{"meta":{"key":"s_mn--pass-06","task":"S_MN","title":"SMN Minnesota DMP fees, initial-payment allocation, and necessary funds ledger","parent_title":"Minnesota debt and debt relief law","edition":"pass-06","path":"/research/s_mn--pass-06/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-27","tables":17,"claims":45,"sources":17,"review_status":"scoped_review_complete_separate_initial_fee_earning_currentness_notice_holds","review_complete":true,"sha256":"6508394f656c193b74aa5b8690e4088fa4f9fba7cde06640855fbe726520aa2b","headings":["A. Answers to the central questions","A1. Can origination and maintenance both be taken from an initial payment?","A2. What remains unresolved about a separately paid origination fee?","A3. Does Minnesota impose the settlement chapter’s “fully performed” test on every DMP fee?","B. Version, enactment, and adjustment findings","B1. Current statutory version and material historical changes","B2. No DMP inflation adjustment established","C. State fee and funds rules applied together","C1. Classification and agreement prerequisites","C2. Joint fee calculation","C3. Charges that cannot be supplied by changing the label","C4. Advance-payment restriction and exceptions","C5. Custody, availability and creditor distribution use different clocks","C6. Consent, insufficient payments and withdrawal","C7. Cancellation, termination and fee refunds","D. Essential federal interaction—DMP-specific, not settlement-derived","D1. Coverage assumptions","D2. What the Commission specifically says about DMPs","D3. Separate state and federal predicates","D4. Account accumulation is not the same as ordinary DMP distribution","E. Actor-and-event decision table","F. Fourteen fresh fictional postures","Common assumptions and accounting convention","M01 — The $300 adversarial test and a different, conditionally compliant contract","Inputs","Rejected proposal: $50 plus $45","Alternative branch—not a retroactive cure","M02 — Both maximum component fees fit a larger initial periodic payment","Inputs","M03 — Separate fee-only candidate: accounting balance does not establish legality","Inputs and disputed alternatives","Demonstrated no-origination path","M04 — Missed payment, partial receipt and cancellation","Inputs","July: funded cycle","August: failed payment","September: partial receipt and cancellation","H. Concise effect crosswalk to P01","Interpretation search and unsuccessful/discovery routes","L. Researcher self-check and final disposition"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_MN/pass-06","facets":{"geography":["us","us-mn"],"debt_type":["rent_lease"],"stage":["origination"],"subject":["counseling-dmp","fees-outcomes","tenancy-housing"]},"scope":"ReviewedP01remainingDMPoriginationmaintenancejointinitialfundsledgeronly","pending_corrections":0},"markdown":"# S_MN PASS-06 — Minnesota DMP fees, initial-payment allocation, and necessary funds ledger\n\n**Research/access date:** October 27, 2026, America/Los_Angeles.\n**Scope:** Debt-management-plan origination and maintenance fees; initial and periodic-payment allocation; advance-payment restrictions; necessary custody, distribution, cancellation, and refund accounting; and the directly relevant federal Telemarketing Sales Rule (TSR).\n\n**Disposition:** The statutory limits can be reconciled for several conditional models, including one that permits both origination and maintenance fees. **No authority was established for deducting $50 plus $45 from the same ordinary $300 periodic payment.** The genuinely separate, fee-only initial-payment theory remains unresolved rather than approved.\n\nP01’s original examples and access history remain preserved. P02 and P04 are separate reviewed components. **P05’s unreviewed settlement-performance findings are not premises for this report.**\n\nThroughout, **S001** means **S_MN-P06-S001**. Claim identifiers **C001–C045** belong exclusively to this pass.\n\n## A. Answers to the central questions\n\n### A1. Can origination and maintenance both be taken from an initial payment?\n\n**Yes, conditionally—but each fee’s individual ceiling is not the entire test.**\n\nSection 332A.13 separately provides an origination allowance, a maintenance ceiling and reasonableness condition, and a restriction on **all authorized fees retained from any periodic payment**. The initial-payment provision contains no express statement exempting an initial payment that is also a periodic plan payment from that retention restriction. [C009–C011; S001, subdivisions 1–4.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nThat produces these distinct results:\n\n| Proposed first-payment treatment | Calculation | Result within this pass |\n| --- | --- | --- |\n| $300 periodic payment; $50 origination plus $45 maintenance | $95 retained; 31.6667% of receipt; $205 left for creditors | **No supported route.** It exceeds the $45 aggregate retention limit by $50. |\n| $300 periodic payment; contract instead specifies $30 origination plus $15 maintenance | $45 retained; 15%; $255 for creditors | **Conditionally compatible with the numerical limits.** Contract, services, timing, consent and distribution conditions remain necessary. |\n| $1,000 periodic payment; $50 origination plus $75 maintenance | $125 retained; 12.5%; $875 for creditors | **Conditionally compatible with both individual ceilings and the aggregate retention limit.** |\n| $50 genuinely separate fee-only payment plus a $300 periodic payment | Depends on whether the $50 is legally distinct from the periodic payment | **Unresolved classification—not a permitted workaround.** |\n| One $300 periodic obligation divided into a $50 “enrollment” debit and a $250 “plan” debit | Same underlying periodic obligation, merely split operationally | Splitting the transfer does not establish a statutory exception. |\n\nThese are applications of the text, **not holdings from a Minnesota appellate decision**. No responsive published majority opinion or binding administrative interpretation was located and read that supplies an initial-periodic-payment exception. The practical conclusion is therefore narrower than a universal pronouncement about every conceivable initial payment: **the stated $95-from-$300 transaction has not been justified.** [C011–C012, C036.]\n\n### A2. What remains unresolved about a separately paid origination fee?\n\nThe statute distinguishes an “initial amount” from a “periodic payment,” but the relevant definitions do not expressly define those terms or establish how to classify a separate fee-only transfer. Two constructions remain materially different:\n\n| Construction | Supporting textual consideration | Missing authority |\n| --- | --- | --- |\n| A genuinely separate initial origination payment is not a periodic payment | Subdivision 1 expressly permits an origination fee from the initial amount; subdivision 4 addresses periodic payments | A responsive construction explaining when a separate payment is genuinely outside subdivision 4, and how the agreement and payment schedule must reflect it |\n| An initial transfer associated with the first scheduled plan payment remains subject to the periodic-payment limit | Subdivision 4 applies to fees authorized by the section and to **any** periodic payment | A responsive application to separately invoiced or separately debited amounts connected to the same scheduled obligation |\n\nNeither construction permits treating labels as decisive. A “nominal enrollment charge,” separate invoice, second debit, or different accounting code does not itself establish an exception. The written agreement, actual obligation, purpose, timing and funds flow matter. [C012; S001–S003.] [MN Revisor+2](https://www.revisor.mn.gov/statutes/cite/332A.02)\n\n**Federal timing is an additional issue.** For the covered DMP model discussed below, moving the origination charge into a separate payment **before** the qualifying DMP enrollment and first payment does not solve the federal advance-fee problem. Moving it afterward may resolve that federal timing issue, but does not resolve Minnesota’s payment-classification question. [C030–C032.] [Federal Register](https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule)\n\n### A3. Does Minnesota impose the settlement chapter’s “fully performed” test on every DMP fee?\n\n**This pass does not import that test.** Chapter 332A supplies its own fee, service-reasonableness, agreement, advance-payment, consent and funds rules. The relevant cancellation language also distinguishes origination fees from fees earned before cancellation or default. It does not provide a universal definition of when every maintenance fee is earned. [C010, C015–C017, C025; S001.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nFor a particular DMP fee, the questions are instead:\n\n- Is the charge authorized by the signed agreement and the applicable statutory fee category?\n- Is the maintenance amount reasonable for services actually provided?\n- Do the monthly and per-payment limits both permit it?\n- Does the advance-payment restriction prohibit receipt or retention at that time?\n- Have any independently applicable federal predicates been satisfied?\n- Is the proposed transfer authorized, correctly recorded, and compatible with timely creditor distribution?\n\nA provider’s receipt of money, a numerical ceiling, a bank debit, and a lawful fee transfer are four different events.\n\n## B. Version, enactment, and adjustment findings\n\n### B1. Current statutory version and material historical changes\n\nThe retrieved Revisor section pages are labeled **2025 Minnesota Statutes**. The targeted 2026 regular-session statutes-changed entries for Chapter 332A identify the previously reviewed accreditation-definition repeal and application amendment. They do not list an amendment to the fee or funds provisions examined here. That is a **targeted regular-session index finding**, not a fully consolidated October 2026 or all-later-session certificate. [C001; S011.] [MN Revisor](https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026)\n\nThe fee provision’s material enacted history was checked directly:\n\n| Authority | Material point | Effective/applicability finding |\n| --- | --- | --- |\n| **Laws 2007, chapter 57, article 3, §56** | Enacted the relevant §332A.13 origination, maintenance, periodic-retention, advance-payment, consent and funds structure | The section expressly became effective **January 1, 2008**. |\n| **Laws 2008, chapter 210, §8** | Changed the trust-deposit language to funds being **available**, and added the limited separate disbursement-account route | Section 10 makes §§1–9 effective the day following final enactment. The act was signed April 21, 2008; this change therefore took effect **April 22, 2008**. |\n| **Laws 2009, chapter 37, article 4** | Relevant DMP definition, agreement and cancellation amendments were inspected as historical context | The precise historical effective-date chain for these selected 2009 changes was **not fully reconstructed**. No particular 2009 date is asserted here. |\n| **Displayed current section bodies** | Supply the present wording used for the 2026 fictional models | Subject to the stated compilation and later-amendment limits. |\n\nThe 2009 limitation does not conceal an assumed date: the models use the retrieved current bodies, not a claim that a historical version governed a particular 2009 transaction. [C002–C003; S008–S010.] [MN Revisor+3](https://www.revisor.mn.gov/laws/2007/0/57/)\n\n### B2. No DMP inflation adjustment established\n\nThe complete §332A.13 body contains no indexing formula for its $50 and $75 amounts. Commerce’s current **July 1, 2026 Consumer Credit Code adjustment notice** expressly concerns Chapter 56 and §47.59—not these DMP fee caps. It cannot be imported into Chapter 332A. No applicable DMP adjustment notice was located in the bounded search. [C004; S001, S017.] [mn.gov // Minnesota's State Portal](https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/index.jsp)\n\nAccordingly, the calculations below use the displayed **$50 origination** and **$75 maintenance** figures. No inflation calculation was invented.\n\nProvider registration charges, renewal charges and bond costs are not additional consumer-fee categories established by this analysis. Their separate existence does not authorize passing them through as an extra debtor charge. [C013; S001, subdivision 3.]\n\n## C. State fee and funds rules applied together\n\n### C1. Classification and agreement prerequisites\n\nMinnesota’s DMP definition focuses on receiving debtor funds and distributing periodic payments to creditors for full repayment of personal, family or household debt. Provider and delegated-service provisions, and holding oneself out as providing the service, also matter. A business cannot establish a noncustodial exclusion merely by having an associated processor receive the money. [C005–C006; S002, subdivisions 8–10, 12.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.02)\n\nA genuinely direct-creditor arrangement—where the consumer pays creditors without provider receipt or distribution—requires its own classification. It does **not** automatically inherit §332A.13’s fee permissions, and a concession-negotiation service may still meet the federal debt-relief definition even without provider custody.\n\nSection 332A.10 requires the executed written agreement before DMP services or plan funds, together with the required pre-agreement assessment and disclosures. Fee amounts, services, anticipated charges, refund policy, cancellation terms and creditor participation are material to this ledger. [C007–C008; S003, subdivisions 1–3.] [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.10)\n\n### C2. Joint fee calculation\n\nFor a periodic receipt PjP_jPj​, define:\n\n- OjO_jOj​: origination amount retained from that receipt;\n- MjM_jMj​: maintenance amount retained from that receipt;\n- MmonthM_{\\text{month}}Mmonth​: total maintenance attributed to the month;\n- PmonthP_{\\text{month}}Pmonth​: the relevant monthly payment amount under the agreement.\n\nThe combined textual constraints are:\n\nPlain text\n```\nTotal origination fee ≤ $50.\n\nMonthly maintenance must be reasonable for the services provided, and:\nM_month ≤ lesser of (15% × monthly payment amount) or $75.\n\nFor each periodic payment:\nO_j + M_j + any other purported fee retention ≤ 15% × P_j.\n\nCreditor allocation from that periodic payment:\nP_j − lawful fee retention ≥ 85% × P_j.\n```\n\nThis is a combined reading of subdivisions 1–4, not a statutory formula expressly printed in this notation. A lower contractual fee remains lower; unused statutory capacity is not automatically earned. [C009–C011; S001, S008.] [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nFor weekly or biweekly schedules, the monthly maintenance ceiling is not a fresh $75 allowance for every installment. The provider must reconcile both the month and every individual receipt. The precise treatment of irregular months, unspecified monthly amounts, and a missed month’s possible contractual fee receivable requires the actual agreement and potentially additional interpretation. [C041–C042.]\n\n### C3. Charges that cannot be supplied by changing the label\n\nThe reviewed provisions do not establish separate provider charges for handling a late payment, returned payment, cancellation, statement, modification, or “enrollment donation.” Section 332A.14 also prohibits demanding or collecting a purported voluntary contribution from the debtor. A bank’s independently imposed charge is a different issue and is not converted into a provider surcharge by this report. [C013; S001, subdivision 3; S006, clauses (5), (7), (8), (16).] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.14)\n\nThe “recurring payments” no-fee rule has a specific listed subject matter: current living and support obligations such as rent, mortgage, utilities, telephone, child support and insurance. It should not be misread to mean that **every recurring monthly DMP installment** is fee-free. Conversely, handling current rent does not enlarge the fee-bearing DMP base merely because the same transfer also includes plan money. [C014; S001, subdivision 4.]\n\nAdditional or separate agreements do not authorize another origination charge. Modifications have their own signed-writing rule and limited exceptions; they do not create an unrestricted new fee. [C027; S003, subdivision 5.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.10)\n\n### C4. Advance-payment restriction and exceptions\n\n| Agreement cadence or circumstance | Operative treatment | What it does not establish |\n| --- | --- | --- |\n| Monthly payment | Fee receipt/retention restricted when the debtor pays **more than 42 days early** | That a payment 42 days early is automatically fee-earned |\n| Biweekly payment | Corresponding threshold: **more than 15 days early** | A new monthly maintenance allowance for every receipt |\n| Weekly payment | Corresponding threshold: **more than seven days early** | Permission to disregard creditor distribution deadlines |\n| Agreement has no specified payment amounts | Portion exceeding twice the average prior regular payment is deemed advance payment | A defined average where no prior regular payments exist |\n| Debtor intends the advance to satisfy contractual obligations due within 30 days | Subdivision 5 does not apply to that circumstance | Waiver of fee ceilings, reasonableness, other state duties or federal predicates |\n\nSubdivision 5 expressly overrides inconsistent provisions of the chapter. The restriction concerns **fees for advance payments**; it is not itself a complete rule about whether funds may be accepted, how long they may be held, or when creditors must receive them. [C015–C017; S001, subdivision 5; S008, article 3, §56.] [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nFor an unspecified-amount agreement with previous regular payments of $100, $150 and $200:\n\nPlain text\n```\nAverage prior payment = ($100 + $150 + $200) ÷ 3 = $150.\nTwice that average = $300.\nNew $400 payment: $100 is deemed advance payment.\n```\n\nThat classification still needs the applicable date and 30-day-intent analysis. It is not a self-executing permission to charge on the entire $400.\n\n### C5. Custody, availability and creditor distribution use different clocks\n\nThe necessary trust rules require available payments to enter the separate trust account. Disbursements to the debtor, creditors and provider originate there, subject to the limited debtor/creditor disbursement-account route. The narrow minimum-bank-balance commingling allowance does not turn debtor funds into operating revenue. [C020; S001, subdivision 8; S009, §8.] [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nThe distribution deadline is measured from **receipt**, not automatically restarted when funds become available: creditors must be paid within 42 days, or earlier where their agreement requires it. The statute contains specified longer-holding circumstances, including reasonable accumulation of a sum certain and a returned payment or another reason making withholding in the debtor’s net interest. These are factual exceptions, not a general 42-day float or permission to accumulate provider fees. [C021; S001, subdivision 9.]\n\nA returned check may require both a provisional-credit reversal in the bank reconciliation and a separate debtor-ledger notation. It does not become a creditor payment. If no cash ever became available, the available-cash model below records zero receipt and separately records the failed attempt.\n\n### C6. Consent, insufficient payments and withdrawal\n\nThe provider must actively seek all creditor consent. Minnesota permits evidence of consent through acceptance of a plan payment as well as express writing. Failure to obtain consent has a ten-day notice requirement; withdrawal or refusal has a prompt-notice requirement with a fifteen-day outside limit. The notices include the specified cancellation information. Where both provisions potentially apply, a provider should not use the longer outside limit to disregard the shorter applicable requirement. [C018–C019; S001, subdivisions 6–7.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.13)\n\nA short payment does not make its full scheduled amount available. For example, if $100 is received against a $400 scheduled payment, the receipt-level retention ceiling is $15. Whether a maintenance receivable otherwise exists depends on the agreement, service and monthly-base interpretation; it is not established simply because the contract originally contemplated $400. [C011, C042.]\n\nThe statute does not supply a general instruction to stop paying creditors while a fee balance accumulates. The related prohibitions against encouraging or condoning stopped creditor payments and plans involving negative amortization remain relevant. [S006, clauses (3), (4), (9), (13).] [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.14)\n\n### C7. Cancellation, termination and fee refunds\n\nThese events require different ledgers:\n\n| Event | Custody treatment | Treatment of prior fees |\n| --- | --- | --- |\n| Debtor cancels without cause on ten days’ written notice | Notify creditors and return unexpended funds within ten days of cancellation | Ordinary cancellation does not itself establish return of every previously lawful fee |\n| Provider cancels for good cause | Thirty days’ written notice; creditor notice and unexpended-funds return within ten days after cancellation | No immediate-forfeiture rule inferred from a missed installment |\n| All listed debts and fees are paid | Automatic termination; immediate return of unexpended funds | No continued maintenance merely because a surplus remains |\n| Material Chapter 332A violation followed by rescission | Separate from ordinary cancellation | Section 332A.17 requires return within ten days of fees paid to the provider or other noncreditors |\n\nThe protection in §332A.13(6) for origination and previously earned fees is not treated as validating an originally unlawful charge or overriding the distinct material-violation rescission provision. Nor does this report invent a universal DMP “immediate excess-fee refund” rule borrowed from the settlement chapter. [C023–C026; S001, S004, S007.] [MN Revisor+2](https://www.revisor.mn.gov/statutes/cite/332A.11)\n\nMonthly and cancellation/termination statements must distinguish receipts, creditor disbursements and deducted fees. The provider must maintain the relevant records for the statutory period. [C022; S005.] [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.12)\n\n## D. Essential federal interaction—DMP-specific, not settlement-derived\n\n### D1. Coverage assumptions\n\nThe positive models below assume a nonexempt for-profit provider selling an unsecured consumer-debt concession DMP through a covered telephone campaign involving interstate calls. That fits the relevant federal debt-relief and telemarketing definitions **on the stipulated facts**, not merely because the service is called a DMP. [C028; S012.] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nThe following distinctions remain necessary:\n\n| Actual facts | Consequence for this pass |\n| --- | --- |\n| Service represents that it will reduce interest, waive fees, or otherwise alter unsecured-debt terms | Potential debt-relief service even where principal will be repaid in full |\n| Pure payment processing with no represented alteration of debt terms | Debt-relief coverage cannot be presumed from payment custody alone |\n| Consumer responds to debt-relief advertising or direct mail | The ordinary inbound advertising/direct-mail exemptions contain debt-relief carve-outs |\n| Truly unsolicited call without prior solicitation | The separate exemption and its conditions require examination |\n| Qualifying face-to-face sales presentation | Specific sequencing and residual-coverage rules apply; not a universal exemption |\n| Provider claims nonprofit status | Actual jurisdictional/entity facts must be established; neither universal TSR coverage nor exemption is assumed |\n| No covered telephone campaign | This pass does not apply the telemarketing rule solely because a website or DMP exists |\n\nThese distinctions come from the freshly read definitions and exemptions. No actual provider’s nonprofit, institutional or other jurisdictional status was adjudicated. [C028–C029; S012, S014.] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\n### D2. What the Commission specifically says about DMPs\n\nThe operative rule requires a qualifying alteration under a customer-executed agreement and a payment under that agreement. Its individual-debt allocation provision applies **to the extent debts are altered individually**. [C030; S013, §310.4(a)(5)(i).] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe Commission’s final-rule explanation addresses DMPs directly. At **75 FR 48489, section III.C.5(a), and footnote 431**, it describes:\n\n- a customer-executed plan with altered terms binding the applicable creditors;\n- evidence of the consumer’s first payment **to the credit-counseling agency for distribution to creditors**;\n- a DMP model in which eligible debts are renegotiated together, rather than individually; and\n- subsequent periodic servicing fees after the qualifying enrollment and first payment.\n\nThus, that described DMP does **not** need to wait until all principal is repaid before any fee may be collected. [C031–C032; S015.] [Federal Register+1](https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule)\n\nThis is the Commission’s published explanation of its rule—not a Minnesota fee interpretation and not a blanket exception for any business using a DMP label. If creditors join at different times, terms are not binding, or debts are individually altered, the factual premise for the footnote’s treatment must be re-examined.\n\n### D3. Separate state and federal predicates\n\n| Proposed event | Minnesota question | Federal question for a covered DMP |\n| --- | --- | --- |\n| Agree on a fee schedule | Is it disclosed and within authorized categories and limits? | Disclosure of a conditional fee is not a substitute for the payment predicates |\n| Receive first plan funds | Executed agreement, proper custody and advance-payment analysis | Is there the qualifying executed, binding DMP described by the rule and Commission? |\n| Transfer origination fee | Initial-payment classification and collective retention limit | Has the qualifying enrollment and first payment occurred? |\n| Transfer monthly servicing fee | Contract, reasonable services, monthly ceiling and receipt-level limit | Is it a subsequent servicing charge within the described DMP structure? |\n| Treat only one creditor as participating | Consent, notification, feasibility and contract issues | Do individual-debt allocation and timing requirements now matter? |\n| Debit a bank account | Entitlement and custody must still be lawful | Applicable express informed consent to the charge and identified account is separately required |\n\nNo federal predicate increases Minnesota’s dollar ceiling, creates a state fee category, or supplies an exception to the periodic-retention restriction. [C030–C034.] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### D4. Account accumulation is not the same as ordinary DMP distribution\n\nThe dedicated-account provision has insurance, consumer ownership, administrator independence, referral-compensation and withdrawal/return conditions. A provider-controlled Minnesota trust account is **not automatically** the independent account contemplated by that federal provision. [C033; S013, §310.4(a)(5)(ii).] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe models do not use a pre-trigger savings account to pay an advance fee. They assume a binding DMP before the first scheduled plan payment and postpone fee transfers until after the qualifying event. The specific federal treatment of an alternative pre-trigger custody arrangement remains held.\n\nThe models also use consumer-initiated payments, not a claim that an automatic debit arrangement has been approved. Other payment-rail or bank-account rules remain outside this limited review. **CROA and TSR credit-repair applicability remain separate boundaries if actual representations make them relevant.**\n\n## E. Actor-and-event decision table\n\n| Actor/event | Required factual record | Proper ledger treatment | What cannot be inferred |\n| --- | --- | --- | --- |\n| Provider conducts pre-agreement assessment | Counseling, financial analysis, proposed plan, affordability and creditor information | Pre-agreement work is separately identified | An independent “consultation” or “enrollment” fee is authorized |\n| Debtor and provider execute agreement | Signed terms, cadence, gross payment, fee schedule, creditor allocations, refund provisions | Establish contractual obligations—not cash receipt | Every disclosed fee is immediately collectible |\n| Debtor authorizes a bank payment | Amount, purpose and applicable consent | Authorization record separate from entitlement | Authorization cures an excessive or premature fee |\n| Bank receives a check or transfer instruction | Pending/cleared/available status and any reversal | Pending instruments separately reconciled | A pending or returned item funded creditors |\n| Provider receives available plan money | Trust receipt with debtor-specific allocation | Custody asset and corresponding debtor-funds responsibility | Entire receipt is provider revenue |\n| Provider proposes origination deduction | Initial-payment classification, lawful amount, joint retention calculation, federal trigger where applicable | Fee transfer only when predicates are met | “Nonrefundable” defeats every cancellation or violation remedy |\n| Provider proposes maintenance deduction | Services, contract, monthly total, each receipt’s retention capacity | Separate monthly and per-receipt checks | $75 is available for each weekly payment |\n| Creditor accepts a payment | Creditor credit date, amount and allocation | Reduce the creditor balance by the amount actually credited | Provider receipt itself reduced the debt |\n| Creditor refuses or withdraws | Date learned, affected payment, required notices | Revise projections and preserve funds accurately | Immediate additional fees or automatic cancellation |\n| Debtor misses or underpays | Actual available cash, contract treatment and creditor consequences | No fictitious receipt; no fictitious creditor credit | A scheduled amount is cash, or late charges are authorized |\n| Debtor cancels | Notice, effective date, unexpended funds, prior lawful fees | Separate custody return from fee-refund analysis | All old fees are refundable—or all are protected |\n| Provider cancels | Good cause and thirty-day notice | Required creditor notice and return following cancellation | One failed payment permits immediate forfeiture |\n| Plan completes | All listed debts and lawful fees paid | Immediate surplus return | Surplus may be retained for future maintenance |\n| Material violation is rescinded | Violation and rescission facts | Separate return of qualifying prior fees | Ordinary cancellation and statutory rescission are identical |\n\nThese are evidence and accounting tests derived from the cited provisions, not a complete account-control or compliance manual. [C007–C035.] [MN Revisor+4](https://www.revisor.mn.gov/statutes/cite/332A.10)\n\n## F. Fourteen fresh fictional postures\n\nAll are hypothetical. None concerns an actual provider or debtor.\n\n| Posture | Facts | Result or exact hold |\n| --- | --- | --- |\n| **P01 — Nominal pre-agreement payment** | Provider requests $10 to “open the plan” before an executed agreement | No established authority to accept it as plan money or a third fee category. |\n| **P02 — First $300 periodic payment** | Proposed $50 origination and $45 maintenance | Aggregate $95 retention is unsupported; see M01. |\n| **P03 — First $1,000 periodic payment** | $50 origination and $75 reasonable maintenance; all other predicates met | Both fit the individual and collective numerical constraints; see M02. |\n| **P04 — Separate $50 payment** | Described as fee-only, in addition to $300 monthly plan money | Classification remains held. A pre-trigger fee also fails the modeled federal timing condition; see M03. |\n| **P05 — Four weekly receipts** | Four $200 payments in one month; provider takes $25 each | Each $25 is below $30, but $100 monthly maintenance exceeds $75. A different $18.75-per-receipt schedule totals $75, subject to services and contract. |\n| **P06 — Monthly receipt 43 days early** | No obligation within 30 days is identified | Subdivision 5 bars the related fee receipt/retention. Custody and distribution still require separate analysis. |\n| **P07 — Biweekly receipt 16 days early** | No applicable 30-day exception | Same restriction; the threshold is more than fifteen days. Exactly fifteen days does not itself establish earning. |\n| **P08 — Weekly receipt eight days early** | Debtor documents intent to satisfy a contractual obligation due within thirty days | The subdivision 5 exception may apply; other caps and predicates remain. |\n| **P09 — Variable payments** | Prior regular payments $100/$150/$200; new payment $400 | $100 is deemed advance. Missing due-date or intent facts remain material. No prior-payment history would leave the average unresolved. |\n| **P10 — Rent plus DMP money** | Transfer includes $500 current rent and $300 DMP payment | Do not charge a handling fee on rent or use it merely to enlarge the fee-bearing DMP base. |\n| **P11 — Direct-creditor payments** | Consumer pays creditors directly; provider only advises | Provider-custody ledger is zero for those payments. Minnesota classification and possible federal debt-relief coverage require the actual service/representation facts. |\n| **P12 — Partial scheduled payment** | $100 received against a $400 schedule; provider wants $30 | $30 exceeds the $15 receipt-retention limit even before resolving monthly-base and earning questions. |\n| **P13 — Returned payment** | $400 payment fails before cash becomes available | Record the failed transaction; do not record $400 of available funds or creditor reduction. No separate provider NSF fee was established. |\n| **P14 — Cancel or finish** | Debtor cancels, provider cancels for cause, or all debts and fees are paid | Apply the appropriate notice and return rule; these events do not share one universal deadline or fee-refund outcome. |\n\nAuthorities: C007, C009–C027, C028–C034, C041–C042. The numerical comparisons are original calculations; their legal conditions remain those stated above.\n\n# G. Fully worked joint funds models\n\n## Common assumptions and accounting convention\n\nThese are **conditional demonstrations**, not approvals.\n\nFor positive branches, assume a legally eligible registrant; a valid written agreement; required assessment and disclosures; reasonable actual services; unsecured consumer debts; customer-executed concessions binding both creditors before the first receipt; a covered for-profit interstate telephone-sales campaign; and no applicable exemption.\n\nFor transparent debt arithmetic, creditors agree to **0% interest and no additional charges during the illustrated period**. This is a fictional contract fact, not a prediction. Real creditor balances must incorporate actual interest, charges and application of payments.\n\nAll positive cash receipts are consumer-initiated and available on the stated date. No automatic-debit compliance is assumed. Fee transfers occur after the federal DMP trigger; maintenance is transferred after the modeled services.\n\nPlain text\n```\nOpening custody\n+ available receipts\n− lawful provider-fee transfers\n− creditor payments\n− returns to debtor\n= closing custody.\n```\n\nCreditor debt balances are calculated separately. A provider fee or debtor refund is never also counted as a creditor payment.\n\nAll selected amounts calculate exactly to cents. No statutory cent-rounding method was located. These examples do not round a fee upward beyond a computed ceiling.\n\n## M01 — The $300 adversarial test and a different, conditionally compliant contract\n\n### Inputs\n\n- Debts: A **$2,000**; B **$4,000**; total **$6,000**.\n- Agreement executed September 7, 2026.\n- Gross plan payment: **$300 monthly**, due on the tenth.\n- Creditor payments due on the fifteenth.\n- Creditor allocation: one-third to A, two-thirds to B.\n- Opening custody: **$0**.\n\n### Rejected proposal: $50 plus $45\n\nPlain text\n```\nMaintenance ceiling:\nmin(15% × $300, $75) = min($45, $75) = $45.\n\nAll-fee retention ceiling for this periodic payment:\n15% × $300 = $45.\n\nProposed fees:\n$50 + $45 = $95.\n\nRetention percentage:\n$95 ÷ $300 × 100 = 31.6667%.\n\nProposed creditor remainder:\n$300 − $95 = $205.\n\nMinimum creditor allocation under the 15% restriction:\n$300 − $45 = $255.\n\nDifference:\n$255 − $205 = $50.\n```\n\nEven taking **only** the full $50 origination from this ordinary $300 periodic payment exceeds the $45 collective retention ceiling. The independent $50 allowance has not been shown to override that ceiling. [C037.]\n\n### Alternative branch—not a retroactive cure\n\nA separately stipulated agreement instead sets **origination at $30** and **monthly maintenance at $15**. There is no additional $20 origination receivable.\n\n| Date/event | Receipts | Fee transfer | Creditor payment | Debtor return | Closing custody |\n| --- | --- | --- | --- | --- | --- |\n| September 10: available plan payment | $300.00 | — | — | — | $300.00 |\n| September 12: A receives $85; B receives $170 | — | — | $255.00 | — | $45.00 |\n| September 13: lawful origination transfer assumed | — | $30.00 | — | — | $15.00 |\n| September 30: reasonable maintenance services completed | — | $15.00 | — | — | $0.00 |\n\nPlain text\n```\nCash:\n$0 + $300 − $45 − $255 − $0 = $0.\n\nMonthly maintenance:\n$15 ≤ $45.\n\nCombined fee retention:\n($30 + $15) ÷ $300 = 15%.\n\nCreditor balances:\nA: $2,000 − $85 = $1,915.\nB: $4,000 − $170 = $3,830.\nTotal: $5,745.\n```\n\nBefore September 30, the remaining $15 is still custody money awaiting the modeled lawful fee transfer—not already spent revenue. After completion, closing custody and presently unearned held fees are zero.\n\n**Result:** The original $95 proposal is not supported. The different $45-total contract is numerically and conditionally reconcilable; reasonableness and the other assumed predicates are not established for any actual provider.\n\n## M02 — Both maximum component fees fit a larger initial periodic payment\n\n### Inputs\n\n- Debts: A **$4,000**; B **$6,000**.\n- Agreement executed September 1, 2026.\n- Gross monthly payment: **$1,000**, due on the fifth.\n- Creditor payments due on the fifteenth.\n- Origination **$50**; reasonable monthly maintenance **$75**.\n- Creditor allocation: 40% to A, 60% to B.\n\nPlain text\n```\nMaintenance ceiling:\nmin(15% × $1,000, $75) = $75.\n\nAll-fee retention ceiling:\n15% × $1,000 = $150.\n\nActual first-cycle fee total:\n$50 + $75 = $125.\n\nRetention percentage:\n$125 ÷ $1,000 = 12.5%.\n\nCreditor remainder:\n$1,000 − $125 = $875.\n\nMinimum creditor amount:\n85% × $1,000 = $850.\n\nActual creditor amount exceeds that minimum by $25.\n```\n\n| Date/event | Receipts | Fee transfer | Creditor payment | Debtor return | Closing custody |\n| --- | --- | --- | --- | --- | --- |\n| September 5: plan payment | $1,000.00 | — | — | — | $1,000.00 |\n| September 8: A $350; B $525 | — | — | $875.00 | — | $125.00 |\n| September 9: origination | — | $50.00 | — | — | $75.00 |\n| September 30: maintenance | — | $75.00 | — | — | $0.00 |\n\nPlain text\n```\nCash:\n$0 + $1,000 − $125 − $875 − $0 = $0.\n\nCreditor balances:\nA: $4,000 − $350 = $3,650.\nB: $6,000 − $525 = $5,475.\nTotal: $9,125.\n```\n\nThe unused $25 of retention capacity is **not another fee allowance**. It remains part of the creditor allocation. No second origination fee is assumed for a later payment.\n\n**Result:** This provides an initial-payment fact pattern permitting both component fees without needing an exception to the periodic-retention rule. It does not establish that $75 is reasonable for every provider’s services. [C038.]\n\n## M03 — Separate fee-only candidate: accounting balance does not establish legality\n\n### Inputs and disputed alternatives\n\n- Debts: A **$2,000**; B **$4,000**.\n- Scheduled monthly plan payment: **$300**.\n- Reasonable maintenance: **$45**.\n- Proposed additional origination payment: **$50**.\n\n**Candidate A:** Collect $50 before the qualifying DMP enrollment/first-payment event. The modeled federal rule does not permit this merely because it is called origination.\n\n**Candidate B:** Collect $50 separately after the qualifying event. Federal timing may no longer be the obstacle, but Minnesota classification remains unresolved.\n\nIf the two amounts are one $350 periodic payment in substance:\n\nPlain text\n```\n15% × $350 = $52.50 maximum collective retention.\nProposed $50 + $45 = $95.\nDifference = $42.50.\n```\n\nIf the $50 is genuinely nonperiodic, the statute’s separate-initial-payment interpretation must be established rather than assumed.\n\nThe following equation can balance physically while remaining legally unsupported:\n\nPlain text\n```\n$0 + $350 − $95 − $255 = $0.\n```\n\nThat is why bank reconciliation alone cannot validate the fee.\n\n### Demonstrated no-origination path\n\nFor this actual hypothetical ledger, the agreement **waives origination**. The consumer mistakenly sends an additional $50, which is never treated as earned and is returned.\n\n| Date/event | Receipts | Fee transfer | Creditor payment | Debtor return | Closing custody |\n| --- | --- | --- | --- | --- | --- |\n| September 10: scheduled payment | $300.00 | — | — | — | $300.00 |\n| September 11: mistaken extra payment | $50.00 | — | — | — | $350.00 |\n| September 12: A $85; B $170 | — | — | $255.00 | — | $95.00 |\n| September 13: extra $50 returned | — | — | — | $50.00 | $45.00 |\n| September 30: maintenance | — | $45.00 | — | — | $0.00 |\n\nPlain text\n```\nCash:\n$0 + $350 − $45 − $255 − $50 = $0.\n\nCreditor balances:\nA = $1,915.\nB = $3,830.\nTotal = $5,745.\n```\n\nThe $50 return does not reduce creditor debt and is not counted as a provider-fee refund because the model never treats it as a fee. Its return follows the stipulated waiver and mistaken-payment facts; it is **not** a holding that every separately paid origination fee must be refunded.\n\n**Result:** A lawful-looking cash balance does not resolve the separate-fee theory. The demonstrated branch avoids that unresolved theory rather than approving it. [C039.]\n\n## M04 — Missed payment, partial receipt and cancellation\n\n### Inputs\n\n- Debts: A **$3,000**; B **$5,000**.\n- Agreement executed July 1, 2026.\n- Gross payment **$400 monthly**, due on the fifth.\n- Creditor payment due on the fifteenth.\n- Origination waived.\n- Maintenance **$30 for a funded cycle**, expressly waived by the contract for a missed or underfunded cycle.\n- Creditors allocate payments 37.5% to A and 62.5% to B.\n- For this illustration only, creditors preserve the zero-interest/no-extra-charge terms during the missed-payment interval.\n\nThe maintenance waiver is a contractual fact—not a universal statutory requirement.\n\n### July: funded cycle\n\nPlain text\n```\nMaintenance ceiling = min(15% × $400, $75) = $60.\nContractual maintenance = $30.\nReceipt retention = $30 ÷ $400 = 7.5%.\nCreditor distribution = $370.\n```\n\nA receives $138.75; B receives $231.25.\n\n### August: failed payment\n\nThe attempted $400 payment is returned before funds become available. It is recorded as a failed transaction, not a $400 available-cash receipt. If a bank statement had shown provisional credit, the bank reconciliation would also show its reversal.\n\n### September: partial receipt and cancellation\n\nThe debtor gives written notice August 31. **September 10 is stipulated as the effective cancellation date**; this is not a legal notice-service computation.\n\nA $100 partial payment becomes available September 5. The contractual underfunded-cycle fee waiver applies. The next creditor due date is September 15. The $100 is returned September 12, with creditor notification and a closing statement.\n\n| Period/event | Receipts | Fee transfers | Creditor payments | Debtor returns | Closing custody |\n| --- | --- | --- | --- | --- | --- |\n| July 5 receipt | $400.00 | — | — | — | $400.00 |\n| July 8 creditor distributions | — | — | $370.00 | — | $30.00 |\n| July 31 maintenance | — | $30.00 | — | — | $0.00 |\n| August failed payment | $0.00 | $0.00 | $0.00 | $0.00 | $0.00 |\n| September 5 partial receipt | $100.00 | — | — | — | $100.00 |\n| September 12 cancellation return | — | $0.00 | $0.00 | $100.00 | $0.00 |\n\nPlain text\n```\nCombined cash:\n$0 + $500 − $30 − $370 − $100 = $0.\n\nCreditor balances:\nA: $3,000 − $138.75 = $2,861.25.\nB: $5,000 − $231.25 = $4,768.75.\nTotal = $7,630.\n```\n\nThe attempted August payment does not reduce debt. The September return does not reduce debt. Missed installments are not added a second time as new principal.\n\nOrdinary cancellation does not automatically require repayment of the assumed-lawful July $30 fee. **If a material violation and statutory rescission were separately established**, the fee-return analysis would change; the $30 would be a provider-fee return, not another creditor payment. The main model does not assume such a violation.\n\n**Result:** Closing custody is zero; creditor debt remains $7,630; no unearned funds remain held; no missed-cycle fee receivable exists because the stipulated contract waived it. [C040.]\n\n## H. Concise effect crosswalk to P01\n\n| Original example | Preserved arithmetic | PASS-06 legal effect |\n| --- | --- | --- |\n| **E05: $300 monthly payment** | $45 maintenance ceiling and $255 remainder | Preserved. It did not authorize adding a full $50 origination deduction to the same ordinary periodic receipt. M01 supplies the joint test; the separate-fee theory remains held. |\n| **E06: $800 monthly payment** | Maintenance ceiling $75; remainder $725; retention 9.375% | Preserved. Adding $50 would create $125 total retention against a $120 receipt-level ceiling. That addition is not approved merely because each component separately fits its own maximum. |\n\nNo original example, source-access date or reviewed record is rewritten. [C043–C044.]\n\n# I. Source register\n\n**Access convention:** All “fresh” entries below were accessed during this **October 27, 2026** research session. Individual fetch timestamps were not exposed and are not invented. Statutory sections within one chapter are separate retrieved bodies, not independent corroborating legal systems.\n\n| Source ID | Issuer, complete literal HTTPS URL | Actual read scope and operative pinpoint | Version/effect and limitations |\n| --- | --- | --- | --- |\n| **S_MN-P06-S001** | Minnesota Revisor, §332A.13. [https://www.revisor.mn.gov/statutes/cite/332A.13](https://www.revisor.mn.gov/statutes/cite/332A.13?utm_source=chatgpt.com) | **Fresh complete read:** subdivisions 1–9 and history. | Displayed 2025 text. Core fee, advance, consent and funds authority. [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.13) |\n| **S_MN-P06-S002** | Minnesota Revisor, §332A.02. [https://www.revisor.mn.gov/statutes/cite/332A.02](https://www.revisor.mn.gov/statutes/cite/332A.02?utm_source=chatgpt.com) | **Fresh targeted read:** subdivisions 5a–10 and 12; relevant provider/delegation/holding-out language and warning. | 2025 display with accreditation warning. Exemption categories not rerun. [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.02) |\n| **S_MN-P06-S003** | Minnesota Revisor, §332A.10. [https://www.revisor.mn.gov/statutes/cite/332A.10](https://www.revisor.mn.gov/statutes/cite/332A.10?utm_source=chatgpt.com) | **Fresh complete operative read:** subdivisions 1–5; relied on agreement prerequisites, assessment, fee/refund disclosures and modification rules. | 2025 display. No full contract-compliance approval. [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.10) |\n| **S_MN-P06-S004** | Minnesota Revisor, §332A.11. [https://www.revisor.mn.gov/statutes/cite/332A.11](https://www.revisor.mn.gov/statutes/cite/332A.11?utm_source=chatgpt.com) | **Fresh complete read:** subdivisions 1–4 and history. | Debtor/provider cancellation and automatic termination. [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.11) |\n| **S_MN-P06-S005** | Minnesota Revisor, §332A.12. [https://www.revisor.mn.gov/statutes/cite/332A.12](https://www.revisor.mn.gov/statutes/cite/332A.12?utm_source=chatgpt.com) | **Fresh operative read:** subdivisions 1, 1a and 2; relied on records, monthly/final statements and access. | Annual regulatory reporting not developed beyond the read. [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.12) |\n| **S_MN-P06-S006** | Minnesota Revisor, §332A.14. [https://www.revisor.mn.gov/statutes/cite/332A.14](https://www.revisor.mn.gov/statutes/cite/332A.14?utm_source=chatgpt.com) | **Fresh operative body read:** relied particularly on clauses (3)–(5), (7)–(10), (12), (13), (16). | Necessary fee/payment prohibitions only; not a complete conduct dossier. [MN Revisor+1](https://www.revisor.mn.gov/statutes/cite/332A.14) |\n| **S_MN-P06-S007** | Minnesota Revisor, §332A.17. [https://www.revisor.mn.gov/statutes/cite/332A.17](https://www.revisor.mn.gov/statutes/cite/332A.17?utm_source=chatgpt.com) | **Fresh complete operative read:** material-violation rescission paragraph and history. | Distinguishes rescission from ordinary cancellation. [MN Revisor](https://www.revisor.mn.gov/statutes/cite/332A.17) |\n| **S_MN-P06-S008** | Minnesota Legislature/Revisor, Laws 2007, chapter 57. [https://www.revisor.mn.gov/laws/2007/0/57/](https://www.revisor.mn.gov/laws/2007/0/57/?utm_source=chatgpt.com) | **Fresh targeted enacted read:** article 3, §56, including its effective-date clause; relevant surrounding agreement/cancellation/records/rescission provisions inspected. | §56 expressly effective January 1, 2008. An initial history-link route failed; the direct act route succeeded. Not a full-act sequential read. [MN Revisor](https://www.revisor.mn.gov/laws/2007/0/57/) |\n| **S_MN-P06-S009** | Minnesota Legislature/Revisor, Laws 2008, chapter 210. [https://www.revisor.mn.gov/laws/2008/0/210/](https://www.revisor.mn.gov/laws/2008/0/210/?utm_source=chatgpt.com) | **Fresh targeted enacted read:** §§6, 8, 10 and signature. | §8 custody change effective April 22, 2008 under §10 and April 21 signature. [MN Revisor+1](https://www.revisor.mn.gov/laws/2008/0/210/) |\n| **S_MN-P06-S010** | Minnesota Legislature/Revisor, Laws 2009, chapter 37. [https://www.revisor.mn.gov/laws/2009/0/37/](https://www.revisor.mn.gov/laws/2009/0/37/?utm_source=chatgpt.com) | **Fresh targeted historical read:** article 4, relevant definition changes and §§15–16; end signature inspected. | Signed May 7, 2009. Exact effective-date chain for the selected historical amendments not completed; signature not substituted for effectiveness. [MN Revisor+1](https://www.revisor.mn.gov/laws/2009/0/37/) |\n| **S_MN-P06-S011** | Minnesota Revisor, 2026 statutes-changed Table 2. [https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026](https://www.revisor.mn.gov/statutes/2026/table2?full&page=5&per_page=500&year=2026&utm_source=chatgpt.com) | **Fresh index read:** relevant Chapter 332A entries, parsed lines 305–306 and surrounding entries. | Regular-session index; not a complete later/special-session certification. [MN Revisor](https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026) |\n| **S_MN-P06-S012** | OFR/eCFR, 16 CFR §310.2. [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com) | **Fresh relevant operative definitions:** customer, debt relief, person, seller, telemarketer and telemarketing; paragraphs (n), (o), (y), (ee), (hh), (ii). | Retrieved eCFR display current through October 23, 2026. Title-level amendment metadata is not attributed to this particular provision. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **S_MN-P06-S013** | OFR/eCFR, 16 CFR §310.4. [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-310.4?utm_source=chatgpt.com) | **Fresh complete relevant passages:** (a)(5)(i)(A)–(C), (ii)(A)–(E), and applicable (a)(7) consent provisions. | Same eCFR version limit. Credit-repair requirements not analyzed as applicable. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_MN-P06-S014** | OFR/eCFR, 16 CFR §310.6. [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com) | **Fresh operative exemptions read**, particularly (b)(3)–(7) and their exceptions. | Coverage depends on actual actor/campaign facts. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6) |\n| **S_MN-P06-S015** | FTC, final TSR amendments, 75 FR 48458. HTML: [https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule](https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule?utm_source=chatgpt.com) Official PDF: [https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf](https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf?utm_source=chatgpt.com) | **Fresh targeted Commission explanation:** III.C.5(a), printed page 48489, especially footnote 431; related timing/account discussion. Official PDF pages 31–32, printed pages 48489–48490, visually inspected. | One underlying final-rule document, not two independent authorities. Published August 10, 2010; (a)(5) effective October 27, 2010. Preamble interpretation is distinguished from current regulatory text. [Federal Register+3](https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule) |\n| **S_MN-P06-S016** | FTC, business compliance guide. [https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com) | **Fresh limited read:** DMP coverage, initial-fee evidence and entity qualifications. | Staff guidance, not binding Commission interpretation. Historical record-retention advice was not imported as current law. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) |\n| **S_MN-P06-S017** | Minnesota Commerce, Consumer Credit Code Adjustments. [https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/](https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/) | **Fresh body read:** 2026 adjustment authority and covered statutes, lines 19–44. | Effective July 1, 2026 notice concerns Chapter 56 and §47.59, not §332A.13. [mn.gov // Minnesota's State Portal](https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/index.jsp) |\n\n### Interpretation search and unsuccessful/discovery routes\n\nThe bounded search used the exact statute and combinations including:\n\n\"332A.13\" \"origination\" \"periodic\" court\n\"332A.13\" \"initial\" \"fee\" interpretation\n\"332A.13\" site:mncourts.gov\n\"332A.13\" site:mn.gov/commerce\n\"332A.13\" site:revisor.mn.gov/rules\n\"332A.13\" \"opinion\"\n\"332A\" \"fee\" \"inflation\" site:mn.gov\n\nNo responsive published judicial-majority opinion or binding agency interpretation was located and opened resolving the separate-initial-fee classification or supplying an exception to the periodic-retention limit. Some searches returned irrelevant material; those results are not evidence of nonexistence.\n\nNo unpublished opinion, party argument, headnote or search snippet is used as law. No operative administrative rule was relied upon without its body being read. The missing interpretation is a **research gap**, not an identified inaccessible decision whose contents are presumed.\n\nP01 E05/E06 and the coordinator’s review history are **supplied historical context**, not fresh public-source readings. P02/P04 operational and registration conclusions were not used to establish fee earning.\n\n# J. Atomic claim register\n\n“High—text” means the retrieved wording directly supports the claim, within the source-version limits. “Conditional” means application depends on stipulated or missing facts. “Held” identifies an unresolved interpretation.\n\n| Claim | Precise actor/predicate/effect | Authority and pinpoint | Confidence, exceptions and limits |\n| --- | --- | --- | --- |\n| **C001** | Retrieved Minnesota bodies are 2025 displays; targeted 2026 index entries do not identify a fee-section change | S001–S007; S011 Chapter 332A entries | High as version/index finding; no all-later-law certificate |\n| **C002** | The relevant original §332A.13 enactment became effective January 1, 2008 | S008, article 3, §56 effective-date clause | High—enacted text |\n| **C003** | The 2008 funds-availability/disbursement-account amendment became effective April 22, 2008 | S009, §§8, 10 and signature | High—express chain |\n| **C004** | No indexing authority appears in §332A.13; the retrieved 2026 adjustment notice covers different statutes | S001 complete body; S017 lines 19–44 | High for these bodies; not proof that every possible notice was searched |\n| **C005** | DMP classification principally involves provider receipt/distribution for full repayment of consumer-purpose debt | S002, subdivision 9 | High—text; actual service facts necessary |\n| **C006** | Delegation and holding out matter; a direct-payment label does not conclusively resolve classification | S002, subdivisions 8–10, 12 | Conditional application |\n| **C007** | Executed agreement and prescribed pre-agreement steps precede covered services/plan money | S003, subdivisions 1–2 | High—text |\n| **C008** | Agreement must disclose fees, services, anticipated charges, refund and cancellation terms | S003, subdivision 3 | High—text; actual agreement not supplied |\n| **C009** | Registrant may charge an origination fee not exceeding $50 from the initial amount | S001, subdivision 1 | High—text; other restrictions still apply |\n| **C010** | Maintenance must be reasonable and no greater than the lesser of 15% monthly payment or $75 | S001, subdivision 2 | High—text; monthly-base and service facts matter |\n| **C011** | Combined fee retention from any periodic payment is limited to 15%; creditor allocation must respect the remainder | S001, subdivision 4; S008, §56 | High—text; initial-periodic application is the stated combined reading, not a located holding |\n| **C012** | A genuinely separate fee-only initial payment is not resolved by the retrieved definitions or an opened controlling interpretation | S001–S003; bounded search | Held; no approval by invoice/debit label |\n| **C013** | Other provider charges and debtor “voluntary contributions” lack authority under the relied-on provisions | S001, subdivision 3; S006, clause (16) | High—text; bank-imposed charges and broader remedies not decided |\n| **C014** | Handling the listed recurring living/support payments cannot generate provider handling fees | S001, subdivision 4 | High—text; additional rule-prescribed categories not exhaustively investigated |\n| **C015** | Fee receipt/retention is restricted for payments more than 42/15/7 days early under monthly/biweekly/weekly schedules | S001, subdivision 5 | High—text; 30-day exception remains |\n| **C016** | For unspecified amounts, excess over twice the prior regular-payment average is deemed advance | S001, subdivision 5 | High—text; no-history computation unresolved |\n| **C017** | Debtor intent to satisfy contractual obligations due within thirty days removes subdivision 5’s restriction | S001, subdivision 5 | High—text; not a waiver of all other restrictions |\n| **C018** | Provider must seek creditor consent; failure invokes the specified ten-day notice/cancellation-right requirement | S001, subdivision 6 | High—text; acceptance of payment may evidence consent |\n| **C019** | Creditor withdrawal/refusal invokes prompt notice, no later than fifteen days after learning of it | S001, subdivision 7 | High—text; does not displace a separately applicable shorter requirement |\n| **C020** | Available payments belong in the separate trust process; statutory routing and narrow commingling exception apply | S001, subdivision 8; S009, §8 | High—text; full trust-control compliance deferred |\n| **C021** | Creditor disbursement runs from receipt, within42 days or earlier creditor due date, subject to stated exceptions | S001, subdivision 9 | High—text; factual exception required |\n| **C022** | Provider must maintain records and provide monthly and cancellation/termination accounting of receipts, payments and fees | S005, subdivisions 1–2 | High—text |\n| **C023** | Debtor cancellation uses ten days’ written notice and a ten-day post-cancellation unexpended-funds/creditor-notice duty | S004, subdivision 1 | High—text; effective notice date fact-dependent |\n| **C024** | Provider good-cause cancellation requires thirty days’ notice; completed plans automatically terminate with immediate surplus return | S004, subdivisions 3–4 | High—text |\n| **C025** | Ordinary cancellation/default does not by itself require return of lawful origination and prior earned fees | S001, subdivision 6; S004 | High as limited rule; does not validate unlawful fees or decide all earning facts |\n| **C026** | Material-violation rescission requires qualifying noncreditor fee returns within ten days | S007, operative paragraph | High—text; actual violation and rescission required |\n| **C027** | Additional agreements do not authorize another origination fee; modifications follow specified writing/exception rules | S003, subdivision 5 | High—text; no fee-reset workaround |\n| **C028** | TSR coverage requires the defined actor, service and telephone-campaign predicates | S012, (n), (o), (y), (ee), (hh), (ii) | High—text; modeled facts assumed |\n| **C029** | Inbound, unsolicited and face-to-face exemptions have distinct conditions; nonprofit status is not resolved by a label | S014, (b)(3)–(7); S015–S016 limited explanation | Conditional; actual entity jurisdiction deferred |\n| **C030** | Covered debt-relief fee collection requires the operative result/agreement/payment predicates and applicable individual-debt allocation | S013, (a)(5)(i) | High—text |\n| **C031** | Commission DMP explanation recognizes a binding customer-executed DMP and first payment to the counseling agency for creditors | S015, III.C.5(a), 75 FR48489 | Strong federal interpretive evidence; not Minnesota construction |\n| **C032** | Under the described jointly renegotiated DMP, individual-debt allocation does not apply and later servicing fees may be collected | S015, footnote431 | Conditional on that factual model; not every DMP label |\n| **C033** | Federal dedicated-account conditions are not established merely by a provider-controlled Minnesota trust account | S013, (a)(5)(ii) | High text plus conditional application |\n| **C034** | Billing authorization is separately required; it does not cure fee entitlement defects | S013, (a)(7) | High—text; other payment-rail law deferred |\n| **C035** | Receipt, fee transfer, creditor credit and debtor return must be separately accounted for | S001, subdivisions 8–9; S005, subdivision 2 | Analytical consequence; actual creditor posting needed |\n| **C036** | No responsive opened majority opinion or binding agency construction resolved the initial-fee exception issue | Search record | Bounded search finding, not nonexistence |\n| **C037** | M01’s proposed $95 retention exceeds the $45 limit; the different $30+$15 contract reconciles conditionally | M01; C009–C011 | Verified arithmetic; hypothetical legal assumptions |\n| **C038** | M02’s $125 from $1,000 satisfies the joint numerical constraints | M02; C009–C011 | Verified arithmetic; reasonableness/timing assumed |\n| **C039** | M03 demonstrates that a zero cash balance can coexist with an unsupported separate-fee theory | M03; C012, C030–C034 | Conditional; demonstrated branch waives origination |\n| **C040** | M04 separates failed receipts, lawful fees, creditor payments and cancellation returns | M04; C020–C026 | Verified ledger; contract waivers and creditor concessions stipulated |\n| **C041** | Weekly/biweekly receipts must satisfy both per-receipt retention and the monthly maintenance ceiling | C010–C011; P05 | Combined reading; irregular-month details held |\n| **C042** | Underpayment limits current retention by the actual periodic receipt; missed-cycle fee earning is not automatic | C010–C011, C015–C017; P12–P13 | Conditional; actual contract/service/base required |\n| **C043** | P01 E05 arithmetic survives, but does not establish $95 retention from $300 | Supplied P01 E05; C037 | Historical reuse plus fresh application |\n| **C044** | P01 E06 arithmetic survives; adding $50 would exceed the $800 payment’s $120 retention limit | Supplied P01 E06; C011 | Historical reuse plus arithmetic |\n| **C045** | No actual provider, account, claimant, contract, broader-state or A066 approval follows | Scope and evidence limits | Express limitation |\n\n# K. Granular coverage and remaining evidence\n\n| Subissue | Status | Claims/models | Exact missing evidence or next action |\n| --- | --- | --- | --- |\n| Complete §332A.13 operative body | **Answered** | C009–C021 | All subdivisions read; interpretation gaps separately retained |\n| Relevant DMP/debtor/provider/creditor definitions | **Answered textually** | C005–C006 | Actual service and delegation facts |\n| Initial/periodic/monthly/earned definitions | **Partial** | C012, C025, C042 | Responsive authority or actual contract where statutory terms are not expressly defined |\n| $50 origination ceiling | **Answered** | C009 | Actual agreement and lawful timing |\n| Maintenance ceiling and reasonableness | **Answered textually** | C010 | Evidence of actual services and reasonableness |\n| Combined first-periodic-payment retention | **Answered as combined textual reading** | C011, M01–M02 | No located controlling contrary/confirming construction |\n| Genuine separate fee-only payment | **Unresolved** | C012, M03 | Published majority opinion or binding agency interpretation addressing classification |\n| Split debit/relabeling theory | **No authority established** | C012 | Actual legal basis; operational labels alone insufficient |\n| Nominal enrollment/application charge | **Answered narrowly** | C007, C013, P01 | No third consumer-fee category established |\n| Registration/bond costs versus consumer fees | **Answered boundary** | C013 | Registration/bond compliance itself deferred |\n| Inflation/indexing | **Answered for read authorities** | C004 | No applicable DMP notice found; broader notice sweep not certified |\n| 2007 fee enactment/effective date | **Answered** | C002 | None within the stated provision |\n| 2008 funds amendment/effective date | **Answered** | C003 | None within the stated provision |\n| Selected 2009 historical effective-date chain | **Partial** | S010 | Complete applicable general/specific date analysis; no guessed date used |\n| Current 2026 regular-session check | **Answered narrowly** | C001 | Complete later/special-session consolidation remains separate |\n| Written agreement and disclosures | **Answered for ledger purposes** | C007–C008 | Actual executed agreement and assessment records |\n| Extra origination/modification fees | **Answered** | C027 | Actual modification facts and applicable limited exception |\n| Monthly advance threshold | **Answered** | C015, P06 | Actual agreement due date |\n| Biweekly advance threshold | **Answered** | C015, P07 | Same |\n| Weekly advance threshold | **Answered** | C015, P08 | Same |\n| Variable-payment calculation | **Answered with boundary** | C016, P09 | Date/intent facts; no-history average unresolved |\n| Thirty-day obligation exception | **Answered conditionally** | C017 | Evidence of debtor intent and contractual obligation |\n| Weekly/biweekly monthly aggregation | **Answered in principle** | C041, P05 | Actual monthly base and irregular-month treatment |\n| Recurring living-expense handling | **Answered for statutory list** | C014, P10 | Any additional commissioner-rule categories not exhaustively reviewed |\n| Custody receipt versus fee earning | **Answered analytically** | C020, C035 | Actual transaction and subledger records |\n| Availability versus receipt clocks | **Answered** | C020–C021 | Actual receipt/availability dates and any return |\n| Trust-to-provider/creditor/debtor routing | **Answered narrowly** | C020 | Full trust controls and bank documentation deferred |\n| Creditor distribution deadline | **Answered** | C021 | Creditor due dates and actual credits |\n| Accumulation/returned-payment exceptions | **Answered textually** | C021 | Fact-specific reasonable/net-interest evidence |\n| Creditor consent | **Answered** | C018 | Actual binding concessions and consent evidence |\n| Withdrawal/refusal notice | **Answered** | C019 | Date learned and notices |\n| Direct-creditor/noncustodial branch | **Partial** | C006, P11 | Actual service, representations, delegation and control |\n| Insufficient payment | **Partial application** | C042, P12 | Contractual monthly-base and earning facts |\n| Late/missed/NSF payment | **Answered for modeled facts** | P13, M04 | Real creditor consequences and bank reconciliation |\n| Monthly/final accounting | **Answered** | C022 | Actual statements not supplied |\n| Ordinary debtor cancellation | **Answered** | C023, C025 | Actual notice/effective date and lawful prior fees |\n| Provider cancellation | **Answered** | C024 | Good cause and thirty-day notice |\n| Automatic termination | **Answered** | C024 | Proof all listed debts and lawful fees paid |\n| Material-violation rescission | **Answered narrowly** | C026 | Actual material violation and exercise of rescission |\n| Federal actor/service/telephone coverage | **Answered conditionally** | C028–C029 | Actual entity and campaign facts |\n| Federal DMP first-fee trigger | **Answered for described DMP** | C030–C032 | Executed binding plan and qualifying first payment |\n| DMP subsequent servicing fees | **Answered federally, state limits separate** | C032 | Actual service/contract/state compliance |\n| Staggered creditor participation | **Unresolved application** | C030–C032 | Whether individual-debt treatment applies and corresponding records |\n| Pre-trigger dedicated account | **Partial** | C033 | Actual ownership, administration, independence and account terms |\n| Bank-debit authorization | **Answered narrowly** | C034 | Actual consent; other payment-rail requirements deferred |\n| P01 nominal enrollment posture | **Completed** | P01 | Hypothetical only |\n| P02–P04 initial-payment postures | **Completed with separate-fee hold** | P02–P04 | M01–M03 specify assumptions |\n| P05 cadence posture | **Completed** | P05 | Irregular-month interpretation remains open |\n| P06–P09 advance-payment postures | **Completed conditionally** | P06–P09 | Date/intent/history facts stated or held |\n| P10–P11 living-expense/direct-pay postures | **Completed with classification limits** | P10–P11 | Actual service/account facts |\n| P12–P14 shortage/failure/exit postures | **Completed** | P12–P14 | Real contract and creditor facts |\n| M01 $300 adversarial joint ledger | **Completed** | C037 | Not actual fee approval |\n| M02 larger initial joint ledger | **Completed conditionally** | C038 | Reasonableness and other assumptions essential |\n| M03 separate-fee candidate | **Completed; authority held** | C039 | Responsive classification authority |\n| M04 missed-payment/cancellation ledger | **Completed conditionally** | C040 | Waivers/concessions are stipulated, not universal |\n| P01 E05 crosswalk | **Completed** | C043 | Original preserved |\n| P01 E06 crosswalk | **Completed** | C044 | Original preserved |\n| Responsive judicial/administrative interpretation | **Not located in bounded search** | C036 | Further official published-opinion/Commerce-order research on exact issue |\n| P05 settlement-performance component | **Excluded; not a premise** | C045 | Separate review remains separate |\n| NMLS/current provider status/2026 transition | **Deferred/preserved** | C045 | P02/P04 holds unchanged |\n| Full trust/bond compliance | **Deferred** | C045 | Account-control, bond and broader supervision component |\n| Nonprofit/attorney registration and exemptions | **Deferred** | C045 | Actual entity/activity qualification |\n| CROA and broader federal credit repair | **Deferred boundary** | C045 | Actual representations and separate operative review |\n| Collection/litigation/wage/bank/other property | **Deferred** | C045 | Separate parent-state components |\n| Sector/local/tribal and remaining state dimensions | **Deferred** | C045 | No completion or acceptance by implication |\n\n## L. Researcher self-check and final disposition\n\n**Actually read:** The complete §332A.13 body; necessary Chapter 332A definitions, agreement, cancellation, records, prohibitions and rescission provisions; the material 2007 and 2008 fee/funds enactments; selected 2009 historical amendments; targeted 2026 index entries; the current Commerce adjustment notice; fresh operative federal definitions, debt-relief fee/account conditions and exemptions; and the Commission’s DMP-specific final-rule explanation. The relevant official Federal Register PDF pages were visually inspected.\n\n**Not established:** A controlling Minnesota interpretation approving a genuinely separate fee-only initial payment, an exception allowing $95 from a $300 ordinary periodic payment, a universal definition of maintenance earning in missed or irregular months, a complete historical 2009 date chain, or exhaustive later-law/rule/case coverage. No actual contract, account or provider record was supplied or examined.\n\nThe ledgers distinguish available custody cash, fee transfers, creditor credits and debtor returns. Their calculations were checked; their legal assumptions remain explicit. No local artifact or publication is claimed.\n\n**Bottom line:** Both origination and maintenance can fit within one initial periodic payment when the combined retention limit is respected. The $1,000 model demonstrates that without inventing an exception. The $300/$95 proposal does not. A separate fee-only transfer remains an unresolved legal classification, not an accounting workaround. Federal DMP timing must be tested on the DMP’s actual structure, while Minnesota’s fee, custody, distribution and cancellation requirements continue independently.\n\nNo component, state, parent, operational, publication or A066 acceptance is implied.\n\n**END S_MN PASS-06** \n\n","tables":[{"headers":["Proposed first-payment treatment","Calculation","Result within this pass"],"index":0,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Proposed first-payment treatment","Calculation","Result within this pass"],["$300 periodic payment; $50 origination plus $45 maintenance","$95 retained; 31.6667% of receipt; $205 left for creditors","No supported route. It exceeds the $45 aggregate retention limit by $50."],["$300 periodic payment; contract instead specifies $30 origination plus $15 maintenance","$45 retained; 15%; $255 for creditors","Conditionally compatible with the numerical limits. Contract, services, timing, consent and distribution conditions remain necessary."],["$1,000 periodic payment; $50 origination plus $75 maintenance","$125 retained; 12.5%; $875 for creditors","Conditionally compatible with both individual ceilings and the aggregate retention limit."],["$50 genuinely separate fee-only payment plus a $300 periodic payment","Depends on whether the $50 is legally distinct from the periodic payment","Unresolved classification—not a permitted workaround."],["One $300 periodic obligation divided into a $50 “enrollment” debit and a $250 “plan” debit","Same underlying periodic obligation, merely split operationally","Splitting the transfer does not establish a statutory exception."]]},{"headers":["Construction","Supporting textual consideration","Missing authority"],"index":1,"links":[],"row_links":[[],[],[]],"rows":[["Construction","Supporting textual consideration","Missing authority"],["A genuinely separate initial origination payment is not a periodic payment","Subdivision 1 expressly permits an origination fee from the initial amount; subdivision 4 addresses periodic payments","A responsive construction explaining when a separate payment is genuinely outside subdivision 4, and how the agreement and payment schedule must reflect it"],["An initial transfer associated with the first scheduled plan payment remains subject to the periodic-payment limit","Subdivision 4 applies to fees authorized by the section and to any periodic payment","A responsive application to separately invoiced or separately debited amounts connected to the same scheduled obligation"]]},{"headers":["Authority","Material point","Effective/applicability finding"],"index":2,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Authority","Material point","Effective/applicability finding"],["Laws 2007, chapter 57, article 3, §56","Enacted the relevant §332A.13 origination, maintenance, periodic-retention, advance-payment, consent and funds structure","The section expressly became effective January 1, 2008."],["Laws 2008, chapter 210, §8","Changed the trust-deposit language to funds being available, and added the limited separate disbursement-account route","Section 10 makes §§1–9 effective the day following final enactment. The act was signed April 21, 2008; this change therefore took effect April 22, 2008."],["Laws 2009, chapter 37, article 4","Relevant DMP definition, agreement and cancellation amendments were inspected as historical context","The precise historical effective-date chain for these selected 2009 changes was not fully reconstructed. No particular 2009 date is asserted here."],["Displayed current section bodies","Supply the present wording used for the 2026 fictional models","Subject to the stated compilation and later-amendment limits."]]},{"headers":["Agreement cadence or circumstance","Operative treatment","What it does not establish"],"index":3,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Agreement cadence or circumstance","Operative treatment","What it does not establish"],["Monthly payment","Fee receipt/retention restricted when the debtor pays more than 42 days early","That a payment 42 days early is automatically fee-earned"],["Biweekly payment","Corresponding threshold: more than 15 days early","A new monthly maintenance allowance for every receipt"],["Weekly payment","Corresponding threshold: more than seven days early","Permission to disregard creditor distribution deadlines"],["Agreement has no specified payment amounts","Portion exceeding twice the average prior regular payment is deemed advance payment","A defined average where no prior regular payments exist"],["Debtor intends the advance to satisfy contractual obligations due within 30 days","Subdivision 5 does not apply to that circumstance","Waiver of fee ceilings, reasonableness, other state duties or federal predicates"]]},{"headers":["Event","Custody treatment","Treatment of prior fees"],"index":4,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Event","Custody treatment","Treatment of prior fees"],["Debtor cancels without cause on ten days’ written notice","Notify creditors and return unexpended funds within ten days of cancellation","Ordinary cancellation does not itself establish return of every previously lawful fee"],["Provider cancels for good cause","Thirty days’ written notice; creditor notice and unexpended-funds return within ten days after cancellation","No immediate-forfeiture rule inferred from a missed installment"],["All listed debts and fees are paid","Automatic termination; immediate return of unexpended funds","No continued maintenance merely because a surplus remains"],["Material Chapter 332A violation followed by rescission","Separate from ordinary cancellation","Section 332A.17 requires return within ten days of fees paid to the provider or other noncreditors"]]},{"headers":["Actual facts","Consequence for this pass"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Actual facts","Consequence for this pass"],["Service represents that it will reduce interest, waive fees, or otherwise alter unsecured-debt terms","Potential debt-relief service even where principal will be repaid in full"],["Pure payment processing with no represented alteration of debt terms","Debt-relief coverage cannot be presumed from payment custody alone"],["Consumer responds to debt-relief advertising or direct mail","The ordinary inbound advertising/direct-mail exemptions contain debt-relief carve-outs"],["Truly unsolicited call without prior solicitation","The separate exemption and its conditions require examination"],["Qualifying face-to-face sales presentation","Specific sequencing and residual-coverage rules apply; not a universal exemption"],["Provider claims nonprofit status","Actual jurisdictional/entity facts must be established; neither universal TSR coverage nor exemption is assumed"],["No covered telephone campaign","This pass does not apply the telemarketing rule solely because a website or DMP exists"]]},{"headers":["Proposed event","Minnesota question","Federal question for a covered DMP"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Proposed event","Minnesota question","Federal question for a covered DMP"],["Agree on a fee schedule","Is it disclosed and within authorized categories and limits?","Disclosure of a conditional fee is not a substitute for the payment predicates"],["Receive first plan funds","Executed agreement, proper custody and advance-payment analysis","Is there the qualifying executed, binding DMP described by the rule and Commission?"],["Transfer origination fee","Initial-payment classification and collective retention limit","Has the qualifying enrollment and first payment occurred?"],["Transfer monthly servicing fee","Contract, reasonable services, monthly ceiling and receipt-level limit","Is it a subsequent servicing charge within the described DMP structure?"],["Treat only one creditor as participating","Consent, notification, feasibility and contract issues","Do individual-debt allocation and timing requirements now matter?"],["Debit a bank account","Entitlement and custody must still be lawful","Applicable express informed consent to the charge and identified account is separately required"]]},{"headers":["Actor/event","Required factual record","Proper ledger treatment","What cannot be inferred"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Actor/event","Required factual record","Proper ledger treatment","What cannot be inferred"],["Provider conducts pre-agreement assessment","Counseling, financial analysis, proposed plan, affordability and creditor information","Pre-agreement work is separately identified","An independent “consultation” or “enrollment” fee is authorized"],["Debtor and provider execute agreement","Signed terms, cadence, gross payment, fee schedule, creditor allocations, refund provisions","Establish contractual obligations—not cash receipt","Every disclosed fee is immediately collectible"],["Debtor authorizes a bank payment","Amount, purpose and applicable consent","Authorization record separate from entitlement","Authorization cures an excessive or premature fee"],["Bank receives a check or transfer instruction","Pending/cleared/available status and any reversal","Pending instruments separately reconciled","A pending or returned item funded creditors"],["Provider receives available plan money","Trust receipt with debtor-specific allocation","Custody asset and corresponding debtor-funds responsibility","Entire receipt is provider revenue"],["Provider proposes origination deduction","Initial-payment classification, lawful amount, joint retention calculation, federal trigger where applicable","Fee transfer only when predicates are met","“Nonrefundable” defeats every cancellation or violation remedy"],["Provider proposes maintenance deduction","Services, contract, monthly total, each receipt’s retention capacity","Separate monthly and per-receipt checks","$75 is available for each weekly payment"],["Creditor accepts a payment","Creditor credit date, amount and allocation","Reduce the creditor balance by the amount actually credited","Provider receipt itself reduced the debt"],["Creditor refuses or withdraws","Date learned, affected payment, required notices","Revise projections and preserve funds accurately","Immediate additional fees or automatic cancellation"],["Debtor misses or underpays","Actual available cash, contract treatment and creditor consequences","No fictitious receipt; no fictitious creditor credit","A scheduled amount is cash, or late charges are authorized"],["Debtor cancels","Notice, effective date, unexpended funds, prior lawful fees","Separate custody return from fee-refund analysis","All old fees are refundable—or all are protected"],["Provider cancels","Good cause and thirty-day notice","Required creditor notice and return following cancellation","One failed payment permits immediate forfeiture"],["Plan completes","All listed debts and lawful fees paid","Immediate surplus return","Surplus may be retained for future maintenance"],["Material violation is rescinded","Violation and rescission facts","Separate return of qualifying prior fees","Ordinary cancellation and statutory rescission are identical"]]},{"headers":["Posture","Facts","Result or exact hold"],"index":8,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Posture","Facts","Result or exact hold"],["P01 — Nominal pre-agreement payment","Provider requests $10 to “open the plan” before an executed agreement","No established authority to accept it as plan money or a third fee category."],["P02 — First $300 periodic payment","Proposed $50 origination and $45 maintenance","Aggregate $95 retention is unsupported; see M01."],["P03 — First $1,000 periodic payment","$50 origination and $75 reasonable maintenance; all other predicates met","Both fit the individual and collective numerical constraints; see M02."],["P04 — Separate $50 payment","Described as fee-only, in addition to $300 monthly plan money","Classification remains held. A pre-trigger fee also fails the modeled federal timing condition; see M03."],["P05 — Four weekly receipts","Four $200 payments in one month; provider takes $25 each","Each $25 is below $30, but $100 monthly maintenance exceeds $75. A different $18.75-per-receipt schedule totals $75, subject to services and contract."],["P06 — Monthly receipt 43 days early","No obligation within 30 days is identified","Subdivision 5 bars the related fee receipt/retention. Custody and distribution still require separate analysis."],["P07 — Biweekly receipt 16 days early","No applicable 30-day exception","Same restriction; the threshold is more than fifteen days. Exactly fifteen days does not itself establish earning."],["P08 — Weekly receipt eight days early","Debtor documents intent to satisfy a contractual obligation due within thirty days","The subdivision 5 exception may apply; other caps and predicates remain."],["P09 — Variable payments","Prior regular payments $100/$150/$200; new payment $400","$100 is deemed advance. Missing due-date or intent facts remain material. No prior-payment history would leave the average unresolved."],["P10 — Rent plus DMP money","Transfer includes $500 current rent and $300 DMP payment","Do not charge a handling fee on rent or use it merely to enlarge the fee-bearing DMP base."],["P11 — Direct-creditor payments","Consumer pays creditors directly; provider only advises","Provider-custody ledger is zero for those payments. Minnesota classification and possible federal debt-relief coverage require the actual service/representation facts."],["P12 — Partial scheduled payment","$100 received against a $400 schedule; provider wants $30","$30 exceeds the $15 receipt-retention limit even before resolving monthly-base and earning questions."],["P13 — Returned payment","$400 payment fails before cash becomes available","Record the failed transaction; do not record $400 of available funds or creditor reduction. No separate provider NSF fee was established."],["P14 — Cancel or finish","Debtor cancels, provider cancels for cause, or all debts and fees are paid","Apply the appropriate notice and return rule; these events do not share one universal deadline or fee-refund outcome."]]},{"headers":["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],"index":9,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],["September 10: available plan payment","$300.00","—","—","—","$300.00"],["September 12: A receives $85; B receives $170","—","—","$255.00","—","$45.00"],["September 13: lawful origination transfer assumed","—","$30.00","—","—","$15.00"],["September 30: reasonable maintenance services completed","—","$15.00","—","—","$0.00"]]},{"headers":["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],"index":10,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],["September 5: plan payment","$1,000.00","—","—","—","$1,000.00"],["September 8: A $350; B $525","—","—","$875.00","—","$125.00"],["September 9: origination","—","$50.00","—","—","$75.00"],["September 30: maintenance","—","$75.00","—","—","$0.00"]]},{"headers":["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],"index":11,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Date/event","Receipts","Fee transfer","Creditor payment","Debtor return","Closing custody"],["September 10: scheduled payment","$300.00","—","—","—","$300.00"],["September 11: mistaken extra payment","$50.00","—","—","—","$350.00"],["September 12: A $85; B $170","—","—","$255.00","—","$95.00"],["September 13: extra $50 returned","—","—","—","$50.00","$45.00"],["September 30: maintenance","—","$45.00","—","—","$0.00"]]},{"headers":["Period/event","Receipts","Fee transfers","Creditor payments","Debtor returns","Closing custody"],"index":12,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Period/event","Receipts","Fee transfers","Creditor payments","Debtor returns","Closing custody"],["July 5 receipt","$400.00","—","—","—","$400.00"],["July 8 creditor distributions","—","—","$370.00","—","$30.00"],["July 31 maintenance","—","$30.00","—","—","$0.00"],["August failed payment","$0.00","$0.00","$0.00","$0.00","$0.00"],["September 5 partial receipt","$100.00","—","—","—","$100.00"],["September 12 cancellation return","—","$0.00","$0.00","$100.00","$0.00"]]},{"headers":["Original example","Preserved arithmetic","PASS-06 legal effect"],"index":13,"links":[],"row_links":[[],[],[]],"rows":[["Original example","Preserved arithmetic","PASS-06 legal effect"],["E05: $300 monthly payment","$45 maintenance ceiling and $255 remainder","Preserved. It did not authorize adding a full $50 origination deduction to the same ordinary periodic receipt. M01 supplies the joint test; the separate-fee theory remains held."],["E06: $800 monthly payment","Maintenance ceiling $75; remainder $725; retention 9.375%","Preserved. Adding $50 would create $125 total retention against a $120 receipt-level ceiling. That addition is not approved merely because each component separately fits its own maximum."]]},{"headers":["Source ID","Issuer, complete literal HTTPS URL","Actual read scope and operative pinpoint","Version/effect and limitations"],"index":14,"links":[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.13?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.13"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.13","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.02?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.02"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.02","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.10?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.10"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.10","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.11?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.11"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.11","text":"MN Revisor"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.12?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.12"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.12","text":"MN Revisor"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.14?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.14"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.14","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.17?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.17"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.17","text":"MN Revisor"},{"href":"https://www.revisor.mn.gov/laws/2007/0/57/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2007/0/57/"},{"href":"https://www.revisor.mn.gov/laws/2007/0/57/","text":"MN Revisor"},{"href":"https://www.revisor.mn.gov/laws/2008/0/210/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2008/0/210/"},{"href":"https://www.revisor.mn.gov/laws/2008/0/210/","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/laws/2009/0/37/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2009/0/37/"},{"href":"https://www.revisor.mn.gov/laws/2009/0/37/","text":"MN Revisor\n+1"},{"href":"https://www.revisor.mn.gov/statutes/2026/table2?full&page=5&per_page=500&year=2026&utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026"},{"href":"https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026","text":"MN Revisor"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR"},{"href":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule"},{"href":"https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf"},{"href":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule","text":"Federal Register\n+3"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission"},{"href":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/","text":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/"},{"href":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/index.jsp","text":"mn.gov // Minnesota's State Portal"}],"row_links":[[],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.13?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.13"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.13","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.02?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.02"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.02","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.10?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.10"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.10","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.11?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.11"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.11","text":"MN Revisor"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.12?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.12"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.12","text":"MN Revisor"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.14?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.14"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.14","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/statutes/cite/332A.17?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/cite/332A.17"},{"href":"https://www.revisor.mn.gov/statutes/cite/332A.17","text":"MN Revisor"}],[{"href":"https://www.revisor.mn.gov/laws/2007/0/57/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2007/0/57/"},{"href":"https://www.revisor.mn.gov/laws/2007/0/57/","text":"MN Revisor"}],[{"href":"https://www.revisor.mn.gov/laws/2008/0/210/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2008/0/210/"},{"href":"https://www.revisor.mn.gov/laws/2008/0/210/","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/laws/2009/0/37/?utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/laws/2009/0/37/"},{"href":"https://www.revisor.mn.gov/laws/2009/0/37/","text":"MN Revisor\n+1"}],[{"href":"https://www.revisor.mn.gov/statutes/2026/table2?full&page=5&per_page=500&year=2026&utm_source=chatgpt.com","text":"https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026"},{"href":"https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026","text":"MN Revisor"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR"}],[{"href":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule"},{"href":"https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf"},{"href":"https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule","text":"Federal Register\n+3"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission"}],[{"href":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/","text":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/"},{"href":"https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/index.jsp","text":"mn.gov // Minnesota's State Portal"}]],"rows":[["Source ID","Issuer, complete literal HTTPS URL","Actual read scope and operative pinpoint","Version/effect and limitations"],["S_MN-P06-S001","Minnesota Revisor, §332A.13. https://www.revisor.mn.gov/statutes/cite/332A.13","Fresh complete read: subdivisions 1–9 and history.","Displayed 2025 text. Core fee, advance, consent and funds authority. \nMN Revisor\n+1"],["S_MN-P06-S002","Minnesota Revisor, §332A.02. https://www.revisor.mn.gov/statutes/cite/332A.02","Fresh targeted read: subdivisions 5a–10 and 12; relevant provider/delegation/holding-out language and warning.","2025 display with accreditation warning. Exemption categories not rerun. \nMN Revisor\n+1"],["S_MN-P06-S003","Minnesota Revisor, §332A.10. https://www.revisor.mn.gov/statutes/cite/332A.10","Fresh complete operative read: subdivisions 1–5; relied on agreement prerequisites, assessment, fee/refund disclosures and modification rules.","2025 display. No full contract-compliance approval. \nMN Revisor\n+1"],["S_MN-P06-S004","Minnesota Revisor, §332A.11. https://www.revisor.mn.gov/statutes/cite/332A.11","Fresh complete read: subdivisions 1–4 and history.","Debtor/provider cancellation and automatic termination. \nMN Revisor"],["S_MN-P06-S005","Minnesota Revisor, §332A.12. https://www.revisor.mn.gov/statutes/cite/332A.12","Fresh operative read: subdivisions 1, 1a and 2; relied on records, monthly/final statements and access.","Annual regulatory reporting not developed beyond the read. \nMN Revisor"],["S_MN-P06-S006","Minnesota Revisor, §332A.14. https://www.revisor.mn.gov/statutes/cite/332A.14","Fresh operative body read: relied particularly on clauses (3)–(5), (7)–(10), (12), (13), (16).","Necessary fee/payment prohibitions only; not a complete conduct dossier. \nMN Revisor\n+1"],["S_MN-P06-S007","Minnesota Revisor, §332A.17. https://www.revisor.mn.gov/statutes/cite/332A.17","Fresh complete operative read: material-violation rescission paragraph and history.","Distinguishes rescission from ordinary cancellation. \nMN Revisor"],["S_MN-P06-S008","Minnesota Legislature/Revisor, Laws 2007, chapter 57. https://www.revisor.mn.gov/laws/2007/0/57/","Fresh targeted enacted read: article 3, §56, including its effective-date clause; relevant surrounding agreement/cancellation/records/rescission provisions inspected.","§56 expressly effective January 1, 2008. An initial history-link route failed; the direct act route succeeded. Not a full-act sequential read. \nMN Revisor"],["S_MN-P06-S009","Minnesota Legislature/Revisor, Laws 2008, chapter 210. https://www.revisor.mn.gov/laws/2008/0/210/","Fresh targeted enacted read: §§6, 8, 10 and signature.","§8 custody change effective April 22, 2008 under §10 and April 21 signature. \nMN Revisor\n+1"],["S_MN-P06-S010","Minnesota Legislature/Revisor, Laws 2009, chapter 37. https://www.revisor.mn.gov/laws/2009/0/37/","Fresh targeted historical read: article 4, relevant definition changes and §§15–16; end signature inspected.","Signed May 7, 2009. Exact effective-date chain for the selected historical amendments not completed; signature not substituted for effectiveness. \nMN Revisor\n+1"],["S_MN-P06-S011","Minnesota Revisor, 2026 statutes-changed Table 2. https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026","Fresh index read: relevant Chapter 332A entries, parsed lines 305–306 and surrounding entries.","Regular-session index; not a complete later/special-session certification. \nMN Revisor"],["S_MN-P06-S012","OFR/eCFR, 16 CFR §310.2. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","Fresh relevant operative definitions: customer, debt relief, person, seller, telemarketer and telemarketing; paragraphs (n), (o), (y), (ee), (hh), (ii).","Retrieved eCFR display current through October 23, 2026. Title-level amendment metadata is not attributed to this particular provision. \neCFR"],["S_MN-P06-S013","OFR/eCFR, 16 CFR §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Fresh complete relevant passages: (a)(5)(i)(A)–(C), (ii)(A)–(E), and applicable (a)(7) consent provisions.","Same eCFR version limit. Credit-repair requirements not analyzed as applicable. \neCFR"],["S_MN-P06-S014","OFR/eCFR, 16 CFR §310.6. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Fresh operative exemptions read, particularly (b)(3)–(7) and their exceptions.","Coverage depends on actual actor/campaign facts. \neCFR"],["S_MN-P06-S015","FTC, final TSR amendments, 75 FR 48458. HTML: https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule Official PDF: https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf","Fresh targeted Commission explanation: III.C.5(a), printed page 48489, especially footnote 431; related timing/account discussion. Official PDF pages 31–32, printed pages 48489–48490, visually inspected.","One underlying final-rule document, not two independent authorities. Published August 10, 2010; (a)(5) effective October 27, 2010. Preamble interpretation is distinguished from current regulatory text. \nFederal Register\n+3"],["S_MN-P06-S016","FTC, business compliance guide. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Fresh limited read: DMP coverage, initial-fee evidence and entity qualifications.","Staff guidance, not binding Commission interpretation. Historical record-retention advice was not imported as current law. \nFederal Trade Commission"],["S_MN-P06-S017","Minnesota Commerce, Consumer Credit Code Adjustments. https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/","Fresh body read: 2026 adjustment authority and covered statutes, lines 19–44.","Effective July 1, 2026 notice concerns Chapter 56 and §47.59, not §332A.13. \nmn.gov // Minnesota's State Portal"]]},{"headers":["Claim","Precise actor/predicate/effect","Authority and pinpoint","Confidence, exceptions and limits"],"index":15,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim","Precise actor/predicate/effect","Authority and pinpoint","Confidence, exceptions and limits"],["C001","Retrieved Minnesota bodies are 2025 displays; targeted 2026 index entries do not identify a fee-section change","S001–S007; S011 Chapter 332A entries","High as version/index finding; no all-later-law certificate"],["C002","The relevant original §332A.13 enactment became effective January 1, 2008","S008, article 3, §56 effective-date clause","High—enacted text"],["C003","The 2008 funds-availability/disbursement-account amendment became effective April 22, 2008","S009, §§8, 10 and signature","High—express chain"],["C004","No indexing authority appears in §332A.13; the retrieved 2026 adjustment notice covers different statutes","S001 complete body; S017 lines 19–44","High for these bodies; not proof that every possible notice was searched"],["C005","DMP classification principally involves provider receipt/distribution for full repayment of consumer-purpose debt","S002, subdivision 9","High—text; actual service facts necessary"],["C006","Delegation and holding out matter; a direct-payment label does not conclusively resolve classification","S002, subdivisions 8–10, 12","Conditional application"],["C007","Executed agreement and prescribed pre-agreement steps precede covered services/plan money","S003, subdivisions 1–2","High—text"],["C008","Agreement must disclose fees, services, anticipated charges, refund and cancellation terms","S003, subdivision 3","High—text; actual agreement not supplied"],["C009","Registrant may charge an origination fee not exceeding $50 from the initial amount","S001, subdivision 1","High—text; other restrictions still apply"],["C010","Maintenance must be reasonable and no greater than the lesser of 15% monthly payment or $75","S001, subdivision 2","High—text; monthly-base and service facts matter"],["C011","Combined fee retention from any periodic payment is limited to 15%; creditor allocation must respect the remainder","S001, subdivision 4; S008, §56","High—text; initial-periodic application is the stated combined reading, not a located holding"],["C012","A genuinely separate fee-only initial payment is not resolved by the retrieved definitions or an opened controlling interpretation","S001–S003; bounded search","Held; no approval by invoice/debit label"],["C013","Other provider charges and debtor “voluntary contributions” lack authority under the relied-on provisions","S001, subdivision 3; S006, clause (16)","High—text; bank-imposed charges and broader remedies not decided"],["C014","Handling the listed recurring living/support payments cannot generate provider handling fees","S001, subdivision 4","High—text; additional rule-prescribed categories not exhaustively investigated"],["C015","Fee receipt/retention is restricted for payments more than 42/15/7 days early under monthly/biweekly/weekly schedules","S001, subdivision 5","High—text; 30-day exception remains"],["C016","For unspecified amounts, excess over twice the prior regular-payment average is deemed advance","S001, subdivision 5","High—text; no-history computation unresolved"],["C017","Debtor intent to satisfy contractual obligations due within thirty days removes subdivision 5’s restriction","S001, subdivision 5","High—text; not a waiver of all other restrictions"],["C018","Provider must seek creditor consent; failure invokes the specified ten-day notice/cancellation-right requirement","S001, subdivision 6","High—text; acceptance of payment may evidence consent"],["C019","Creditor withdrawal/refusal invokes prompt notice, no later than fifteen days after learning of it","S001, subdivision 7","High—text; does not displace a separately applicable shorter requirement"],["C020","Available payments belong in the separate trust process; statutory routing and narrow commingling exception apply","S001, subdivision 8; S009, §8","High—text; full trust-control compliance deferred"],["C021","Creditor disbursement runs from receipt, within42 days or earlier creditor due date, subject to stated exceptions","S001, subdivision 9","High—text; factual exception required"],["C022","Provider must maintain records and provide monthly and cancellation/termination accounting of receipts, payments and fees","S005, subdivisions 1–2","High—text"],["C023","Debtor cancellation uses ten days’ written notice and a ten-day post-cancellation unexpended-funds/creditor-notice duty","S004, subdivision 1","High—text; effective notice date fact-dependent"],["C024","Provider good-cause cancellation requires thirty days’ notice; completed plans automatically terminate with immediate surplus return","S004, subdivisions 3–4","High—text"],["C025","Ordinary cancellation/default does not by itself require return of lawful origination and prior earned fees","S001, subdivision 6; S004","High as limited rule; does not validate unlawful fees or decide all earning facts"],["C026","Material-violation rescission requires qualifying noncreditor fee returns within ten days","S007, operative paragraph","High—text; actual violation and rescission required"],["C027","Additional agreements do not authorize another origination fee; modifications follow specified writing/exception rules","S003, subdivision 5","High—text; no fee-reset workaround"],["C028","TSR coverage requires the defined actor, service and telephone-campaign predicates","S012, (n), (o), (y), (ee), (hh), (ii)","High—text; modeled facts assumed"],["C029","Inbound, unsolicited and face-to-face exemptions have distinct conditions; nonprofit status is not resolved by a label","S014, (b)(3)–(7); S015–S016 limited explanation","Conditional; actual entity jurisdiction deferred"],["C030","Covered debt-relief fee collection requires the operative result/agreement/payment predicates and applicable individual-debt allocation","S013, (a)(5)(i)","High—text"],["C031","Commission DMP explanation recognizes a binding customer-executed DMP and first payment to the counseling agency for creditors","S015, III.C.5(a), 75 FR48489","Strong federal interpretive evidence; not Minnesota construction"],["C032","Under the described jointly renegotiated DMP, individual-debt allocation does not apply and later servicing fees may be collected","S015, footnote431","Conditional on that factual model; not every DMP label"],["C033","Federal dedicated-account conditions are not established merely by a provider-controlled Minnesota trust account","S013, (a)(5)(ii)","High text plus conditional application"],["C034","Billing authorization is separately required; it does not cure fee entitlement defects","S013, (a)(7)","High—text; other payment-rail law deferred"],["C035","Receipt, fee transfer, creditor credit and debtor return must be separately accounted for","S001, subdivisions 8–9; S005, subdivision 2","Analytical consequence; actual creditor posting needed"],["C036","No responsive opened majority opinion or binding agency construction resolved the initial-fee exception issue","Search record","Bounded search finding, not nonexistence"],["C037","M01’s proposed $95 retention exceeds the $45 limit; the different $30+$15 contract reconciles conditionally","M01; C009–C011","Verified arithmetic; hypothetical legal assumptions"],["C038","M02’s $125 from $1,000 satisfies the joint numerical constraints","M02; C009–C011","Verified arithmetic; reasonableness/timing assumed"],["C039","M03 demonstrates that a zero cash balance can coexist with an unsupported separate-fee theory","M03; C012, C030–C034","Conditional; demonstrated branch waives origination"],["C040","M04 separates failed receipts, lawful fees, creditor payments and cancellation returns","M04; C020–C026","Verified ledger; contract waivers and creditor concessions stipulated"],["C041","Weekly/biweekly receipts must satisfy both per-receipt retention and the monthly maintenance ceiling","C010–C011; P05","Combined reading; irregular-month details held"],["C042","Underpayment limits current retention by the actual periodic receipt; missed-cycle fee earning is not automatic","C010–C011, C015–C017; P12–P13","Conditional; actual contract/service/base required"],["C043","P01 E05 arithmetic survives, but does not establish $95 retention from $300","Supplied P01 E05; C037","Historical reuse plus fresh application"],["C044","P01 E06 arithmetic survives; adding $50 would exceed the $800 payment’s $120 retention limit","Supplied P01 E06; C011","Historical reuse plus arithmetic"],["C045","No actual provider, account, claimant, contract, broader-state or A066 approval follows","Scope and evidence limits","Express limitation"]]},{"headers":["Subissue","Status","Claims/models","Exact missing evidence or next action"],"index":16,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Subissue","Status","Claims/models","Exact missing evidence or next action"],["Complete §332A.13 operative body","Answered","C009–C021","All subdivisions read; interpretation gaps separately retained"],["Relevant DMP/debtor/provider/creditor definitions","Answered textually","C005–C006","Actual service and delegation facts"],["Initial/periodic/monthly/earned definitions","Partial","C012, C025, C042","Responsive authority or actual contract where statutory terms are not expressly defined"],["$50 origination ceiling","Answered","C009","Actual agreement and lawful timing"],["Maintenance ceiling and reasonableness","Answered textually","C010","Evidence of actual services and reasonableness"],["Combined first-periodic-payment retention","Answered as combined textual reading","C011, M01–M02","No located controlling contrary/confirming construction"],["Genuine separate fee-only payment","Unresolved","C012, M03","Published majority opinion or binding agency interpretation addressing classification"],["Split debit/relabeling theory","No authority established","C012","Actual legal basis; operational labels alone insufficient"],["Nominal enrollment/application charge","Answered narrowly","C007, C013, P01","No third consumer-fee category established"],["Registration/bond costs versus consumer fees","Answered boundary","C013","Registration/bond compliance itself deferred"],["Inflation/indexing","Answered for read authorities","C004","No applicable DMP notice found; broader notice sweep not certified"],["2007 fee enactment/effective date","Answered","C002","None within the stated provision"],["2008 funds amendment/effective date","Answered","C003","None within the stated provision"],["Selected 2009 historical effective-date chain","Partial","S010","Complete applicable general/specific date analysis; no guessed date used"],["Current 2026 regular-session check","Answered narrowly","C001","Complete later/special-session consolidation remains separate"],["Written agreement and disclosures","Answered for ledger purposes","C007–C008","Actual executed agreement and assessment records"],["Extra origination/modification fees","Answered","C027","Actual modification facts and applicable limited exception"],["Monthly advance threshold","Answered","C015, P06","Actual agreement due date"],["Biweekly advance threshold","Answered","C015, P07","Same"],["Weekly advance threshold","Answered","C015, P08","Same"],["Variable-payment calculation","Answered with boundary","C016, P09","Date/intent facts; no-history average unresolved"],["Thirty-day obligation exception","Answered conditionally","C017","Evidence of debtor intent and contractual obligation"],["Weekly/biweekly monthly aggregation","Answered in principle","C041, P05","Actual monthly base and irregular-month treatment"],["Recurring living-expense handling","Answered for statutory list","C014, P10","Any additional commissioner-rule categories not exhaustively reviewed"],["Custody receipt versus fee earning","Answered analytically","C020, C035","Actual transaction and subledger records"],["Availability versus receipt clocks","Answered","C020–C021","Actual receipt/availability dates and any return"],["Trust-to-provider/creditor/debtor routing","Answered narrowly","C020","Full trust controls and bank documentation deferred"],["Creditor distribution deadline","Answered","C021","Creditor due dates and actual credits"],["Accumulation/returned-payment exceptions","Answered textually","C021","Fact-specific reasonable/net-interest evidence"],["Creditor consent","Answered","C018","Actual binding concessions and consent evidence"],["Withdrawal/refusal notice","Answered","C019","Date learned and notices"],["Direct-creditor/noncustodial branch","Partial","C006, P11","Actual service, representations, delegation and control"],["Insufficient payment","Partial application","C042, P12","Contractual monthly-base and earning facts"],["Late/missed/NSF payment","Answered for modeled facts","P13, M04","Real creditor consequences and bank reconciliation"],["Monthly/final accounting","Answered","C022","Actual statements not supplied"],["Ordinary debtor cancellation","Answered","C023, C025","Actual notice/effective date and lawful prior fees"],["Provider cancellation","Answered","C024","Good cause and thirty-day notice"],["Automatic termination","Answered","C024","Proof all listed debts and lawful fees paid"],["Material-violation rescission","Answered narrowly","C026","Actual material violation and exercise of rescission"],["Federal actor/service/telephone coverage","Answered conditionally","C028–C029","Actual entity and campaign facts"],["Federal DMP first-fee trigger","Answered for described DMP","C030–C032","Executed binding plan and qualifying first payment"],["DMP subsequent servicing fees","Answered federally, state limits separate","C032","Actual service/contract/state compliance"],["Staggered creditor participation","Unresolved application","C030–C032","Whether individual-debt treatment applies and corresponding records"],["Pre-trigger dedicated account","Partial","C033","Actual ownership, administration, independence and account terms"],["Bank-debit authorization","Answered narrowly","C034","Actual consent; other payment-rail requirements deferred"],["P01 nominal enrollment posture","Completed","P01","Hypothetical only"],["P02–P04 initial-payment postures","Completed with separate-fee hold","P02–P04","M01–M03 specify assumptions"],["P05 cadence posture","Completed","P05","Irregular-month interpretation remains open"],["P06–P09 advance-payment postures","Completed conditionally","P06–P09","Date/intent/history facts stated or held"],["P10–P11 living-expense/direct-pay postures","Completed with classification limits","P10–P11","Actual service/account facts"],["P12–P14 shortage/failure/exit postures","Completed","P12–P14","Real contract and creditor facts"],["M01 $300 adversarial joint ledger","Completed","C037","Not actual fee approval"],["M02 larger initial joint ledger","Completed conditionally","C038","Reasonableness and other assumptions essential"],["M03 separate-fee candidate","Completed; authority held","C039","Responsive classification authority"],["M04 missed-payment/cancellation ledger","Completed conditionally","C040","Waivers/concessions are stipulated, not universal"],["P01 E05 crosswalk","Completed","C043","Original preserved"],["P01 E06 crosswalk","Completed","C044","Original preserved"],["Responsive judicial/administrative interpretation","Not located in bounded search","C036","Further official published-opinion/Commerce-order research on exact issue"],["P05 settlement-performance component","Excluded; not a premise","C045","Separate review remains separate"],["NMLS/current provider status/2026 transition","Deferred/preserved","C045","P02/P04 holds unchanged"],["Full trust/bond compliance","Deferred","C045","Account-control, bond and broader supervision component"],["Nonprofit/attorney registration and exemptions","Deferred","C045","Actual entity/activity qualification"],["CROA and broader federal credit repair","Deferred boundary","C045","Actual representations and separate operative review"],["Collection/litigation/wage/bank/other property","Deferred","C045","Separate parent-state components"],["Sector/local/tribal and remaining state dimensions","Deferred","C045","No completion or acceptance by implication"]]}],"claims":[{"claim_id":"S_MN-P06-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C001","Precise actor/predicate/effect":"Retrieved Minnesota bodies are 2025 displays; targeted 2026 index entries do not identify a fee-section change","Authority and pinpoint":"S001–S007; S011 Chapter 332A entries","Confidence, exceptions and limits":"High as version/index finding; no all-later-law certificate"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C002","Precise actor/predicate/effect":"The relevant original §332A.13 enactment became effective January 1, 2008","Authority and pinpoint":"S008, article 3, §56 effective-date clause","Confidence, exceptions and limits":"High—enacted text"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C003","Precise actor/predicate/effect":"The 2008 funds-availability/disbursement-account amendment became effective April 22, 2008","Authority and pinpoint":"S009, §§8, 10 and signature","Confidence, exceptions and limits":"High—express chain"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C004","Precise actor/predicate/effect":"No indexing authority appears in §332A.13; the retrieved 2026 adjustment notice covers different statutes","Authority and pinpoint":"S001 complete body; S017 lines 19–44","Confidence, exceptions and limits":"High for these bodies; not proof that every possible notice was searched"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C005","Precise actor/predicate/effect":"DMP classification principally involves provider receipt/distribution for full repayment of consumer-purpose debt","Authority and pinpoint":"S002, subdivision 9","Confidence, exceptions and limits":"High—text; actual service facts necessary"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C006","Precise actor/predicate/effect":"Delegation and holding out matter; a direct-payment label does not conclusively resolve classification","Authority and pinpoint":"S002, subdivisions 8–10, 12","Confidence, exceptions and limits":"Conditional application"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C007","Precise actor/predicate/effect":"Executed agreement and prescribed pre-agreement steps precede covered services/plan money","Authority and pinpoint":"S003, subdivisions 1–2","Confidence, exceptions and limits":"High—text"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C008","Precise actor/predicate/effect":"Agreement must disclose fees, services, anticipated charges, refund and cancellation terms","Authority and pinpoint":"S003, subdivision 3","Confidence, exceptions and limits":"High—text; actual agreement not supplied"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C009","Precise actor/predicate/effect":"Registrant may charge an origination fee not exceeding $50 from the initial amount","Authority and pinpoint":"S001, subdivision 1","Confidence, exceptions and limits":"High—text; other restrictions still apply"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C010","Precise actor/predicate/effect":"Maintenance must be reasonable and no greater than the lesser of 15% monthly payment or $75","Authority and pinpoint":"S001, subdivision 2","Confidence, exceptions and limits":"High—text; monthly-base and service facts matter"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C011","Precise actor/predicate/effect":"Combined fee retention from any periodic payment is limited to 15%; creditor allocation must respect the remainder","Authority and pinpoint":"S001, subdivision 4; S008, §56","Confidence, exceptions and limits":"High—text; initial-periodic application is the stated combined reading, not a located holding"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C012","Precise actor/predicate/effect":"A genuinely separate fee-only initial payment is not resolved by the retrieved definitions or an opened controlling interpretation","Authority and pinpoint":"S001–S003; bounded search","Confidence, exceptions and limits":"Held; no approval by invoice/debit label"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C013","Precise actor/predicate/effect":"Other provider charges and debtor “voluntary contributions” lack authority under the relied-on provisions","Authority and pinpoint":"S001, subdivision 3; S006, clause (16)","Confidence, exceptions and limits":"High—text; bank-imposed charges and broader remedies not decided"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C014","Precise actor/predicate/effect":"Handling the listed recurring living/support payments cannot generate provider handling fees","Authority and pinpoint":"S001, subdivision 4","Confidence, exceptions and limits":"High—text; additional rule-prescribed categories not exhaustively investigated"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C015","Precise actor/predicate/effect":"Fee receipt/retention is restricted for payments more than 42/15/7 days early under monthly/biweekly/weekly schedules","Authority and pinpoint":"S001, subdivision 5","Confidence, exceptions and limits":"High—text; 30-day exception remains"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C016","Precise actor/predicate/effect":"For unspecified amounts, excess over twice the prior regular-payment average is deemed advance","Authority and pinpoint":"S001, subdivision 5","Confidence, exceptions and limits":"High—text; no-history computation unresolved"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C017","Precise actor/predicate/effect":"Debtor intent to satisfy contractual obligations due within thirty days removes subdivision 5’s restriction","Authority and pinpoint":"S001, subdivision 5","Confidence, exceptions and limits":"High—text; not a waiver of all other restrictions"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C018","Precise actor/predicate/effect":"Provider must seek creditor consent; failure invokes the specified ten-day notice/cancellation-right requirement","Authority and pinpoint":"S001, subdivision 6","Confidence, exceptions and limits":"High—text; acceptance of payment may evidence consent"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C019","Precise actor/predicate/effect":"Creditor withdrawal/refusal invokes prompt notice, no later than fifteen days after learning of it","Authority and pinpoint":"S001, subdivision 7","Confidence, exceptions and limits":"High—text; does not displace a separately applicable shorter requirement"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C020","Precise actor/predicate/effect":"Available payments belong in the separate trust process; statutory routing and narrow commingling exception apply","Authority and pinpoint":"S001, subdivision 8; S009, §8","Confidence, exceptions and limits":"High—text; full trust-control compliance deferred"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C021","Precise actor/predicate/effect":"Creditor disbursement runs from receipt, within42 days or earlier creditor due date, subject to stated exceptions","Authority and pinpoint":"S001, subdivision 9","Confidence, exceptions and limits":"High—text; factual exception required"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C022","Precise actor/predicate/effect":"Provider must maintain records and provide monthly and cancellation/termination accounting of receipts, payments and fees","Authority and pinpoint":"S005, subdivisions 1–2","Confidence, exceptions and limits":"High—text"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C023","Precise actor/predicate/effect":"Debtor cancellation uses ten days’ written notice and a ten-day post-cancellation unexpended-funds/creditor-notice duty","Authority and pinpoint":"S004, subdivision 1","Confidence, exceptions and limits":"High—text; effective notice date fact-dependent"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C024","Precise actor/predicate/effect":"Provider good-cause cancellation requires thirty days’ notice; completed plans automatically terminate with immediate surplus return","Authority and pinpoint":"S004, subdivisions 3–4","Confidence, exceptions and limits":"High—text"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C025","Precise actor/predicate/effect":"Ordinary cancellation/default does not by itself require return of lawful origination and prior earned fees","Authority and pinpoint":"S001, subdivision 6; S004","Confidence, exceptions and limits":"High as limited rule; does not validate unlawful fees or decide all earning facts"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C026","Precise actor/predicate/effect":"Material-violation rescission requires qualifying noncreditor fee returns within ten days","Authority and pinpoint":"S007, operative paragraph","Confidence, exceptions and limits":"High—text; actual violation and rescission required"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C027","Precise actor/predicate/effect":"Additional agreements do not authorize another origination fee; modifications follow specified writing/exception rules","Authority and pinpoint":"S003, subdivision 5","Confidence, exceptions and limits":"High—text; no fee-reset workaround"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C028","Precise actor/predicate/effect":"TSR coverage requires the defined actor, service and telephone-campaign predicates","Authority and pinpoint":"S012, (n), (o), (y), (ee), (hh), (ii)","Confidence, exceptions and limits":"High—text; modeled facts assumed"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C029","Precise actor/predicate/effect":"Inbound, unsolicited and face-to-face exemptions have distinct conditions; nonprofit status is not resolved by a label","Authority and pinpoint":"S014, (b)(3)–(7); S015–S016 limited explanation","Confidence, exceptions and limits":"Conditional; actual entity jurisdiction deferred"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C030","Precise actor/predicate/effect":"Covered debt-relief fee collection requires the operative result/agreement/payment predicates and applicable individual-debt allocation","Authority and pinpoint":"S013, (a)(5)(i)","Confidence, exceptions and limits":"High—text"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C031","Precise actor/predicate/effect":"Commission DMP explanation recognizes a binding customer-executed DMP and first payment to the counseling agency for creditors","Authority and pinpoint":"S015, III.C.5(a), 75 FR48489","Confidence, exceptions and limits":"Strong federal interpretive evidence; not Minnesota construction"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C032","Precise actor/predicate/effect":"Under the described jointly renegotiated DMP, individual-debt allocation does not apply and later servicing fees may be collected","Authority and pinpoint":"S015, footnote431","Confidence, exceptions and limits":"Conditional on that factual model; not every DMP label"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C033","Precise actor/predicate/effect":"Federal dedicated-account conditions are not established merely by a provider-controlled Minnesota trust account","Authority and pinpoint":"S013, (a)(5)(ii)","Confidence, exceptions and limits":"High text plus conditional application"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C034","Precise actor/predicate/effect":"Billing authorization is separately required; it does not cure fee entitlement defects","Authority and pinpoint":"S013, (a)(7)","Confidence, exceptions and limits":"High—text; other payment-rail law deferred"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C035","Precise actor/predicate/effect":"Receipt, fee transfer, creditor credit and debtor return must be separately accounted for","Authority and pinpoint":"S001, subdivisions 8–9; S005, subdivision 2","Confidence, exceptions and limits":"Analytical consequence; actual creditor posting needed"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C036","Precise actor/predicate/effect":"No responsive opened majority opinion or binding agency construction resolved the initial-fee exception issue","Authority and pinpoint":"Search record","Confidence, exceptions and limits":"Bounded search finding, not nonexistence"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C037","Precise actor/predicate/effect":"M01’s proposed $95 retention exceeds the $45 limit; the different $30+$15 contract reconciles conditionally","Authority and pinpoint":"M01; C009–C011","Confidence, exceptions and limits":"Verified arithmetic; hypothetical legal assumptions"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C038","Precise actor/predicate/effect":"M02’s $125 from $1,000 satisfies the joint numerical constraints","Authority and pinpoint":"M02; C009–C011","Confidence, exceptions and limits":"Verified arithmetic; reasonableness/timing assumed"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C039","Precise actor/predicate/effect":"M03 demonstrates that a zero cash balance can coexist with an unsupported separate-fee theory","Authority and pinpoint":"M03; C012, C030–C034","Confidence, exceptions and limits":"Conditional; demonstrated branch waives origination"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C040","Precise actor/predicate/effect":"M04 separates failed receipts, lawful fees, creditor payments and cancellation returns","Authority and pinpoint":"M04; C020–C026","Confidence, exceptions and limits":"Verified ledger; contract waivers and creditor concessions stipulated"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C041","Precise actor/predicate/effect":"Weekly/biweekly receipts must satisfy both per-receipt retention and the monthly maintenance ceiling","Authority and pinpoint":"C010–C011; P05","Confidence, exceptions and limits":"Combined reading; irregular-month details held"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C042","Precise actor/predicate/effect":"Underpayment limits current retention by the actual periodic receipt; missed-cycle fee earning is not automatic","Authority and pinpoint":"C010–C011, C015–C017; P12–P13","Confidence, exceptions and limits":"Conditional; actual contract/service/base required"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C043","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C043","Precise actor/predicate/effect":"P01 E05 arithmetic survives, but does not establish $95 retention from $300","Authority and pinpoint":"Supplied P01 E05; C037","Confidence, exceptions and limits":"Historical reuse plus fresh application"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C044","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C044","Precise actor/predicate/effect":"P01 E06 arithmetic survives; adding $50 would exceed the $800 payment’s $120 retention limit","Authority and pinpoint":"Supplied P01 E06; C011","Confidence, exceptions and limits":"Historical reuse plus arithmetic"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MN-P06-C045","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C045","Precise actor/predicate/effect":"No actual provider, account, claimant, contract, broader-state or A066 approval follows","Authority and pinpoint":"Scope and evidence limits","Confidence, exceptions and limits":"Express limitation"},"raw_table_index":15,"coordinator_verification_status":"same_coordinator_scoped_selected_primary_and_arithmetic_checks;not_all_source_or_current_law_verification;see_review","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_MN-P06-S001","urls":["https://www.revisor.mn.gov/statutes/cite/332A.13","https://www.revisor.mn.gov/statutes/cite/332A.13?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S001","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.13. https://www.revisor.mn.gov/statutes/cite/332A.13","Actual read scope and operative pinpoint":"Fresh complete read: subdivisions 1–9 and history.","Version/effect and limitations":"Displayed 2025 text. Core fee, advance, consent and funds authority. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S002","urls":["https://www.revisor.mn.gov/statutes/cite/332A.02","https://www.revisor.mn.gov/statutes/cite/332A.02?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S002","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.02. https://www.revisor.mn.gov/statutes/cite/332A.02","Actual read scope and operative pinpoint":"Fresh targeted read: subdivisions 5a–10 and 12; relevant provider/delegation/holding-out language and warning.","Version/effect and limitations":"2025 display with accreditation warning. Exemption categories not rerun. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S003","urls":["https://www.revisor.mn.gov/statutes/cite/332A.10","https://www.revisor.mn.gov/statutes/cite/332A.10?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S003","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.10. https://www.revisor.mn.gov/statutes/cite/332A.10","Actual read scope and operative pinpoint":"Fresh complete operative read: subdivisions 1–5; relied on agreement prerequisites, assessment, fee/refund disclosures and modification rules.","Version/effect and limitations":"2025 display. No full contract-compliance approval. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S004","urls":["https://www.revisor.mn.gov/statutes/cite/332A.11","https://www.revisor.mn.gov/statutes/cite/332A.11?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S004","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.11. https://www.revisor.mn.gov/statutes/cite/332A.11","Actual read scope and operative pinpoint":"Fresh complete read: subdivisions 1–4 and history.","Version/effect and limitations":"Debtor/provider cancellation and automatic termination. \nMN Revisor"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S005","urls":["https://www.revisor.mn.gov/statutes/cite/332A.12","https://www.revisor.mn.gov/statutes/cite/332A.12?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S005","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.12. https://www.revisor.mn.gov/statutes/cite/332A.12","Actual read scope and operative pinpoint":"Fresh operative read: subdivisions 1, 1a and 2; relied on records, monthly/final statements and access.","Version/effect and limitations":"Annual regulatory reporting not developed beyond the read. \nMN Revisor"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S006","urls":["https://www.revisor.mn.gov/statutes/cite/332A.14","https://www.revisor.mn.gov/statutes/cite/332A.14?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S006","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.14. https://www.revisor.mn.gov/statutes/cite/332A.14","Actual read scope and operative pinpoint":"Fresh operative body read: relied particularly on clauses (3)–(5), (7)–(10), (12), (13), (16).","Version/effect and limitations":"Necessary fee/payment prohibitions only; not a complete conduct dossier. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S007","urls":["https://www.revisor.mn.gov/statutes/cite/332A.17","https://www.revisor.mn.gov/statutes/cite/332A.17?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S007","Issuer, complete literal HTTPS URL":"Minnesota Revisor, §332A.17. https://www.revisor.mn.gov/statutes/cite/332A.17","Actual read scope and operative pinpoint":"Fresh complete operative read: material-violation rescission paragraph and history.","Version/effect and limitations":"Distinguishes rescission from ordinary cancellation. \nMN Revisor"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S008","urls":["https://www.revisor.mn.gov/laws/2007/0/57/","https://www.revisor.mn.gov/laws/2007/0/57/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S008","Issuer, complete literal HTTPS URL":"Minnesota Legislature/Revisor, Laws 2007, chapter 57. https://www.revisor.mn.gov/laws/2007/0/57/","Actual read scope and operative pinpoint":"Fresh targeted enacted read: article 3, §56, including its effective-date clause; relevant surrounding agreement/cancellation/records/rescission provisions inspected.","Version/effect and limitations":"§56 expressly effective January 1, 2008. An initial history-link route failed; the direct act route succeeded. Not a full-act sequential read. \nMN Revisor"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S009","urls":["https://www.revisor.mn.gov/laws/2008/0/210/","https://www.revisor.mn.gov/laws/2008/0/210/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S009","Issuer, complete literal HTTPS URL":"Minnesota Legislature/Revisor, Laws 2008, chapter 210. https://www.revisor.mn.gov/laws/2008/0/210/","Actual read scope and operative pinpoint":"Fresh targeted enacted read: §§6, 8, 10 and signature.","Version/effect and limitations":"§8 custody change effective April 22, 2008 under §10 and April 21 signature. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S010","urls":["https://www.revisor.mn.gov/laws/2009/0/37/","https://www.revisor.mn.gov/laws/2009/0/37/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S010","Issuer, complete literal HTTPS URL":"Minnesota Legislature/Revisor, Laws 2009, chapter 37. https://www.revisor.mn.gov/laws/2009/0/37/","Actual read scope and operative pinpoint":"Fresh targeted historical read: article 4, relevant definition changes and §§15–16; end signature inspected.","Version/effect and limitations":"Signed May 7, 2009. Exact effective-date chain for the selected historical amendments not completed; signature not substituted for effectiveness. \nMN Revisor\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S011","urls":["https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026","https://www.revisor.mn.gov/statutes/2026/table2?full&page=5&per_page=500&year=2026&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S011","Issuer, complete literal HTTPS URL":"Minnesota Revisor, 2026 statutes-changed Table 2. https://www.revisor.mn.gov/statutes/2026/table2?full=&page=5&per_page=500&year=2026","Actual read scope and operative pinpoint":"Fresh index read: relevant Chapter 332A entries, parsed lines 305–306 and surrounding entries.","Version/effect and limitations":"Regular-session index; not a complete later/special-session certification. \nMN Revisor"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S012","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S012","Issuer, complete literal HTTPS URL":"OFR/eCFR, 16 CFR §310.2. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","Actual read scope and operative pinpoint":"Fresh relevant operative definitions: customer, debt relief, person, seller, telemarketer and telemarketing; paragraphs (n), (o), (y), (ee), (hh), (ii).","Version/effect and limitations":"Retrieved eCFR display current through October 23, 2026. Title-level amendment metadata is not attributed to this particular provision. \neCFR"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S013","urls":["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-310.4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S013","Issuer, complete literal HTTPS URL":"OFR/eCFR, 16 CFR §310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Actual read scope and operative pinpoint":"Fresh complete relevant passages: (a)(5)(i)(A)–(C), (ii)(A)–(E), and applicable (a)(7) consent provisions.","Version/effect and limitations":"Same eCFR version limit. Credit-repair requirements not analyzed as applicable. \neCFR"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S014","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S014","Issuer, complete literal HTTPS URL":"OFR/eCFR, 16 CFR §310.6. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Actual read scope and operative pinpoint":"Fresh operative exemptions read, particularly (b)(3)–(7) and their exceptions.","Version/effect and limitations":"Coverage depends on actual actor/campaign facts. \neCFR"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S015","urls":["https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule","https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf","https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S015","Issuer, complete literal HTTPS URL":"FTC, final TSR amendments, 75 FR 48458. HTML: https://www.federalregister.gov/documents/2010/08/10/2010-19412/telemarketing-sales-rule Official PDF: https://www.govinfo.gov/content/pkg/FR-2010-08-10/pdf/2010-19412.pdf","Actual read scope and operative pinpoint":"Fresh targeted Commission explanation: III.C.5(a), printed page 48489, especially footnote 431; related timing/account discussion. Official PDF pages 31–32, printed pages 48489–48490, visually inspected.","Version/effect and limitations":"One underlying final-rule document, not two independent authorities. Published August 10, 2010; (a)(5) effective October 27, 2010. Preamble interpretation is distinguished from current regulatory text. \nFederal Register\n+3"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S016","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MN-P06-S016","Issuer, complete literal HTTPS URL":"FTC, business compliance guide. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Actual read scope and operative pinpoint":"Fresh limited read: DMP coverage, initial-fee evidence and entity qualifications.","Version/effect and limitations":"Staff guidance, not binding Commission interpretation. Historical record-retention advice was not imported as current law. \nFederal Trade Commission"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."},{"source_id":"S_MN-P06-S017","urls":["https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/","https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/index.jsp"],"researcher_record":{"Source ID":"S_MN-P06-S017","Issuer, complete literal HTTPS URL":"Minnesota Commerce, Consumer Credit Code Adjustments. https://mn.gov/commerce/money/industry/interest-rates/consumer-credit-code/","Actual read scope and operative pinpoint":"Fresh body read: 2026 adjustment authority and covered statutes, lines 19–44.","Version/effect and limitations":"Effective July 1, 2026 notice concerns Chapter 56 and §47.59, not §332A.13. \nmn.gov // Minnesota's State Portal"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_review_scope":"Selected fresh primary checks and exact historical access limits retained; no blanket verification."}],"coverage":[{"topic":"Complete §332A.13 operative body","researcher_record":{"Subissue":"Complete §332A.13 operative body","Status":"Answered","Claims/models":"C009–C021","Exact missing evidence or next action":"All subdivisions read; interpretation gaps separately retained"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Relevant DMP/debtor/provider/creditor definitions","researcher_record":{"Subissue":"Relevant DMP/debtor/provider/creditor definitions","Status":"Answered textually","Claims/models":"C005–C006","Exact missing evidence or next action":"Actual service and delegation facts"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Initial/periodic/monthly/earned definitions","researcher_record":{"Subissue":"Initial/periodic/monthly/earned definitions","Status":"Partial","Claims/models":"C012, C025, C042","Exact missing evidence or next action":"Responsive authority or actual contract where statutory terms are not expressly defined"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"$50 origination ceiling","researcher_record":{"Subissue":"$50 origination ceiling","Status":"Answered","Claims/models":"C009","Exact missing evidence or next action":"Actual agreement and lawful timing"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Maintenance ceiling and reasonableness","researcher_record":{"Subissue":"Maintenance ceiling and reasonableness","Status":"Answered textually","Claims/models":"C010","Exact missing evidence or next action":"Evidence of actual services and reasonableness"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Combined first-periodic-payment retention","researcher_record":{"Subissue":"Combined first-periodic-payment retention","Status":"Answered as combined textual reading","Claims/models":"C011, M01–M02","Exact missing evidence or next action":"No located controlling contrary/confirming construction"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Genuine separate fee-only payment","researcher_record":{"Subissue":"Genuine separate fee-only payment","Status":"Unresolved","Claims/models":"C012, M03","Exact missing evidence or next action":"Published majority opinion or binding agency interpretation addressing classification"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Split debit/relabeling theory","researcher_record":{"Subissue":"Split debit/relabeling theory","Status":"No authority established","Claims/models":"C012","Exact missing evidence or next action":"Actual legal basis; operational labels alone insufficient"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Nominal enrollment/application charge","researcher_record":{"Subissue":"Nominal enrollment/application charge","Status":"Answered narrowly","Claims/models":"C007, C013, P01","Exact missing evidence or next action":"No third consumer-fee category established"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Registration/bond costs versus consumer fees","researcher_record":{"Subissue":"Registration/bond costs versus consumer fees","Status":"Answered boundary","Claims/models":"C013","Exact missing evidence or next action":"Registration/bond compliance itself deferred"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Inflation/indexing","researcher_record":{"Subissue":"Inflation/indexing","Status":"Answered for read authorities","Claims/models":"C004","Exact missing evidence or next action":"No applicable DMP notice found; broader notice sweep not certified"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"2007 fee enactment/effective date","researcher_record":{"Subissue":"2007 fee enactment/effective date","Status":"Answered","Claims/models":"C002","Exact missing evidence or next action":"None within the stated provision"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"2008 funds amendment/effective date","researcher_record":{"Subissue":"2008 funds amendment/effective date","Status":"Answered","Claims/models":"C003","Exact missing evidence or next action":"None within the stated provision"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Selected 2009 historical effective-date chain","researcher_record":{"Subissue":"Selected 2009 historical effective-date chain","Status":"Partial","Claims/models":"S010","Exact missing evidence or next action":"Complete applicable general/specific date analysis; no guessed date used"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Current 2026 regular-session check","researcher_record":{"Subissue":"Current 2026 regular-session check","Status":"Answered narrowly","Claims/models":"C001","Exact missing evidence or next action":"Complete later/special-session consolidation remains separate"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Written agreement and disclosures","researcher_record":{"Subissue":"Written agreement and disclosures","Status":"Answered for ledger purposes","Claims/models":"C007–C008","Exact missing evidence or next action":"Actual executed agreement and assessment records"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Extra origination/modification fees","researcher_record":{"Subissue":"Extra origination/modification fees","Status":"Answered","Claims/models":"C027","Exact missing evidence or next action":"Actual modification facts and applicable limited exception"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Monthly advance threshold","researcher_record":{"Subissue":"Monthly advance threshold","Status":"Answered","Claims/models":"C015, P06","Exact missing evidence or next action":"Actual agreement due date"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Biweekly advance threshold","researcher_record":{"Subissue":"Biweekly advance threshold","Status":"Answered","Claims/models":"C015, P07","Exact missing evidence or next action":"Same"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Weekly advance threshold","researcher_record":{"Subissue":"Weekly advance threshold","Status":"Answered","Claims/models":"C015, P08","Exact missing evidence or next action":"Same"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Variable-payment calculation","researcher_record":{"Subissue":"Variable-payment calculation","Status":"Answered with boundary","Claims/models":"C016, P09","Exact missing evidence or next action":"Date/intent facts; no-history average unresolved"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Thirty-day obligation exception","researcher_record":{"Subissue":"Thirty-day obligation exception","Status":"Answered conditionally","Claims/models":"C017","Exact missing evidence or next action":"Evidence of debtor intent and contractual obligation"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Weekly/biweekly monthly aggregation","researcher_record":{"Subissue":"Weekly/biweekly monthly aggregation","Status":"Answered in principle","Claims/models":"C041, P05","Exact missing evidence or next action":"Actual monthly base and irregular-month treatment"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Recurring living-expense handling","researcher_record":{"Subissue":"Recurring living-expense handling","Status":"Answered for statutory list","Claims/models":"C014, P10","Exact missing evidence or next action":"Any additional commissioner-rule categories not exhaustively reviewed"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Custody receipt versus fee earning","researcher_record":{"Subissue":"Custody receipt versus fee earning","Status":"Answered analytically","Claims/models":"C020, C035","Exact missing evidence or next action":"Actual transaction and subledger records"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Availability versus receipt clocks","researcher_record":{"Subissue":"Availability versus receipt clocks","Status":"Answered","Claims/models":"C020–C021","Exact missing evidence or next action":"Actual receipt/availability dates and any return"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Trust-to-provider/creditor/debtor routing","researcher_record":{"Subissue":"Trust-to-provider/creditor/debtor routing","Status":"Answered narrowly","Claims/models":"C020","Exact missing evidence or next action":"Full trust controls and bank documentation deferred"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor distribution deadline","researcher_record":{"Subissue":"Creditor distribution deadline","Status":"Answered","Claims/models":"C021","Exact missing evidence or next action":"Creditor due dates and actual credits"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Accumulation/returned-payment exceptions","researcher_record":{"Subissue":"Accumulation/returned-payment exceptions","Status":"Answered textually","Claims/models":"C021","Exact missing evidence or next action":"Fact-specific reasonable/net-interest evidence"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor consent","researcher_record":{"Subissue":"Creditor consent","Status":"Answered","Claims/models":"C018","Exact missing evidence or next action":"Actual binding concessions and consent evidence"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Withdrawal/refusal notice","researcher_record":{"Subissue":"Withdrawal/refusal notice","Status":"Answered","Claims/models":"C019","Exact missing evidence or next action":"Date learned and notices"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Direct-creditor/noncustodial branch","researcher_record":{"Subissue":"Direct-creditor/noncustodial branch","Status":"Partial","Claims/models":"C006, P11","Exact missing evidence or next action":"Actual service, representations, delegation and control"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Insufficient payment","researcher_record":{"Subissue":"Insufficient payment","Status":"Partial application","Claims/models":"C042, P12","Exact missing evidence or next action":"Contractual monthly-base and earning facts"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Late/missed/NSF payment","researcher_record":{"Subissue":"Late/missed/NSF payment","Status":"Answered for modeled facts","Claims/models":"P13, M04","Exact missing evidence or next action":"Real creditor consequences and bank reconciliation"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Monthly/final accounting","researcher_record":{"Subissue":"Monthly/final accounting","Status":"Answered","Claims/models":"C022","Exact missing evidence or next action":"Actual statements not supplied"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Ordinary debtor cancellation","researcher_record":{"Subissue":"Ordinary debtor cancellation","Status":"Answered","Claims/models":"C023, C025","Exact missing evidence or next action":"Actual notice/effective date and lawful prior fees"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Provider cancellation","researcher_record":{"Subissue":"Provider cancellation","Status":"Answered","Claims/models":"C024","Exact missing evidence or next action":"Good cause and thirty-day notice"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Automatic termination","researcher_record":{"Subissue":"Automatic termination","Status":"Answered","Claims/models":"C024","Exact missing evidence or next action":"Proof all listed debts and lawful fees paid"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Material-violation rescission","researcher_record":{"Subissue":"Material-violation rescission","Status":"Answered narrowly","Claims/models":"C026","Exact missing evidence or next action":"Actual material violation and exercise of rescission"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Federal actor/service/telephone coverage","researcher_record":{"Subissue":"Federal actor/service/telephone coverage","Status":"Answered conditionally","Claims/models":"C028–C029","Exact missing evidence or next action":"Actual entity and campaign facts"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Federal DMP first-fee trigger","researcher_record":{"Subissue":"Federal DMP first-fee trigger","Status":"Answered for described DMP","Claims/models":"C030–C032","Exact missing evidence or next action":"Executed binding plan and qualifying first payment"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"DMP subsequent servicing fees","researcher_record":{"Subissue":"DMP subsequent servicing fees","Status":"Answered federally, state limits separate","Claims/models":"C032","Exact missing evidence or next action":"Actual service/contract/state compliance"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Staggered creditor participation","researcher_record":{"Subissue":"Staggered creditor participation","Status":"Unresolved application","Claims/models":"C030–C032","Exact missing evidence or next action":"Whether individual-debt treatment applies and corresponding records"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Pre-trigger dedicated account","researcher_record":{"Subissue":"Pre-trigger dedicated account","Status":"Partial","Claims/models":"C033","Exact missing evidence or next action":"Actual ownership, administration, independence and account terms"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Bank-debit authorization","researcher_record":{"Subissue":"Bank-debit authorization","Status":"Answered narrowly","Claims/models":"C034","Exact missing evidence or next action":"Actual consent; other payment-rail requirements deferred"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P01 nominal enrollment posture","researcher_record":{"Subissue":"P01 nominal enrollment posture","Status":"Completed","Claims/models":"P01","Exact missing evidence or next action":"Hypothetical only"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P02–P04 initial-payment postures","researcher_record":{"Subissue":"P02–P04 initial-payment postures","Status":"Completed with separate-fee hold","Claims/models":"P02–P04","Exact missing evidence or next action":"M01–M03 specify assumptions"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P05 cadence posture","researcher_record":{"Subissue":"P05 cadence posture","Status":"Completed","Claims/models":"P05","Exact missing evidence or next action":"Irregular-month interpretation remains open"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P06–P09 advance-payment postures","researcher_record":{"Subissue":"P06–P09 advance-payment postures","Status":"Completed conditionally","Claims/models":"P06–P09","Exact missing evidence or next action":"Date/intent/history facts stated or held"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P10–P11 living-expense/direct-pay postures","researcher_record":{"Subissue":"P10–P11 living-expense/direct-pay postures","Status":"Completed with classification limits","Claims/models":"P10–P11","Exact missing evidence or next action":"Actual service/account facts"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P12–P14 shortage/failure/exit postures","researcher_record":{"Subissue":"P12–P14 shortage/failure/exit postures","Status":"Completed","Claims/models":"P12–P14","Exact missing evidence or next action":"Real contract and creditor facts"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"M01 $300 adversarial joint ledger","researcher_record":{"Subissue":"M01 $300 adversarial joint ledger","Status":"Completed","Claims/models":"C037","Exact missing evidence or next action":"Not actual fee approval"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"M02 larger initial joint ledger","researcher_record":{"Subissue":"M02 larger initial joint ledger","Status":"Completed conditionally","Claims/models":"C038","Exact missing evidence or next action":"Reasonableness and other assumptions essential"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"M03 separate-fee candidate","researcher_record":{"Subissue":"M03 separate-fee candidate","Status":"Completed; authority held","Claims/models":"C039","Exact missing evidence or next action":"Responsive classification authority"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"M04 missed-payment/cancellation ledger","researcher_record":{"Subissue":"M04 missed-payment/cancellation ledger","Status":"Completed conditionally","Claims/models":"C040","Exact missing evidence or next action":"Waivers/concessions are stipulated, not universal"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P01 E05 crosswalk","researcher_record":{"Subissue":"P01 E05 crosswalk","Status":"Completed","Claims/models":"C043","Exact missing evidence or next action":"Original preserved"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P01 E06 crosswalk","researcher_record":{"Subissue":"P01 E06 crosswalk","Status":"Completed","Claims/models":"C044","Exact missing evidence or next action":"Original preserved"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Responsive judicial/administrative interpretation","researcher_record":{"Subissue":"Responsive judicial/administrative interpretation","Status":"Not located in bounded search","Claims/models":"C036","Exact missing evidence or next action":"Further official published-opinion/Commerce-order research on exact issue"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"P05 settlement-performance component","researcher_record":{"Subissue":"P05 settlement-performance component","Status":"Excluded; not a premise","Claims/models":"C045","Exact missing evidence or next action":"Separate review remains separate"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"NMLS/current provider status/2026 transition","researcher_record":{"Subissue":"NMLS/current provider status/2026 transition","Status":"Deferred/preserved","Claims/models":"C045","Exact missing evidence or next action":"P02/P04 holds unchanged"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Full trust/bond compliance","researcher_record":{"Subissue":"Full trust/bond compliance","Status":"Deferred","Claims/models":"C045","Exact missing evidence or next action":"Account-control, bond and broader supervision component"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit/attorney registration and exemptions","researcher_record":{"Subissue":"Nonprofit/attorney registration and exemptions","Status":"Deferred","Claims/models":"C045","Exact missing evidence or next action":"Actual entity/activity qualification"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"CROA and broader federal credit repair","researcher_record":{"Subissue":"CROA and broader federal credit repair","Status":"Deferred boundary","Claims/models":"C045","Exact missing evidence or next action":"Actual representations and separate operative review"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Collection/litigation/wage/bank/other property","researcher_record":{"Subissue":"Collection/litigation/wage/bank/other property","Status":"Deferred","Claims/models":"C045","Exact missing evidence or next action":"Separate parent-state components"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"},{"topic":"Sector/local/tribal and remaining state dimensions","researcher_record":{"Subissue":"Sector/local/tribal and remaining state dimensions","Status":"Deferred","Claims/models":"C045","Exact missing evidence or next action":"No completion or acceptance by implication"},"raw_table_index":16,"coordinator_acceptance":"scoped_review_complete_with_material_evidence_holds;not_accepted","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_MN-P06-initial-retention-custody-earning-holds-20261027","status":"scoped_review_complete_separate_initial_fee_earning_currentness_notice_holds","at":"2026-10-27T10:32:00.653068+00:00"}]}