{"meta":{"key":"s_mo--pass-01","task":"S_MO","title":"SMO — Missouri Debt Relief Provider Access & Consumer Fees","parent_title":"Missouri debt and debt relief law","edition":"pass-01","path":"/research/s_mo--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":6,"claims":28,"sources":14,"review_status":"revise","review_complete":true,"sha256":"ac03710c20fbbbab939d229c5b23a4ff76095ef215ed705939624eee3b45925a","headings":["A. Substantive findings","Executive determination","A1. Definitions and model classification","A2. Prohibition, permitted structures and exemptions","A3. Consumer fees","A4. When fees can actually be received","A5. Missouri regulator and market-access procedure","A6. Directly verified bond requirement — supplemental finding","B. Primary source register","C. Consolidated claim register","D. Worked fee examples and component coverage","D1. Worked examples","D2. Coverage and exact gaps","D2. Coverage and exact gaps — continuation","E. Researcher self-check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_MO/pass-01","facets":{"geography":["us","us-mo"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"FreshMissouriprovider-access/feescomponentonly; allbroaderstatecategoriesrequired","pending_corrections":0},"markdown":"# S_MO — Missouri Debt Relief Provider Access & Consumer Fees\n\nSettleADebt.com | PASS-01 | Research date: October 24, 2026 (Pacific) | Baseline: October 22, 2026\n\nResearch status: Substantive primary-statute findings established; operational authorization and several boundary questions remain held.\n\n## A. Substantive findings\n\n### Executive determination\n\nMissouri has a particularly important distinction between debt management plans (DMPs) and debt settlement plans (DSPs). Its current published statutory framework, Revised Statutes of Missouri §§ 425.010–425.043, expressly recognizes both, but makes acting or offering to act as a debt adjuster outside either type of plan a misdemeanor.\n\nThe principal conclusions from the Missouri Revisor's operative text are:\n\n1. Debt settlement is not categorically prohibited. Missouri recognizes a written DSP contemplating creditor settlements for less than principal. That recognition is not a license or blanket authorization for any particular company.\n2. DMP fees have express numerical limits: a $50 initial/setup maximum and a monthly maximum of the greater of $35 or 8% of monthly creditor distributions, subject to the statutory cost-of-administration and performance requirements.\n3. DSP fees are governed by a per-debt allocation rule and performance prerequisites. The examined chapter does not specify a universal 15%, 20%, 25%, or other percentage ceiling for settlement fees.\n4. Fees cannot be received merely upon enrollment. Section 425.043(3) requires a qualifying debt alteration and at least one debtor payment under the applicable plan, with further allocation restrictions for settlement fees.\n5. The statute has defined exclusions. Missouri attorneys, qualifying debtor employees, certain court-authorized actors, no-cost creditor representatives, and qualifying loan arrangers are treated differently. Neither nonprofit status alone nor an out-of-state business location establishes an exemption.\n6. A Missouri DSP is not equivalent to verified provider authorization. The specific state registration, licensing, regulator-lookup and other potentially applicable requirements must be independently resolved before a provider is classified as market-ready.\n\nThe current Revisor displays the controlling substantive provisions as effective August 28, 2011, except § 425.030, which dates to August 28, 1963. Those are legislative effective dates, not the dates on which the webpages were updated. Missouri Revisor of Statutes+3\n\n### A1. Definitions and model classification\n\nS_MO-P1-C001 — Debt adjuster. Under § 425.010(1), a person becomes a debt adjuster by providing or offering debt relief services for consideration. The definition is activity-based, not dependent on the business calling itself a settlement company, counseling service, technology platform, or negotiator.\n\nS_MO-P1-C002 — Debt relief services. Section 425.010(4) encompasses programs represented expressly or implicitly as renegotiating, settling, or otherwise changing payment or other terms of debt involving unsecured creditors or debt collectors. Interest and fee reductions can therefore trigger coverage even without principal forgiveness.\n\nS_MO-P1-C003 — DMP. Section 425.010(2) describes a written agreement contemplating creditor reductions in finance charges or delinquency-related fees, with compensation limited to reasonable consideration.\n\nS_MO-P1-C004 — DSP. Section 425.010(5) describes a written agreement contemplating settlement for less than principal. A promise to obtain principal reduction is therefore materially different from an ordinary DMP concession.\n\nS_MO-P1-C005 — Debtor and purpose. The defined debtor is an individual or individuals. A corporation-only debt is not expressly included in that definition. However, whether an individual's business-purpose debt is covered, and whether other Missouri statutes regulate commercial negotiation, remain unresolved.\n\nThese propositions are grounded in the full operative definitions at § 425.010(1)–(6). Missouri Revisor of Statutes\n\n| Business model | Missouri Chapter 425 classification | Finding |\n| --- | --- | --- |\n| For-fee credit-card principal settlement | DSP if the statutory written-plan conditions are satisfied | Recognized, conditional |\n| For-fee interest-rate or late-fee concessions | DMP when statutory plan conditions fit | Recognized, conditional |\n| Payment distribution with creditor concessions | Potential DMP | Custody alone is not decisive |\n| Noncustodial negotiation of unsecured debts | Potential DSP or DMP | Not exempt merely because funds never pass through provider |\n| Paid advice without negotiating or altering debt terms | Fact-dependent | Hold classification |\n| Pure creditor payment processing | Fact-dependent | Hold classification |\n| Business entity's own commercial debt | Outside express individual-debtor definition | Other laws not cleared |\n| Individual's business-purpose debt | Definition does not expressly require consumer purpose | Hold detailed application |\n| Remote provider serving Missouri individuals | Potential in-state activity | Nexus and authorization hold |\n\n### A2. Prohibition, permitted structures and exemptions\n\nS_MO-P1-C006 — Prohibited conduct. Section 425.020 states that acting or offering to act as a debt adjuster in Missouri other than under a DMP or DSP is a misdemeanor. The statute does not say that acquiring a generic business license cures operating outside those plans.\n\nS_MO-P1-C007 — Enforcement. Section 425.030 authorizes the attorney general to seek a circuit-court injunction and appointment of a receiver to protect debtor money and property. This is an enforcement provision, not a provider licensing procedure. Missouri Revisor of Statutes+1\n\nS_MO-P1-C008 — Express exclusions. Section 425.040 excludes the following from the chapter's definition of debt adjuster:\n\n- An attorney at law of Missouri.\n- A regular, full-time employee adjusting the debts of that employee's debtor-employer.\n- A person acting under a court order, judgment, or authority conferred by Missouri or federal law.\n- A creditor or creditor agent whose debt-adjusting services cost the debtor nothing.\n- A person who, at the debtor's request, arranges or makes a loan and, with the debtor's authorization, adjusts debts by disbursing the loan proceeds without compensation for debt relief services.\n\nThe loan-arranger exclusion requires all of its stated conditions, including the debtor's request, authorization, qualifying disbursement activity, and absence of compensation for debt relief services.\n\nS_MO-P1-C009 — Exemption boundaries. Section 425.040 does not list a general nonprofit exemption, a general out-of-state provider exemption, or an exemption for every company affiliated with an attorney. Missouri attorney status is a specific statutory exclusion, not an automatic exemption for a separately operated commercial settlement company. Missouri Revisor of Statutes\n\n### A3. Consumer fees\n\nDMP INITIAL / SETUP\n\n# $50\n\nStatutory maximum, not automatic collection permissionDMP MONTHLY\n\n# Greater of $35 or 8%\n\n8% of monthly distributions to creditorsS_MO-P1-C010 — DMP limits. Section 425.010(6) defines reasonable consideration as an administrative-cost fee not exceeding the $50 initial amount and the monthly formula above. The statute's word greater matters: $35 is not a universal maximum where 8% exceeds it.\n\nS_MO-P1-C011 — No verified DMP indexing. The current published definition specifies fixed dollar amounts and a percentage. No indexing mechanism appears in that provision. This does not establish that no separate administrative interpretation exists.\n\nS_MO-P1-C012 — DSP numerical limits. Sections 425.010(5) and 425.043(3) establish consideration and allocation rules but do not themselves specify a statewide maximum percentage of enrolled debt or savings. An industry fee percentage cannot be presented as Missouri's statutory ceiling.\n\nS_MO-P1-C013 — DSP allocation. Section 425.043(3)(3) provides two alternatives for allocating settlement fees:\n\n- Proportional allocation using the individual debt's enrollment balance relative to all enrolled debt and the total contracted fee.\n- A uniform percentage of actual savings, with savings measured against enrollment balance and the amount actually paid to satisfy the debt.\n\nThe statutory rule does not permit collecting an entire multi-debt program fee simply because the first debt reached a settlement.\n\nS_MO-P1-C014 — Fee categories not independently cleared. Separate DSP enrollment, maintenance, monthly, per-debt, administrative and cancellation charges cannot be deemed permissible merely because § 425.010(5) does not state a percentage cap. Each must be evaluated under § 425.043(3), the applicable contract and any additional law.\n\nPrimary pinpoints: § 425.010(5)–(6); § 425.043(3)(1)–(3). Missouri Revisor of Statutes+1\n\n### A4. When fees can actually be received\n\nS_MO-P1-C015 — State performance trigger. Missouri § 425.043(3) prohibits receipt of a debt relief fee until the adjuster has renegotiated, settled, reduced or otherwise altered at least one debt under a DMP or DSP and the debtor has made at least one payment under that plan.\n\nS_MO-P1-C016 — DSP per-debt limitation. The same subsection adds the proportional or uniform-savings calculation for settlement fees. A first qualifying payment is necessary but does not, by itself, establish that every proposed fee amount is earned.\n\nS_MO-P1-C017 — Federal TSR independently applies when its coverage requirements are met. Under 16 CFR § 310.4(a)(5), the federal debt-relief advance-fee prohibition also requires the creditor's written agreement to the changed debt terms, the customer's agreement to the result, and a qualifying payment to the creditor or collector. For multiple enrolled debts, federal proportional or uniform-savings allocation restrictions also apply.\n\nThe federal rule is not a Missouri licensing system, and its application depends on the covered telemarketing activity and exemptions. FTC guidance confirms that a general attorney exemption does not exist for covered telemarketing. Federal Trade Commission+2\n\nS_MO-P1-C018 — Dedicated accounts and cancellation. Missouri § 425.043(4) conditionally permits accumulating funds in an insured financial institution account, subject to debtor ownership, interest rights, account-administrator relationship restrictions, no referral compensation, withdrawal without penalty, and return of unearned funds within seven business days after the debtor's request.\n\nA deposit into the account is not equivalent to a fee lawfully received by the provider. Missouri's exact account-administration conditions must be assessed separately from the federal TSR's account rules, which are not worded identically. Missouri Revisor of Statutes\n\nS_MO-P1-C019 — Disclosure and misrepresentation. Section 425.043(1)–(2) requires specified pre-consent disclosures and prohibits material misrepresentations, including claims concerning results, savings, credit consequences, collection activity, and nonprofit status. These duties apply regardless of whether a proposed fee is within a numerical limit.\n\n### A5. Missouri regulator and market-access procedure\n\nAn important additional primary regulator finding resolves the basic licensing-versus-bond distinction.\n\nThe Missouri Division of Finance expressly states on its Consumer Credit Licensing page that Missouri does not require a debt-adjuster license under Chapter 425, but a debt adjuster must post a bond before entering the business.\n\nThis is not an ordinary licensing regime. The Division provides debt-adjuster information and bond forms. Missouri Division of Finance\n\nS_MO-P1-C020 — Regulatory structure. Chapter 425's principal access gate is the required bond, not a debt-adjuster license. This distinction is established by the regulator's published operational statement, subject to verification of the exact statutory bond terms.\n\nS_MO-P1-C021 — No named-provider clearance. Neither a completed information form nor a company claiming Missouri coverage proves its bond is on file, valid, sufficient or applicable to its business model. No specific provider's status has been checked.\n\nS_MO-P1-C022 — Separate regulatory categories. The Division also lists credit service organizations, money transmitters and other regulated financial businesses. Whether a particular debt-relief operator independently enters one of those categories depends on its actual conduct. Chapter 425's no-license statement does not eliminate those possible obligations.\n\nThe Division's public entry point is:\n\n[https://finance.mo.gov/consumer-credit-licensing](https://finance.mo.gov/consumer-credit-licensing?utm_source=chatgpt.com)\n\nAdditional primary documents: [https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf](https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf?utm_source=chatgpt.com)\n\nThe current statutory bond amount, noncustodial versus custodial requirements, filing mechanics, form version, and public lookup are specifically held pending direct examination of § 425.027 and the forms. They should not be inferred from a third-party chart.\n\n### A6. Directly verified bond requirement — supplemental finding\n\nThe official text of § 425.027 has now been opened and read.\n\nS_MO-P1-C023 — Bond amounts.\n\n| Operation | Statutory bond principal |\n| --- | --- |\n| Applicant declares it will handle no consumer monies | $50,000 |\n| All other applicants | $100,000 |\n\nSection 425.027 uses the phrase initial license application, although the Division expressly says there is no debt-adjuster licensing requirement. The two sources must be read together: the statutory wording should be preserved, while the Division's operational guidance identifies the actual bond-based procedure. This textual inconsistency is not evidence that a license is issued. Missouri Revisor of Statutes+1\n\nS_MO-P1-C024 — Bond protection. The bond benefits debtors damaged by a debt adjuster's breach of a DMP or DSP or improper administration of debtor funds. The Division's director may investigate debtor complaints and pursue or release a bond claim for a debtor under § 425.027.\n\nS_MO-P1-C025 — No-charge plans. Section 425.025 expressly preserves administration of a DMP or DSP free of charge by an individual or organization. This is a no-fee pathway, not proof that an otherwise compensated service may avoid Chapter 425 by describing itself as nonprofit. Missouri Revisor of Statutes\n\nThe $50,000/$100,000 figures are surety bond principal amounts, not consumer service fees. They must never enter a customer fee calculator as charges payable to the provider.\n\n## B. Primary source register\n\nAll access checks below occurred October 24, 2026. “Read” means operative text was returned and examined, not merely that a search result existed.\n\n| Source ID | Authority and literal URL | Exact pinpoint / effective status / examination |\n| --- | --- | --- |\n| S_MO-P1-S001 | Missouri Revisor, § 425.010. [https://revisor.mo.gov/main/OneSection.aspx?section=425.010](https://revisor.mo.gov/main/OneSection.aspx?section=425.010&utm_source=chatgpt.com) | (1)–(6), definitions and DMP fees. Effective 2011-08-28. Read. |\n| S_MO-P1-S002 | Missouri Revisor, § 425.020. [https://revisor.mo.gov/main/OneSection.aspx?section=425.020](https://revisor.mo.gov/main/OneSection.aspx?section=425.020&utm_source=chatgpt.com) | Entire operative prohibition. Effective 2011-08-28. Read. |\n| S_MO-P1-S003 | Missouri Revisor, § 425.025. [https://revisor.mo.gov/main/OneSection.aspx?section=425.025](https://revisor.mo.gov/main/OneSection.aspx?section=425.025&utm_source=chatgpt.com) | Entire free-of-charge provision. Effective 2011-08-28. Read. |\n| S_MO-P1-S004 | Missouri Revisor, § 425.027. [https://revisor.mo.gov/main/OneSection.aspx?section=425.027](https://revisor.mo.gov/main/OneSection.aspx?section=425.027&utm_source=chatgpt.com) | Bond amounts (1)–(2), bond beneficiaries and director powers. Effective 2011-08-28. Read. |\n| S_MO-P1-S005 | Missouri Revisor, § 425.030. [https://revisor.mo.gov/main/OneSection.aspx?section=425.030](https://revisor.mo.gov/main/OneSection.aspx?section=425.030&utm_source=chatgpt.com) | Injunction and receiver. Effective 1963-08-28. Read. |\n| S_MO-P1-S006 | Missouri Revisor, § 425.040. [https://revisor.mo.gov/main/OneSection.aspx?section=425.040](https://revisor.mo.gov/main/OneSection.aspx?section=425.040&utm_source=chatgpt.com) | Exclusions (1)–(5). Effective 2011-08-28. Read. |\n| S_MO-P1-S007 | Missouri Revisor, § 425.043. [https://revisor.mo.gov/main/OneSection.aspx?section=425.043](https://revisor.mo.gov/main/OneSection.aspx?section=425.043&utm_source=chatgpt.com) | (1) disclosures; (2) misrepresentations; (3) fees; (4) accounts. Effective 2011-08-28. Read. |\n| S_MO-P1-S008 | Missouri Division of Finance, Consumer Credit Licensing. [https://finance.mo.gov/consumer-credit-licensing](https://finance.mo.gov/consumer-credit-licensing?utm_source=chatgpt.com) | “Additional Information — Debt Adjusters,” lines 37–45. Current page, undated substantive guidance. Read. Operational, not independent statutory authority. |\n| S_MO-P1-S009 | Electronic CFR, 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) | (a)(5)(i)(A)–(C), (a)(5)(ii)(A)–(E), and (a)(2). Displayed version up to date 2026-10-22. Read. Federal, conditional applicability. |\n| S_MO-P1-S010 | FTC, Debt Relief Services and TSR 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) | Coverage, fees, allocation, attorney discussion. Historical agency guidance. Substantive retrieved passages read, not complete document audit. |\n| S_MO-P1-S011 | FTC, Complying with the TSR. [https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule](https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule?utm_source=chatgpt.com) | Debt relief advance-fee and account discussions. Substantive retrieved passages read. |\n| S_MO-P1-S012 | Missouri Division of Finance, Consumer Credit Lawbook. [https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf](https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf?utm_source=chatgpt.com) | Chapter 425, table of contents and reproduced provisions. Discovery excerpts only; full PDF and version not inspected. Not used instead of current Revisor. |\n| S_MO-P1-S013 | Missouri Revisor, Chapter 425 index. [https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043](https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043&utm_source=chatgpt.com) | Section inventory and displayed effective dates. Discovery/index only; individual sections S001–S007 were separately opened. |\n| S_MO-P1-S014 | FTC, Debt Relief Services TSR Questions. [https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com) | Fees, cancellation and 2010 effective dates. Retrieved passages read, not a current codified rule. |\n\nAll S001–S007 are Missouri primary statutes; S008 is primary state agency operational material; S009 is current federal regulatory text; S010, S011 and S014 are federal interpretive guidance. The FTC's 2010 rule implementation history does not change Missouri's 2011 statutory effective dates.\n\nSource support: Missouri Revisor of Statutes+8\n\n## C. Consolidated claim register\n\n“High” indicates direct textual support for the stated proposition, not a conclusion that every possible applicable law has been exhausted.\n\n| Claim ID | Precise proposition | Sources / pinpoint | Confidence and boundary |\n| --- | --- | --- | --- |\n| C001 | Paid debt relief offers or services can establish debt-adjuster status | S001(1) | High; factual conduct matters |\n| C002 | Debt relief includes changes to unsecured debt terms, not only principal forgiveness | S001(4) | High |\n| C003 | DMP is a written concession-oriented agreement | S001(2) | High |\n| C004 | DSP is a written less-than-principal settlement agreement | S001(5) | High |\n| C005 | Defined debtor is individual(s) | S001(3) | High text; business-purpose reach partial |\n| C006 | Acting outside a DMP/DSP is a misdemeanor | S002 | High |\n| C007 | AG can seek injunction and receiver | S005 | High |\n| C008 | Five express statutory exclusions | S006(1)–(5) | High; fact-specific |\n| C009 | No general nonprofit or remote-provider exclusion in § 425.040 | S006 | High for this section; other law open |\n| C010 | DMP setup $50 maximum; monthly greater of $35 or 8% | S001(6) | High; performance condition separately applies |\n| C011 | No indexing language in statutory DMP fee definition | S001(6) | High for text; external adjustments unverified |\n| C012 | No express universal DSP percentage cap in examined Chapter 425 | S001(5), S007(3) | High for examined chapter; other law open |\n| C013 | DSP proportional or uniform-savings fee allocation | S007(3)(3)(a)–(b) | High |\n| C014 | Ancillary fee labels do not bypass timing or allocation | S001(1), S007(3) | Strong statutory reading; category-specific applications open |\n| C015 | Debt alteration and debtor payment precede state fee receipt | S007(3)(1)–(2) | High |\n| C016 | First qualifying payment does not automatically earn entire DSP fee | S007(3)(3) | High |\n| C017 | Covered TSR transactions have independent fee triggers and allocation rules | S009(a)(5)(i) | High; federal coverage conditional |\n| C018 | Missouri dedicated-account conditions and seven-business-day return | S007(1)(4), (4)(1)–(5) | High; earned-fee calculation still required |\n| C019 | Mandatory pre-consent disclosures and misrepresentation restrictions | S007(1)–(2) | High |\n| C020 | Division says no Chapter 425 debt-adjuster license; bond required | S008, Debt Adjusters | High operational statement; statutory wording conflict disclosed |\n| C021 | Named provider's bond or authorization not verified | S008, S004 | Unresolved actual provider status |\n| C022 | Other financial regulatory categories may apply to additional activities | S008, license categories | Conditional; no categorical overlap established |\n| C023 | Bond $50,000 noncustodial declaration; $100,000 otherwise | S004(1)–(2) | High |\n| C024 | Bond protects qualifying debtor claims; director has specified powers | S004, paragraph following (2) | High |\n| C025 | DMP/DSP may be administered free of charge | S003 | High |\n| C026 | TSR dedicated account requires independent administration and qualifying refunds | S009(a)(5)(ii) | High if TSR applies |\n| C027 | TSR separately restricts fees for represented credit improvement | S009(a)(2) | High text; CROA overlap unresolved |\n| C028 | No current provider bond filing, lookup result or form version verified | S008, form links | Explicit hold |\n\nImportant interpretation limit: C012 is not a positive determination that any chosen DSP fee percentage is lawful. It identifies the absence of an express percentage cap in the particular statutory provisions examined. A lawful charge still depends on the actual business model, required bond, agreement, allocation, timing and independently applicable laws.\n\n## D. Worked fee examples and component coverage\n\n### D1. Worked examples\n\nThese are arithmetic and statutory-boundary tests, not approved provider contracts. All dollars are USD, rounded to cents. The examples assume that the required Missouri bond has been properly posted, a valid written plan exists, and any independently applicable federal requirements are satisfied. Where those facts are absent, the result is a collection hold.\n\n#### Example MO-E01 — Low-distribution DMP\n\nPlain text\n```\nMonthly amount distributed to creditors: $200.00\nPercentage rate:                       8%\nPercentage calculation:       $200 × .08 = $16.00\nStatutory comparison:          max($35, $16)\nMonthly numerical ceiling:              $35.00\n```\n\nThe $35 result is a statutory ceiling, not necessarily an appropriate charge. Section 425.010(6) also requires the fee to cover administration costs. If the qualifying creditor concession and debtor-payment prerequisites have not occurred, the amount currently collectible is $0.\n\nSources: S001(6), S007(3). Claims: C010, C015.\n\n#### Example MO-E02 — Higher-distribution DMP\n\nPlain text\n```\nMonthly creditor distributions:      $1,000.00\nPercentage rate:                           8%\nPercentage calculation:   $1,000 × .08 = $80\nStatutory comparison:             max($35, $80)\nMonthly numerical ceiling:              $80.00\n\nSeparate initial/setup ceiling:          $50.00\n```\n\nThe $50 setup amount is not automatically collectible on signing. It is subject to the applicable fee-receipt restriction. This example does not presume that an initial payment earns every separately described administrative charge.\n\nSources: S001(6), S007(3). Claims: C010, C015.\n\n#### Example MO-E03 — Proportional DSP fee, first debt\n\nAssume a contract with three debts and a single total fee calculated as 20% of total enrolled balances. The 20% is an illustrative contract assumption, not a verified Missouri legal fee ceiling.\n\nPlain text\n```\nDebt A enrolled:                       $4,000.00\nDebt B enrolled:                       $6,000.00\nDebt C enrolled:                      $10,000.00\nTotal enrolled:                       $20,000.00\n\nAssumed total contracted fee:\n$20,000 × .20 =                       $4,000.00\n\nDebt A allocation:\n$4,000 × ($4,000 / $20,000) =           $800.00\n\nDebt A settlement amount:              $2,200.00\nDebt A settlement savings:             $1,800.00\n\nMaximum allocated fee for Debt A:        $800.00\n```\n\nIf Debt A has a qualifying settlement and payment, $800 is the proportionally allocated amount. Whether it can actually be received depends on the complete state and federal conditions.\n\nA $4,000 fee following only Debt A's settlement would violate the proportional allocation premise. The result does not change because the debtor has already deposited $4,000 into a dedicated account.\n\nSources: S007(3)(3)(a), S009(a)(5)(i)(C)(1). Claims: C013, C016, C017.\n\n#### Example MO-E04 — Previously earned fee consistency\n\nContinue the same contract, same three enrollment balances, and same proportional allocation method as MO-E03.\n\nPlain text\n```\nTotal enrolled balance:               $20,000.00\nTotal contracted fee:                  $4,000.00\n\nDebt A:\nEnrollment balance:                    $4,000.00\nAllocated fee:                           $800.00\nQualifying result and payment:               Yes\nPreviously earned fee:                   $800.00\n\nDebt B:\nEnrollment balance:                    $6,000.00\nAllocated fee:\n$4,000 × ($6,000 / $20,000) =          $1,200.00\nQualifying result and payment:               Yes\n\nDebt C:\nEnrollment balance:                   $10,000.00\nAllocated fee:                         $2,000.00\nQualifying result and payment:                No\n\nCumulative allocated/earned fees:\n$800 + $1,200 =                       $2,000.00\n\nUnallocated-to-earned-status balance:\n$4,000 - $2,000 =                     $2,000.00\n```\n\nThe $800 previously earned from Debt A is consistent with the same contracted fee, enrollment balances and allocation method. Debt B's $1,200 is not a new fee formula.\n\nIf the debtor cancels at this point, the example assumes both qualifying payments occurred and all relevant conditions were met. It does not assume Debt C's $2,000 has been earned.\n\nSources: S007(3)–(4), S009(a)(5). Claims: C013, C016, C018.\n\n#### Example MO-E05 — Savings-based DSP, partial settlement\n\nThis example uses a separate contract, with a uniform 25% savings-based fee across all debts.\n\nPlain text\n```\nDebt A enrolled balance:               $8,000.00\nDebt A amount required to satisfy:     $5,000.00\n\nSavings:\n$8,000 - $5,000 =                      $3,000.00\n\nAssumed savings-fee rate:                    25%\n\nAllocated savings-based fee:\n$3,000 × .25 =                           $750.00\n```\n\nThe creditor may permit installments toward the $5,000 settlement. One qualifying payment can satisfy the relevant payment trigger, but merely making an ordinary payment without an agreed debt alteration does not.\n\nThe $750 is not calculated on the original $8,000 balance. The same 25% savings rate must apply to the other debts in this contract. The contract cannot switch to the proportional method for Debt B merely because that produces more revenue.\n\nSources: S007(3)(3)(b), S009(a)(5)(i)(C)(2). Claims: C013, C017.\n\n#### Example MO-E06 — Failed settlement and cancellation\n\nPlain text\n```\nTotal debtor deposits:                 $3,000.00\nCreditor settlements achieved:                 0\nQualifying payments under agreements:          0\n\nEarned settlement fees:                   $0.00\n```\n\nAssuming all $3,000 remains in a qualifying dedicated account and there are no lawful independent account-administrator charges or creditor disbursements, the debtor is entitled to the full $3,000 upon withdrawal, within the applicable seven-business-day period after the request.\n\nIf a separate administrator has assessed charges, their legality and amounts must be established independently. This example does not authorize a provider to retain a cancellation penalty or an unearned setup fee.\n\nSources: S007(3)–(4), S009(a)(5)(ii). Claims: C015, C018, C026.\n\n#### Example MO-E07 — No-charge counseling\n\nPlain text\n```\nConsumer debts discussed:             $12,000.00\nDebt relief fee charged:                   $0.00\nDebt relief compensation received:         $0.00\n```\n\nSection 425.025 expressly allows free administration of a DMP or DSP. A provider charging the debtor indirectly through another arrangement cannot automatically rely on this example; the actual compensation and representation structure must be examined.\n\nSource: S003. Claim: C025.\n\n### D2. Coverage and exact gaps\n\n| Component | Status | Claims | Missing evidence / next investigation |\n| --- | --- | --- | --- |\n| Debt adjuster definition | Answered | C001–C002 | Apply facts to hybrid products |\n| DMP versus DSP | Answered | C003–C004 | Examine mixed plans and plan amendments |\n| Individual debtor definition | Partial | C |  |\n\n\n\n---\n\nCoordinator provenance: separately preserved missing-remainder continuation; first partial row retained verbatim above, not a single original response.\n\n### D2. Coverage and exact gaps — continuation\n\n| Component | Status | Claims | Missing evidence / exact next investigation |\n| --- | --- | --- | --- |\n| Individual debtor definition | Partial | C005 | Section 425.010(3) expressly defines a debtor as an individual or individuals. This pass did not establish whether every individual business-purpose obligation is covered, whether sole-proprietor debt is treated differently from entity debt, or whether another Missouri law reaches entity/commercial debt outside Chapter 425. Next: inspect Chapter 425 application decisions and any commercial-debt-adjustment provisions without importing a consumer-purpose limitation that the definition does not expressly state. |\n| Custodial versus noncustodial models | Partial | C001–C004, C018, C023 | The activity definitions do not make possession of consumer funds the sole coverage test. Section 425.027 changes the bond amount depending on whether consumer monies will be handled, and § 425.043(4) governs qualifying dedicated accounts. This pass did not resolve every noncustodial technology, referral, negotiation-only, creditor-payment or account-administrator configuration. |\n| Resident and remote-provider nexus | Unresolved | C001, C006 | The examined text prohibits acting or offering to act as a debt adjuster “in this state,” but no controlling Missouri authority defining the remote-provider, solicitation, contracting, debtor-residence or performance nexus was opened. Do not treat an out-of-state office as an exemption or Missouri residence alone as conclusively resolving every nexus question. |\n| Chapter 425 operating pathway | Partial | C006, C020, C023–C024 | Operating outside a DMP or DSP is prohibited, and the Division states that Chapter 425 requires a bond rather than a debt-adjuster license. The exact operational sequence, filing acceptance, renewal requirements, amendment duties, cancellation procedure and consequences of bond lapse were not established. |\n| Attorney exclusion | Partial | C008–C009 | Section 425.040 expressly excludes a Missouri attorney at law. This pass did not establish when a law firm, nonlawyer affiliate, marketing company, shared-services entity or attorney-connected commercial program may rely on that exclusion. No blanket attorney-enterprise exemption was found or claimed. |\n| Nonprofit status | Answered only as to § 425.040; otherwise open | C009, C019, C025 | Section 425.040 contains no general nonprofit exclusion, and § 425.043 prohibits material misrepresentations concerning nonprofit status. Section 425.025 permits genuinely free administration. Other nonprofit, tax, charitable-solicitation or institutional provisions were not examined. |\n| Other express exclusions | Partial | C008 | The employee, court/legal-authority, no-cost creditor-agent and qualifying loan-arranger exclusions were identified. Their factual boundaries, especially compensation, debtor authorization, loan proceeds, creditor agency and indirect remuneration, require transaction-specific analysis. |\n| No-charge plan pathway | Answered, bounded | C025 | A DMP or DSP may be administered free of charge. This does not resolve indirect compensation, lead fees, creditor payments, account charges or affiliated-provider revenue. |\n| DMP setup and monthly amounts | Answered as statutory numbers; application partial | C010–C011, C015 | The examined current statutory text states a maximum $50 initial fee and a monthly maximum equal to the greater of $35 or 8% of monthly creditor distributions, also tied to reasonable administrative cost. The statute does not itself make either amount automatically collectible. |\n| DMP indexing or adjusted amounts | Partial | C011 | No indexing clause appears in § 425.010(6). No current adjustment notice, administrative order, fee bulletin or authoritative indexed schedule was opened. Therefore, no CPI-derived or unofficial adjusted dollar amount is accepted. |\n| DSP percentage, savings and aggregate limits | Partial | C012–C014 | No universal DSP percentage ceiling was located in the examined Chapter 425 provisions. The absence of an express percentage cap is not affirmative approval of 15%, 20%, 25% or another rate. Ancillary, enrollment, monthly, administrative, per-debt, savings-based and aggregate charges remain subject to classification, contract, allocation, timing and other applicable law. |\n| Missouri fee-receipt timing | Answered, bounded | C015–C016 | A qualifying debt alteration and at least one debtor payment under the plan are required before receipt of a fee. For DSPs, the per-debt allocation rule further limits the amount. Unresolved issues include application to plan amendments, unsuccessful negotiations, replacement settlements, disputed payments and rescinded creditor agreements. |\n| Federal TSR timing overlap | Partial | C017, C026 | The exact federal advance-fee provision was examined and treated as independently applicable only when TSR coverage exists. This pass did not decide every inbound/outbound call, internet lead, face-to-face, attorney, nonprofit or other TSR coverage/exemption question. Missouri limits are not federal advance-fee authorization. |\n| Credit-repair representations and CROA overlap | Unresolved | C027 only as to the separately examined TSR provision | The TSR’s represented-credit-improvement fee restriction was noted. CROA’s definitions, exemptions, contract rules and fee timing were not fully researched here. No universal CROA coverage or exemption is claimed. |\n| Dedicated accounts and debtor ownership | Partial | C018, C026 | Missouri account ownership, interest, administrator-independence, referral-compensation, penalty-free withdrawal and seven-business-day return conditions were identified. The complete federal/state interaction, administrator charges, bank terms, account closure mechanics and treatment of already disbursed creditor payments remain open. |\n| Cancellation and unearned-fund return | Partial | C018, C026 | The examples correctly held unearned fees and remaining consumer funds rather than treating cancellation as permission to retain a penalty. This pass did not establish every contractual cancellation right, refund formula, dispute process or treatment of properly earned fees. |\n| Worked-fee calculations | Answered only as bounded examples | C010, C013, C015–C018, C025–C026 | The examples separate numerical ceilings, earned-fee allocation and collection timing. They are not approved contracts. Every production calculation must preserve one contract method across debts and use the same enrolled balances and total contracted fee. |\n| Prior-fee scenario consistency | Answered for the stated proportional example; otherwise open | C013, C016 | MO-E04 reconciled the previously earned $800 against the same balances, $4,000 total contracted fee and proportional method used for the current debt. No deduction is deemed earned merely because a payment occurred. Different contract facts require a fresh reconstruction. |\n| Partial settlements and failed settlements | Partial | C013, C015–C017 | A qualifying altered debt and qualifying payment may support only the correctly allocated fee. Ordinary payments, unsuccessful negotiation or an unenforceable proposed settlement do not automatically trigger a fee. Missouri case authority on borderline performance was not read. |\n| Bond principal amounts | Answered as statutory amounts | C023–C024 | Section 425.027 states $50,000 when the applicant declares it will handle no consumer monies and $100,000 otherwise. These are bond principal amounts, not consumer fees. Bond form language, surety conditions, renewal and current filing instructions remain unverified. |\n| “Initial license application” wording versus agency no-license statement | Partial | C020, C023 | The statutory wording and Division guidance were preserved without converting the program into ordinary licensing. No formal interpretation, rule, opinion or case reconciling that terminology was opened. |\n| Current application and filing procedure | Unresolved | C020, C028 | The Division’s public page states that a bond must be posted before entering the business, but no current application packet, bond form version, filing fee, submission method, approval document or renewal instruction was fully opened and verified. |\n| Public registry or provider lookup | Unresolved | C021, C028 | No authoritative public registry or bond lookup was established, and no named provider’s current bond or authority was checked. A marketing statement, form download or agency homepage does not prove provider authorization. |\n| Other regulatory classifications | Partial | C022 | Money transmission, credit-services-organization, lending, collection, legal-services and other categories may depend on actual conduct. Their Missouri triggers and exclusions were not resolved in this pass. |\n| Disclosures and representations | Answered as Chapter 425 baseline | C019 | Section 425.043’s pre-consent disclosures and misrepresentation prohibitions were identified. Advertising regulations, UDAP decisions, testimonial rules and medium-specific disclosure requirements remain later work. |\n| Regulations and adoption orders | Unresolved | No additional claim issued | No complete operative Missouri regulation or adoption order specifically implementing these Chapter 425 provisions was identified and read. Absence of a regulation is not established. Next: inspect the current Missouri Code of State Regulations and Secretary of State rulemaking history. |\n| Controlling Missouri decisions | Unresolved | No additional claim issued | No controlling Missouri appellate or federal decision interpreting Chapter 425’s definitions, nexus, exclusions, fee timing, allocation, bond language or private consequences was opened. Case-law silence is not claimed. |\n| Statutory and source history | Partial | C011, C020, C023 | The Revisor-displayed effective dates were recorded. Session laws, amendment history, model-act lineage, archived versions, historical agency bulletins and dated fee tables were not reconstructed. No later model revision was treated as Missouri law. |\n| Agreement, funds, bond and remedies beyond access/fees | Deferred/partial | C007, C018, C023–C024 | Only provisions needed to answer present access and fee questions were addressed. Full contract formation, required clauses, rescission, trust/account administration, bond claims, private remedies, AG powers and receivership remain separate passes. |\n| Collections, litigation, limitations and exemptions | Deferred | — | Collection conduct, creditor litigation, limitations periods, judgment effects, exemptions, garnishment and settlement enforceability were outside this component and remain open. |\n| Secured debt, sectors, local and tribal law | Deferred | — | Chapter 425’s examined debt-relief definition concerns unsecured debt. Mortgages, auto debt, tax debt, student debt, medical debt, utilities, regulated institutions, local rules and tribal jurisdiction were not cleared. |\n| Contract, full federal overlap and publication readiness | Deferred | — | Contract law, E-SIGN, UETA, CROA, FDCPA, FCRA, bankruptcy, tax consequences and complete TSR coverage require later work. Nothing in this pass constitutes whole-state, parent-dossier, A066, operational or publication acceptance. |\n\n## E. Researcher self-check\n\n**Actual access date:** October 24, 2026, Pacific time. The October 22 baseline was not treated as the current-verification date. This continuation performed no new browsing and relies only on the preserved PASS-01 source and claim register.\n\n**Actually opened and read:** S_MO-P1-S001 through S007—the individual Missouri Revisor pages for §§ 425.010, 425.020, 425.025, 425.027, 425.030, 425.040 and 425.043—were opened and their relevant operative text examined. S008, the Missouri Division of Finance consumer-credit-licensing page, was read for its debt-adjuster no-license/bond statement. S009, the current eCFR page for 16 CFR § 310.4, was read for the specifically cited debt-relief fee, allocation, dedicated-account and represented-credit-improvement clauses.\n\n**Partially read:** S010, S011 and S014 were used only for the retrieved FTC passages identified in the source register. They were not treated as complete, line-by-line audits of each guidance document and do not replace the codified federal text.\n\n**Discovery or index only:** S012, the Division’s Consumer Credit Lawbook PDF, was supported only by discovery/search-rendered material; the complete PDF, all pages, publication date and revision status were not inspected. S013 was used as a chapter index and displayed-effective-date locator, not as a substitute for opening the individual statutory sections. Search-rendered excerpts were not treated as complete operative verification.\n\n**Not read or verified:** No current debt-adjuster application packet, executed bond form, filing receipt, renewal instruction, public registry, named-provider record, Missouri regulation, rulemaking/adoption order, controlling decision, complete session-law history, historical bulletin series or archived fee table was opened. No application was filed; no agency, provider, surety, attorney or consumer was contacted.\n\n**Supplied and reused material:** No Missouri finding supplied by an earlier foundation cell was adopted as evidence. Earlier foundation material remained a lead only. The source and claim IDs in this continuation are reused solely from the immutable visible PASS-01 segment; no new claim ID or read history has been created.\n\n**Process limits:** No Deep Research, Work mode, API, Chrome control, account or permission change, CAPTCHA workaround, private borrower data, local write, external publication or other Chat was used. This was the missing-output continuation of the provider-access/consumer-fees component, not an independent review and not acceptance of Missouri as complete, operationally cleared or publication-ready.\n\nEND S_MO PASS-01\n\nEND S_MO PASS-01-CONTINUATION-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Missouri Chapter 425 classification","Finding"],["For-fee credit-card principal settlement","DSP if the statutory written-plan conditions are satisfied","Recognized, conditional"],["For-fee interest-rate or late-fee concessions","DMP when statutory plan conditions fit","Recognized, conditional"],["Payment distribution with creditor concessions","Potential DMP","Custody alone is not decisive"],["Noncustodial negotiation of unsecured debts","Potential DSP or DMP","Not exempt merely because funds never pass through provider"],["Paid advice without negotiating or altering debt terms","Fact-dependent","Hold classification"],["Pure creditor payment processing","Fact-dependent","Hold classification"],["Business entity's own commercial debt","Outside express individual-debtor definition","Other laws not cleared"],["Individual's business-purpose debt","Definition does not expressly require consumer purpose","Hold detailed application"],["Remote provider serving Missouri individuals","Potential in-state activity","Nexus and authorization hold"]],"original_segment":"segment-01","original_segment_table_index":0},{"headers":[],"index":1,"links":[],"row_links":[[],[],[]],"rows":[["Operation","Statutory bond principal"],["Applicant declares it will handle no consumer monies","$50,000"],["All other applicants","$100,000"]],"original_segment":"segment-01","original_segment_table_index":1},{"headers":[],"index":2,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.010&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.010"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.020&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.020"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.025&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.025"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.030&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.030"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.040&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.040"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043"},{"href":"https://finance.mo.gov/consumer-credit-licensing?utm_source=chatgpt.com","text":"https://finance.mo.gov/consumer-credit-licensing"},{"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.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/complying-telemarketing-sales-rule?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule"},{"href":"https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf?utm_source=chatgpt.com","text":"https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf"},{"href":"https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043&utm_source=chatgpt.com","text":"https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.010&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.010"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.020&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.020"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.025&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.025"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.030&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.030"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.040&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.040"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043&utm_source=chatgpt.com","text":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043"}],[{"href":"https://finance.mo.gov/consumer-credit-licensing?utm_source=chatgpt.com","text":"https://finance.mo.gov/consumer-credit-licensing"}],[{"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.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/complying-telemarketing-sales-rule?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule"}],[{"href":"https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf?utm_source=chatgpt.com","text":"https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf"}],[{"href":"https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043&utm_source=chatgpt.com","text":"https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com","text":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking"}]],"rows":[["Source ID","Authority and literal URL","Exact pinpoint / effective status / examination"],["S_MO-P1-S001","Missouri Revisor, § 425.010. https://revisor.mo.gov/main/OneSection.aspx?section=425.010","(1)–(6), definitions and DMP fees. Effective 2011-08-28. Read."],["S_MO-P1-S002","Missouri Revisor, § 425.020. https://revisor.mo.gov/main/OneSection.aspx?section=425.020","Entire operative prohibition. Effective 2011-08-28. Read."],["S_MO-P1-S003","Missouri Revisor, § 425.025. https://revisor.mo.gov/main/OneSection.aspx?section=425.025","Entire free-of-charge provision. Effective 2011-08-28. Read."],["S_MO-P1-S004","Missouri Revisor, § 425.027. https://revisor.mo.gov/main/OneSection.aspx?section=425.027","Bond amounts (1)–(2), bond beneficiaries and director powers. Effective 2011-08-28. Read."],["S_MO-P1-S005","Missouri Revisor, § 425.030. https://revisor.mo.gov/main/OneSection.aspx?section=425.030","Injunction and receiver. Effective 1963-08-28. Read."],["S_MO-P1-S006","Missouri Revisor, § 425.040. https://revisor.mo.gov/main/OneSection.aspx?section=425.040","Exclusions (1)–(5). Effective 2011-08-28. Read."],["S_MO-P1-S007","Missouri Revisor, § 425.043. https://revisor.mo.gov/main/OneSection.aspx?section=425.043","(1) disclosures; (2) misrepresentations; (3) fees; (4) accounts. Effective 2011-08-28. Read."],["S_MO-P1-S008","Missouri Division of Finance, Consumer Credit Licensing. https://finance.mo.gov/consumer-credit-licensing","“Additional Information — Debt Adjusters,” lines 37–45. Current page, undated substantive guidance. Read. Operational, not independent statutory authority."],["S_MO-P1-S009","Electronic CFR, 16 CFR § 310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","(a)(5)(i)(A)–(C), (a)(5)(ii)(A)–(E), and (a)(2). Displayed version up to date 2026-10-22. Read. Federal, conditional applicability."],["S_MO-P1-S010","FTC, Debt Relief Services and TSR Guide. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Coverage, fees, allocation, attorney discussion. Historical agency guidance. Substantive retrieved passages read, not complete document audit."],["S_MO-P1-S011","FTC, Complying with the TSR. https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule","Debt relief advance-fee and account discussions. Substantive retrieved passages read."],["S_MO-P1-S012","Missouri Division of Finance, Consumer Credit Lawbook. https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf","Chapter 425, table of contents and reproduced provisions. Discovery excerpts only; full PDF and version not inspected. Not used instead of current Revisor."],["S_MO-P1-S013","Missouri Revisor, Chapter 425 index. https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043","Section inventory and displayed effective dates. Discovery/index only; individual sections S001–S007 were separately opened."],["S_MO-P1-S014","FTC, Debt Relief Services TSR Questions. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","Fees, cancellation and 2010 effective dates. Retrieved passages read, not a current codified rule."]],"original_segment":"segment-01","original_segment_table_index":2},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise proposition","Sources / pinpoint","Confidence and boundary"],["C001","Paid debt relief offers or services can establish debt-adjuster status","S001(1)","High; factual conduct matters"],["C002","Debt relief includes changes to unsecured debt terms, not only principal forgiveness","S001(4)","High"],["C003","DMP is a written concession-oriented agreement","S001(2)","High"],["C004","DSP is a written less-than-principal settlement agreement","S001(5)","High"],["C005","Defined debtor is individual(s)","S001(3)","High text; business-purpose reach partial"],["C006","Acting outside a DMP/DSP is a misdemeanor","S002","High"],["C007","AG can seek injunction and receiver","S005","High"],["C008","Five express statutory exclusions","S006(1)–(5)","High; fact-specific"],["C009","No general nonprofit or remote-provider exclusion in § 425.040","S006","High for this section; other law open"],["C010","DMP setup $50 maximum; monthly greater of $35 or 8%","S001(6)","High; performance condition separately applies"],["C011","No indexing language in statutory DMP fee definition","S001(6)","High for text; external adjustments unverified"],["C012","No express universal DSP percentage cap in examined Chapter 425","S001(5), S007(3)","High for examined chapter; other law open"],["C013","DSP proportional or uniform-savings fee allocation","S007(3)(3)(a)–(b)","High"],["C014","Ancillary fee labels do not bypass timing or allocation","S001(1), S007(3)","Strong statutory reading; category-specific applications open"],["C015","Debt alteration and debtor payment precede state fee receipt","S007(3)(1)–(2)","High"],["C016","First qualifying payment does not automatically earn entire DSP fee","S007(3)(3)","High"],["C017","Covered TSR transactions have independent fee triggers and allocation rules","S009(a)(5)(i)","High; federal coverage conditional"],["C018","Missouri dedicated-account conditions and seven-business-day return","S007(1)(4), (4)(1)–(5)","High; earned-fee calculation still required"],["C019","Mandatory pre-consent disclosures and misrepresentation restrictions","S007(1)–(2)","High"],["C020","Division says no Chapter 425 debt-adjuster license; bond required","S008, Debt Adjusters","High operational statement; statutory wording conflict disclosed"],["C021","Named provider's bond or authorization not verified","S008, S004","Unresolved actual provider status"],["C022","Other financial regulatory categories may apply to additional activities","S008, license categories","Conditional; no categorical overlap established"],["C023","Bond $50,000 noncustodial declaration; $100,000 otherwise","S004(1)–(2)","High"],["C024","Bond protects qualifying debtor claims; director has specified powers","S004, paragraph following (2)","High"],["C025","DMP/DSP may be administered free of charge","S003","High"],["C026","TSR dedicated account requires independent administration and qualifying refunds","S009(a)(5)(ii)","High if TSR applies"],["C027","TSR separately restricts fees for represented credit improvement","S009(a)(2)","High text; CROA overlap unresolved"],["C028","No current provider bond filing, lookup result or form version verified","S008, form links","Explicit hold"]],"original_segment":"segment-01","original_segment_table_index":3},{"headers":[],"index":4,"links":[],"row_links":[[],[],[],[]],"rows":[["Component","Status","Claims","Missing evidence / next investigation"],["Debt adjuster definition","Answered","C001–C002","Apply facts to hybrid products"],["DMP versus DSP","Answered","C003–C004","Examine mixed plans and plan amendments"],["Individual debtor definition","Partial","C",""]],"original_segment":"segment-01","original_segment_table_index":4},{"headers":["Component","Status","Claims","Missing evidence / exact next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","Missing evidence / exact next investigation"],["Individual debtor definition","Partial","C005","Section 425.010(3) expressly defines a debtor as an individual or individuals. This pass did not establish whether every individual business-purpose obligation is covered, whether sole-proprietor debt is treated differently from entity debt, or whether another Missouri law reaches entity/commercial debt outside Chapter 425. Next: inspect Chapter 425 application decisions and any commercial-debt-adjustment provisions without importing a consumer-purpose limitation that the definition does not expressly state."],["Custodial versus noncustodial models","Partial","C001–C004, C018, C023","The activity definitions do not make possession of consumer funds the sole coverage test. Section 425.027 changes the bond amount depending on whether consumer monies will be handled, and § 425.043(4) governs qualifying dedicated accounts. This pass did not resolve every noncustodial technology, referral, negotiation-only, creditor-payment or account-administrator configuration."],["Resident and remote-provider nexus","Unresolved","C001, C006","The examined text prohibits acting or offering to act as a debt adjuster “in this state,” but no controlling Missouri authority defining the remote-provider, solicitation, contracting, debtor-residence or performance nexus was opened. Do not treat an out-of-state office as an exemption or Missouri residence alone as conclusively resolving every nexus question."],["Chapter 425 operating pathway","Partial","C006, C020, C023–C024","Operating outside a DMP or DSP is prohibited, and the Division states that Chapter 425 requires a bond rather than a debt-adjuster license. The exact operational sequence, filing acceptance, renewal requirements, amendment duties, cancellation procedure and consequences of bond lapse were not established."],["Attorney exclusion","Partial","C008–C009","Section 425.040 expressly excludes a Missouri attorney at law. This pass did not establish when a law firm, nonlawyer affiliate, marketing company, shared-services entity or attorney-connected commercial program may rely on that exclusion. No blanket attorney-enterprise exemption was found or claimed."],["Nonprofit status","Answered only as to § 425.040; otherwise open","C009, C019, C025","Section 425.040 contains no general nonprofit exclusion, and § 425.043 prohibits material misrepresentations concerning nonprofit status. Section 425.025 permits genuinely free administration. Other nonprofit, tax, charitable-solicitation or institutional provisions were not examined."],["Other express exclusions","Partial","C008","The employee, court/legal-authority, no-cost creditor-agent and qualifying loan-arranger exclusions were identified. Their factual boundaries, especially compensation, debtor authorization, loan proceeds, creditor agency and indirect remuneration, require transaction-specific analysis."],["No-charge plan pathway","Answered, bounded","C025","A DMP or DSP may be administered free of charge. This does not resolve indirect compensation, lead fees, creditor payments, account charges or affiliated-provider revenue."],["DMP setup and monthly amounts","Answered as statutory numbers; application partial","C010–C011, C015","The examined current statutory text states a maximum $50 initial fee and a monthly maximum equal to the greater of $35 or 8% of monthly creditor distributions, also tied to reasonable administrative cost. The statute does not itself make either amount automatically collectible."],["DMP indexing or adjusted amounts","Partial","C011","No indexing clause appears in § 425.010(6). No current adjustment notice, administrative order, fee bulletin or authoritative indexed schedule was opened. Therefore, no CPI-derived or unofficial adjusted dollar amount is accepted."],["DSP percentage, savings and aggregate limits","Partial","C012–C014","No universal DSP percentage ceiling was located in the examined Chapter 425 provisions. The absence of an express percentage cap is not affirmative approval of 15%, 20%, 25% or another rate. Ancillary, enrollment, monthly, administrative, per-debt, savings-based and aggregate charges remain subject to classification, contract, allocation, timing and other applicable law."],["Missouri fee-receipt timing","Answered, bounded","C015–C016","A qualifying debt alteration and at least one debtor payment under the plan are required before receipt of a fee. For DSPs, the per-debt allocation rule further limits the amount. Unresolved issues include application to plan amendments, unsuccessful negotiations, replacement settlements, disputed payments and rescinded creditor agreements."],["Federal TSR timing overlap","Partial","C017, C026","The exact federal advance-fee provision was examined and treated as independently applicable only when TSR coverage exists. This pass did not decide every inbound/outbound call, internet lead, face-to-face, attorney, nonprofit or other TSR coverage/exemption question. Missouri limits are not federal advance-fee authorization."],["Credit-repair representations and CROA overlap","Unresolved","C027 only as to the separately examined TSR provision","The TSR’s represented-credit-improvement fee restriction was noted. CROA’s definitions, exemptions, contract rules and fee timing were not fully researched here. No universal CROA coverage or exemption is claimed."],["Dedicated accounts and debtor ownership","Partial","C018, C026","Missouri account ownership, interest, administrator-independence, referral-compensation, penalty-free withdrawal and seven-business-day return conditions were identified. The complete federal/state interaction, administrator charges, bank terms, account closure mechanics and treatment of already disbursed creditor payments remain open."],["Cancellation and unearned-fund return","Partial","C018, C026","The examples correctly held unearned fees and remaining consumer funds rather than treating cancellation as permission to retain a penalty. This pass did not establish every contractual cancellation right, refund formula, dispute process or treatment of properly earned fees."],["Worked-fee calculations","Answered only as bounded examples","C010, C013, C015–C018, C025–C026","The examples separate numerical ceilings, earned-fee allocation and collection timing. They are not approved contracts. Every production calculation must preserve one contract method across debts and use the same enrolled balances and total contracted fee."],["Prior-fee scenario consistency","Answered for the stated proportional example; otherwise open","C013, C016","MO-E04 reconciled the previously earned $800 against the same balances, $4,000 total contracted fee and proportional method used for the current debt. No deduction is deemed earned merely because a payment occurred. Different contract facts require a fresh reconstruction."],["Partial settlements and failed settlements","Partial","C013, C015–C017","A qualifying altered debt and qualifying payment may support only the correctly allocated fee. Ordinary payments, unsuccessful negotiation or an unenforceable proposed settlement do not automatically trigger a fee. Missouri case authority on borderline performance was not read."],["Bond principal amounts","Answered as statutory amounts","C023–C024","Section 425.027 states $50,000 when the applicant declares it will handle no consumer monies and $100,000 otherwise. These are bond principal amounts, not consumer fees. Bond form language, surety conditions, renewal and current filing instructions remain unverified."],["“Initial license application” wording versus agency no-license statement","Partial","C020, C023","The statutory wording and Division guidance were preserved without converting the program into ordinary licensing. No formal interpretation, rule, opinion or case reconciling that terminology was opened."],["Current application and filing procedure","Unresolved","C020, C028","The Division’s public page states that a bond must be posted before entering the business, but no current application packet, bond form version, filing fee, submission method, approval document or renewal instruction was fully opened and verified."],["Public registry or provider lookup","Unresolved","C021, C028","No authoritative public registry or bond lookup was established, and no named provider’s current bond or authority was checked. A marketing statement, form download or agency homepage does not prove provider authorization."],["Other regulatory classifications","Partial","C022","Money transmission, credit-services-organization, lending, collection, legal-services and other categories may depend on actual conduct. Their Missouri triggers and exclusions were not resolved in this pass."],["Disclosures and representations","Answered as Chapter 425 baseline","C019","Section 425.043’s pre-consent disclosures and misrepresentation prohibitions were identified. Advertising regulations, UDAP decisions, testimonial rules and medium-specific disclosure requirements remain later work."],["Regulations and adoption orders","Unresolved","No additional claim issued","No complete operative Missouri regulation or adoption order specifically implementing these Chapter 425 provisions was identified and read. Absence of a regulation is not established. Next: inspect the current Missouri Code of State Regulations and Secretary of State rulemaking history."],["Controlling Missouri decisions","Unresolved","No additional claim issued","No controlling Missouri appellate or federal decision interpreting Chapter 425’s definitions, nexus, exclusions, fee timing, allocation, bond language or private consequences was opened. Case-law silence is not claimed."],["Statutory and source history","Partial","C011, C020, C023","The Revisor-displayed effective dates were recorded. Session laws, amendment history, model-act lineage, archived versions, historical agency bulletins and dated fee tables were not reconstructed. No later model revision was treated as Missouri law."],["Agreement, funds, bond and remedies beyond access/fees","Deferred/partial","C007, C018, C023–C024","Only provisions needed to answer present access and fee questions were addressed. Full contract formation, required clauses, rescission, trust/account administration, bond claims, private remedies, AG powers and receivership remain separate passes."],["Collections, litigation, limitations and exemptions","Deferred","—","Collection conduct, creditor litigation, limitations periods, judgment effects, exemptions, garnishment and settlement enforceability were outside this component and remain open."],["Secured debt, sectors, local and tribal law","Deferred","—","Chapter 425’s examined debt-relief definition concerns unsecured debt. Mortgages, auto debt, tax debt, student debt, medical debt, utilities, regulated institutions, local rules and tribal jurisdiction were not cleared."],["Contract, full federal overlap and publication readiness","Deferred","—","Contract law, E-SIGN, UETA, CROA, FDCPA, FCRA, bankruptcy, tax consequences and complete TSR coverage require later work. Nothing in this pass constitutes whole-state, parent-dossier, A066, operational or publication acceptance."]],"original_segment":"continuation-01","original_segment_table_index":0}],"claims":[{"claim_id":"S_MO-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C001","Precise proposition":"Paid debt relief offers or services can establish debt-adjuster status","Sources / pinpoint":"S001(1)","Confidence and boundary":"High; factual conduct matters"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise proposition":"Debt relief includes changes to unsecured debt terms, not only principal forgiveness","Sources / pinpoint":"S001(4)","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise proposition":"DMP is a written concession-oriented agreement","Sources / pinpoint":"S001(2)","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise proposition":"DSP is a written less-than-principal settlement agreement","Sources / pinpoint":"S001(5)","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise proposition":"Defined debtor is individual(s)","Sources / pinpoint":"S001(3)","Confidence and boundary":"High text; business-purpose reach partial"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise proposition":"Acting outside a DMP/DSP is a misdemeanor","Sources / pinpoint":"S002","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise proposition":"AG can seek injunction and receiver","Sources / pinpoint":"S005","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise proposition":"Five express statutory exclusions","Sources / pinpoint":"S006(1)–(5)","Confidence and boundary":"High; fact-specific"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise proposition":"No general nonprofit or remote-provider exclusion in § 425.040","Sources / pinpoint":"S006","Confidence and boundary":"High for this section; other law open"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise proposition":"DMP setup $50 maximum; monthly greater of $35 or 8%","Sources / pinpoint":"S001(6)","Confidence and boundary":"High; performance condition separately applies"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise proposition":"No indexing language in statutory DMP fee definition","Sources / pinpoint":"S001(6)","Confidence and boundary":"High for text; external adjustments unverified"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise proposition":"No express universal DSP percentage cap in examined Chapter 425","Sources / pinpoint":"S001(5), S007(3)","Confidence and boundary":"High for examined chapter; other law open"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise proposition":"DSP proportional or uniform-savings fee allocation","Sources / pinpoint":"S007(3)(3)(a)–(b)","Confidence and boundary":"High"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise proposition":"Ancillary fee labels do not bypass timing or allocation","Sources / pinpoint":"S001(1), S007(3)","Confidence and boundary":"Strong statutory reading; category-specific applications open"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise proposition":"Debt alteration and debtor payment precede state fee receipt","Sources / pinpoint":"S007(3)(1)–(2)","Confidence and boundary":"High"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise proposition":"First qualifying payment does not automatically earn entire DSP fee","Sources / pinpoint":"S007(3)(3)","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise proposition":"Covered TSR transactions have independent fee triggers and allocation rules","Sources / pinpoint":"S009(a)(5)(i)","Confidence and boundary":"High; federal coverage conditional"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise proposition":"Missouri dedicated-account conditions and seven-business-day return","Sources / pinpoint":"S007(1)(4), (4)(1)–(5)","Confidence and boundary":"High; earned-fee calculation still required"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise proposition":"Mandatory pre-consent disclosures and misrepresentation restrictions","Sources / pinpoint":"S007(1)–(2)","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise proposition":"Division says no Chapter 425 debt-adjuster license; bond required","Sources / pinpoint":"S008, Debt Adjusters","Confidence and boundary":"High operational statement; statutory wording conflict disclosed"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise proposition":"Named provider's bond or authorization not verified","Sources / pinpoint":"S008, S004","Confidence and boundary":"Unresolved actual provider status"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise proposition":"Other financial regulatory categories may apply to additional activities","Sources / pinpoint":"S008, license categories","Confidence and boundary":"Conditional; no categorical overlap established"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise proposition":"Bond $50,000 noncustodial declaration; $100,000 otherwise","Sources / pinpoint":"S004(1)–(2)","Confidence and boundary":"High"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise proposition":"Bond protects qualifying debtor claims; director has specified powers","Sources / pinpoint":"S004, paragraph following (2)","Confidence and boundary":"High"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise proposition":"DMP/DSP may be administered free of charge","Sources / pinpoint":"S003","Confidence and boundary":"High"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise proposition":"TSR dedicated account requires independent administration and qualifying refunds","Sources / pinpoint":"S009(a)(5)(ii)","Confidence and boundary":"High if TSR applies"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise proposition":"TSR separately restricts fees for represented credit improvement","Sources / pinpoint":"S009(a)(2)","Confidence and boundary":"High text; CROA overlap unresolved"},"coordinator_verification_status":"reviewed_with_state_federal_account_predicate_and_savings_partialplan_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MO-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise proposition":"No current provider bond filing, lookup result or form version verified","Sources / pinpoint":"S008, form links","Confidence and boundary":"Explicit hold"},"coordinator_verification_status":"qualified_by_reviewed_pass02_with_pass03_date_patch_broader_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_resolution_pass":"pass-02","coordinator_resolution_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_MO-P1-S001","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.010","https://revisor.mo.gov/main/OneSection.aspx?section=425.010&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S001","Authority and literal URL":"Missouri Revisor, § 425.010. https://revisor.mo.gov/main/OneSection.aspx?section=425.010","Exact pinpoint / effective status / examination":"(1)–(6), definitions and DMP fees. Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S002","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.020","https://revisor.mo.gov/main/OneSection.aspx?section=425.020&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S002","Authority and literal URL":"Missouri Revisor, § 425.020. https://revisor.mo.gov/main/OneSection.aspx?section=425.020","Exact pinpoint / effective status / examination":"Entire operative prohibition. Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S003","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.025","https://revisor.mo.gov/main/OneSection.aspx?section=425.025&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S003","Authority and literal URL":"Missouri Revisor, § 425.025. https://revisor.mo.gov/main/OneSection.aspx?section=425.025","Exact pinpoint / effective status / examination":"Entire free-of-charge provision. Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S004","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.027","https://revisor.mo.gov/main/OneSection.aspx?section=425.027&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S004","Authority and literal URL":"Missouri Revisor, § 425.027. https://revisor.mo.gov/main/OneSection.aspx?section=425.027","Exact pinpoint / effective status / examination":"Bond amounts (1)–(2), bond beneficiaries and director powers. Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S005","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.030","https://revisor.mo.gov/main/OneSection.aspx?section=425.030&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S005","Authority and literal URL":"Missouri Revisor, § 425.030. https://revisor.mo.gov/main/OneSection.aspx?section=425.030","Exact pinpoint / effective status / examination":"Injunction and receiver. Effective 1963-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S006","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.040","https://revisor.mo.gov/main/OneSection.aspx?section=425.040&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S006","Authority and literal URL":"Missouri Revisor, § 425.040. https://revisor.mo.gov/main/OneSection.aspx?section=425.040","Exact pinpoint / effective status / examination":"Exclusions (1)–(5). Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S007","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.043","https://revisor.mo.gov/main/OneSection.aspx?section=425.043&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S007","Authority and literal URL":"Missouri Revisor, § 425.043. https://revisor.mo.gov/main/OneSection.aspx?section=425.043","Exact pinpoint / effective status / examination":"(1) disclosures; (2) misrepresentations; (3) fees; (4) accounts. Effective 2011-08-28. Read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S008","urls":["https://finance.mo.gov/consumer-credit-licensing","https://finance.mo.gov/consumer-credit-licensing?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S008","Authority and literal URL":"Missouri Division of Finance, Consumer Credit Licensing. https://finance.mo.gov/consumer-credit-licensing","Exact pinpoint / effective status / examination":"“Additional Information — Debt Adjusters,” lines 37–45. Current page, undated substantive guidance. Read. Operational, not independent statutory authority."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S009","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_MO-P1-S009","Authority and literal URL":"Electronic CFR, 16 CFR § 310.4. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact pinpoint / effective status / examination":"(a)(5)(i)(A)–(C), (a)(5)(ii)(A)–(E), and (a)(2). Displayed version up to date 2026-10-22. Read. Federal, conditional applicability."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S010","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_MO-P1-S010","Authority and literal URL":"FTC, Debt Relief Services and TSR Guide. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact pinpoint / effective status / examination":"Coverage, fees, allocation, attorney discussion. Historical agency guidance. Substantive retrieved passages read, not complete document audit."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S011","urls":["https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule","https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S011","Authority and literal URL":"FTC, Complying with the TSR. https://www.ftc.gov/business-guidance/resources/complying-telemarketing-sales-rule","Exact pinpoint / effective status / examination":"Debt relief advance-fee and account discussions. Substantive retrieved passages read."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S012","urls":["https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf","https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S012","Authority and literal URL":"Missouri Division of Finance, Consumer Credit Lawbook. https://finance.mo.gov/Contribute%20Documents/ConsumerCreditLawBook.pdf","Exact pinpoint / effective status / examination":"Chapter 425, table of contents and reproduced provisions. Discovery excerpts only; full PDF and version not inspected. Not used instead of current Revisor."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S013","urls":["https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043","https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S013","Authority and literal URL":"Missouri Revisor, Chapter 425 index. https://www.revisor.mo.gov/main/OneChapterRng.aspx?tb1=425.010+to+425.043","Exact pinpoint / effective status / examination":"Section inventory and displayed effective dates. Discovery/index only; individual sections S001–S007 were separately opened."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MO-P1-S014","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MO-P1-S014","Authority and literal URL":"FTC, Debt Relief Services TSR Questions. https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","Exact pinpoint / effective status / examination":"Fees, cancellation and 2010 effective dates. Retrieved passages read, not a current codified rule."},"coordinator_verification_status":"see_exact_primary_sections_new_forms_staff_guidance_and_explicit_reuse_in_reviews/S_MO-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Debt adjuster definition","researcher_record":{"Component":"Debt adjuster definition","Status":"Answered","Claims":"C001–C002","Missing evidence / next investigation":"Apply facts to hybrid products"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"DMP versus DSP","researcher_record":{"Component":"DMP versus DSP","Status":"Answered","Claims":"C003–C004","Missing evidence / next investigation":"Examine mixed plans and plan amendments"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Individual debtor definition","researcher_record":{"Component":"Individual debtor definition","Status":"Partial","Claims":"C005","Missing evidence / next investigation":"Section 425.010(3) expressly defines a debtor as an individual or individuals. This pass did not establish whether every individual business-purpose obligation is covered, whether sole-proprietor debt is treated differently from entity debt, or whether another Missouri law reaches entity/commercial debt outside Chapter 425. Next: inspect Chapter 425 application decisions and any commercial-debt-adjustment provisions without importing a consumer-purpose limitation that the definition does not expressly state."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial versus noncustodial models","researcher_record":{"Component":"Custodial versus noncustodial models","Status":"Partial","Claims":"C001–C004, C018, C023","Missing evidence / next investigation":"The activity definitions do not make possession of consumer funds the sole coverage test. Section 425.027 changes the bond amount depending on whether consumer monies will be handled, and § 425.043(4) governs qualifying dedicated accounts. This pass did not resolve every noncustodial technology, referral, negotiation-only, creditor-payment or account-administrator configuration."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Resident and remote-provider nexus","researcher_record":{"Component":"Resident and remote-provider nexus","Status":"Unresolved","Claims":"C001, C006","Missing evidence / next investigation":"The examined text prohibits acting or offering to act as a debt adjuster “in this state,” but no controlling Missouri authority defining the remote-provider, solicitation, contracting, debtor-residence or performance nexus was opened. Do not treat an out-of-state office as an exemption or Missouri residence alone as conclusively resolving every nexus question."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Chapter 425 operating pathway","researcher_record":{"Component":"Chapter 425 operating pathway","Status":"Partial","Claims":"C006, C020, C023–C024","Missing evidence / next investigation":"Operating outside a DMP or DSP is prohibited, and the Division states that Chapter 425 requires a bond rather than a debt-adjuster license. The exact operational sequence, filing acceptance, renewal requirements, amendment duties, cancellation procedure and consequences of bond lapse were not established."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exclusion","researcher_record":{"Component":"Attorney exclusion","Status":"Partial","Claims":"C008–C009","Missing evidence / next investigation":"Section 425.040 expressly excludes a Missouri attorney at law. This pass did not establish when a law firm, nonlawyer affiliate, marketing company, shared-services entity or attorney-connected commercial program may rely on that exclusion. No blanket attorney-enterprise exemption was found or claimed."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit status","researcher_record":{"Component":"Nonprofit status","Status":"Answered only as to § 425.040; otherwise open","Claims":"C009, C019, C025","Missing evidence / next investigation":"Section 425.040 contains no general nonprofit exclusion, and § 425.043 prohibits material misrepresentations concerning nonprofit status. Section 425.025 permits genuinely free administration. Other nonprofit, tax, charitable-solicitation or institutional provisions were not examined."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Other express exclusions","researcher_record":{"Component":"Other express exclusions","Status":"Partial","Claims":"C008","Missing evidence / next investigation":"The employee, court/legal-authority, no-cost creditor-agent and qualifying loan-arranger exclusions were identified. Their factual boundaries, especially compensation, debtor authorization, loan proceeds, creditor agency and indirect remuneration, require transaction-specific analysis."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"No-charge plan pathway","researcher_record":{"Component":"No-charge plan pathway","Status":"Answered, bounded","Claims":"C025","Missing evidence / next investigation":"A DMP or DSP may be administered free of charge. This does not resolve indirect compensation, lead fees, creditor payments, account charges or affiliated-provider revenue."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"DMP setup and monthly amounts","researcher_record":{"Component":"DMP setup and monthly amounts","Status":"Answered as statutory numbers; application partial","Claims":"C010–C011, C015","Missing evidence / next investigation":"The examined current statutory text states a maximum $50 initial fee and a monthly maximum equal to the greater of $35 or 8% of monthly creditor distributions, also tied to reasonable administrative cost. The statute does not itself make either amount automatically collectible."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"DMP indexing or adjusted amounts","researcher_record":{"Component":"DMP indexing or adjusted amounts","Status":"Partial","Claims":"C011","Missing evidence / next investigation":"No indexing clause appears in § 425.010(6). No current adjustment notice, administrative order, fee bulletin or authoritative indexed schedule was opened. Therefore, no CPI-derived or unofficial adjusted dollar amount is accepted."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"DSP percentage, savings and aggregate limits","researcher_record":{"Component":"DSP percentage, savings and aggregate limits","Status":"Partial","Claims":"C012–C014","Missing evidence / next investigation":"No universal DSP percentage ceiling was located in the examined Chapter 425 provisions. The absence of an express percentage cap is not affirmative approval of 15%, 20%, 25% or another rate. Ancillary, enrollment, monthly, administrative, per-debt, savings-based and aggregate charges remain subject to classification, contract, allocation, timing and other applicable law."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Missouri fee-receipt timing","researcher_record":{"Component":"Missouri fee-receipt timing","Status":"Answered, bounded","Claims":"C015–C016","Missing evidence / next investigation":"A qualifying debt alteration and at least one debtor payment under the plan are required before receipt of a fee. For DSPs, the per-debt allocation rule further limits the amount. Unresolved issues include application to plan amendments, unsuccessful negotiations, replacement settlements, disputed payments and rescinded creditor agreements."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR timing overlap","researcher_record":{"Component":"Federal TSR timing overlap","Status":"Partial","Claims":"C017, C026","Missing evidence / next investigation":"The exact federal advance-fee provision was examined and treated as independently applicable only when TSR coverage exists. This pass did not decide every inbound/outbound call, internet lead, face-to-face, attorney, nonprofit or other TSR coverage/exemption question. Missouri limits are not federal advance-fee authorization."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-repair representations and CROA overlap","researcher_record":{"Component":"Credit-repair representations and CROA overlap","Status":"Unresolved","Claims":"C027 only as to the separately examined TSR provision","Missing evidence / next investigation":"The TSR’s represented-credit-improvement fee restriction was noted. CROA’s definitions, exemptions, contract rules and fee timing were not fully researched here. No universal CROA coverage or exemption is claimed."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Dedicated accounts and debtor ownership","researcher_record":{"Component":"Dedicated accounts and debtor ownership","Status":"Partial","Claims":"C018, C026","Missing evidence / next investigation":"Missouri account ownership, interest, administrator-independence, referral-compensation, penalty-free withdrawal and seven-business-day return conditions were identified. The complete federal/state interaction, administrator charges, bank terms, account closure mechanics and treatment of already disbursed creditor payments remain open."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation and unearned-fund return","researcher_record":{"Component":"Cancellation and unearned-fund return","Status":"Partial","Claims":"C018, C026","Missing evidence / next investigation":"The examples correctly held unearned fees and remaining consumer funds rather than treating cancellation as permission to retain a penalty. This pass did not establish every contractual cancellation right, refund formula, dispute process or treatment of properly earned fees."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Worked-fee calculations","researcher_record":{"Component":"Worked-fee calculations","Status":"Answered only as bounded examples","Claims":"C010, C013, C015–C018, C025–C026","Missing evidence / next investigation":"The examples separate numerical ceilings, earned-fee allocation and collection timing. They are not approved contracts. Every production calculation must preserve one contract method across debts and use the same enrolled balances and total contracted fee."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Prior-fee scenario consistency","researcher_record":{"Component":"Prior-fee scenario consistency","Status":"Answered for the stated proportional example; otherwise open","Claims":"C013, C016","Missing evidence / next investigation":"MO-E04 reconciled the previously earned $800 against the same balances, $4,000 total contracted fee and proportional method used for the current debt. No deduction is deemed earned merely because a payment occurred. Different contract facts require a fresh reconstruction."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Partial settlements and failed settlements","researcher_record":{"Component":"Partial settlements and failed settlements","Status":"Partial","Claims":"C013, C015–C017","Missing evidence / next investigation":"A qualifying altered debt and qualifying payment may support only the correctly allocated fee. Ordinary payments, unsuccessful negotiation or an unenforceable proposed settlement do not automatically trigger a fee. Missouri case authority on borderline performance was not read."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Bond principal amounts","researcher_record":{"Component":"Bond principal amounts","Status":"Answered as statutory amounts","Claims":"C023–C024","Missing evidence / next investigation":"Section 425.027 states $50,000 when the applicant declares it will handle no consumer monies and $100,000 otherwise. These are bond principal amounts, not consumer fees. Bond form language, surety conditions, renewal and current filing instructions remain unverified."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"“Initial license application” wording versus agency no-license statement","researcher_record":{"Component":"“Initial license application” wording versus agency no-license statement","Status":"Partial","Claims":"C020, C023","Missing evidence / next investigation":"The statutory wording and Division guidance were preserved without converting the program into ordinary licensing. No formal interpretation, rule, opinion or case reconciling that terminology was opened."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Current application and filing procedure","researcher_record":{"Component":"Current application and filing procedure","Status":"Unresolved","Claims":"C020, C028","Missing evidence / next investigation":"The Division’s public page states that a bond must be posted before entering the business, but no current application packet, bond form version, filing fee, submission method, approval document or renewal instruction was fully opened and verified."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Public registry or provider lookup","researcher_record":{"Component":"Public registry or provider lookup","Status":"Unresolved","Claims":"C021, C028","Missing evidence / next investigation":"No authoritative public registry or bond lookup was established, and no named provider’s current bond or authority was checked. A marketing statement, form download or agency homepage does not prove provider authorization."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Other regulatory classifications","researcher_record":{"Component":"Other regulatory classifications","Status":"Partial","Claims":"C022","Missing evidence / next investigation":"Money transmission, credit-services-organization, lending, collection, legal-services and other categories may depend on actual conduct. Their Missouri triggers and exclusions were not resolved in this pass."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Disclosures and representations","researcher_record":{"Component":"Disclosures and representations","Status":"Answered as Chapter 425 baseline","Claims":"C019","Missing evidence / next investigation":"Section 425.043’s pre-consent disclosures and misrepresentation prohibitions were identified. Advertising regulations, UDAP decisions, testimonial rules and medium-specific disclosure requirements remain later work."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Regulations and adoption orders","researcher_record":{"Component":"Regulations and adoption orders","Status":"Unresolved","Claims":"No additional claim issued","Missing evidence / next investigation":"No complete operative Missouri regulation or adoption order specifically implementing these Chapter 425 provisions was identified and read. Absence of a regulation is not established. Next: inspect the current Missouri Code of State Regulations and Secretary of State rulemaking history."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling Missouri decisions","researcher_record":{"Component":"Controlling Missouri decisions","Status":"Unresolved","Claims":"No additional claim issued","Missing evidence / next investigation":"No controlling Missouri appellate or federal decision interpreting Chapter 425’s definitions, nexus, exclusions, fee timing, allocation, bond language or private consequences was opened. Case-law silence is not claimed."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory and source history","researcher_record":{"Component":"Statutory and source history","Status":"Partial","Claims":"C011, C020, C023","Missing evidence / next investigation":"The Revisor-displayed effective dates were recorded. Session laws, amendment history, model-act lineage, archived versions, historical agency bulletins and dated fee tables were not reconstructed. No later model revision was treated as Missouri law."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement, funds, bond and remedies beyond access/fees","researcher_record":{"Component":"Agreement, funds, bond and remedies beyond access/fees","Status":"Deferred/partial","Claims":"C007, C018, C023–C024","Missing evidence / next investigation":"Only provisions needed to answer present access and fee questions were addressed. Full contract formation, required clauses, rescission, trust/account administration, bond claims, private remedies, AG powers and receivership remain separate passes."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Collections, litigation, limitations and exemptions","researcher_record":{"Component":"Collections, litigation, limitations and exemptions","Status":"Deferred","Claims":"—","Missing evidence / next investigation":"Collection conduct, creditor litigation, limitations periods, judgment effects, exemptions, garnishment and settlement enforceability were outside this component and remain open."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt, sectors, local and tribal law","researcher_record":{"Component":"Secured debt, sectors, local and tribal law","Status":"Deferred","Claims":"—","Missing evidence / next investigation":"Chapter 425’s examined debt-relief definition concerns unsecured debt. Mortgages, auto debt, tax debt, student debt, medical debt, utilities, regulated institutions, local rules and tribal jurisdiction were not cleared."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"},{"topic":"Contract, full federal overlap and publication readiness","researcher_record":{"Component":"Contract, full federal overlap and publication readiness","Status":"Deferred","Claims":"—","Missing evidence / next investigation":"Contract law, E-SIGN, UETA, CROA, FDCPA, FCRA, bankruptcy, tax consequences and complete TSR coverage require later work. Nothing in this pass constitutes whole-state, parent-dossier, A066, operational or publication acceptance."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","segment_provenance":"first2complete original rows plus32complete continuation rows; originalunfinishedrowretainedonlyinraw","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}