disclaimer.","Freshly read parsed text and page images for relevant pages. Principal current state-law source. \nMaine State Legislature\n+1"],["S_ME-P1-S002","Title 17, §701, Business prohibited — Maine Revisor","https://www.legislature.maine.gov/statutes/17/title17sec701.html","§701(1)–(2). Current webpage extracted Oct. 5, 2026.","Fresh official read. Establishes express budget-planning prohibition and exceptions. \nMaine State Legislature"],["S_ME-P1-S003","Title 17, §702, Budget planning defined — Maine Revisor","https://www.legislature.maine.gov/statutes/17/title17sec702.html","§702. Current webpage extracted Oct. 5, 2026.","Fresh official read. \nMaine State Legislature"],["S_ME-P1-S004","Title 9-A, §1-301, General definitions — Maine Revisor","https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html","Subsections 38-A and 39. Current webpage extracted Oct. 5, 2026.","Fresh official read; used only for institutional exclusions. \nMaine State Legislature"],["S_ME-P1-S005","Public Law 1999, chapter 560 — Maine Legislature","https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm","Original chapter enactment; emergency effective March 15, 2000.","Fresh official historical read. Establishes attorney grandfather date and original nonprofit-only architecture. \nMaine Legislature"],["S_ME-P1-S006","Public Law 2007, chapter 36, An Act To Amend the Debt Management Services Laws — Maine Legislature","https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp","§§5–9, 13; effective Sept. 20, 2007.","Fresh official historical read. Repealed nonprofit restriction and enacted current consumer-fee framework. \nMaine Legislature"],["S_ME-P1-S007","Department of Professional and Financial Regulation Rules — Maine Secretary of State","https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules","Official inventory listing for 02-030 C.M.R. ch. 706.","Search result freshly checked; direct page returned 403. Supports official existence/title, not the full rule wording. \nMaine.gov"],["S_ME-P1-S008","02-030 C.M.R. ch. 706, debt-management registration/NMLS rule","https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706; https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f","§§I–IV; reported effective Sept. 2, 2023, filing 2023-139.","Full matching reproductions freshly read. Not official/certified Maine-hosted text; official downloadable Word route inaccessible. \nLegal Information Institute\n+2"],["S_ME-P1-S009","Debt Management Service Providers — Maine BCCP","https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","Current operational registration page; search index identifies who must register and NMLS filing.","Discovery/search-index text only; direct fetch returned 403. Procedure support only, not substitute for statute/rule. \nMaine.gov\n+1"],["S_ME-P1-S010","Licensee Search — Maine BCCP","https://www.maine.gov/pfr/consumercredit/license_search.htm","Current public lookup route identifying NMLS for debt-management registrations.","Search-index text read; direct fetch returned 403. No named-provider lookup performed. \nMaine.gov"],["S_ME-P1-S011","Electronic Surety Bonds — Maine BCCP","https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html","Operational ESB instructions; DMS providers included.","Search-index text read; direct fetch returned 403. Bond-form details not independently inspected. \nMaine.gov\n+1"],["S_ME-P1-S012","Nationwide Multistate Licensing System — CSBS","https://www.csbs.org/nationwide-multistate-licensing-system-nmls","System-of-record and Consumer Access descriptions.","Fresh primary operational read; not state substantive-law authority. \nCSBS"],["S_ME-P1-S013","NMLS Licensing Checklists, Requirements, and Fees","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Dynamic checklist compiler.","Route opened with no exposed checklist text. Exact current Maine generated checklist remains unverified. \nNationwide Licensing System"],["S_ME-P1-S014","Legal Solutions Debt, LLC enforcement order — Maine BCCP","https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983","Dec. 6, 2013 administrative order.","Official-page search excerpts read; direct full order inaccessible. Historical agency action, not controlling judicial precedent. \nMaine.gov\n+2"],["S_ME-P1-S015","Granite Law California LLP enforcement order — Maine BCCP","https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984","Historical administrative order involving attorney-connected mortgage-relief activity.","Official-page search excerpts read; direct full order inaccessible. Not relied on as a complete or controlling interpretation. \nMaine.gov\n+2"],["S_ME-P1-S016","Telemarketing Sales Rule — eCFR, 16 CFR Part 310","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","§§310.2(o), 310.2(ii), 310.4(a)(5), 310.6(b)(5)–(6). Title 16 up to date through Oct. 22, 2026.","Fresh primary federal regulatory read. eCFR is authoritative but unofficial. \neCFR\n+2"],["S_ME-P1-S017","BCCP 2025–2026 Regulatory Agenda — Maine BCCP","https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","Rule 706 agenda entry states Bureau may update the rule based on operational experience and to correct errors.","Search-index passage read. Full PDF route could not be opened/rendered. Agenda is planning material, not an adopted or proposed rule by itself. \nMaine.gov\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and exact pinpoint","Conditions, exceptions, currentness","Confidence"],"index":6,"links":[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://www.legislature.maine.gov/statutes/17/title17sec701.html","text":"Maine State Legislature\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State 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Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","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://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f","text":"Midpage"},{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","text":"Maine.gov\n+2"},{"href":"https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706","text":"Legal Information Institute\n+2"},{"href":"https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","text":"Maine.gov\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"},{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],"row_links":[[],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State 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Legislature\n+1"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","text":"eCFR\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","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://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],[{"href":"https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f","text":"Midpage"}],[{"href":"https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","text":"Maine.gov\n+2"}],[{"href":"https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706","text":"Legal Information Institute\n+2"}],[{"href":"https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","text":"Maine.gov\n+1"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}],[{"href":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","text":"Maine State Legislature\n+1"}]],"rows":[["Claim ID","Precise assertion","Sources and exact pinpoint","Conditions, exceptions, currentness","Confidence"],["S_ME-P1-C001","Maine’s DMS definition reaches receipt, arrangement, direct/indirect control, and settlement or term-alteration intermediation.","S001, §6172(2)(A)–(D), pp. 1–2. \nMaine State Legislature","Conduct controls; an offer to act can suffice.","High"],["S_ME-P1-C002","Covered obligations are personal, family, or household debts; business/commercial debts are excluded.","S001, §6172(1-C), p. 1. \nMaine State Legislature","Mixed-purpose debts unresolved.","High"],["S_ME-P1-C003","A provider may be located anywhere; service offered to a consumer in Maine for fee or other consideration creates statutory nexus. Maine-based outbound providers are also included.","S001, §6172(3), p. 2. \nMaine State Legislature","“In this State” is not separately defined; consideration need not expressly be consumer-paid.","High on text; medium on edge nexus"],["S_ME-P1-C004","Traditional custodial budget planning is prohibited unless an enumerated exception applies, including registration under chapter 80-A.","S002, §701(1)–(2); S003, §702. \nMaine State Legislature\n+1","Applies to periodic debtor payment followed by provider distribution under a plan.","High"],["S_ME-P1-C005","Noncustodial payment-arrangement assistance can be covered.","S001, §6172(2)(B), and potentially (C). \nMaine State Legislature","Actual facts about control and arrangement matter.","High"],["S_ME-P1-C006","Principal reduction and other payment-term modification are covered intermediary activities.","S001, §6172(2)(D). \nMaine State Legislature","Compensation may still lack a fee base if no debt reduction occurs.","High"],["S_ME-P1-C007","Covered organizations must apply for registration; separate registration is required for each place of business; issuance is conditional on specified fitness factors.","S001, §6173(2), (2-A), (3). \nMaine State Legislature\n+1","Registration is not automatic upon filing.","High"],["S_ME-P1-C008","Current Maine law permits for-profit registration and provides no nonprofit exemption.","S006, §§6–7 and appropriation language; effective Sept. 20, 2007. \nMaine Legislature","Other entity exclusions may still apply.","High"],["S_ME-P1-C009","Attorney exclusion is limited to a person admitted in Maine as of March 15, 2000 and does not apply to the extent DMS is that attorney’s exclusive activity.","S001, §6172(3)(C); S005 effective clause. \nMaine State Legislature\n+1","No blanket law-firm, partner, or post-2000 attorney exemption.","High on text"],["S_ME-P1-C010","Supervised financial organization and supervised lender exclusions depend on their Title 9-A defined status.","S001, §6172(3), (5), (6); S004, §1-301(38-A), (39). \nMaine State Legislature\n+1","Affiliate status is not automatically inherited.","High"],["S_ME-P1-C011","Maine provides no express self-creditor exemption.","S001, §6172. \nMaine State Legislature","A creditor may not fit “intermediary,” but A–C, affiliate, and payment-control facts remain unresolved.","Held / medium-low"],["S_ME-P1-C012","§§6174-A and 6174-B do not apply to a Maine-located provider serving no Maine resident.","S001, §§6174-A(4), 6174-B(3). \nMaine State Legislature","Registration definition still reaches Maine-based outbound activity; destination-state law remains.","High"],["S_ME-P1-C013","Initial/setup fee must be reasonable and no more than $75 once.","S001, §6174-A(1). \nMaine State Legislature","Does not establish advance collection date.","High"],["S_ME-P1-C014","Monthly fee must be reasonable, no more than $40, and applies to a provider that distributes monthly creditor payments.","S001, §6174-A(2)(A). \nMaine State Legislature","Exact monthly earning date not stated.","High"],["S_ME-P1-C015","Settlement fee must be reasonable and no more than 15% of actual debt reduction as part of each settlement.","S001, §6174-A(2)(B). \nMaine State Legislature","Composition of “debt” and failed-settlement treatment not fully defined.","High on formula"],["S_ME-P1-C016","Covered providers must offer an approved education program and may charge a reasonable fee up to $50; counselor certification evidence is due within 12 months of initial employment.","S001, §6174-B(1)–(2). \nMaine State Legislature","Maine-outbound-only carveout applies.","High"],["S_ME-P1-C017","Monthly-distribution and settlement fees are alternative service-fee tracks.","S001, §6174-A(2), “either … or.” \nMaine State Legislature","No controlling opinion located; hybrid arrangements need confirmation.","Medium-high"],["S_ME-P1-C018","Fees may not be duplicated merely because obligations are joint with a spouse or household member.","S001, §6174-A(3). \nMaine State Legislature","Applies to fees authorized under §6174-A(1)–(2).","High"],["S_ME-P1-C019","The current consumer-fee amounts are unchanged from the 2007 enactment and have no statutory indexing provision.","S001, §6174-A and section history; S006, §8. \nMaine State Legislature\n+1","Current consolidated text through Oct. 1, 2026.","High"],["S_ME-P1-C020","Maine does not expressly state a collection date for the setup, monthly, or education fee; the settlement formula is outcome-dependent but lacks a separate request/receipt rule.","S001, §§6174-A, 6174-B. \nMaine State Legislature","Absence in chapter text is not advance-fee permission.","High on textual absence; medium overall"],["S_ME-P1-C021","Written agreement must precede performance and disclose services, fees, registration number, and written-cancellation right.","S001, §6176(1)–(2)(A), (B), (E). \nMaine State Legislature","Full contract-law and electronic-signature analysis remains open.","High"],["S_ME-P1-C022","Creditor-payment funds must be deposited within two business days, separately recorded, remitted within 15 business days, and not commingled.","S001, §6175. \nMaine State Legislature","Applies to funds received for creditor payment, not necessarily noncustodial models.","High"],["S_ME-P1-C023","TSR debt-relief coverage includes unsecured debt term alteration; covered telemarketing generally involves more than one interstate call, and inbound debt-relief ad responses are not within ordinary inbound exemptions.","S016, §§310.2(o), 310.2(ii), 310.6(b)(5)–(6). \neCFR\n+2","Entity and jurisdictional exclusions not completed here.","High"],["S_ME-P1-C024","Under covered TSR activity, no debt-relief fee may be requested or received until one debt is altered under an executed agreement and the customer makes one payment under that creditor agreement.","S016, §310.4(a)(5)(i)(A)–(C). \neCFR\n+1","Federal rule does not increase Maine fee ceilings.","High"],["S_ME-P1-C025","TSR dedicated accounts require insured institution, consumer ownership, independent administration, no referral compensation, free withdrawal, and return of unearned funds within seven business days.","S016, §310.4(a)(5)(ii). \neCFR","Only when TSR applies and account is used.","High"],["S_ME-P1-C026","Statute permits regulator initial fees up to $800, renewal up to $600, NMLS processing fees, and $100 late fee; Rule 706 currently sets lower state fees.","S001, §6173(2-B)(B); S008, §IV(4)–(5). \nMaine State Legislature\n+1","These are provider application fees, not consumer charges.","High"],["S_ME-P1-C027","Rule 706 sets company application $500, branch application $250, and company/branch renewal $250.","S008, §IV(4)(e), (5)(c). \nMidpage","NMLS fees additional; possible future rule update not adopted in sources read.","High subject to official-text gap"],["S_ME-P1-C028","NMLS is the current filing/system-of-record route, and Consumer Access is the public authorization-check route.","S009–S012. \nMaine.gov\n+2","No named provider checked.","High operationally"],["S_ME-P1-C029","Rule 706 is reported effective Sept. 2, 2023; its text contains overlapping registration-period provisions.","S008, note and §IV(2), (5)(b), (7)(b). \nLegal Information Institute\n+2","Official Maine downloadable text inaccessible; use live NMLS status.","Medium-high"],["S_ME-P1-C030","The 2025–2026 agenda’s “may update” statement is not an effective or proposed amendment by itself.","S017. \nMaine.gov\n+1","Full agenda PDF was inaccessible.","High on legal-status distinction"],["S_ME-P1-C031","A noncustodial arranger that neither distributes monthly payments nor achieves debt reduction lacks a verified recurring Maine fee pathway.","S001, §§6172(2)(B), 6174-A(2). \nMaine State Legislature\n+1","Setup fee and federal timing still require separate treatment.","Medium-high"],["S_ME-P1-C032","A prospective rate reduction with no present balance reduction has no clearly verified Maine settlement-fee base.","S001, §6174-A(2)(B). \nMaine State Legislature","Accrued-interest and fee forgiveness remain unresolved.","Held / medium"],["S_ME-P1-C033","Provider coverage may be triggered by “other consideration,” but chapter 80-A does not clearly resolve creditor-paid or referral compensation.","S001, §§6172(3), 6174-A; S008, §IV(6)(q). \nMaine State Legislature\n+1","No affirmative permission inferred.","Held"],["S_ME-P1-C034","A debt-management provider may not purchase debt, lend, take security, operate as debt collector, or structure negative amortization.","S001, §6179. \nMaine State Legislature","Full collection and secured-debt treatment remains open.","High"],["S_ME-P1-C035","Each enumerated consumer fee remains independently subject to reasonableness.","S001, §§6174-A(1), (2), 6174-B(2). \nMaine State Legislature","Maximum is not automatic entitlement.","High"],["S_ME-P1-C036","Statute/rule wording is not perfectly aligned for natural persons: statute says organization applies; rule contemplates sole proprietors and individuals.","S001, §§6172(4), 6173(2); S008, §IV(6)(a), (c), (h). \nMaine State Legislature\n+1","Operational route exists; controlling construction not located.","Medium"],["S_ME-P1-C037","No general chapter-80-A pro-rata refund formula or fee-refund deadline was found; cancellation, creditor funds, unlawful fees, and TSR funds are separate questions.","S001, §§6175–6176; S016, §310.4(a)(5)(ii)(E). \nMaine State Legislature\n+1","Negative finding limited to sources and scope actually read.","Medium"]]},{"headers":["Topic","Pass status","Claim IDs","Exact remaining evidence / next investigation"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Topic","Pass status","Claim IDs","Exact remaining evidence / next investigation"],["Four-part DMS definition","Answered","C001","Apply to final operating facts and contracts in a later implementation pass"],["Consumer versus business purpose","Answered at statutory level","C002","Mixed-purpose debt, personal guarantees, and use changes need cases/guidance"],["Custodial DMP / budget planning","Answered","C004, C022","Full trust-account audit, reports, examinations, and remedies remain open"],["Noncustodial payment arrangement","Answered on coverage; partial on fees","C005, C031","Obtain Maine interpretation of “distributes monthly payments”"],["Principal-reduction settlement","Answered","C006, C015","Agreement-specific fee trigger and rescinded-settlement treatment remain open"],["Interest and term concessions","Partial","C006, C032","Need authoritative definition of “debt reduced,” especially future interest"],["Remote provider nexus","Partial","C003","Determine meaning of “consumer in this State” versus resident, domicile, and physical presence"],["Maine outbound-only provider","Answered on express carveout; partial on reach","C012","Determine transaction-by-transaction effect if provider serves both Maine and non-Maine consumers"],["Registration requirement","Answered for organizations","C007","Resolve natural-person/sole-proprietor wording tension through agency interpretation or case law"],["For-profit/nonprofit status","Answered","C008","Federal nonprofit/FTC status remains separate"],["Attorney exclusion","Answered textually; application partial","C009","Full Granite Law order, later agency interpretations, firm/entity treatment, and current-good-standing question"],["Financial institution/lender exclusions","Answered textually","C010","Entity-by-entity authority and affiliate separateness must be verified"],["Self-creditor treatment","Unresolved","C011","Search formal advisory rulings and cases; analyze creditor/affiliate facts"],["Setup fee","Ceiling answered; timing partial","C013, C020, C024","Maine earning/refund interpretation and federal coverage"],["Monthly fee","Ceiling answered; trigger partial","C014, C020, C031","Determine fee treatment for skipped months, partial distributions, and third-party processors"],["Settlement fee","Formula answered; components partial","C015, C032","Accrued interest, posted fees, failed settlements, and prospective savings"],["Education fee","Ceiling answered; timing partial","C016, C020","Obtain approved-program standards and separate/bundled federal treatment"],["Fee-track stacking","Textual answer; no controlling opinion","C017","Seek written agency interpretation or controlling authority"],["Joint obligations","Answered","C018","Reenrollment and successive agreements not studied"],["Indexing/current amounts","Answered through Oct. 1, 2026 consolidated statute","C019","Monitor later session-law changes; no invented CPI amount"],["Creditor-paid/fair-share/referral compensation","Unresolved","C033","Formal guidance, examination manuals, and enforcement decisions"],["State fee collection timing","Partial","C020–C021","Search additional administrative orders and cases for earning/refund rules"],["Federal TSR timing","Answered as common context","C023–C025","Provider-specific jurisdiction, entity exclusions, and call-flow audit remain open"],["Current NMLS process","Answered operationally","C026–C029","Generate and read current Maine checklist from NMLS; inspect live application fields"],["Current company/branch fees","Answered subject to official-rule-text limitation","C026–C027","Confirm current generated NMLS fee chart at filing"],["Registration periods","Partial due rule overlap","C029","Rely on live NMLS authority dates; seek BCCP interpretation"],["Current public lookup","Answered procedurally","C028","Check exact legal entity/DBA/NMLS ID when supplied"],["Electronic surety bond","Partially answered","C027–C029","Read current bond form, cancellation notice, claims, and replacement rules"],["Rule 706 official text","Partial","C029","Retrieve official Word/adoption filing through an accessible public route"],["Possible rule update","Unresolved—not effective law","C030","Check Maine rulemaking notices and adopted-rule filings after agenda entry"],["Controlling court interpretation","Unresolved","—","Full citator, Maine Superior Court dockets, Law Court opinions, and federal Maine cases"],["Cancellation/refund","Partial","C021, C025, C037","State fee refund, credit, chargeback, termination, and failed-settlement rules"],["Lead generator/marketing platform","Partial","C001, C003, C033","Analyze representations, agency, intake, transfer, compensation, and referrals"],["Debt collector overlap","Boundary answered only","C034","Full Title 32 collection licensing and litigation pass remains open"],["Residential mortgage/secured debt","Excluded from this pass","—","§6183 and all mortgage-relief-specific conditions require a separate pass"],["Full agreement requirements","Only provisions needed for fee timing covered","C021","Electronic consent, signatures, disclosures, modification, assignment, governing law"],["Full funds/account regime","Only core timing covered","C022, C025","Audits, account title, processor roles, insolvency, reconciliation, reporting"],["Bond and remedies","Only access gate mentioned","C027","Bond claims, penalties, private actions, restitution, limitations, administrative procedure"],["Collection, litigation, limitation periods","Open","—","Separate component required"],["Sector, local, tribal, contract, and preemption issues","Open","—","Separate component required"],["Whole-state/A066 acceptance","Expressly not reached","—","All remaining Maine components and coordinator review required"]]}],"claims":[{"claim_id":"S_ME-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C001","Precise assertion":"Maine’s DMS definition reaches receipt, arrangement, direct/indirect control, and settlement or term-alteration intermediation.","Sources and exact pinpoint":"S001, §6172(2)(A)–(D), pp. 1–2. \nMaine State Legislature","Conditions, exceptions, currentness":"Conduct controls; an offer to act can suffice.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C002","Precise assertion":"Covered obligations are personal, family, or household debts; business/commercial debts are excluded.","Sources and exact pinpoint":"S001, §6172(1-C), p. 1. \nMaine State Legislature","Conditions, exceptions, currentness":"Mixed-purpose debts unresolved.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C003","Precise assertion":"A provider may be located anywhere; service offered to a consumer in Maine for fee or other consideration creates statutory nexus. Maine-based outbound providers are also included.","Sources and exact pinpoint":"S001, §6172(3), p. 2. \nMaine State Legislature","Conditions, exceptions, currentness":"“In this State” is not separately defined; consideration need not expressly be consumer-paid.","Confidence":"High on text; medium on edge nexus"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C004","Precise assertion":"Traditional custodial budget planning is prohibited unless an enumerated exception applies, including registration under chapter 80-A.","Sources and exact pinpoint":"S002, §701(1)–(2); S003, §702. \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Applies to periodic debtor payment followed by provider distribution under a plan.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C005","Precise assertion":"Noncustodial payment-arrangement assistance can be covered.","Sources and exact pinpoint":"S001, §6172(2)(B), and potentially (C). \nMaine State Legislature","Conditions, exceptions, currentness":"Actual facts about control and arrangement matter.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C006","Precise assertion":"Principal reduction and other payment-term modification are covered intermediary activities.","Sources and exact pinpoint":"S001, §6172(2)(D). \nMaine State Legislature","Conditions, exceptions, currentness":"Compensation may still lack a fee base if no debt reduction occurs.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C007","Precise assertion":"Covered organizations must apply for registration; separate registration is required for each place of business; issuance is conditional on specified fitness factors.","Sources and exact pinpoint":"S001, §6173(2), (2-A), (3). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Registration is not automatic upon filing.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C008","Precise assertion":"Current Maine law permits for-profit registration and provides no nonprofit exemption.","Sources and exact pinpoint":"S006, §§6–7 and appropriation language; effective Sept. 20, 2007. \nMaine Legislature","Conditions, exceptions, currentness":"Other entity exclusions may still apply.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C009","Precise assertion":"Attorney exclusion is limited to a person admitted in Maine as of March 15, 2000 and does not apply to the extent DMS is that attorney’s exclusive activity.","Sources and exact pinpoint":"S001, §6172(3)(C); S005 effective clause. \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"No blanket law-firm, partner, or post-2000 attorney exemption.","Confidence":"High on text"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C010","Precise assertion":"Supervised financial organization and supervised lender exclusions depend on their Title 9-A defined status.","Sources and exact pinpoint":"S001, §6172(3), (5), (6); S004, §1-301(38-A), (39). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Affiliate status is not automatically inherited.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C011","Precise assertion":"Maine provides no express self-creditor exemption.","Sources and exact pinpoint":"S001, §6172. \nMaine State Legislature","Conditions, exceptions, currentness":"A creditor may not fit “intermediary,” but A–C, affiliate, and payment-control facts remain unresolved.","Confidence":"Held / medium-low"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C012","Precise assertion":"§§6174-A and 6174-B do not apply to a Maine-located provider serving no Maine resident.","Sources and exact pinpoint":"S001, §§6174-A(4), 6174-B(3). \nMaine State Legislature","Conditions, exceptions, currentness":"Registration definition still reaches Maine-based outbound activity; destination-state law remains.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C013","Precise assertion":"Initial/setup fee must be reasonable and no more than $75 once.","Sources and exact pinpoint":"S001, §6174-A(1). \nMaine State Legislature","Conditions, exceptions, currentness":"Does not establish advance collection date.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C014","Precise assertion":"Monthly fee must be reasonable, no more than $40, and applies to a provider that distributes monthly creditor payments.","Sources and exact pinpoint":"S001, §6174-A(2)(A). \nMaine State Legislature","Conditions, exceptions, currentness":"Exact monthly earning date not stated.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C015","Precise assertion":"Settlement fee must be reasonable and no more than 15% of actual debt reduction as part of each settlement.","Sources and exact pinpoint":"S001, §6174-A(2)(B). \nMaine State Legislature","Conditions, exceptions, currentness":"Composition of “debt” and failed-settlement treatment not fully defined.","Confidence":"High on formula"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C016","Precise assertion":"Covered providers must offer an approved education program and may charge a reasonable fee up to $50; counselor certification evidence is due within 12 months of initial employment.","Sources and exact pinpoint":"S001, §6174-B(1)–(2). \nMaine State Legislature","Conditions, exceptions, currentness":"Maine-outbound-only carveout applies.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C017","Precise assertion":"Monthly-distribution and settlement fees are alternative service-fee tracks.","Sources and exact pinpoint":"S001, §6174-A(2), “either … or.” \nMaine State Legislature","Conditions, exceptions, currentness":"No controlling opinion located; hybrid arrangements need confirmation.","Confidence":"Medium-high"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C018","Precise assertion":"Fees may not be duplicated merely because obligations are joint with a spouse or household member.","Sources and exact pinpoint":"S001, §6174-A(3). \nMaine State Legislature","Conditions, exceptions, currentness":"Applies to fees authorized under §6174-A(1)–(2).","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C019","Precise assertion":"The current consumer-fee amounts are unchanged from the 2007 enactment and have no statutory indexing provision.","Sources and exact pinpoint":"S001, §6174-A and section history; S006, §8. \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Current consolidated text through Oct. 1, 2026.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C020","Precise assertion":"Maine does not expressly state a collection date for the setup, monthly, or education fee; the settlement formula is outcome-dependent but lacks a separate request/receipt rule.","Sources and exact pinpoint":"S001, §§6174-A, 6174-B. \nMaine State Legislature","Conditions, exceptions, currentness":"Absence in chapter text is not advance-fee permission.","Confidence":"High on textual absence; medium overall"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C021","Precise assertion":"Written agreement must precede performance and disclose services, fees, registration number, and written-cancellation right.","Sources and exact pinpoint":"S001, §6176(1)–(2)(A), (B), (E). \nMaine State Legislature","Conditions, exceptions, currentness":"Full contract-law and electronic-signature analysis remains open.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C022","Precise assertion":"Creditor-payment funds must be deposited within two business days, separately recorded, remitted within 15 business days, and not commingled.","Sources and exact pinpoint":"S001, §6175. \nMaine State Legislature","Conditions, exceptions, currentness":"Applies to funds received for creditor payment, not necessarily noncustodial models.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C023","Precise assertion":"TSR debt-relief coverage includes unsecured debt term alteration; covered telemarketing generally involves more than one interstate call, and inbound debt-relief ad responses are not within ordinary inbound exemptions.","Sources and exact pinpoint":"S016, §§310.2(o), 310.2(ii), 310.6(b)(5)–(6). \neCFR\n+2","Conditions, exceptions, currentness":"Entity and jurisdictional exclusions not completed here.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C024","Precise assertion":"Under covered TSR activity, no debt-relief fee may be requested or received until one debt is altered under an executed agreement and the customer makes one payment under that creditor agreement.","Sources and exact pinpoint":"S016, §310.4(a)(5)(i)(A)–(C). \neCFR\n+1","Conditions, exceptions, currentness":"Federal rule does not increase Maine fee ceilings.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C025","Precise assertion":"TSR dedicated accounts require insured institution, consumer ownership, independent administration, no referral compensation, free withdrawal, and return of unearned funds within seven business days.","Sources and exact pinpoint":"S016, §310.4(a)(5)(ii). \neCFR","Conditions, exceptions, currentness":"Only when TSR applies and account is used.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C026","Precise assertion":"Statute permits regulator initial fees up to $800, renewal up to $600, NMLS processing fees, and $100 late fee; Rule 706 currently sets lower state fees.","Sources and exact pinpoint":"S001, §6173(2-B)(B); S008, §IV(4)–(5). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"These are provider application fees, not consumer charges.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C027","Precise assertion":"Rule 706 sets company application $500, branch application $250, and company/branch renewal $250.","Sources and exact pinpoint":"S008, §IV(4)(e), (5)(c). \nMidpage","Conditions, exceptions, currentness":"NMLS fees additional; possible future rule update not adopted in sources read.","Confidence":"High subject to official-text gap"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C028","Precise assertion":"NMLS is the current filing/system-of-record route, and Consumer Access is the public authorization-check route.","Sources and exact pinpoint":"S009–S012. \nMaine.gov\n+2","Conditions, exceptions, currentness":"No named provider checked.","Confidence":"High operationally"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C029","Precise assertion":"Rule 706 is reported effective Sept. 2, 2023; its text contains overlapping registration-period provisions.","Sources and exact pinpoint":"S008, note and §IV(2), (5)(b), (7)(b). \nLegal Information Institute\n+2","Conditions, exceptions, currentness":"Official Maine downloadable text inaccessible; use live NMLS status.","Confidence":"Medium-high"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C030","Precise assertion":"The 2025–2026 agenda’s “may update” statement is not an effective or proposed amendment by itself.","Sources and exact pinpoint":"S017. \nMaine.gov\n+1","Conditions, exceptions, currentness":"Full agenda PDF was inaccessible.","Confidence":"High on legal-status distinction"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C031","Precise assertion":"A noncustodial arranger that neither distributes monthly payments nor achieves debt reduction lacks a verified recurring Maine fee pathway.","Sources and exact pinpoint":"S001, §§6172(2)(B), 6174-A(2). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Setup fee and federal timing still require separate treatment.","Confidence":"Medium-high"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C032","Precise assertion":"A prospective rate reduction with no present balance reduction has no clearly verified Maine settlement-fee base.","Sources and exact pinpoint":"S001, §6174-A(2)(B). \nMaine State Legislature","Conditions, exceptions, currentness":"Accrued-interest and fee forgiveness remain unresolved.","Confidence":"Held / medium"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C033","Precise assertion":"Provider coverage may be triggered by “other consideration,” but chapter 80-A does not clearly resolve creditor-paid or referral compensation.","Sources and exact pinpoint":"S001, §§6172(3), 6174-A; S008, §IV(6)(q). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"No affirmative permission inferred.","Confidence":"Held"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C034","Precise assertion":"A debt-management provider may not purchase debt, lend, take security, operate as debt collector, or structure negative amortization.","Sources and exact pinpoint":"S001, §6179. \nMaine State Legislature","Conditions, exceptions, currentness":"Full collection and secured-debt treatment remains open.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C035","Precise assertion":"Each enumerated consumer fee remains independently subject to reasonableness.","Sources and exact pinpoint":"S001, §§6174-A(1), (2), 6174-B(2). \nMaine State Legislature","Conditions, exceptions, currentness":"Maximum is not automatic entitlement.","Confidence":"High"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C036","Precise assertion":"Statute/rule wording is not perfectly aligned for natural persons: statute says organization applies; rule contemplates sole proprietors and individuals.","Sources and exact pinpoint":"S001, §§6172(4), 6173(2); S008, §IV(6)(a), (c), (h). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Operational route exists; controlling construction not located.","Confidence":"Medium"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"claim_id":"S_ME-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_ME-P1-C037","Precise assertion":"No general chapter-80-A pro-rata refund formula or fee-refund deadline was found; cancellation, creditor funds, unlawful fees, and TSR funds are separate questions.","Sources and exact pinpoint":"S001, §§6175–6176; S016, §310.4(a)(5)(ii)(E). \nMaine State Legislature\n+1","Conditions, exceptions, currentness":"Negative finding limited to sources and scope actually read.","Confidence":"Medium"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."}],"sources":[{"source_id":"S_ME-P1-S001","urls":["https://legislature.maine.gov/statutes/32/title32ch80-A.pdf"],"researcher_record":{"Source ID":"S_ME-P1-S001","Title / issuer":"Maine Revised Statutes, Title 32, Chapter 80-A, Debt Management Services — Maine Revisor of Statutes","Direct literal URL":"https://legislature.maine.gov/statutes/32/title32ch80-A.pdf","Pinpoint, version, and legal status":"§§6172–6176 and 6179; pp. 1–7. Generated Oct. 5, 2026; states current through Oct. 1, 2026. Consolidated official Revisor text, with uncertified-text disclaimer.","Actual access/check and limitations":"Freshly read parsed text and page images for relevant pages. Principal current state-law source. \nMaine State Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S002","urls":["https://www.legislature.maine.gov/statutes/17/title17sec701.html"],"researcher_record":{"Source ID":"S_ME-P1-S002","Title / issuer":"Title 17, §701, Business prohibited — Maine Revisor","Direct literal URL":"https://www.legislature.maine.gov/statutes/17/title17sec701.html","Pinpoint, version, and legal status":"§701(1)–(2). Current webpage extracted Oct. 5, 2026.","Actual access/check and limitations":"Fresh official read. Establishes express budget-planning prohibition and exceptions. \nMaine State Legislature"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S003","urls":["https://www.legislature.maine.gov/statutes/17/title17sec702.html"],"researcher_record":{"Source ID":"S_ME-P1-S003","Title / issuer":"Title 17, §702, Budget planning defined — Maine Revisor","Direct literal URL":"https://www.legislature.maine.gov/statutes/17/title17sec702.html","Pinpoint, version, and legal status":"§702. Current webpage extracted Oct. 5, 2026.","Actual access/check and limitations":"Fresh official read. \nMaine State Legislature"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S004","urls":["https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html"],"researcher_record":{"Source ID":"S_ME-P1-S004","Title / issuer":"Title 9-A, §1-301, General definitions — Maine Revisor","Direct literal URL":"https://legislature.maine.gov/statutes/9-A/title9-Asec1-301.html","Pinpoint, version, and legal status":"Subsections 38-A and 39. Current webpage extracted Oct. 5, 2026.","Actual access/check and limitations":"Fresh official read; used only for institutional exclusions. \nMaine State Legislature"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S005","urls":["https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm"],"researcher_record":{"Source ID":"S_ME-P1-S005","Title / issuer":"Public Law 1999, chapter 560 — Maine Legislature","Direct literal URL":"https://www.mainelegislature.org/ros/LOM/LOM119th/2Pub551-600/2Pub551-600-09.htm","Pinpoint, version, and legal status":"Original chapter enactment; emergency effective March 15, 2000.","Actual access/check and limitations":"Fresh official historical read. Establishes attorney grandfather date and original nonprofit-only architecture. \nMaine Legislature"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S006","urls":["https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp"],"researcher_record":{"Source ID":"S_ME-P1-S006","Title / issuer":"Public Law 2007, chapter 36, An Act To Amend the Debt Management Services Laws — Maine Legislature","Direct literal URL":"https://www.mainelegislature.org/legis/bills/bills_123rd/chapters/PUBLIC36.asp","Pinpoint, version, and legal status":"§§5–9, 13; effective Sept. 20, 2007.","Actual access/check and limitations":"Fresh official historical read. Repealed nonprofit restriction and enacted current consumer-fee framework. \nMaine Legislature"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S007","urls":["https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules"],"researcher_record":{"Source ID":"S_ME-P1-S007","Title / issuer":"Department of Professional and Financial Regulation Rules — Maine Secretary of State","Direct literal URL":"https://www.maine.gov/sos/rulemaking/agency-rules/department-professional-and-financial-regulation-rules","Pinpoint, version, and legal status":"Official inventory listing for 02-030 C.M.R. ch. 706.","Actual access/check and limitations":"Search result freshly checked; direct page returned 403. Supports official existence/title, not the full rule wording. \nMaine.gov"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S008","urls":["https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706","https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f"],"researcher_record":{"Source ID":"S_ME-P1-S008","Title / issuer":"02-030 C.M.R. ch. 706, debt-management registration/NMLS rule","Direct literal URL":"https://www.law.cornell.edu/regulations/maine/department-02/division-030/chapter-706; https://app.midpage.ai/laws/me-rules/department_professional_and_financial_regulation_rules/u02_030_Bureau_of_Consumer_Credit_Protection/c706-482f3f","Pinpoint, version, and legal status":"§§I–IV; reported effective Sept. 2, 2023, filing 2023-139.","Actual access/check and limitations":"Full matching reproductions freshly read. Not official/certified Maine-hosted text; official downloadable Word route inaccessible. \nLegal Information Institute\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S009","urls":["https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm"],"researcher_record":{"Source ID":"S_ME-P1-S009","Title / issuer":"Debt Management Service Providers — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/industry/licensing/debt_management.htm","Pinpoint, version, and legal status":"Current operational registration page; search index identifies who must register and NMLS filing.","Actual access/check and limitations":"Discovery/search-index text only; direct fetch returned 403. Procedure support only, not substitute for statute/rule. \nMaine.gov\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S010","urls":["https://www.maine.gov/pfr/consumercredit/license_search.htm"],"researcher_record":{"Source ID":"S_ME-P1-S010","Title / issuer":"Licensee Search — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/license_search.htm","Pinpoint, version, and legal status":"Current public lookup route identifying NMLS for debt-management registrations.","Actual access/check and limitations":"Search-index text read; direct fetch returned 403. No named-provider lookup performed. \nMaine.gov"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S011","urls":["https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html"],"researcher_record":{"Source ID":"S_ME-P1-S011","Title / issuer":"Electronic Surety Bonds — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/industry/licensing/nmls/bonds.html","Pinpoint, version, and legal status":"Operational ESB instructions; DMS providers included.","Actual access/check and limitations":"Search-index text read; direct fetch returned 403. Bond-form details not independently inspected. \nMaine.gov\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S012","urls":["https://www.csbs.org/nationwide-multistate-licensing-system-nmls"],"researcher_record":{"Source ID":"S_ME-P1-S012","Title / issuer":"Nationwide Multistate Licensing System — CSBS","Direct literal URL":"https://www.csbs.org/nationwide-multistate-licensing-system-nmls","Pinpoint, version, and legal status":"System-of-record and Consumer Access descriptions.","Actual access/check and limitations":"Fresh primary operational read; not state substantive-law authority. \nCSBS"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S013","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx"],"researcher_record":{"Source ID":"S_ME-P1-S013","Title / issuer":"NMLS Licensing Checklists, Requirements, and Fees","Direct literal URL":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Pinpoint, version, and legal status":"Dynamic checklist compiler.","Actual access/check and limitations":"Route opened with no exposed checklist text. Exact current Maine generated checklist remains unverified. \nNationwide Licensing System"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S014","urls":["https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983"],"researcher_record":{"Source ID":"S_ME-P1-S014","Title / issuer":"Legal Solutions Debt, LLC enforcement order — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609983","Pinpoint, version, and legal status":"Dec. 6, 2013 administrative order.","Actual access/check and limitations":"Official-page search excerpts read; direct full order inaccessible. Historical agency action, not controlling judicial precedent. \nMaine.gov\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S015","urls":["https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984"],"researcher_record":{"Source ID":"S_ME-P1-S015","Title / issuer":"Granite Law California LLP enforcement order — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=609984","Pinpoint, version, and legal status":"Historical administrative order involving attorney-connected mortgage-relief activity.","Actual access/check and limitations":"Official-page search excerpts read; direct full order inaccessible. Not relied on as a complete or controlling interpretation. \nMaine.gov\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S016","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"],"researcher_record":{"Source ID":"S_ME-P1-S016","Title / issuer":"Telemarketing Sales Rule — eCFR, 16 CFR Part 310","Direct literal URL":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Pinpoint, version, and legal status":"§§310.2(o), 310.2(ii), 310.4(a)(5), 310.6(b)(5)–(6). Title 16 up to date through Oct. 22, 2026.","Actual access/check and limitations":"Fresh primary federal regulatory read. eCFR is authoritative but unofficial. \neCFR\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"source_id":"S_ME-P1-S017","urls":["https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf"],"researcher_record":{"Source ID":"S_ME-P1-S017","Title / issuer":"BCCP 2025–2026 Regulatory Agenda — Maine BCCP","Direct literal URL":"https://www.maine.gov/pfr/consumercredit/laws_rules/2025-2026_agenda.pdf","Pinpoint, version, and legal status":"Rule 706 agenda entry states Bureau may update the rule based on operational experience and to correct errors.","Actual access/check and limitations":"Search-index passage read. Full PDF route could not be opened/rendered. Agenda is planning material, not an adopted or proposed rule by itself. \nMaine.gov\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."}],"coverage":[{"topic":"Four-part DMS definition","researcher_record":{"Topic":"Four-part DMS definition","Pass status":"Answered","Claim IDs":"C001","Exact remaining evidence / next investigation":"Apply to final operating facts and contracts in a later implementation pass"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Consumer versus business purpose","researcher_record":{"Topic":"Consumer versus business purpose","Pass status":"Answered at statutory level","Claim IDs":"C002","Exact remaining evidence / next investigation":"Mixed-purpose debt, personal guarantees, and use changes need cases/guidance"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Custodial DMP / budget planning","researcher_record":{"Topic":"Custodial DMP / budget planning","Pass status":"Answered","Claim IDs":"C004, C022","Exact remaining evidence / next investigation":"Full trust-account audit, reports, examinations, and remedies remain open"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Noncustodial payment arrangement","researcher_record":{"Topic":"Noncustodial payment arrangement","Pass status":"Answered on coverage; partial on fees","Claim IDs":"C005, C031","Exact remaining evidence / next investigation":"Obtain Maine interpretation of “distributes monthly payments”"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Principal-reduction settlement","researcher_record":{"Topic":"Principal-reduction settlement","Pass status":"Answered","Claim IDs":"C006, C015","Exact remaining evidence / next investigation":"Agreement-specific fee trigger and rescinded-settlement treatment remain open"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Interest and term concessions","researcher_record":{"Topic":"Interest and term concessions","Pass status":"Partial","Claim IDs":"C006, C032","Exact remaining evidence / next investigation":"Need authoritative definition of “debt reduced,” especially future interest"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Remote provider nexus","researcher_record":{"Topic":"Remote provider nexus","Pass status":"Partial","Claim IDs":"C003","Exact remaining evidence / next investigation":"Determine meaning of “consumer in this State” versus resident, domicile, and physical presence"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Maine outbound-only provider","researcher_record":{"Topic":"Maine outbound-only provider","Pass status":"Answered on express carveout; partial on reach","Claim IDs":"C012","Exact remaining evidence / next investigation":"Determine transaction-by-transaction effect if provider serves both Maine and non-Maine consumers"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Registration requirement","researcher_record":{"Topic":"Registration requirement","Pass status":"Answered for organizations","Claim IDs":"C007","Exact remaining evidence / next investigation":"Resolve natural-person/sole-proprietor wording tension through agency interpretation or case law"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"For-profit/nonprofit status","researcher_record":{"Topic":"For-profit/nonprofit status","Pass status":"Answered","Claim IDs":"C008","Exact remaining evidence / next investigation":"Federal nonprofit/FTC status remains separate"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Attorney exclusion","researcher_record":{"Topic":"Attorney exclusion","Pass status":"Answered textually; application partial","Claim IDs":"C009","Exact remaining evidence / next investigation":"Full Granite Law order, later agency interpretations, firm/entity treatment, and current-good-standing question"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Financial institution/lender exclusions","researcher_record":{"Topic":"Financial institution/lender exclusions","Pass status":"Answered textually","Claim IDs":"C010","Exact remaining evidence / next investigation":"Entity-by-entity authority and affiliate separateness must be verified"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Self-creditor treatment","researcher_record":{"Topic":"Self-creditor treatment","Pass status":"Unresolved","Claim IDs":"C011","Exact remaining evidence / next investigation":"Search formal advisory rulings and cases; analyze creditor/affiliate facts"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Setup fee","researcher_record":{"Topic":"Setup fee","Pass status":"Ceiling answered; timing partial","Claim IDs":"C013, C020, C024","Exact remaining evidence / next investigation":"Maine earning/refund interpretation and federal coverage"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Monthly fee","researcher_record":{"Topic":"Monthly fee","Pass status":"Ceiling answered; trigger partial","Claim IDs":"C014, C020, C031","Exact remaining evidence / next investigation":"Determine fee treatment for skipped months, partial distributions, and third-party processors"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Settlement fee","researcher_record":{"Topic":"Settlement fee","Pass status":"Formula answered; components partial","Claim IDs":"C015, C032","Exact remaining evidence / next investigation":"Accrued interest, posted fees, failed settlements, and prospective savings"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Education fee","researcher_record":{"Topic":"Education fee","Pass status":"Ceiling answered; timing partial","Claim IDs":"C016, C020","Exact remaining evidence / next investigation":"Obtain approved-program standards and separate/bundled federal treatment"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Fee-track stacking","researcher_record":{"Topic":"Fee-track stacking","Pass status":"Textual answer; no controlling opinion","Claim IDs":"C017","Exact remaining evidence / next investigation":"Seek written agency interpretation or controlling authority"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Joint obligations","researcher_record":{"Topic":"Joint obligations","Pass status":"Answered","Claim IDs":"C018","Exact remaining evidence / next investigation":"Reenrollment and successive agreements not studied"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Indexing/current amounts","researcher_record":{"Topic":"Indexing/current amounts","Pass status":"Answered through Oct. 1, 2026 consolidated statute","Claim IDs":"C019","Exact remaining evidence / next investigation":"Monitor later session-law changes; no invented CPI amount"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Creditor-paid/fair-share/referral compensation","researcher_record":{"Topic":"Creditor-paid/fair-share/referral compensation","Pass status":"Unresolved","Claim IDs":"C033","Exact remaining evidence / next investigation":"Formal guidance, examination manuals, and enforcement decisions"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"State fee collection timing","researcher_record":{"Topic":"State fee collection timing","Pass status":"Partial","Claim IDs":"C020–C021","Exact remaining evidence / next investigation":"Search additional administrative orders and cases for earning/refund rules"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Federal TSR timing","researcher_record":{"Topic":"Federal TSR timing","Pass status":"Answered as common context","Claim IDs":"C023–C025","Exact remaining evidence / next investigation":"Provider-specific jurisdiction, entity exclusions, and call-flow audit remain open"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Current NMLS process","researcher_record":{"Topic":"Current NMLS process","Pass status":"Answered operationally","Claim IDs":"C026–C029","Exact remaining evidence / next investigation":"Generate and read current Maine checklist from NMLS; inspect live application fields"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Current company/branch fees","researcher_record":{"Topic":"Current company/branch fees","Pass status":"Answered subject to official-rule-text limitation","Claim IDs":"C026–C027","Exact remaining evidence / next investigation":"Confirm current generated NMLS fee chart at filing"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Registration periods","researcher_record":{"Topic":"Registration periods","Pass status":"Partial due rule overlap","Claim IDs":"C029","Exact remaining evidence / next investigation":"Rely on live NMLS authority dates; seek BCCP interpretation"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Current public lookup","researcher_record":{"Topic":"Current public lookup","Pass status":"Answered procedurally","Claim IDs":"C028","Exact remaining evidence / next investigation":"Check exact legal entity/DBA/NMLS ID when supplied"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Electronic surety bond","researcher_record":{"Topic":"Electronic surety bond","Pass status":"Partially answered","Claim IDs":"C027–C029","Exact remaining evidence / next investigation":"Read current bond form, cancellation notice, claims, and replacement rules"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Rule 706 official text","researcher_record":{"Topic":"Rule 706 official text","Pass status":"Partial","Claim IDs":"C029","Exact remaining evidence / next investigation":"Retrieve official Word/adoption filing through an accessible public route"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Possible rule update","researcher_record":{"Topic":"Possible rule update","Pass status":"Unresolved—not effective law","Claim IDs":"C030","Exact remaining evidence / next investigation":"Check Maine rulemaking notices and adopted-rule filings after agenda entry"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Controlling court interpretation","researcher_record":{"Topic":"Controlling court interpretation","Pass status":"Unresolved","Claim IDs":"—","Exact remaining evidence / next investigation":"Full citator, Maine Superior Court dockets, Law Court opinions, and federal Maine cases"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Cancellation/refund","researcher_record":{"Topic":"Cancellation/refund","Pass status":"Partial","Claim IDs":"C021, C025, C037","Exact remaining evidence / next investigation":"State fee refund, credit, chargeback, termination, and failed-settlement rules"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Lead generator/marketing platform","researcher_record":{"Topic":"Lead generator/marketing platform","Pass status":"Partial","Claim IDs":"C001, C003, C033","Exact remaining evidence / next investigation":"Analyze representations, agency, intake, transfer, compensation, and referrals"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Debt collector overlap","researcher_record":{"Topic":"Debt collector overlap","Pass status":"Boundary answered only","Claim IDs":"C034","Exact remaining evidence / next investigation":"Full Title 32 collection licensing and litigation pass remains open"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Residential mortgage/secured debt","researcher_record":{"Topic":"Residential mortgage/secured debt","Pass status":"Excluded from this pass","Claim IDs":"—","Exact remaining evidence / next investigation":"§6183 and all mortgage-relief-specific conditions require a separate pass"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Full agreement requirements","researcher_record":{"Topic":"Full agreement requirements","Pass status":"Only provisions needed for fee timing covered","Claim IDs":"C021","Exact remaining evidence / next investigation":"Electronic consent, signatures, disclosures, modification, assignment, governing law"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Full funds/account regime","researcher_record":{"Topic":"Full funds/account regime","Pass status":"Only core timing covered","Claim IDs":"C022, C025","Exact remaining evidence / next investigation":"Audits, account title, processor roles, insolvency, reconciliation, reporting"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Bond and remedies","researcher_record":{"Topic":"Bond and remedies","Pass status":"Only access gate mentioned","Claim IDs":"C027","Exact remaining evidence / next investigation":"Bond claims, penalties, private actions, restitution, limitations, administrative procedure"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Collection, litigation, limitation periods","researcher_record":{"Topic":"Collection, litigation, limitation periods","Pass status":"Open","Claim IDs":"—","Exact remaining evidence / next investigation":"Separate component required"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Sector, local, tribal, contract, and preemption issues","researcher_record":{"Topic":"Sector, local, tribal, contract, and preemption issues","Pass status":"Open","Claim IDs":"—","Exact remaining evidence / next investigation":"Separate component required"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."},{"topic":"Whole-state/A066 acceptance","researcher_record":{"Topic":"Whole-state/A066 acceptance","Pass status":"Expressly not reached","Claim IDs":"—","Exact remaining evidence / next investigation":"All remaining Maine components and coordinator review required"},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification."}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}