{"meta":{"key":"s_mo--pass-02","task":"S_MO","title":"Bounded correction and evidence reconciliation","parent_title":"Missouri debt and debt relief law","edition":"pass-02","path":"/research/s_mo--pass-02/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":19,"sources":9,"review_status":"accepted_with_limits","review_complete":true,"sha256":"19d87f63dc5db64e8d12d8cbad7dd7966a566cac6cad6b042b03f70315c063a7","headings":["Bounded correction and evidence reconciliation","1. Dedicated-account replacement","Replacement for P1 A4, C018 and C026","Exact state/federal account-condition matrix","2. Minimal replacement for MO-E05","3. Federal source-attribution correction","Replacement for the federal portion of P1 C017","Federal source layers","4. Bond and public-form reconciliation","Replacement for the early A5 hold","Statute/agency/forms/version/gap matrix","5. PASS-02 source register","6. PASS-02 claim register","7. Focused correction-coverage table","8. 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-02","facets":{"geography":["us","us-mo"],"debt_type":[],"stage":[],"subject":["client-money"]},"scope":"Boundedstate/federalaccountpredicateandE05actualpaid/partialplanqualification;sourceattributionandnewlyreadformsminimalgapreconciliationonly,notfullbondoperationsorreport","pending_corrections":0},"markdown":"# SettleADebt S_MO PASS-02\n\n## Bounded correction and evidence reconciliation\n\n**Actual access date:** October 24, 2026, Pacific time\n**Actual mode/model:** Regular Chat, GPT-5.6 Sol Pro\n**Disposition:** This correction preserves both original PASS-01 segments and their source history. It is not an independent review, whole-state acceptance, provider approval, filing program, or publication clearance.\n\n## 1. Dedicated-account replacement\n\n### Replacement for P1 A4, C018 and C026\n\nMissouri § 425.043.4 does **not** impose the same administrator-independence wording as the federal TSR. Missouri’s introductory clause literally refers to an account used for the adjuster’s **“fees for payments”** to creditors or collectors. That wording is preserved; this correction does not silently replace it with “fees **and** payments” or resolve whether the enacted wording contains an omission.\n\nMissouri § 425.043.4(3) applies its nonaffiliation condition only **“if the debt adjuster does not administer the account.”** It therefore cannot be restated as an unconditional Missouri requirement for an independent administrator. At the same time, the conditional wording is not affirmative permission for self-administration: the statute simply does not state the conditions governing that branch. The covered federal rule is different: § 310.4(a)(5)(ii)(C) requires the entity administering the account to be unaffiliated with the debt-relief service without Missouri’s conditional opening. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043)\n\nMissouri subsection 3 prohibits the adjuster from **receiving** a fee before the state conditions are met. The covered federal provision prohibits **requesting or receiving** a fee. Requiring money to be placed into a consumer-owned qualifying account is analytically separate from requesting or receiving the provider’s fee. No actual account administrator, account agreement, provider structure, sales channel or federal-coverage fact was examined; operational approval remains held. [Missouri Revisor of Statutes+2](https://revisor.mo.gov/main/OneSection.aspx?section=425.043)\n\n### Exact state/federal account-condition matrix\n\n| Issue | Missouri — § 425.043 | Federal — 16 CFR § 310.4(a)(5) | Reconciliation |\n| --- | --- | --- | --- |\n| Account introductory wording | Subsection 4 literally refers to funds used for the adjuster’s **“fees for payments”** to creditors or collectors. | Subsection (ii) refers to funds used for provider fees **“and for payments”** to creditors or collectors. | The texts are not silently conformed. Missouri’s unusual wording remains uninterpreted. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Fee-request/receipt rule | Subsection 3 prohibits **receipt** of a fee before alteration, payment and, for DSP debts, allocation conditions. Subsection 4 conditionally permits requesting or requiring account deposits. | Subsection (i) prohibits **requesting or receiving** the provider’s fee until (A)–(C) are satisfied; subsection (ii) separately allows qualifying account deposits. | A deposit in a customer-owned account is not automatically a fee received by the provider. Federal timing can be broader where the TSR applies. [Missouri Revisor of Statutes+2](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Financial institution | Funds must be held at an insured financial institution. | Same operative requirement. | Textually aligned on this condition. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Ownership and interest | The debtor owns the funds and receives accrued interest, if any. | The customer owns the funds and receives accrued interest, if any. | Textually aligned for ownership and interest. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Administrator independence | **If the adjuster does not administer**, the administering entity cannot be owned, controlled by or affiliated with the adjuster. | The entity administering the account cannot be owned, controlled by or affiliated with the debt-relief service. | Missouri is conditional; federal language is unqualified. Missouri does not thereby affirmatively authorize self-administration. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Referral compensation | The administering entity may not give or accept compensation for referrals of business **by the debt adjuster**. | The administering entity may not give or accept compensation for referrals involving the debt-relief service. | Similar protection, but the exact relational wording differs. No account-provider fee arrangement was tested. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Withdrawal | The debtor may withdraw from the debt-relief service at any time without penalty. | Same operative customer right. | Textually aligned on penalty-free withdrawal. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| Seven-business-day return | Missouri requires return of all account funds except funds earned in compliance with **“subdivision (3) of subsection 3”** within seven business days. | Federal law excludes only fees earned in compliance with § 310.4(a)(5)(i)(A)–(C), also with a seven-business-day deadline. | Missouri’s literal cross-reference points to subsection 3’s allocation subdivision; subsection 3 separately imposes the alteration and payment conditions. This correction does not judicially reconcile the cross-reference. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n\nThe preserved E06 assumption remains unchanged: with $3,000 still held, no qualifying settlement, no earned fee and no other lawful charge or creditor disbursement assumed, the example showed $0 earned. PASS-02 does not add a cancellation offset.\n\n## 2. Minimal replacement for MO-E05\n\nThe assumed 25% savings rate remains a contract input, **not a Missouri fee ceiling**.\n\n| E05 branch | Inputs and calculation | Missouri analysis | Federal analysis, if the TSR applies | Result |\n| --- | --- | --- | --- | --- |\n| **A. $5,000 has actually been paid and the debt is satisfied** | Enrolled balance: $8,000. Amount actually paid to satisfy: $5,000. Savings: $8,000 − $5,000 = **$3,000**. Uniform assumed fee: $3,000 × 25% = **$750**. | The savings base matches § 425.043.3(3)(b). Receipt still requires the qualifying alteration under subdivision (1), at least one payment under subdivision (2), the uniform percentage requirement and all other applicable state conditions. | The calculation also matches § 310.4(a)(5)(i)(C)(2). Collection remains conditional on (A), (B), complete allocation and actual TSR coverage. | **$750 is the allocated arithmetic result, not unconditional collection approval.** [Missouri Revisor of Statutes+2](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| **B. Bona fide $5,000 installment settlement; only the first scheduled installment has been paid** | The settlement requires $5,000 in total, but the debt has not yet been fully paid. **Do not calculate savings as $8,000 minus the first installment.** | Section 425.043.3(2)’s one-payment condition may be met, but § 425.043.3(3)(b) defines savings using the amount **actually paid to satisfy** the debt. No Missouri judicial, Division, AG or rulemaking interpretation of this incomplete-installment branch was read. Immediate Missouri collection of $750 remains **HELD**. | The Commission’s final-rule explanation states that the one-payment provision specifically accommodates bona fide installment settlements; after the first installment, the appropriate fee may be sent. The same explanation uses the amount required to satisfy the debt as the savings base. That is primary federal rulemaking history, not Missouri authority. | **Federal layer materially supports first-installment earning in a bona fide installment settlement, but combined Missouri operational approval remains HELD.** [GovInfo+3](https://www.govinfo.gov/link/fr/75/48516) |\n\nThe federal final-rule explanation also says that when a creditor requires one lump-sum payment, a provider cannot artificially divide that settlement and collect a fee after a merely partial payment. [GovInfo](https://www.govinfo.gov/link/fr/75/48516)\n\n**Exact remaining Missouri question:** Does § 425.043.3(3)(b)’s reference to the amount “actually paid to satisfy” a debt permit a savings-based fee after the first payment under a bona fide installment settlement, using the total contractual settlement amount as the savings denominator, or must satisfaction/payment completion occur first? The next authoritative targets are a Missouri appellate decision, Division of Finance interpretation, formal AG opinion, operative rule or contemporaneous Missouri enactment history addressing that precise branch.\n\n## 3. Federal source-attribution correction\n\n### Replacement for the federal portion of P1 C017\n\nFor a covered transaction, the **operative rule text** in 16 CFR § 310.4(a)(5)(i) prohibits requesting or receiving a fee until:\n\n1. The seller or telemarketer has altered at least one debt pursuant to a settlement agreement, DMP or other valid contractual agreement **executed by the customer**;\n2. The customer has made at least one payment under that agreement between the customer and creditor or collector; and\n3. The complete proportional or uniform-savings allocation rule is satisfied.\n\nThe codified language does not itself say, in those terms, that the creditor’s agreement must be written while the customer may assent orally. That proposition must not be attributed directly to the CFR text. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### Federal source layers\n\n| Source layer | What it actually establishes | Qualification |\n| --- | --- | --- |\n| **Operative eCFR** | § 310.4(a)(5)(i)(A)–(C) contains the customer-executed valid-agreement, qualifying-payment and allocation requirements. Section (ii)(A)–(E) contains the dedicated-account conditions. | Authoritative but unofficial eCFR display; shown up to date as of October 22, 2026. It says **requesting or receiving**. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **Commission final-rule statement of basis and purpose, August 10, 2010** | Explains that customer execution may be oral or written; discusses documentation of creditor agreement; specifically addresses bona fide installment settlements; and explains the savings base using the amount required to satisfy the debt. | Primary federal rulemaking history, but not a replacement for the codified text or applicable contract law. It does not decide Missouri § 425.043. [GovInfo+2](https://www.govinfo.gov/link/fr/75/48516) |\n| **FTC Guide for Business, July 2010** | States that the creditor agreement should be in writing while the customer may agree orally; uses the amount required to satisfy the debt for the savings calculation. Example 13 has the consumer pay the full $600 settlement before the $100 fee. | The guide expressly identifies itself as FTC staff views and **not binding on the Commission**. It should not be presented as the literal CFR wording. [Federal Trade Commission+3](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) |\n| **FTC FAQ, October 2010** | States that using attorneys or calling a charge a retainer does not automatically avoid the rule; an individual attorney’s coverage depends on telemarketing and other facts. It also warns against collecting a full multi-debt fee after one debt. | Staff FAQ, not a universal attorney-coverage determination or substitute for the regulation. [Federal Trade Commission+3](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking) |\n\nNo conclusion is made here that a particular oral assent, electronic act or unsigned factual arrangement constitutes a valid agreement under the TSR, federal law or applicable state contract law. The correction is one of **source attribution**, not a newly recognized oral-agreement loophole. The July 2010 guide’s historical recordkeeping discussion is not adopted as a current record-retention rule in this pass.\n\n## 4. Bond and public-form reconciliation\n\n### Replacement for the early A5 hold\n\nThe early PASS-01 statement that the bond amounts had not yet been read reflected the research state at that point in the first assembly. It was later superseded **within PASS-01** by A6 and C023–C024 after the complete operative § 425.027 page was read. The later finding controls as to the statutory principal amounts and statutory beneficiaries:\n\n- $50,000 if the applicant declares the operation will handle no consumer monies;\n- $100,000 otherwise;\n- statutory protection for debtors under either a DMP or DSP; and\n- specified Division-director complaint and bond-claim powers.\n\nThat chronological reconciliation does not cure the separate operational-form, version, acceptance, renewal or registry gaps. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.027)\n\n### Statute/agency/forms/version/gap matrix\n\n| Evidence layer | Exact evidence read | What it establishes | What remains unresolved |\n| --- | --- | --- | --- |\n| **§ 425.027 operative statute** | Uses “initial license application”; states $50,000 for an applicant declaring no consumer monies will be handled and $100,000 otherwise; benefits debtors damaged under a DMP **or DSP**; authorizes the director to investigate complaints and make or release a bond claim. Effective-version display: August 28, 2011. | Resolves the statutory amounts and statutory protection described in P1 C023–C024. | Does not itself explain the agency’s no-license procedure, submission package, renewal, acceptance or public lookup. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) |\n| **Division consumer-credit page** | States that Chapter 425 still has no debt-adjuster licensing requirement and that a debt adjuster must post a bond before entering the business. It currently links the information and bond forms. | Establishes the Division’s published operational characterization: bond required, no ordinary debt-adjuster license. | Does not prove that a submitted form has been accepted, a bond is active or a particular provider may operate. [Missouri Division of Finance](https://finance.mo.gov/consumer-credit-licensing) |\n| **Debt Adjuster’s Information form, /media/366** | One-page undated blank form. It instructs the filer to attach a $100,000 bond and mail the completed form to Division of Finance, P.O. Box 716, Jefferson City, Missouri 65102-0716. It contains a year blank, office-use “425-” blank and company, officer/director and preparer fields. | Establishes the text and fields of the blank form currently linked by the Division. | It does not show the statutory $50,000 branch; prove annual renewal; create a licensing system; certify its revision date; or prove an actual filing or acceptance. [Missouri Division of Finance+1](https://finance.mo.gov/media/366) |\n| **Missouri Debt Adjusters Bond form, /media/371** | One-page undated blank $100,000 form. It refers to beneficiaries under a DMP and §§ 425.010–425.040. Its terms include automatic annual renewal absent notice, conditional cancellation on 60 days’ written notice, preservation of accrued/notice-period liability, presentation of covered claims for up to 36 months after expiration of the notice period, an aggregate cap and attached power of attorney. | Establishes the language of the currently linked blank bond form. | It does not mention the $50,000 branch, DSP beneficiaries or § 425.043. Its form terms are not automatically universal statutory renewal or limitations rules. It is not an executed bond or current-version certification. [Missouri Division of Finance+2](https://finance.mo.gov/media/371) |\n| **Combined reconciliation** | The statute recognizes two bond amounts and DMP/DSP protection; both currently linked forms are written around $100,000, and the bond form text mentions only DMPs and §§ 425.010–425.040. | The divergence is a real evidence issue to preserve. | It does **not** establish that the $50,000 branch was repealed, that $100,000 is universally required, that DSP claims lack statutory protection, that a license now exists, or that these forms constitute a complete presently acceptable filing package. |\n\nNo actual provider lookup, bond-file search, submission, filing-fee check, registry inspection, surety inquiry or Division contact was performed.\n\n## 5. PASS-02 source register\n\nScreenshots used to inspect the three PDFs are verification views of the same underlying documents, not additional independent authorities.\n\n| Source ID | P1 relationship | Authority, literal URL and pinpoint | Access/source status and limitation |\n| --- | --- | --- | --- |\n| **S_MO-P2-S001** | Fresh reread of P1 S007 | Missouri Revisor, § 425.043: https://revisor.mo.gov/main/OneSection.aspx?section=425.043; subsections 3 and 4, including 4(1)–(5), history and August 28, 2011 effective display. | **Fresh complete operative-page read.** Used for exact Missouri account, receipt, allocation and seven-business-day language. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) |\n| **S_MO-P2-S002** | P1 S009 had been explicitly reused from an earlier Oregon primary read; this is a new Missouri-P2 refresh, not a retroactive change to P1 history | eCFR, 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), (ii)(A)–(E). | **Fresh operative-text read.** Display states title current through October 22, 2026. Federal coverage remains conditional. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_MO-P2-S003** | Fresh selected reread of P1 S010 | FTC, *Debt Relief Services & the Telemarketing Sales Rule: A Guide for Business*: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business; lines corresponding to “Collecting Fees,” Examples 12–13 and dedicated accounts; July 2010. | **Fresh selected-section read.** FTC staff guidance; page says it is not binding on the Commission. Not treated as operative CFR text. [Federal Trade Commission+2](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) |\n| **S_MO-P2-S004** | Fresh selected reread of P1 S014 | FTC, *What People Are Asking*: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking; attorney Q&A and fee Q&A; October 2010. | **Fresh selected-section read.** Staff FAQ; not a complete federal-coverage or attorney-exemption analysis. [Federal Trade Commission+2](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking) |\n| **S_MO-P2-S005** | New PASS-02 authority | FTC, *Telemarketing Sales Rule—Final Rule Amendments*, 75 Fed. Reg. 48458, 48489–90: https://www.govinfo.gov/link/fr/75/48516; footnote 432, contractual-agreement discussion, fee requirements and dedicated-account discussion. | **Fresh primary rulemaking PDF read; relevant pages visually inspected.** Resolves the federal installment explanation but is not Missouri authority. [GovInfo+4](https://www.govinfo.gov/link/fr/75/48516) |\n| **S_MO-P2-S006** | Fresh reread of P1 S004 | Missouri Revisor, § 425.027: https://revisor.mo.gov/main/OneSection.aspx?section=425.027; complete operative text and history. | **Fresh complete operative-page read.** Preserves $50,000/$100,000 branches, DMP/DSP beneficiaries and “initial license application” wording. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) |\n| **S_MO-P2-S007** | Fresh reread of P1 S008 | Missouri Division of Finance, Consumer Credit Licensing: https://finance.mo.gov/consumer-credit-licensing; Debt Adjusters, lines 39–45. | **Fresh agency-page read.** Operational guidance only; no named-provider status or filing acceptance. [Missouri Division of Finance](https://finance.mo.gov/consumer-credit-licensing) |\n| **S_MO-P2-S008** | P1 contained only the link/form gap; form text was not then read | Division of Finance, *Debt Adjuster’s Information*: https://finance.mo.gov/media/366; complete one-page blank form. | **Fresh complete PDF text and visual read.** Undated on its face; currently linked; not an executed filing or revision certification. [Missouri Division of Finance+1](https://finance.mo.gov/media/366) |\n| **S_MO-P2-S009** | P1 contained only the link/form gap; form text was not then read | Division of Finance, *Missouri Debt Adjusters Bond*: https://finance.mo.gov/media/371; complete one-page blank form. | **Fresh complete PDF text and visual read.** Undated on its face; currently linked; not an executed bond or universal statement of statutory law. [Missouri Division of Finance+2](https://finance.mo.gov/media/371) |\n\n## 6. PASS-02 claim register\n\n| Claim ID | Corrected or new precise assertion | P1 alias affected | Source/pinpoint | Confidence and limit |\n| --- | --- | --- | --- | --- |\n| **S_MO-P2-C001** | Missouri subsection 4’s introductory phrase uses “fees for payments”; PASS-02 does not replace it with “and for payments.” | S_MO-C018 | S001, § 425.043.4 introductory clause. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | High as text; meaning unresolved. |\n| **S_MO-P2-C002** | Missouri requires an insured account, debtor ownership and payment of accrued interest, if any. | S_MO-C018 | S001, § 425.043.4(1)–(2). [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | High. |\n| **S_MO-P2-C003** | Missouri’s nonaffiliation condition applies when the adjuster does not administer the account; it is not an unconditional independence rule or affirmative self-administration permission. | S_MO-C018 | S001, § 425.043.4(3). [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | High for wording; self-administration legal effect held. |\n| **S_MO-P2-C004** | Missouri prohibits referral compensation described in 4(4) and requires penalty-free withdrawal and seven-business-day return, subject to the literal 4(5) cross-reference to subdivision 3 of subsection 3. | S_MO-C018 | S001, § 425.043.4(4)–(5). [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | High for text; cross-reference interaction held. |\n| **S_MO-P2-C005** | The covered federal account rule requires an unaffiliated administrator without Missouri’s conditional opening and excludes only fees earned under (i)(A)–(C) from the seven-day return. | S_MO-C026 | S002, § 310.4(a)(5)(ii)(C)–(E). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High if TSR applies. |\n| **S_MO-P2-C006** | Missouri subsection 3 prohibits receiving a fee; covered federal law prohibits requesting or receiving it. A qualifying customer-owned deposit is analytically distinct. | S_MO-C015, S_MO-C017, S_MO-C018, S_MO-C026 | S001 § 425.043.3–4; S002 § 310.4(a)(5)(i)–(ii). [Missouri Revisor of Statutes+2](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | High for verbs; application factual. |\n| **S_MO-P2-C007** | The operative federal trigger is the customer-executed valid agreement, payment under that agreement and complete allocation rule. | S_MO-C017 | S002, § 310.4(a)(5)(i)(A)–(C). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | High if TSR applies. |\n| **S_MO-P2-C008** | Creditor-writing/customer-oral formulations arise from Commission explanation and FTC staff guidance, not the literal text of § 310.4(a)(5)(i). | S_MO-C017 | S003; S005, 75 Fed. Reg. 48489. [Federal Trade Commission+2](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) | High source attribution; individual validity held. |\n| **S_MO-P2-C009** | No automatic federal TSR exemption arises merely from using attorneys or labeling charges retainers; actual TSR coverage remains fact-dependent. | Federal discussion associated with S_MO-C017 | S004, attorney Q&A. [Federal Trade Commission](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking) | High as staff guidance; not full coverage adjudication. |\n| **S_MO-P2-C010** | In completed E05, $8,000 minus $5,000 equals $3,000 savings and 25% equals a $750 allocated fee. | S_MO-C013, S_MO-C015, S_MO-C017 | S001 § 425.043.3(3)(b); S002 § 310.4(a)(5)(i)(C)(2). [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | Arithmetic high; collection conditional. |\n| **S_MO-P2-C011** | The federal final-rule explanation specifically treats the first payment under a bona fide installment settlement as satisfying the payment timing component and uses the amount required to satisfy for savings. | S_MO-C013, S_MO-C017 | S005, 75 Fed. Reg. 48489–90 and n.432. [GovInfo+2](https://www.govinfo.gov/link/fr/75/48516) | Strong federal interpretive source; coverage conditional. |\n| **S_MO-P2-C012** | The federal installment explanation is not Missouri interpretation; immediate Missouri collection of E05’s $750 after only the first installment remains held. | S_MO-C013, S_MO-C015 | S001 § 425.043.3(2)–(3)(b); absence of Missouri interpretation in this bounded pass. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.043) | Explicit hold. |\n| **S_MO-P2-C013** | Section 425.027 states $50,000 for a no-consumer-monies declaration and $100,000 otherwise; the bond benefits qualifying DMP or DSP debtors and the director has specified claim powers. | S_MO-C023, S_MO-C024 | S006, complete operative text. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) | High. |\n| **S_MO-P2-C014** | The early P1 bond-amount hold was superseded by P1 A6/C023–C024 only as to the statutory text, not operational procedure. | S_MO-C023, S_MO-C024 | S006 plus preserved P1 chronology. [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) | High reconciliation. |\n| **S_MO-P2-C015** | The Division says no Chapter 425 debt-adjuster license is required, but a bond must be posted before entering the business; the statute’s “initial license application” wording remains preserved. | S_MO-C020, S_MO-C023 | S006; S007, Debt Adjusters. [Missouri Revisor of Statutes+1](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) | High evidence; formal reconciliation absent. |\n| **S_MO-P2-C016** | The currently linked undated information form directs attachment of a $100,000 bond and mailing to the Division, and requests company, management and preparer information. | S_MO-C028 | S008, complete page. [Missouri Division of Finance+1](https://finance.mo.gov/media/366) | High form text; not actual filing proof. |\n| **S_MO-P2-C017** | The currently linked undated bond form is a $100,000 DMP-focused form with annual-renewal, 60-day cancellation, 36-month claim-presentation, aggregate-cap and POA terms. | S_MO-C023, S_MO-C024, S_MO-C028 | S009, complete page. [Missouri Division of Finance+2](https://finance.mo.gov/media/371) | High form text; form terms are not automatically universal statutes. |\n| **S_MO-P2-C018** | The forms’ omission of the $50,000 branch, DSP language and § 425.043 does not prove repeal, universal $100,000 coverage, loss of DSP protection or a new licensing system. | S_MO-C020, S_MO-C023, S_MO-C024, S_MO-C028 | S006–S009. [Missouri Revisor of Statutes+3](https://revisor.mo.gov/main/OneSection.aspx?section=425.027) | High as noninference; operational meaning held. |\n| **S_MO-P2-C019** | No actual account, sales process, provider bond, registry result, accepted form or filing status was verified. | S_MO-C028 | Scope record; S007–S009 supply only public guidance and blank forms. | Explicit hold. |\n\n## 7. Focused correction-coverage table\n\n| Correction component | Status | P2 claims | Effect on PASS-01 / exact remaining evidence |\n| --- | --- | --- | --- |\n| Missouri account introductory wording | Corrected | C001 | Preserve “fees for payments”; do not silently conform it to federal wording. Interpretive authority remains needed. |\n| Missouri administrator independence | Corrected/partial | C003 | Replace any generic state-independence statement with the conditional 4(3) formulation. Self-administration is not approved. |\n| State insured-account, ownership and interest conditions | Reconciled | C002 | Original substantive conditions preserved. |\n| Referral compensation and seven-day return | Corrected | C004 | Preserve the exact state referral language and 4(5) cross-reference. |\n| Federal administrator independence | Reconciled | C005 | Federal condition is unqualified, but only where the TSR applies. |\n| State “receive” versus federal “request or receive” | Corrected | C006 | Depositing customer funds is not equated with provider fee receipt. Actual account facts remain absent. |\n| Exact federal fee trigger | Corrected | C007–C009 | Creditor-writing/customer-oral language is no longer misattributed to the CFR. Federal coverage and specific agreement validity remain held. |\n| E05 after complete $5,000 satisfaction | Corrected | C010 | $3,000 savings and $750 allocation retained; actual collectibility remains conditional. |\n| E05 bona fide installment — federal layer | Answered more precisely | C011 | Commission rulemaking history supports first-payment timing and required-satisfaction base, subject to TSR coverage. |\n| E05 bona fide installment — Missouri layer | Unresolved | C012 | Immediate $750 collection remains held pending Missouri interpretation. Do not subtract only the first installment from $8,000. |\n| Early/later P1 bond-amount chronology | Reconciled | C013–C014 | Later statutory read supersedes the early amount hold only. |\n| “Initial license application” versus agency no-license statement | Partial | C015 | Both texts preserved; formal reconciliation or procedural authority remains absent. |\n| Information form | Newly read; partial | C016 | Form text established. Revision date, $50,000 branch, filing fee, acceptance and renewal remain held. |\n| Bond form | Newly read; partial | C017–C018 | Form terms established. Statutory/form discrepancy, current approval and alternative bond form remain held. |\n| Actual application, bond, provider or registry status | Unresolved | C019 | Requires a later focused operational pass using an authoritative current lookup or accepted-filing evidence; none was performed here. |\n| Missouri cases, regulations, agency interpretations and enactment history | Unresolved | C003, C012, C015, C018 | Needed for self-administration, installment savings, license terminology and form/statute reconciliation. |\n| Other PASS-01 state components | Unchanged/deferred | — | Contract, sales, sector, local, tribal, collection, litigation, limitations, remedies, full bond administration, actual-provider and other previously preserved holds remain open. |\n\n## 8. Researcher self-check\n\n**Freshly read in PASS-02:** the complete operative pages for Missouri §§ 425.043 and 425.027; the relevant operative eCFR subsections; selected July 2010 FTC Guide and October 2010 FAQ portions; relevant pages of the August 2010 Commission final-rule statement; the current Division debt-adjuster page; and both complete one-page public forms. All three PDFs were also visually inspected.\n\n**P1 history preserved:** the P1 eCFR source had been explicitly reused from an earlier Oregon primary read. PASS-02’s fresh eCFR access is recorded as a new correction check and does not retroactively rewrite the P1 research history. The two Division forms had previously been links/gaps, not read authorities; their text was first substantively read here.\n\n**Search-only or discovery treatment:** a narrow official-source search for the installment issue led to the Federal Register final-rule document. Search snippets, FTC complaints and stipulated orders returned during discovery were not added as claim authorities. No Missouri judicial or formal agency interpretation of incomplete installment settlements was located and read in this bounded pass.\n\n**Not read or verified:** no executed bond, provider record, registry result, filing acceptance, current form revision certificate, filing fee schedule, alternate $50,000 form, renewal submission, Missouri regulation, formal Division interpretation, AG opinion, Missouri appellate decision, surety practice or private account agreement.\n\nNo application was submitted; no provider, regulator, surety, attorney or consumer was contacted. No Chrome control, Work mode, Deep Research, API, account change, private borrower data, local write or publication occurred. This remains a coordinator correction to the Missouri provider-access/fee component, not independent review, A066 acceptance, whole-state clearance or operational authorization.\n\n**END S_MO PASS-02**\n\n","tables":[{"headers":["Issue","Missouri — § 425.043","Federal — 16 CFR § 310.4(a)(5)","Reconciliation"],"index":0,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}]],"rows":[["Issue","Missouri — § 425.043","Federal — 16 CFR § 310.4(a)(5)","Reconciliation"],["Account introductory wording","Subsection 4 literally refers to funds used for the adjuster’s “fees for payments” to creditors or collectors.","Subsection (ii) refers to funds used for provider fees “and for payments” to creditors or collectors.","The texts are not silently conformed. Missouri’s unusual wording remains uninterpreted. \nMissouri Revisor of Statutes\n+1"],["Fee-request/receipt rule","Subsection 3 prohibits receipt of a fee before alteration, payment and, for DSP debts, allocation conditions. Subsection 4 conditionally permits requesting or requiring account deposits.","Subsection (i) prohibits requesting or receiving the provider’s fee until (A)–(C) are satisfied; subsection (ii) separately allows qualifying account deposits.","A deposit in a customer-owned account is not automatically a fee received by the provider. Federal timing can be broader where the TSR applies. \nMissouri Revisor of Statutes\n+2"],["Financial institution","Funds must be held at an insured financial institution.","Same operative requirement.","Textually aligned on this condition. \nMissouri Revisor of Statutes\n+1"],["Ownership and interest","The debtor owns the funds and receives accrued interest, if any.","The customer owns the funds and receives accrued interest, if any.","Textually aligned for ownership and interest. \nMissouri Revisor of Statutes\n+1"],["Administrator independence","If the adjuster does not administer, the administering entity cannot be owned, controlled by or affiliated with the adjuster.","The entity administering the account cannot be owned, controlled by or affiliated with the debt-relief service.","Missouri is conditional; federal language is unqualified. Missouri does not thereby affirmatively authorize self-administration. \nMissouri Revisor of Statutes\n+1"],["Referral compensation","The administering entity may not give or accept compensation for referrals of business by the debt adjuster.","The administering entity may not give or accept compensation for referrals involving the debt-relief service.","Similar protection, but the exact relational wording differs. No account-provider fee arrangement was tested. \nMissouri Revisor of Statutes\n+1"],["Withdrawal","The debtor may withdraw from the debt-relief service at any time without penalty.","Same operative customer right.","Textually aligned on penalty-free withdrawal. \nMissouri Revisor of Statutes\n+1"],["Seven-business-day return","Missouri requires return of all account funds except funds earned in compliance with “subdivision (3) of subsection 3” within seven business days.","Federal law excludes only fees earned in compliance with § 310.4(a)(5)(i)(A)–(C), also with a seven-business-day deadline.","Missouri’s literal cross-reference points to subsection 3’s allocation subdivision; subsection 3 separately imposes the alteration and payment conditions. This correction does not judicially reconcile the cross-reference. \nMissouri Revisor of Statutes\n+1"]]},{"headers":["E05 branch","Inputs and calculation","Missouri analysis","Federal analysis, if the TSR applies","Result"],"index":1,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"},{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+3"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"}],[{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+3"}]],"rows":[["E05 branch","Inputs and calculation","Missouri analysis","Federal analysis, if the TSR applies","Result"],["A. $5,000 has actually been paid and the debt is satisfied","Enrolled balance: $8,000. Amount actually paid to satisfy: $5,000. Savings: $8,000 − $5,000 = $3,000. Uniform assumed fee: $3,000 × 25% = $750.","The savings base matches § 425.043.3(3)(b). Receipt still requires the qualifying alteration under subdivision (1), at least one payment under subdivision (2), the uniform percentage requirement and all other applicable state conditions.","The calculation also matches § 310.4(a)(5)(i)(C)(2). Collection remains conditional on (A), (B), complete allocation and actual TSR coverage.","$750 is the allocated arithmetic result, not unconditional collection approval. \nMissouri Revisor of Statutes\n+2"],["B. Bona fide $5,000 installment settlement; only the first scheduled installment has been paid","The settlement requires $5,000 in total, but the debt has not yet been fully paid. Do not calculate savings as $8,000 minus the first installment.","Section 425.043.3(2)’s one-payment condition may be met, but § 425.043.3(3)(b) defines savings using the amount actually paid to satisfy the debt. No Missouri judicial, Division, AG or rulemaking interpretation of this incomplete-installment branch was read. Immediate Missouri collection of $750 remains HELD.","The Commission’s final-rule explanation states that the one-payment provision specifically accommodates bona fide installment settlements; after the first installment, the appropriate fee may be sent. The same explanation uses the amount required to satisfy the debt as the savings base. That is primary federal rulemaking history, not Missouri authority.","Federal layer materially supports first-installment earning in a bona fide installment settlement, but combined Missouri operational approval remains HELD. \nGovInfo\n+3"]]},{"headers":["Source layer","What it actually establishes","Qualification"],"index":2,"links":[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"},{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+2"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+3"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission\n+3"}],"row_links":[[],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"}],[{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+2"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+3"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission\n+3"}]],"rows":[["Source layer","What it actually establishes","Qualification"],["Operative eCFR","§ 310.4(a)(5)(i)(A)–(C) contains the customer-executed valid-agreement, qualifying-payment and allocation requirements. Section (ii)(A)–(E) contains the dedicated-account conditions.","Authoritative but unofficial eCFR display; shown up to date as of October 22, 2026. It says requesting or receiving. \neCFR\n+2"],["Commission final-rule statement of basis and purpose, August 10, 2010","Explains that customer execution may be oral or written; discusses documentation of creditor agreement; specifically addresses bona fide installment settlements; and explains the savings base using the amount required to satisfy the debt.","Primary federal rulemaking history, but not a replacement for the codified text or applicable contract law. It does not decide Missouri § 425.043. \nGovInfo\n+2"],["FTC Guide for Business, July 2010","States that the creditor agreement should be in writing while the customer may agree orally; uses the amount required to satisfy the debt for the savings calculation. Example 13 has the consumer pay the full $600 settlement before the $100 fee.","The guide expressly identifies itself as FTC staff views and not binding on the Commission. It should not be presented as the literal CFR wording. \nFederal Trade Commission\n+3"],["FTC FAQ, October 2010","States that using attorneys or calling a charge a retainer does not automatically avoid the rule; an individual attorney’s coverage depends on telemarketing and other facts. It also warns against collecting a full multi-debt fee after one debt.","Staff FAQ, not a universal attorney-coverage determination or substitute for the regulation. \nFederal Trade Commission\n+3"]]},{"headers":["Evidence layer","Exact evidence read","What it establishes","What remains unresolved"],"index":3,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"},{"href":"https://finance.mo.gov/consumer-credit-licensing","text":"Missouri Division of Finance"},{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"},{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"}],[{"href":"https://finance.mo.gov/consumer-credit-licensing","text":"Missouri Division of Finance"}],[{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"}],[{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"}],[]],"rows":[["Evidence layer","Exact evidence read","What it establishes","What remains unresolved"],["§ 425.027 operative statute","Uses “initial license application”; states $50,000 for an applicant declaring no consumer monies will be handled and $100,000 otherwise; benefits debtors damaged under a DMP or DSP; authorizes the director to investigate complaints and make or release a bond claim. Effective-version display: August 28, 2011.","Resolves the statutory amounts and statutory protection described in P1 C023–C024.","Does not itself explain the agency’s no-license procedure, submission package, renewal, acceptance or public lookup. \nMissouri Revisor of Statutes"],["Division consumer-credit page","States that Chapter 425 still has no debt-adjuster licensing requirement and that a debt adjuster must post a bond before entering the business. It currently links the information and bond forms.","Establishes the Division’s published operational characterization: bond required, no ordinary debt-adjuster license.","Does not prove that a submitted form has been accepted, a bond is active or a particular provider may operate. \nMissouri Division of Finance"],["Debt Adjuster’s Information form, /media/366","One-page undated blank form. It instructs the filer to attach a $100,000 bond and mail the completed form to Division of Finance, P.O. Box 716, Jefferson City, Missouri 65102-0716. It contains a year blank, office-use “425-” blank and company, officer/director and preparer fields.","Establishes the text and fields of the blank form currently linked by the Division.","It does not show the statutory $50,000 branch; prove annual renewal; create a licensing system; certify its revision date; or prove an actual filing or acceptance. \nMissouri Division of Finance\n+1"],["Missouri Debt Adjusters Bond form, /media/371","One-page undated blank $100,000 form. It refers to beneficiaries under a DMP and §§ 425.010–425.040. Its terms include automatic annual renewal absent notice, conditional cancellation on 60 days’ written notice, preservation of accrued/notice-period liability, presentation of covered claims for up to 36 months after expiration of the notice period, an aggregate cap and attached power of attorney.","Establishes the language of the currently linked blank bond form.","It does not mention the $50,000 branch, DSP beneficiaries or § 425.043. Its form terms are not automatically universal statutory renewal or limitations rules. It is not an executed bond or current-version certification. \nMissouri Division of Finance\n+2"],["Combined reconciliation","The statute recognizes two bond amounts and DMP/DSP protection; both currently linked forms are written around $100,000, and the bond form text mentions only DMPs and §§ 425.010–425.040.","The divergence is a real evidence issue to preserve.","It does not establish that the $50,000 branch was repealed, that $100,000 is universally required, that DSP claims lack statutory protection, that a license now exists, or that these forms constitute a complete presently acceptable filing package."]]},{"headers":["Source ID","P1 relationship","Authority, literal URL and pinpoint","Access/source status and limitation"],"index":4,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission\n+2"},{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+4"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"},{"href":"https://finance.mo.gov/consumer-credit-licensing","text":"Missouri Division of Finance"},{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"},{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission\n+2"}],[{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+4"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"}],[{"href":"https://finance.mo.gov/consumer-credit-licensing","text":"Missouri Division of Finance"}],[{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"}],[{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"}]],"rows":[["Source ID","P1 relationship","Authority, literal URL and pinpoint","Access/source status and limitation"],["S_MO-P2-S001","Fresh reread of P1 S007","Missouri Revisor, § 425.043: https://revisor.mo.gov/main/OneSection.aspx?section=425.043; subsections 3 and 4, including 4(1)–(5), history and August 28, 2011 effective display.","Fresh complete operative-page read. Used for exact Missouri account, receipt, allocation and seven-business-day language. \nMissouri Revisor of Statutes\n+1"],["S_MO-P2-S002","P1 S009 had been explicitly reused from an earlier Oregon primary read; this is a new Missouri-P2 refresh, not a retroactive change to P1 history","eCFR, 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), (ii)(A)–(E).","Fresh operative-text read. Display states title current through October 22, 2026. Federal coverage remains conditional. \neCFR\n+2"],["S_MO-P2-S003","Fresh selected reread of P1 S010","FTC, Debt Relief Services & the Telemarketing Sales Rule: A Guide for Business: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business; lines corresponding to “Collecting Fees,” Examples 12–13 and dedicated accounts; July 2010.","Fresh selected-section read. FTC staff guidance; page says it is not binding on the Commission. Not treated as operative CFR text. \nFederal Trade Commission\n+2"],["S_MO-P2-S004","Fresh selected reread of P1 S014","FTC, What People Are Asking: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking; attorney Q&A and fee Q&A; October 2010.","Fresh selected-section read. Staff FAQ; not a complete federal-coverage or attorney-exemption analysis. \nFederal Trade Commission\n+2"],["S_MO-P2-S005","New PASS-02 authority","FTC, Telemarketing Sales Rule—Final Rule Amendments, 75 Fed. Reg. 48458, 48489–90: https://www.govinfo.gov/link/fr/75/48516; footnote 432, contractual-agreement discussion, fee requirements and dedicated-account discussion.","Fresh primary rulemaking PDF read; relevant pages visually inspected. Resolves the federal installment explanation but is not Missouri authority. \nGovInfo\n+4"],["S_MO-P2-S006","Fresh reread of P1 S004","Missouri Revisor, § 425.027: https://revisor.mo.gov/main/OneSection.aspx?section=425.027; complete operative text and history.","Fresh complete operative-page read. Preserves $50,000/$100,000 branches, DMP/DSP beneficiaries and “initial license application” wording. \nMissouri Revisor of Statutes"],["S_MO-P2-S007","Fresh reread of P1 S008","Missouri Division of Finance, Consumer Credit Licensing: https://finance.mo.gov/consumer-credit-licensing; Debt Adjusters, lines 39–45.","Fresh agency-page read. Operational guidance only; no named-provider status or filing acceptance. \nMissouri Division of Finance"],["S_MO-P2-S008","P1 contained only the link/form gap; form text was not then read","Division of Finance, Debt Adjuster’s Information: https://finance.mo.gov/media/366; complete one-page blank form.","Fresh complete PDF text and visual read. Undated on its face; currently linked; not an executed filing or revision certification. \nMissouri Division of Finance\n+1"],["S_MO-P2-S009","P1 contained only the link/form gap; form text was not then read","Division of Finance, Missouri Debt Adjusters Bond: https://finance.mo.gov/media/371; complete one-page blank form.","Fresh complete PDF text and visual read. Undated on its face; currently linked; not an executed bond or universal statement of statutory law. \nMissouri Division of Finance\n+2"]]},{"headers":["Claim ID","Corrected or new precise assertion","P1 alias affected","Source/pinpoint","Confidence and limit"],"index":5,"links":[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+2"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes\n+1"},{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"},{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"},{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes\n+3"}],"row_links":[[],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking","text":"Federal Trade Commission"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://www.govinfo.gov/link/fr/75/48516","text":"GovInfo\n+2"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.043","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes\n+1"}],[{"href":"https://finance.mo.gov/media/366","text":"Missouri Division of Finance\n+1"}],[{"href":"https://finance.mo.gov/media/371","text":"Missouri Division of Finance\n+2"}],[{"href":"https://revisor.mo.gov/main/OneSection.aspx?section=425.027","text":"Missouri Revisor of Statutes\n+3"}],[]],"rows":[["Claim ID","Corrected or new precise assertion","P1 alias affected","Source/pinpoint","Confidence and limit"],["S_MO-P2-C001","Missouri subsection 4’s introductory phrase uses “fees for payments”; PASS-02 does not replace it with “and for payments.”","S_MO-C018","S001, § 425.043.4 introductory clause. \nMissouri Revisor of Statutes","High as text; meaning unresolved."],["S_MO-P2-C002","Missouri requires an insured account, debtor ownership and payment of accrued interest, if any.","S_MO-C018","S001, § 425.043.4(1)–(2). \nMissouri Revisor of Statutes","High."],["S_MO-P2-C003","Missouri’s nonaffiliation condition applies when the adjuster does not administer the account; it is not an unconditional independence rule or affirmative self-administration permission.","S_MO-C018","S001, § 425.043.4(3). \nMissouri Revisor of Statutes","High for wording; self-administration legal effect held."],["S_MO-P2-C004","Missouri prohibits referral compensation described in 4(4) and requires penalty-free withdrawal and seven-business-day return, subject to the literal 4(5) cross-reference to subdivision 3 of subsection 3.","S_MO-C018","S001, § 425.043.4(4)–(5). \nMissouri Revisor of Statutes","High for text; cross-reference interaction held."],["S_MO-P2-C005","The covered federal account rule requires an unaffiliated administrator without Missouri’s conditional opening and excludes only fees earned under (i)(A)–(C) from the seven-day return.","S_MO-C026","S002, § 310.4(a)(5)(ii)(C)–(E). \neCFR","High if TSR applies."],["S_MO-P2-C006","Missouri subsection 3 prohibits receiving a fee; covered federal law prohibits requesting or receiving it. A qualifying customer-owned deposit is analytically distinct.","S_MO-C015, S_MO-C017, S_MO-C018, S_MO-C026","S001 § 425.043.3–4; S002 § 310.4(a)(5)(i)–(ii). \nMissouri Revisor of Statutes\n+2","High for verbs; application factual."],["S_MO-P2-C007","The operative federal trigger is the customer-executed valid agreement, payment under that agreement and complete allocation rule.","S_MO-C017","S002, § 310.4(a)(5)(i)(A)–(C). \neCFR\n+1","High if TSR applies."],["S_MO-P2-C008","Creditor-writing/customer-oral formulations arise from Commission explanation and FTC staff guidance, not the literal text of § 310.4(a)(5)(i).","S_MO-C017","S003; S005, 75 Fed. Reg. 48489. \nFederal Trade Commission\n+2","High source attribution; individual validity held."],["S_MO-P2-C009","No automatic federal TSR exemption arises merely from using attorneys or labeling charges retainers; actual TSR coverage remains fact-dependent.","Federal discussion associated with S_MO-C017","S004, attorney Q&A. \nFederal Trade Commission","High as staff guidance; not full coverage adjudication."],["S_MO-P2-C010","In completed E05, $8,000 minus $5,000 equals $3,000 savings and 25% equals a $750 allocated fee.","S_MO-C013, S_MO-C015, S_MO-C017","S001 § 425.043.3(3)(b); S002 § 310.4(a)(5)(i)(C)(2). \nMissouri Revisor of Statutes\n+1","Arithmetic high; collection conditional."],["S_MO-P2-C011","The federal final-rule explanation specifically treats the first payment under a bona fide installment settlement as satisfying the payment timing component and uses the amount required to satisfy for savings.","S_MO-C013, S_MO-C017","S005, 75 Fed. Reg. 48489–90 and n.432. \nGovInfo\n+2","Strong federal interpretive source; coverage conditional."],["S_MO-P2-C012","The federal installment explanation is not Missouri interpretation; immediate Missouri collection of E05’s $750 after only the first installment remains held.","S_MO-C013, S_MO-C015","S001 § 425.043.3(2)–(3)(b); absence of Missouri interpretation in this bounded pass. \nMissouri Revisor of Statutes","Explicit hold."],["S_MO-P2-C013","Section 425.027 states $50,000 for a no-consumer-monies declaration and $100,000 otherwise; the bond benefits qualifying DMP or DSP debtors and the director has specified claim powers.","S_MO-C023, S_MO-C024","S006, complete operative text. \nMissouri Revisor of Statutes","High."],["S_MO-P2-C014","The early P1 bond-amount hold was superseded by P1 A6/C023–C024 only as to the statutory text, not operational procedure.","S_MO-C023, S_MO-C024","S006 plus preserved P1 chronology. \nMissouri Revisor of Statutes","High reconciliation."],["S_MO-P2-C015","The Division says no Chapter 425 debt-adjuster license is required, but a bond must be posted before entering the business; the statute’s “initial license application” wording remains preserved.","S_MO-C020, S_MO-C023","S006; S007, Debt Adjusters. \nMissouri Revisor of Statutes\n+1","High evidence; formal reconciliation absent."],["S_MO-P2-C016","The currently linked undated information form directs attachment of a $100,000 bond and mailing to the Division, and requests company, management and preparer information.","S_MO-C028","S008, complete page. \nMissouri Division of Finance\n+1","High form text; not actual filing proof."],["S_MO-P2-C017","The currently linked undated bond form is a $100,000 DMP-focused form with annual-renewal, 60-day cancellation, 36-month claim-presentation, aggregate-cap and POA terms.","S_MO-C023, S_MO-C024, S_MO-C028","S009, complete page. \nMissouri Division of Finance\n+2","High form text; form terms are not automatically universal statutes."],["S_MO-P2-C018","The forms’ omission of the $50,000 branch, DSP language and § 425.043 does not prove repeal, universal $100,000 coverage, loss of DSP protection or a new licensing system.","S_MO-C020, S_MO-C023, S_MO-C024, S_MO-C028","S006–S009. \nMissouri Revisor of Statutes\n+3","High as noninference; operational meaning held."],["S_MO-P2-C019","No actual account, sales process, provider bond, registry result, accepted form or filing status was verified.","S_MO-C028","Scope record; S007–S009 supply only public guidance and blank forms.","Explicit hold."]]},{"headers":["Correction component","Status","P2 claims","Effect on PASS-01 / exact remaining evidence"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Correction component","Status","P2 claims","Effect on PASS-01 / exact remaining evidence"],["Missouri account introductory wording","Corrected","C001","Preserve “fees for payments”; do not silently conform it to federal wording. Interpretive authority remains needed."],["Missouri administrator independence","Corrected/partial","C003","Replace any generic state-independence statement with the conditional 4(3) formulation. Self-administration is not approved."],["State insured-account, ownership and interest conditions","Reconciled","C002","Original substantive conditions preserved."],["Referral compensation and seven-day return","Corrected","C004","Preserve the exact state referral language and 4(5) cross-reference."],["Federal administrator independence","Reconciled","C005","Federal condition is unqualified, but only where the TSR applies."],["State “receive” versus federal “request or receive”","Corrected","C006","Depositing customer funds is not equated with provider fee receipt. Actual account facts remain absent."],["Exact federal fee trigger","Corrected","C007–C009","Creditor-writing/customer-oral language is no longer misattributed to the CFR. Federal coverage and specific agreement validity remain held."],["E05 after complete $5,000 satisfaction","Corrected","C010","$3,000 savings and $750 allocation retained; actual collectibility remains conditional."],["E05 bona fide installment — federal layer","Answered more precisely","C011","Commission rulemaking history supports first-payment timing and required-satisfaction base, subject to TSR coverage."],["E05 bona fide installment — Missouri layer","Unresolved","C012","Immediate $750 collection remains held pending Missouri interpretation. Do not subtract only the first installment from $8,000."],["Early/later P1 bond-amount chronology","Reconciled","C013–C014","Later statutory read supersedes the early amount hold only."],["“Initial license application” versus agency no-license statement","Partial","C015","Both texts preserved; formal reconciliation or procedural authority remains absent."],["Information form","Newly read; partial","C016","Form text established. Revision date, $50,000 branch, filing fee, acceptance and renewal remain held."],["Bond form","Newly read; partial","C017–C018","Form terms established. Statutory/form discrepancy, current approval and alternative bond form remain held."],["Actual application, bond, provider or registry status","Unresolved","C019","Requires a later focused operational pass using an authoritative current lookup or accepted-filing evidence; none was performed here."],["Missouri cases, regulations, agency interpretations and enactment history","Unresolved","C003, C012, C015, C018","Needed for self-administration, installment savings, license terminology and form/statute reconciliation."],["Other PASS-01 state components","Unchanged/deferred","—","Contract, sales, sector, local, tribal, collection, litigation, limitations, remedies, full bond administration, actual-provider and other previously preserved holds remain open."]]}],"claims":[{"claim_id":"S_MO-P2-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C001","Corrected or new precise assertion":"Missouri subsection 4’s introductory phrase uses “fees for payments”; PASS-02 does not replace it with “and for payments.”","P1 alias affected":"S_MO-C018","Source/pinpoint":"S001, § 425.043.4 introductory clause. \nMissouri Revisor of Statutes","Confidence and limit":"High as text; meaning unresolved."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C002","Corrected or new precise assertion":"Missouri requires an insured account, debtor ownership and payment of accrued interest, if any.","P1 alias affected":"S_MO-C018","Source/pinpoint":"S001, § 425.043.4(1)–(2). \nMissouri Revisor of Statutes","Confidence and limit":"High."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C003","Corrected or new precise assertion":"Missouri’s nonaffiliation condition applies when the adjuster does not administer the account; it is not an unconditional independence rule or affirmative self-administration permission.","P1 alias affected":"S_MO-C018","Source/pinpoint":"S001, § 425.043.4(3). \nMissouri Revisor of Statutes","Confidence and limit":"High for wording; self-administration legal effect held."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C004","Corrected or new precise assertion":"Missouri prohibits referral compensation described in 4(4) and requires penalty-free withdrawal and seven-business-day return, subject to the literal 4(5) cross-reference to subdivision 3 of subsection 3.","P1 alias affected":"S_MO-C018","Source/pinpoint":"S001, § 425.043.4(4)–(5). \nMissouri Revisor of Statutes","Confidence and limit":"High for text; cross-reference interaction held."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C005","Corrected or new precise assertion":"The covered federal account rule requires an unaffiliated administrator without Missouri’s conditional opening and excludes only fees earned under (i)(A)–(C) from the seven-day return.","P1 alias affected":"S_MO-C026","Source/pinpoint":"S002, § 310.4(a)(5)(ii)(C)–(E). \neCFR","Confidence and limit":"High if TSR applies."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C006","Corrected or new precise assertion":"Missouri subsection 3 prohibits receiving a fee; covered federal law prohibits requesting or receiving it. A qualifying customer-owned deposit is analytically distinct.","P1 alias affected":"S_MO-C015, S_MO-C017, S_MO-C018, S_MO-C026","Source/pinpoint":"S001 § 425.043.3–4; S002 § 310.4(a)(5)(i)–(ii). \nMissouri Revisor of Statutes\n+2","Confidence and limit":"High for verbs; application factual."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C007","Corrected or new precise assertion":"The operative federal trigger is the customer-executed valid agreement, payment under that agreement and complete allocation rule.","P1 alias affected":"S_MO-C017","Source/pinpoint":"S002, § 310.4(a)(5)(i)(A)–(C). \neCFR\n+1","Confidence and limit":"High if TSR applies."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C008","Corrected or new precise assertion":"Creditor-writing/customer-oral formulations arise from Commission explanation and FTC staff guidance, not the literal text of § 310.4(a)(5)(i).","P1 alias affected":"S_MO-C017","Source/pinpoint":"S003; S005, 75 Fed. Reg. 48489. \nFederal Trade Commission\n+2","Confidence and limit":"High source attribution; individual validity held."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C009","Corrected or new precise assertion":"No automatic federal TSR exemption arises merely from using attorneys or labeling charges retainers; actual TSR coverage remains fact-dependent.","P1 alias affected":"Federal discussion associated with S_MO-C017","Source/pinpoint":"S004, attorney Q&A. \nFederal Trade Commission","Confidence and limit":"High as staff guidance; not full coverage adjudication."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C010","Corrected or new precise assertion":"In completed E05, $8,000 minus $5,000 equals $3,000 savings and 25% equals a $750 allocated fee.","P1 alias affected":"S_MO-C013, S_MO-C015, S_MO-C017","Source/pinpoint":"S001 § 425.043.3(3)(b); S002 § 310.4(a)(5)(i)(C)(2). \nMissouri Revisor of Statutes\n+1","Confidence and limit":"Arithmetic high; collection conditional."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C011","Corrected or new precise assertion":"The federal final-rule explanation specifically treats the first payment under a bona fide installment settlement as satisfying the payment timing component and uses the amount required to satisfy for savings.","P1 alias affected":"S_MO-C013, S_MO-C017","Source/pinpoint":"S005, 75 Fed. Reg. 48489–90 and n.432. \nGovInfo\n+2","Confidence and limit":"Strong federal interpretive source; coverage conditional."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C012","Corrected or new precise assertion":"The federal installment explanation is not Missouri interpretation; immediate Missouri collection of E05’s $750 after only the first installment remains held.","P1 alias affected":"S_MO-C013, S_MO-C015","Source/pinpoint":"S001 § 425.043.3(2)–(3)(b); absence of Missouri interpretation in this bounded pass. \nMissouri Revisor of Statutes","Confidence and limit":"Explicit hold."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C013","Corrected or new precise assertion":"Section 425.027 states $50,000 for a no-consumer-monies declaration and $100,000 otherwise; the bond benefits qualifying DMP or DSP debtors and the director has specified claim powers.","P1 alias affected":"S_MO-C023, S_MO-C024","Source/pinpoint":"S006, complete operative text. \nMissouri Revisor of Statutes","Confidence and limit":"High."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C014","Corrected or new precise assertion":"The early P1 bond-amount hold was superseded by P1 A6/C023–C024 only as to the statutory text, not operational procedure.","P1 alias affected":"S_MO-C023, S_MO-C024","Source/pinpoint":"S006 plus preserved P1 chronology. \nMissouri Revisor of Statutes","Confidence and limit":"High reconciliation."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C015","Corrected or new precise assertion":"The Division says no Chapter 425 debt-adjuster license is required, but a bond must be posted before entering the business; the statute’s “initial license application” wording remains preserved.","P1 alias affected":"S_MO-C020, S_MO-C023","Source/pinpoint":"S006; S007, Debt Adjusters. \nMissouri Revisor of Statutes\n+1","Confidence and limit":"High evidence; formal reconciliation absent."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C016","Corrected or new precise assertion":"The currently linked undated information form directs attachment of a $100,000 bond and mailing to the Division, and requests company, management and preparer information.","P1 alias affected":"S_MO-C028","Source/pinpoint":"S008, complete page. \nMissouri Division of Finance\n+1","Confidence and limit":"High form text; not actual filing proof."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C017","Corrected or new precise assertion":"The currently linked undated bond form is a $100,000 DMP-focused form with annual-renewal, 60-day cancellation, 36-month claim-presentation, aggregate-cap and POA terms.","P1 alias affected":"S_MO-C023, S_MO-C024, S_MO-C028","Source/pinpoint":"S009, complete page. \nMissouri Division of Finance\n+2","Confidence and limit":"High form text; form terms are not automatically universal statutes."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C018","Corrected or new precise assertion":"The forms’ omission of the $50,000 branch, DSP language and § 425.043 does not prove repeal, universal $100,000 coverage, loss of DSP protection or a new licensing system.","P1 alias affected":"S_MO-C020, S_MO-C023, S_MO-C024, S_MO-C028","Source/pinpoint":"S006–S009. \nMissouri Revisor of Statutes\n+3","Confidence and limit":"High as noninference; operational meaning held."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"claim_id":"S_MO-P2-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MO-P2-C019","Corrected or new precise assertion":"No actual account, sales process, provider bond, registry result, accepted form or filing status was verified.","P1 alias affected":"S_MO-C028","Source/pinpoint":"Scope record; S007–S009 supply only public guidance and blank forms.","Confidence and limit":"Explicit hold."},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_MO-P2-S001","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.043"],"researcher_record":{"Source ID":"S_MO-P2-S001","P1 relationship":"Fresh reread of P1 S007","Authority, literal URL and pinpoint":"Missouri Revisor, § 425.043: https://revisor.mo.gov/main/OneSection.aspx?section=425.043; subsections 3 and 4, including 4(1)–(5), history and August 28, 2011 effective display.","Access/source status and limitation":"Fresh complete operative-page read. Used for exact Missouri account, receipt, allocation and seven-business-day language. \nMissouri Revisor of Statutes\n+1"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S002","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_MO-P2-S002","P1 relationship":"P1 S009 had been explicitly reused from an earlier Oregon primary read; this is a new Missouri-P2 refresh, not a retroactive change to P1 history","Authority, literal URL and pinpoint":"eCFR, 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), (ii)(A)–(E).","Access/source status and limitation":"Fresh operative-text read. Display states title current through October 22, 2026. Federal coverage remains conditional. \neCFR\n+2"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S003","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"],"researcher_record":{"Source ID":"S_MO-P2-S003","P1 relationship":"Fresh selected reread of P1 S010","Authority, literal URL and pinpoint":"FTC, Debt Relief Services & the Telemarketing Sales Rule: A Guide for Business: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business; lines corresponding to “Collecting Fees,” Examples 12–13 and dedicated accounts; July 2010.","Access/source status and limitation":"Fresh selected-section read. FTC staff guidance; page says it is not binding on the Commission. Not treated as operative CFR text. \nFederal Trade Commission\n+2"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S004","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking"],"researcher_record":{"Source ID":"S_MO-P2-S004","P1 relationship":"Fresh selected reread of P1 S014","Authority, literal URL and pinpoint":"FTC, What People Are Asking: https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-what-people-are-asking; attorney Q&A and fee Q&A; October 2010.","Access/source status and limitation":"Fresh selected-section read. Staff FAQ; not a complete federal-coverage or attorney-exemption analysis. \nFederal Trade Commission\n+2"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S005","urls":["https://www.govinfo.gov/link/fr/75/48516"],"researcher_record":{"Source ID":"S_MO-P2-S005","P1 relationship":"New PASS-02 authority","Authority, literal URL and pinpoint":"FTC, Telemarketing Sales Rule—Final Rule Amendments, 75 Fed. Reg. 48458, 48489–90: https://www.govinfo.gov/link/fr/75/48516; footnote 432, contractual-agreement discussion, fee requirements and dedicated-account discussion.","Access/source status and limitation":"Fresh primary rulemaking PDF read; relevant pages visually inspected. Resolves the federal installment explanation but is not Missouri authority. \nGovInfo\n+4"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S006","urls":["https://revisor.mo.gov/main/OneSection.aspx?section=425.027"],"researcher_record":{"Source ID":"S_MO-P2-S006","P1 relationship":"Fresh reread of P1 S004","Authority, literal URL and pinpoint":"Missouri Revisor, § 425.027: https://revisor.mo.gov/main/OneSection.aspx?section=425.027; complete operative text and history.","Access/source status and limitation":"Fresh complete operative-page read. Preserves $50,000/$100,000 branches, DMP/DSP beneficiaries and “initial license application” wording. \nMissouri Revisor of Statutes"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S007","urls":["https://finance.mo.gov/consumer-credit-licensing"],"researcher_record":{"Source ID":"S_MO-P2-S007","P1 relationship":"Fresh reread of P1 S008","Authority, literal URL and pinpoint":"Missouri Division of Finance, Consumer Credit Licensing: https://finance.mo.gov/consumer-credit-licensing; Debt Adjusters, lines 39–45.","Access/source status and limitation":"Fresh agency-page read. Operational guidance only; no named-provider status or filing acceptance. \nMissouri Division of Finance"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S008","urls":["https://finance.mo.gov/media/366"],"researcher_record":{"Source ID":"S_MO-P2-S008","P1 relationship":"P1 contained only the link/form gap; form text was not then read","Authority, literal URL and pinpoint":"Division of Finance, Debt Adjuster’s Information: https://finance.mo.gov/media/366; complete one-page blank form.","Access/source status and limitation":"Fresh complete PDF text and visual read. Undated on its face; currently linked; not an executed filing or revision certification. \nMissouri Division of Finance\n+1"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"source_id":"S_MO-P2-S009","urls":["https://finance.mo.gov/media/371"],"researcher_record":{"Source ID":"S_MO-P2-S009","P1 relationship":"P1 contained only the link/form gap; form text was not then read","Authority, literal URL and pinpoint":"Division of Finance, Missouri Debt Adjusters Bond: https://finance.mo.gov/media/371; complete one-page blank form.","Access/source status and limitation":"Fresh complete PDF text and visual read. Undated on its face; currently linked; not an executed bond or universal statement of statutory law. \nMissouri Division of Finance\n+2"},"coordinator_verification_status":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"}],"coverage":[{"topic":"Missouri account introductory wording","researcher_record":{"Correction component":"Missouri account introductory wording","Status":"Corrected","P2 claims":"C001","Effect on PASS-01 / exact remaining evidence":"Preserve “fees for payments”; do not silently conform it to federal wording. Interpretive authority remains needed."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Missouri administrator independence","researcher_record":{"Correction component":"Missouri administrator independence","Status":"Corrected/partial","P2 claims":"C003","Effect on PASS-01 / exact remaining evidence":"Replace any generic state-independence statement with the conditional 4(3) formulation. Self-administration is not approved."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"State insured-account, ownership and interest conditions","researcher_record":{"Correction component":"State insured-account, ownership and interest conditions","Status":"Reconciled","P2 claims":"C002","Effect on PASS-01 / exact remaining evidence":"Original substantive conditions preserved."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Referral compensation and seven-day return","researcher_record":{"Correction component":"Referral compensation and seven-day return","Status":"Corrected","P2 claims":"C004","Effect on PASS-01 / exact remaining evidence":"Preserve the exact state referral language and 4(5) cross-reference."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Federal administrator independence","researcher_record":{"Correction component":"Federal administrator independence","Status":"Reconciled","P2 claims":"C005","Effect on PASS-01 / exact remaining evidence":"Federal condition is unqualified, but only where the TSR applies."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"State “receive” versus federal “request or receive”","researcher_record":{"Correction component":"State “receive” versus federal “request or receive”","Status":"Corrected","P2 claims":"C006","Effect on PASS-01 / exact remaining evidence":"Depositing customer funds is not equated with provider fee receipt. Actual account facts remain absent."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Exact federal fee trigger","researcher_record":{"Correction component":"Exact federal fee trigger","Status":"Corrected","P2 claims":"C007–C009","Effect on PASS-01 / exact remaining evidence":"Creditor-writing/customer-oral language is no longer misattributed to the CFR. Federal coverage and specific agreement validity remain held."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"E05 after complete $5,000 satisfaction","researcher_record":{"Correction component":"E05 after complete $5,000 satisfaction","Status":"Corrected","P2 claims":"C010","Effect on PASS-01 / exact remaining evidence":"$3,000 savings and $750 allocation retained; actual collectibility remains conditional."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"E05 bona fide installment — federal layer","researcher_record":{"Correction component":"E05 bona fide installment — federal layer","Status":"Answered more precisely","P2 claims":"C011","Effect on PASS-01 / exact remaining evidence":"Commission rulemaking history supports first-payment timing and required-satisfaction base, subject to TSR coverage."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"E05 bona fide installment — Missouri layer","researcher_record":{"Correction component":"E05 bona fide installment — Missouri layer","Status":"Unresolved","P2 claims":"C012","Effect on PASS-01 / exact remaining evidence":"Immediate $750 collection remains held pending Missouri interpretation. Do not subtract only the first installment from $8,000."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Early/later P1 bond-amount chronology","researcher_record":{"Correction component":"Early/later P1 bond-amount chronology","Status":"Reconciled","P2 claims":"C013–C014","Effect on PASS-01 / exact remaining evidence":"Later statutory read supersedes the early amount hold only."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"“Initial license application” versus agency no-license statement","researcher_record":{"Correction component":"“Initial license application” versus agency no-license statement","Status":"Partial","P2 claims":"C015","Effect on PASS-01 / exact remaining evidence":"Both texts preserved; formal reconciliation or procedural authority remains absent."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Information form","researcher_record":{"Correction component":"Information form","Status":"Newly read; partial","P2 claims":"C016","Effect on PASS-01 / exact remaining evidence":"Form text established. Revision date, $50,000 branch, filing fee, acceptance and renewal remain held."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Bond form","researcher_record":{"Correction component":"Bond form","Status":"Newly read; partial","P2 claims":"C017–C018","Effect on PASS-01 / exact remaining evidence":"Form terms established. Statutory/form discrepancy, current approval and alternative bond form remain held."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Actual application, bond, provider or registry status","researcher_record":{"Correction component":"Actual application, bond, provider or registry status","Status":"Unresolved","P2 claims":"C019","Effect on PASS-01 / exact remaining evidence":"Requires a later focused operational pass using an authoritative current lookup or accepted-filing evidence; none was performed here."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Missouri cases, regulations, agency interpretations and enactment history","researcher_record":{"Correction component":"Missouri cases, regulations, agency interpretations and enactment history","Status":"Unresolved","P2 claims":"C003, C012, C015, C018","Effect on PASS-01 / exact remaining evidence":"Needed for self-administration, installment savings, license terminology and form/statute reconciliation."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"},{"topic":"Other PASS-01 state components","researcher_record":{"Correction component":"Other PASS-01 state components","Status":"Unchanged/deferred","P2 claims":"—","Effect on PASS-01 / exact remaining evidence":"Contract, sales, sector, local, tribal, collection, litigation, limitations, remedies, full bond administration, actual-provider and other previously preserved holds remain open."},"coordinator_acceptance":"bounded_substance_supported_with_pass03_date_patch_broader_holds_remain","coordinator_review":"[internal evidence reference]","provenance_patch_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}