{"meta":{"key":"s_ms--pass-03","task":"S_MS","title":"SMS Mississippi consumer-money custody, escrow, processor, and return component","parent_title":"Mississippi debt and debt relief law","edition":"pass-03","path":"/research/s_ms--pass-03/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":40,"sources":10,"review_status":"funds_processor_component_reviewed_with_currentness_and_application_holds","review_complete":true,"sha256":"0258ba2681a1f13fded5d165d534bda785ac5960c7afc5a8234ad68076b256cb","headings":["Component conclusion","1. Account-model and control matrix","2. Chapter 22 custody, escrow, and ledger requirements","2.1 Receipt and deposit","2.2 What the statute expressly protects","2.3 Segregation and individual accounting","2.4 Creditor remittance","2.5 Misdirected payments","2.6 Fair-share credits","3. Chapter 22 processor architecture","3.1 Functional processor definition","3.2 Ten-day notice and disclosed information","3.3 Security and pre-use confirmations","3.4 Contract termination","3.5 Provider responsibility is not displaced","4. Cancellation, termination, failed plans, cessation, and returns","4.1 Consumer cancellation","4.2 Rejected proposal or failed plan","4.3 Provider insolvency or regulatory cessation","4.4 Federal dedicated-account return","5. Separate Mississippi money-transmission gateway","5.1 Why the gateway matters","5.2 Material exemptions","5.3 Authorized-delegate architecture","5.4 Records and reconciliation","5.5 Timely transmission and refunds","5.6 Receipts and current delegate disclosures","5.7 Money-transmitter permissible investments and statutory trust","6. Reconciliation of the state and federal account rules","Ledger 1 — direct provider custody and the fifteen-business-day clock","Ledger 2 — current balance already reflects prior lawful earnings","Ledger 3 — provider-caused misdirection","Ledger 4 — pooled escrow and consumer subledgers","Ledger 5 — consumer-owned dedicated account with provider instructions","Ledger 6 — conditional money-transmitter refund","Ledger 7 — fair-share contribution","Ledger 8 — money-transmitter permissible-investment shortfall","D.1 Chapter 22 custody and processor claims","D.2 Money-transmission and federal-overlay claims","Actually read in this pass","Reused with preserved limits","Not read or not established","Process"],"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_MS/pass-03","facets":{"geography":["us","us-ms"],"debt_type":[],"stage":[],"subject":["client-money"]},"scope":"ExactreviewedremainingP1funds/escrow/trust/processor/return component; priorP2source/federal/currentness/provider andbroaderholdsretained.","pending_corrections":0},"markdown":"# S_MS PASS-03 — Mississippi consumer-money custody, escrow, processor, and return component\n\n**Fresh public-source access:** October 25, 2026, Pacific / October 26, 2026, UTC.\n**Relationship to prior work:** focused continuation of S_MS PASS-01 and PASS-02. Their supported findings, examples, IDs, and access limits remain preserved. This is **not an independent review** and does not reopen the provider-fee menu, federal overview, § 81-22-3(c)(xi) interpretation, or failed official HB 1265 routes.\n\n## Component conclusion\n\nMississippi’s debt-management statute imposes a short-cycle creditor-payment architecture on a covered provider that receives consumer money: deposit the money within two business days into a federally insured escrow account for the consumer’s benefit, keep consumer-level records, keep escrow separate from provider operating accounts, and remit the money to creditors within fifteen business days. It also requires correction of provider-caused misdirection and reimbursement of resulting actual creditor charges. That structure does **not** read like authority for a licensed provider or its processor to accumulate creditor-payment principal for months. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThe statute reaches more than literal possession. Debt-management service includes arranging payments and exercising or arranging direct or indirect control over consumer funds. Its processor definition reaches an entity that holds, has access to, can effectuate possession of, distributes, or participates in the chain of distribution of consumer money. A “consumer-owned,” “dedicated,” “escrow,” “FBO,” or “independent” account label therefore does not answer the Mississippi classification question; the actual access, instruction, transfer, withdrawal, affiliate, and contract rights must be examined. [LegiScan+1](https://legiscan.com/MS/text/HB1265/id/3401614)\n\nChapter 22 gives the consumer a written cancellation right, but the relevant clauses read for this pass do **not** state a general Mississippi deadline for returning remaining principal after cancellation, a failed plan, a rejected settlement, provider cessation, or account closure. The federal seven-business-day return rule applies only when the Telemarketing Sales Rule and all of its dedicated-account conditions apply. Mississippi’s separate Money Transmission Modernization Act may supply a conditional ten-day refund rule, but only if that separate statute covers the entity and transaction and none of its refund exclusions or exceptions applies. [MS Banking & Consumer Finance+3](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n# A. Substantive findings\n\n## 1. Account-model and control matrix\n\n| Account or flow model | Mississippi Chapter 22 result | Processor / money-transmission / federal overlay | Proof still required |\n| --- | --- | --- | --- |\n| **Provider directly receives periodic creditor-payment money** | Covered custody model. Deposit within two business days into the specified federally insured escrow structure; remit to creditors within fifteen business days; maintain separate consumer records; do not commingle escrow with operating accounts. **S_MS-P3-C003–C008** | Separate money-transmission analysis may also be material if the provider is receiving money for transmission and cannot establish an exemption. | Actual bank title, deposit agreement, funds-flow map, receipt date, good-funds convention, disbursement ledger, license, and consumer agreement. |\n| **Contracted processor holds, accesses, initiates, or distributes the money** | Potential statutory “third-party payment processor.” Section 81-22-28 imposes advance notice, contract disclosure, security, pre-use confirmation, examination authorization, and termination duties. **C013–C018** | Processor may independently be a licensed money transmitter, an authorized delegate, or within a narrow exemption; Chapter 22 processor compliance is not itself a money-transmission exemption. | Processor legal entity, exact contract, bank/ACH authority, account access, sponsor bank, DBCF confirmations, bond/deposit evidence, and money-transmitter status. |\n| **Consumer-owned dedicated account, but provider or affiliate can issue transfer instructions or cause payments** | Consumer ownership does not establish noncontrol. Direct or indirect control and processor-chain language remain material. Whether those rights amount to provider “receipt” or “holding” for § 81-22-3(c)(xi) was not authoritatively resolved. **C002, C011, C019** | If the TSR applies, customer ownership, independent administration, no referral compensation, and seven-business-day return are required. Those federal conditions do not decide Mississippi indirect control or the meaning of “regulated by the FTC.” | Account agreement, administrator ownership, all affiliates, API/portal permissions, ACH roles, debit authority, who can change payees, who can stop or redirect transfers, and compensation relationships. |\n| **Consumer controls an ordinary bank account; provider has no access, authority, instruction right, or place in the payment chain; consumer pays creditors directly** | Section 81-22-9 custody duties may not be triggered on those narrow facts, but arranging payments, negotiating, or settling can still be debt-management service. The for-profit exclusion still requires actual for-profit status plus every statutory condition. **C002, C019** | No processor or money-transmission conclusion can be drawn merely because funds move through a consumer bank. | Evidence that the provider and every affiliate truly lack access, control, payment initiation, custody, and indirect compensation tied to the account. |\n| **Entity solely supplies electronic routing and settlement; sponsoring bank performs the regulated settlement function** | Expressly excluded from Chapter 22’s definition of “third-party payment processor” only when its role is truly limited to electronic routing and settlement. That exclusion does not remove the debt-management provider’s own obligations. **C012** | A separate payment-system or financial-institution exemption may apply under Title 75-16, but only within its exact scope. | Technical service description, sponsor-bank agreement, settlement accounts, loss allocation, authority over transactions, and proof the entity does not exercise broader control. |\n| **Processor operates as authorized delegate of a Mississippi money-transmitter licensee** | Authorized-delegate status does not replace Chapter 22 duties if the same entity is also a Chapter 22 processor. | Written appointment and scope are required. Delegate-held money net of fees is held in trust for the **licensee**, not expressly for the consumer. No subdelegate is allowed. **C026–C028** | Principal license, delegate listing, written contract, remittance terms, posted disclosure, actual scope, and whether debt-management processing falls within the appointment. |\n| **Processor claims agent-of-payee exemption** | No automatic Chapter 22 effect. | Title 75-16’s exemption requires a written appointment by the payee, public holding-out by that payee, and treatment of the consumer’s payment as received so the obligation is extinguished and the consumer bears no loss if the agent fails to remit. **C025** | Creditor/payee-signed agreement, creditor public representations, debt-crediting rule, risk-of-loss provision, and transaction-level treatment. |\n| **Provider or processor accumulates creditor-payment principal for several months before a settlement or creditor payment** | For funds received for creditor payment, the fifteen-business-day remittance command is facially inconsistent with months-long accumulation. A consumer-owned account with no provider receipt but some indirect influence remains fact- and interpretation-dependent. **C006, C010, C019** | TSR-compliant accumulation is not Mississippi authorization. A federal dedicated account may be permissible federally while still presenting an unresolved state-control or exclusion issue. | Exact custody/control facts and a primary DBCF interpretation or controlling decision addressing dedicated settlement accounts. |\n\nThe 2026 carried-forward text preserves the broad direct/indirect-control definition, the complete § 81-22-9 custody duties, and the processor definition and architecture. DBCF’s official 2026 summary supports continuation of Chapter 22 after July 1, 2026, while the complete official signed/current-codification chain remains held as described in PASS-02. [LegiScan+2](https://legiscan.com/MS/text/HB1265/id/3401614)\n\n## 2. Chapter 22 custody, escrow, and ledger requirements\n\n### 2.1 Receipt and deposit\n\nFor money received from or on behalf of a consumer **for payment to creditors**, the provider must deposit all such money:\n\n- Within **two business days of receipt**.\n- Into a **federally insured escrow account**.\n- For the **benefit of the consumer**.\n- In a **supervised financial organization**. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n### 2.2 What the statute expressly protects\n\nThe escrow account is expressly:\n\n- Free from **trustee process**.\n- Unavailable to creditors of the **debt-management provider**. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThose words do **not**, without additional authority, establish:\n\n- Immunity from a consumer’s own judgment creditors.\n- Immunity from garnishment directed at the consumer.\n- Immunity from bank setoff.\n- Federal deposit-insurance pass-through to every consumer subledger.\n- Bankruptcy ownership or priority beyond the statutory wording.\n- Protection from processor creditors.\n- NCUA rather than FDIC eligibility.\n- A particular bank-account title.\n- Consumer ownership of interest.\n- A required Mississippi bank location.\n\n“Supervised financial organization” is not defined in the Chapter 22 definitions actually read. No published DBCF construction resolving the institution or insurance mechanics was located in this pass. **S_MS-P3-C009, C034.**\n\n### 2.3 Segregation and individual accounting\n\nThe provider must maintain a separate record of account for each consumer and cannot commingle consumer-benefit escrow accounts with the provider’s operating accounts. The text does not expressly require a different bank account number for every consumer; a pooled escrow with accurate consumer subledgers is not textually foreclosed, but that is a limited textual inference, not approval of any actual pooled structure. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nAt least quarterly, the provider must give the consumer a written report accounting for:\n\n- Funds received for obligations listed in the agreement.\n- Disbursements to each listed creditor since the preceding report. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThe provider must keep compliance books, accounts, and records separate from its other businesses and retain each consumer’s records for six years after the final transaction. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThe statute does not expressly prescribe, in the clauses read:\n\n- Daily reconciliation.\n- A daily positive-pay or zero-balance test.\n- A shortage-cure deadline.\n- Consumer online access.\n- Monthly rather than quarterly statements.\n- Pending-ACH treatment.\n- Check-clearing assumptions.\n- Reversal or chargeback allocation.\n- Interest allocation.\n- An express permission to deduct provider fees from creditor-payment principal.\n\nA fee deduction therefore requires an independently lawful fee, valid agreement authority, and actual earning/timing support. A ledger entry or available balance is not itself legal permission to withdraw the fee.\n\n### 2.4 Creditor remittance\n\nThe provider must remit money received from or for the consumer to creditors within **fifteen business days of receipt**. The wording is tied to receipt of funds, not creditor acceptance of a proposal or settlement success. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nFor direct custody, this prevents treating the account as an open-ended settlement reserve. If an amount is being held for many months, the operator must establish a different lawful characterization and account architecture rather than relying on the ordinary § 81-22-9 creditor-payment escrow provision.\n\nThe statute does not define:\n\n- Whether “receipt” means initiation, provisional credit, settled funds, or collected funds.\n- How rejected or reversed ACH entries affect the clock.\n- How weekends and financial-institution holidays are counted beyond “business days.”\n- Whether a consumer’s post-receipt written instruction to suspend payment changes the original deadline.\n\nThose questions remain held.\n\n### 2.5 Misdirected payments\n\nIf the provider causes a payment to be misdirected, it must:\n\n1. Correct or remedy the misdirection; and\n2. Reimburse the consumer for actual costs or fees imposed by a creditor because of that misdirection. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThis is not automatically a command to pay the consumer the misdirected principal as an additional cash refund. The provider must correct the principal movement and separately reimburse proven resulting creditor charges without double-paying the same amount.\n\n### 2.6 Fair-share credits\n\nWhere the provider receives creditor “fair share” contributions, its records must show that the consumer received credit for the **full amount of the payment due**, not the amount net of the creditor’s contribution. Verification may be through the creditor’s statement or a monthly or quarterly consumer statement. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n## 3. Chapter 22 processor architecture\n\n### 3.1 Functional processor definition\n\nA statutory third-party payment processor is an entity that, under contract with the licensee:\n\n- Holds consumer money.\n- Has access to it.\n- Can effectuate possession of it by any means.\n- Distributes it.\n- Is in the chain of distribution to creditors. [LegiScan](https://legiscan.com/MS/text/HB1265/id/3401614)\n\nEntities that **solely** provide electronic routing and settlement, and their sponsoring banks, are excluded from that definition. “Solely” matters: account administration, transfer discretion, payee control, custody, fee withdrawal, or funds-release authority may move an entity beyond that narrow description.\n\n### 3.2 Ten-day notice and disclosed information\n\nBefore using a processor, § 81-22-28 requires ten days’ written notice to DBCF. The notice must include:\n\n- Processor name and address.\n- Description of services.\n- Contract or agreement.\n- Highest daily amount of consumer funds to be held or transmitted.\n\nOn request, the processor must provide the prior month’s highest daily amount held or transmitted. [LegiScan](https://legiscan.com/MS/text/HB1265/id/3401614)\n\nThe literal subsection says money of “**another licensee’s consumers**.” The same unusual wording appears in the 2026 carried-forward reproduction. No published interpretation was located explaining whether that wording limits the subsection, refers to consumers assigned among licensees, or reflects drafting language. It should be preserved rather than silently rewritten as “the licensee’s consumers.”\n\n### 3.3 Security and pre-use confirmations\n\nThe processor must ordinarily file:\n\n- A $50,000 surety bond for the first licensee.\n- An additional $50,000 for each additional licensee.\n- A maximum required processor bond of $150,000.\n\nCash, a certificate of deposit, or government bonds may be filed instead. A licensee may not use the processor until it receives DBCF’s written confirmation that the department has received the processor’s bond or substitute assets. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nBefore services begin, the processor must also:\n\n- Authorize DBCF in writing to examine money-related books, records, documents, and electronic material.\n- Receive DBCF’s written confirmation that the authorization is sufficient.\n\nThe licensee pays the examination cost. If the licensee itself elected the statutory cash, CD, or government-bond alternative, subsection (7) removes the processor’s separate bond/deposit requirement. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThis pass traces those amounts only to explain the custody architecture. Beneficiaries, bond-claim procedure, aggregate recovery, cancellation, priority, and consumer claim rights remain for the full bond pass.\n\n### 3.4 Contract termination\n\nEvery processor contract must require thirty days’ written termination notice to the party being terminated. The licensee must immediately notify DBCF in writing when termination notice is given. [LegiScan](https://legiscan.com/MS/text/HB1265/id/3401614)\n\nSection 81-22-28 does not itself state:\n\n- A consumer-notice deadline.\n- A migration protocol.\n- A deadline to return processor-held principal.\n- A successor-processor procedure.\n- A bank-account closure process.\n- A continuing reconciliation or statement schedule after notice.\n- A processor insolvency waterfall.\n\nThose matters require the contract, bank agreement, other statutes, and later remedies/bond work.\n\n### 3.5 Provider responsibility is not displaced\n\nSection 81-22-9 places the deposit, remittance, accounting, commingling, and misdirection duties on the **debt-management provider**. Section 81-22-28 regulates use of a processor but does not expressly transfer or eliminate those provider duties. Whether the provider is contractually or legally responsible for every processor-caused loss, reversal, cyber event, or unauthorized transfer remains a later agency, contract, and remedies issue; the provider cannot establish compliance merely by pointing to the processor. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nDBCF’s current application page reinforces the operational importance of that relationship by requiring the applicant to submit third-party servicing/outsourcing contracts and a narrative explaining how client payments will be processed. Those application materials support procedure, not approval of a specific structure. [MS Banking & Consumer Finance](https://dbcf.ms.gov/consumer-finance/)\n\n## 4. Cancellation, termination, failed plans, cessation, and returns\n\n### 4.1 Consumer cancellation\n\nThe agreement must state that either party may cancel by written notice. It must also identify the federally insured institution, list covered obligations and creditors, state the scheduled consumer remittances and creditor payments, and authorize disclosure of escrow records to DBCF during an examination. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThe cancellation clause does not specify:\n\n- When cancellation becomes effective.\n- Whether notice is effective on sending or receipt.\n- Whether scheduled payments already transmitted can be recalled.\n- Whether pending creditor payments should be completed or returned.\n- A general deadline for returning remaining principal.\n- A statutory fee-proration or refund formula.\n- A required form of return.\n- A required recipient when a creditor payment is already committed.\n\nTherefore, cancellation of the service, revocation of ACH authorization, closure of a bank account, and return of held money are distinct legal and operational events.\n\n### 4.2 Rejected proposal or failed plan\n\nChapter 22 does not supply a special “settlement rejected” or “plan failed” exception to the fifteen-business-day remittance rule. For money already received as creditor-payment principal, ordinary remittance duties remain facially applicable unless the consumer’s authorization is lawfully changed, the money is returned under another applicable rule, or another primary authority changes the result. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nThe absence of an express Chapter 22 return deadline is **not** a universal no-return rule. It means the answer may depend on:\n\n- Account ownership and custody.\n- Consumer instructions.\n- Pending or completed payment commitments.\n- Contract terms.\n- The money-transmission statute.\n- The federal dedicated-account rule.\n- General contract, restitution, consumer-protection, insolvency, and remedies law reserved for later passes.\n\n### 4.3 Provider insolvency or regulatory cessation\n\nA Chapter 22 licensee must report a bankruptcy or reorganization filing to DBCF within fifteen days, and insolvency is a statutory ground for suspension or revocation. The clauses read do not provide a complete consumer-funds wind-down, transfer, or distribution procedure. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\nNo Chapter 22 clause read establishes:\n\n- A one-day or seven-day consumer notice.\n- Automatic account freezing.\n- Appointment of a successor servicer.\n- A consumer-principal distribution waterfall.\n- Priority over a processor’s creditors.\n- Treatment of pending electronic items.\n- Return of unearned fees.\n- A bond draw on insolvency.\n\nThose remain open.\n\n### 4.4 Federal dedicated-account return\n\nOnly when the TSR applies and the account satisfies every condition in § 310.4(a)(5)(ii):\n\n- It is at an insured financial institution.\n- The customer owns the funds and any accrued interest.\n- The administrator is not owned, controlled by, or affiliated with the debt-relief service.\n- No referral compensation is exchanged.\n- The customer may withdraw from the debt-relief service at any time without penalty.\n\nThe customer must then receive all account money other than fees actually earned in compliance with every element of § 310.4(a)(5)(i)(A)–(C), within seven business days after the request. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThis does not:\n\n- Establish that every Mississippi debt service is telemarketing.\n- Establish that § 81-22-3(c)(xi) is satisfied.\n- Resolve whether the provider receives, holds, or indirectly controls Mississippi funds.\n- Permit subtraction of a contracted but unearned fee.\n- Authorize switching between the proportional and savings methods.\n- Mean the bank account itself must be closed.\n- Automatically revoke ACH instructions or stop an already completed creditor payment.\n\n## 5. Separate Mississippi money-transmission gateway\n\n## 5.1 Why the gateway matters\n\nMississippi’s Money Transmission Modernization Act defines money transmission to include receiving money or monetary value for transmission from a person located in Mississippi. A person may not conduct, advertise, solicit, or hold itself out as conducting money transmission unless licensed, acting within a written authorized-delegate appointment, or within a statutory exemption. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nA Chapter 22 processor notice, bond, or DBCF confirmation is not listed as a Title 75-16 exemption. A processor can therefore require two separate analyses:\n\n1. Chapter 22 processor architecture; and\n2. Title 75-16 license, authorized-delegate, or exemption status.\n\nA debt-management provider exclusion also does not automatically pass through to its account administrator, processor, affiliate, or ACH operator.\n\n### 5.2 Material exemptions\n\nThe potentially relevant exemptions are narrow:\n\n| Exemption | Required predicates | Why a label is insufficient |\n| --- | --- | --- |\n| **Payment-system operator** | Processing, clearing, or settlement between exempt persons or licensees in connection with specified payment rails. | A platform doing custody, account administration, consumer contracting, or transfer discretion may exceed mere system operation. |\n| **Agent of payee** | Written payee appointment; payee publicly holds the agent out; payment is treated as received and extinguishes the payer’s obligation; payer bears no loss if the agent fails to remit. | Calling a processor “agent” or listing a creditor as payee does not prove these terms. |\n| **Intermediary** | The entity with the underlying obligation is licensed or exempt, the sender’s confirmation identifies it as the transmission provider, and it bears sole responsibility to make the sender whole. | A downstream processor cannot simply borrow the upstream entity’s status. |\n| **Federally insured depository institution** | The legal entity itself must fall within the institutional exemption. | A bank relationship does not exempt an unaffiliated program manager or processor. |\n| **Third-party service provider or agent of an exempt institution** | Written contract specifying functions and the exempt institution assumes all risk of loss and legal responsibility upon the service provider’s receipt. | Sponsorship alone is insufficient. |\n| **Commissioner exemption** | Actual regulation or order and the precise facts covered by it. | No such order was located for debt-management processors in this pass. |\n\n### 5.3 Authorized-delegate architecture\n\nUnder the current-readable 2026 amendment text, a money-transmitter licensee must have policies, perform a risk-based background review, and execute a written delegate contract. The contract must:\n\n- Appoint the delegate to transmit on the licensee’s behalf.\n- Define the relationship, rights, and duties.\n- Require legal compliance.\n- Govern remittance and handling.\n- Impose a trust, net of fees, for the benefit of the licensee.\n- Require records.\n- Consent to examination.\n- Recognize DBCF’s authority over the designation. [LegiScan](https://legiscan.com/MS/text/HB1596/id/3411125)\n\nThe delegate:\n\n- Holds money net of fees in trust for the **licensee**.\n- Is subject to a statutory trust amount even if it commingles the money with its own property.\n- Cannot use a subdelegate.\n- Must immediately stop acting as delegate when the principal license is suspended, revoked, surrendered, or expires.\n- Must be notified by the licensee, with documentation to DBCF, within five business days of such a license event. [LegiScan+1](https://legiscan.com/MS/text/HB1596/id/3411125)\n\nThat trust is not the same as Chapter 22’s consumer-benefit escrow and does not establish consumer ownership, federal deposit insurance, or a direct consumer claim.\n\n### 5.4 Records and reconciliation\n\nA money-transmitter licensee must retain for at least five years:\n\n- Each money-transmission obligation.\n- A monthly-posted general ledger.\n- Bank statements and bank-reconciliation records.\n- Records of outstanding obligations.\n- Records of obligations paid.\n- Its authorized-delegate list.\n\nOut-of-state records must be made accessible to the commissioner on seven business days’ written notice, and the records are open to inspection. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nThose duties are more specific about general ledgers and bank reconciliation than Chapter 22’s consumer-funds provisions. They apply only if the money-transmission statute covers the entity.\n\n### 5.5 Timely transmission and refunds\n\nA covered money-transmitter licensee must forward money according to the sender agreement unless it reasonably suspects fraud, crime, or another legal violation. If it does not forward the money, it must generally answer the sender’s inquiry unless legally prohibited. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nThe refund provision generally requires refund to the sender within ten days after a sufficient written request, unless:\n\n- The transaction is subject to the federal Remittance Rule.\n- The money was received under a written licensee-payee agreement to process payment for goods or services.\n- The money has been forwarded within ten days after receipt.\n- Instructions have committed an equivalent amount within that period.\n- The agreement specifies later transmission and the later time has not arrived.\n- There is a reasonable crime or legal-violation basis.\n- The request does not identify the sender or transaction sufficiently. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nWhether payment of an existing debt under a creditor-processing agreement falls within the “goods or services” exclusion was not resolved. The wording must not be assumed to include or exclude every debt payment.\n\n### 5.6 Receipts and current delegate disclosures\n\nFor covered personal, family, or household money transmission outside the specified exceptions, the licensee or delegate must give a retainable receipt with sender, recipient, date, transaction ID, licensee/NMLS/contact information, amount, fees, and taxes. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nEffective July 1, 2026, an authorized delegate must prominently identify itself and each principal licensee, state that it acts as agent for the licensee, provide complaint information, and display the prescribed fraud warning. DBCF published both a June 12, 2026 implementation memorandum and Form 001. [MS Banking & Consumer Finance+3](https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf)\n\n### 5.7 Money-transmitter permissible investments and statutory trust\n\nA money-transmitter licensee must maintain permissible investments with market value at least equal to all outstanding money-transmission obligations. In specified insolvency, bankruptcy, receivership, dissolution, reorganization, or nonbeneficiary-creditor events, those investments are held in statutory trust for purchasers and holders of outstanding obligations, protected from nonbeneficiary attachment, and administered pro rata and equitably across applicable states. [MS Banking & Consumer Finance+2](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\nThis is not:\n\n- An ordinary-times consumer-owned bank account.\n- A guarantee that every obligation is paid in full.\n- Proof of deposit insurance.\n- A Chapter 22 escrow substitute.\n- A determination of claims, administration costs, multistate allocation, or priority among competing legal rights.\n\n## 6. Reconciliation of the state and federal account rules\n\n| Question | Chapter 22 | Conditional federal TSR account rule | Result |\n| --- | --- | --- | --- |\n| Who owns the money? | Account is for the consumer’s benefit; the statute does not expressly state complete legal title or interest ownership. | Customer owns the funds and any interest. | Federal ownership does not resolve Mississippi receipt, holding, or indirect control. |\n| Who may administer it? | Provider may use a qualifying Chapter 22 processor after the statutory notice/security/examination steps. | Administrator must be independent, unaffiliated, and free of referral compensation. | A processor can satisfy one regime and fail the other. |\n| How quickly is principal moved? | Creditor-payment funds must be deposited within two business days and remitted within fifteen business days. | The rule permits deposits in a qualifying dedicated account, but governs fee timing and withdrawal rather than creating a Mississippi long-hold authorization. | Months-long accumulation in a direct Chapter 22 escrow is not established as lawful. |\n| What happens on withdrawal? | Written cancellation right; no general principal-return deadline found in the reviewed clauses. | Remaining funds, less only lawfully earned fees, within seven business days. | Seven days applies only if federal coverage and every account predicate are established. |\n| Does federal compliance establish § 81-22-3(c)(xi)? | No. The state exclusion independently requires for-profit status, no receipt or holding, delayed fee receipt, and FTC regulation. | Federal compliance may be relevant evidence but is not the state test. | “TSR-compliant account” is not a Mississippi exclusion or license. |\n| Can the provider deduct a fee? | Only a separately lawful state fee with contractual and earning support; Chapter 22’s funds provision does not itself authorize deductions from principal. | Only fees earned under the complete debt-level trigger and allocation conditions. | Contracted amount, arithmetic equality, and account availability are not earning permission. |\n\n# B. Bounded ledger examples\n\nUnless stated otherwise, each example assumes no interest, pending checks, pending ACH transfers, reversals, chargebacks, returned items, bank holds, or unrecorded transactions. Calculations use dollars and cents. They demonstrate ledger consequences, not provider approval or complete legal liability.\n\n## Ledger 1 — direct provider custody and the fifteen-business-day clock\n\n**Inputs**\n\nPlain text\n```\nConsumer creditor-payment money received:       $1,000.00\nCompleted lawful creditor remittance:               700.00\nProvider fee withdrawn from this principal:           0.00\nPending/reversed items assumed:                        0.00\n```\n\n**Current held principal**\n\nPlain text\n```\n$1,000.00 - $700.00 = $300.00\n```\n\n**Result**\n\n- The original $1,000 must be placed in the qualifying escrow within two business days.\n- The remaining $300 is still consumer creditor-payment principal.\n- In the ordinary custody model, the remaining $300 must be remitted within the original fifteen-business-day receipt period.\n- Cancellation before that deadline changes the required factual analysis, but Chapter 22 does not itself supply a general return deadline or recipient rule.\n- If, separately, this is a qualifying TSR dedicated account and the consumer withdraws with no earned fee, the conditional federal return amount is $300 within seven business days. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n## Ledger 2 — current balance already reflects prior lawful earnings\n\n**Inputs**\n\nPlain text\n```\nConfirmed current held balance:                    $495.00\nPrior creditor remittances:        already reflected in $495\nPrior fee assumed lawfully earned\nand already deducted:                              $180.00\nAdditional unpaid earned fee:                        $0.00\nPending/reversed items:                              $0.00\n```\n\n**Return candidate**\n\nPlain text\n```\n$495.00 - $0.00 = $495.00\n```\n\n**Result**\n\nThe return candidate is **$495**, not $315 and not $420. Deducting the prior $180 again would double-subtract it. Substituting the $75 setup ceiling for the assumed prior fee would improperly reopen the prior transaction and create a fictional $420 result. The state return timing remains held; the conditional TSR deadline would be seven business days if all federal account predicates apply.\n\n## Ledger 3 — provider-caused misdirection\n\n**Inputs**\n\nPlain text\n```\nConsumer money received:                           $800.00\nSent to intended creditor:                          300.00\nSent by provider error to wrong creditor:            500.00\nCurrent cash still held:                               0.00\nActual late fee imposed by intended creditor:         35.00\n```\n\n**Ledger**\n\nPlain text\n```\nPrincipal requiring correction/remedy:              $500.00\nSeparate actual creditor-fee reimbursement:           35.00\n```\n\n**Result**\n\nThe provider must correct or remedy the $500 misdirection and reimburse the $35 actual creditor charge. The statute does not automatically require a $535 cash payment to the consumer in addition to correcting the $500 transfer. The correction path must avoid double payment. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n## Ledger 4 — pooled escrow and consumer subledgers\n\n**Book balance**\n\nPlain text\n```\nConsumer A subledger:                             $1,200.00\nConsumer B subledger:                              3,300.00\nAll other consumer subledgers:                     5,500.00\n                                                   --------\nTotal consumer subledgers:                       $10,000.00\nBank escrow balance:                              10,000.00\nDifference:                                           $0.00\n```\n\nThis is numerically reconciled. It does not by itself establish deposit insurance, legal title, valid pending-item treatment, correct creditor allocations, or overall compliance.\n\n**Shortage variant**\n\nPlain text\n```\nTotal consumer subledgers:                       $10,000.00\nActual bank balance:                               9,850.00\n                                                   --------\nUnexplained shortage:                               $150.00\n```\n\nThe reviewed Chapter 22 provisions require separate consumer records and no operating-account commingling but do not specify a shortage-cure deadline. The $150 discrepancy therefore requires immediate factual reconciliation, while the exact statutory remedy remains outside this component. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n## Ledger 5 — consumer-owned dedicated account with provider instructions\n\n**Inputs**\n\nPlain text\n```\nConsumer deposits:                               $1,500.00\nCompleted creditor transfer:                        900.00\nCurrent account balance:                             600.00\nLawfully earned but unpaid fee:                        0.00\n```\n\n**Classification**\n\nIf the provider or affiliate can instruct the administrator to transfer the $900, select payees, release money, redirect a transfer, or trigger a fee debit, the consumer-owned label does not eliminate possible indirect control or processor-chain status.\n\n**Conditional federal withdrawal**\n\nPlain text\n```\n$600.00 - $0.00 = $600.00\n```\n\nIf all TSR account conditions and federal coverage apply, the consumer receives $600 within seven business days after withdrawing from the service. Mississippi’s separate control, receipt, holding, and exclusion questions remain unresolved. [LegiScan+2](https://legiscan.com/MS/text/HB1265/id/3401614)\n\n## Ledger 6 — conditional money-transmitter refund\n\n**Assumptions**\n\n- Entity is a covered licensed money transmitter.\n- Transaction is not within the federal Remittance Rule.\n- No written licensee-payee goods/services processing exclusion applies.\n- Sender submits a sufficient written request.\n- No money has been forwarded.\n- No equivalent amount has been committed.\n- No later-forwarding agreement or crime exception applies.\n\nPlain text\n```\nMoney received for transmission:                    $900.00\nForwarded or committed:                                0.00\nRefund due under assumptions:                       $900.00\n```\n\n**Result:** $900 within ten days after receipt of the written request. If the money was forwarded or equivalently committed within the statutory period, or an exclusion applies, that result changes. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\n## Ledger 7 — fair-share contribution\n\nPlain text\n```\nConsumer payment due to creditor:                   $400.00\nAmount remitted and credited to consumer:            400.00\nSeparate voluntary creditor contribution\npaid to provider:                                     20.00\nCorrect consumer credit:                             400.00\nIncorrect net consumer credit:                       380.00\n```\n\nThe consumer must receive the full $400 account credit. The separate $20 creditor contribution cannot reduce the consumer’s credited payment. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf)\n\n## Ledger 8 — money-transmitter permissible-investment shortfall\n\n**Inputs**\n\nPlain text\n```\nAggregate outstanding obligations:              $100,000.00\nMarket value of permissible investments:          95,000.00\n                                                  ----------\nStatutory coverage shortfall:                       5,000.00\n```\n\nAssume, solely for arithmetic, a triggering insolvency event and one qualifying holder with a $1,000 obligation:\n\nPlain text\n```\nHolder share = $1,000 ÷ $100,000 = 1%\nIllustrative gross pro-rata share = 1% × $95,000\n                                 = $950.00\n```\n\nThe statute requires investments at least equal to outstanding obligations, so the $5,000 shortfall fails the numeric requirement. The $950 figure is only a simplified gross pro-rata illustration; actual claim allowance, asset valuation, letters of credit, multistate allocation, administration expenses, recoveries, and priority remain unresolved. [MS Banking & Consumer Finance+1](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf)\n\n# C. PASS-03 source register\n\n| Source ID | Title, issuer, and direct literal URL | Exact passage/version/effective status | Actual access and limitations |\n| --- | --- | --- | --- |\n| **S_MS-P3-S001** | *Legislative Updates: 2026 Regular Session*, Mississippi Department of Banking and Consumer Finance. https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf | Three-page PDF. PDF page 1/index 0, lines 9–11: HB 1265 removes the July 1, 2026 repeal date and is effective July 1, 2026. Lines 12–31 summarize HB 1596 and its July 1, 2026 effectiveness. | **Freshly read; previously read in P2.** Official agency enactment summary, not full enacted wording or current-code audit. Metadata wording referring to 2019 does not match the visible 2026 body. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf) |\n| **S_MS-P3-S002** | HB 1265 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1265/id/3401614 | Reproduced document identifies itself as Mississippi Legislature, 2026 Regular Session, HB 1265, “As Sent to Governor.” Lines 60–99: § 81-22-3; lines 106–115: § 81-22-9; lines 116–133: § 81-22-11; lines 146–155: § 81-22-15; lines 211–218: § 81-22-28; line 220: July 1, 2026 effective clause. | **Freshly read in P3.** Nonofficial host. Host “Enrolled/Passed” labels were not used as status authority. Used to compare complete carried-forward wording with S003. [LegiScan+2](https://legiscan.com/MS/text/HB1265/id/3401614) |\n| **S_MS-P3-S003** | *Mississippi Debt Management Services Act*, DBCF-hosted compilation. https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf | Thirteen PDF pages. § 81-22-9 on printed pages 5–6/PDF indices 4–5; § 81-22-11 on printed pages 6–7/indices 5–6; § 81-22-15 on printed page 8/index 7; § 81-22-25 on printed page 11/index 10; § 81-22-28 on printed pages 12–13/indices 11–12. | **Relevant complete clauses freshly read and page images inspected.** Agency-hosted primary-text compilation but historically stale: histories run through 2019 and headings carry an obsolete 2022 repeal date. Used with S001/S002, not alone for 2026 effectiveness. [MS Banking & Consumer Finance+4](https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf) |\n| **S_MS-P3-S004** | DBCF Consumer Finance page. https://dbcf.ms.gov/consumer-finance/ | Debt-management body at lines 113–136. Requires NMLS filing, security, agreement, fee schedule, third-party servicing/outsourcing contracts, and payment-processing narrative. Page also links current money-transmission materials. | **Freshly read.** Current public procedure only. Actual NMLS checklist, applicant materials, processor confirmation, and provider record were not read. [MS Banking & Consumer Finance](https://dbcf.ms.gov/consumer-finance/) |\n| **S_MS-P3-S005** | Mississippi Administrative Code, Title 5, Part 4, Organizational Rules, Mississippi Secretary of State. https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf | Twenty PDF pages. Rule 1.3(6) and 1.3(7)(a)–(d), printed pages 5–6/PDF indices 4–5, parsed lines 161–198. | **Freshly reread; page images inspected.** Confirms examination/investigation powers and government examination costs. It adds no detailed debt-management custody rule. No exhaustive rulemaking/adoption/current-version audit. [Mississippi Secretary of State](https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf) |\n| **S_MS-P3-S006** | Mississippi HB 1428 SG, *Money Transmission Modernization Act*, official DBCF-hosted legislative PDF. https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf | Seventy-five PDF pages. Definitions on printed pages 5–10; exemptions pp. 10–14; license p. 20; records pp. 45–46; delegate relationship pp. 46–49; refunds pp. 49–51; receipts pp. 51–52; permissible investments/trust pp. 55–56; transition pp. 74–75; effective July 1, 2025. | **Freshly read in all materially relied-on sections; relevant page images inspected.** DBCF-hosted “As Sent to Governor” text with official page markings. DBCF’s current page identifies the act as effective July 1, 2025. Licensee-specific transition timing can depend on renewal and was not resolved for a named entity. [MS Banking & Consumer Finance+3](https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf) |\n| **S_MS-P3-S007** | Mississippi HB 1596 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1596/id/3411125 | Reproduced “As Sent to Governor” text. Lines 337–372 amend § 75-16-51; lines 373–379 carry forward § 75-16-65; lines 381–407 create § 75-16-89 and set July 1, 2026 effectiveness. | **Freshly read.** Nonofficial host; editorial enactment labels not treated as primary status proof. Currentness supported separately by S001, S008, and S009. [LegiScan+1](https://legiscan.com/MS/text/HB1596/id/3411125) |\n| **S_MS-P3-S008** | *Memo to Industry — HB1596 Authorized Delegate Disclosure Requirements*, DBCF, June 12, 2026. https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf | One-page PDF. Lines 9–28 explain § 75-16-89 delegate disclosures, website treatment, fraud warning, and July 1, 2026 effective date. | **Freshly read; page image inspected.** Official operational implementation memo. It does not interpret debt-management custody or Title 75-16 exemptions. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf) |\n| **S_MS-P3-S009** | DBCF MTMA Form 001, *Authorized Delegate Disclosures*. https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf | One-page form, effective July 1, 2026. Identifies delegate, principal licensed money transmitter, agency status, and complaint information. | **Freshly read; page image inspected.** Demonstrates prescribed public disclosure, not proof that any particular processor is an authorized delegate. [MS Banking & Consumer Finance](https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf) |\n| **S_MS-P3-S010** | 16 C.F.R. § 310.4, Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | § 310.4(a)(5)(i)(A)–(C), lines 115–122; dedicated-account requirements at § 310.4(a)(5)(ii)(A)–(E), lines 123–131. eCFR displayed Title 16 current through October 22, 2026. | **Freshly read in P2 and relied upon here as the preserved conditional overlay.** Authoritative but unofficial eCFR. No universal TSR coverage inferred. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n# D. PASS-03 claim register\n\n## D.1 Chapter 22 custody and processor claims\n\n| Claim ID | Precise assertion | Source IDs and exact pinpoints | Predicates, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_MS-P3-C001** | Chapter 22’s continuation beyond July 1, 2026 remains strongly supported, and the 2026 carried-forward text reproduces the relevant custody, reporting, and processor clauses without an observed operative change from the DBCF compilation. | S001, page 1/index 0, lines 9–11; S002 §§ 5, 6, 9, and 16; S003 corresponding sections. | **High for continuation and comparison performed; medium-high for complete current official codification.** Signed/current official chain remains held. |\n| **C002** | Debt-management service reaches receiving money, arranging payments, and exercising or arranging direct or indirect control over consumer funds. | S002, § 81-22-3(b)(i)–(iii), lines 65–70. | **High as text.** Application depends on actual rights, not account labels. |\n| **C003** | All consumer money received for creditor payment must be deposited within two business days into a federally insured escrow account for the consumer’s benefit in a supervised financial organization. | S003, § 81-22-9(1), printed page 5/PDF index 4, lines 146–152; S002 corresponding § 81-22-9. | **High as text.** “Receipt,” “supervised financial organization,” and insurance mechanics remain undefined or unresolved. |\n| **C004** | The escrow account is free from trustee process and unavailable to provider creditors. | S003, § 81-22-9(1), lines 149–152. | **High, narrowly stated.** No broader garnishment, setoff, bankruptcy, processor-creditor, or pass-through-insurance protection inferred. |\n| **C005** | The provider must keep a separate account record for each consumer and cannot commingle consumer-benefit escrow with provider operating accounts. | S003, § 81-22-9(2)(a), (3), lines 153–162. | **High.** Separate subledgers do not necessarily mean separate bank accounts. |\n| **C006** | Creditor-payment money must be remitted to creditors within fifteen business days after receipt. | S003, § 81-22-9(2)(b), lines 153–157. | **High for direct covered funds.** Effect of reversals, changed instructions, and independent dedicated accounts remains unresolved. |\n| **C007** | Provider-caused misdirection must be corrected or remedied, and the consumer must be reimbursed for actual resulting creditor costs or fees. | S003, § 81-22-9(2)(c), lines 158–160. | **High.** Exact correction method and downstream recovery are fact-dependent. |\n| **C008** | The consumer agreement must identify the institution, contain written-cancellation rights, list obligations and creditors, state payment schedules, and permit DBCF examination access to escrow records. | S003, § 81-22-11(2)(d)–(h), printed pages 6–7/PDF indices 5–6, lines 183–195. | **High.** Agreement-form completeness remains a later pass. |\n| **C009** | Chapter 22 requires at least quarterly consumer receipt/disbursement reports, separate compliance records, and six-year consumer record retention. | S003, § 81-22-15(1)–(2), printed page 8/PDF index 7, lines 225–240. | **High.** No explicit daily reconciliation or online-access rule found. |\n| **C010** | Direct or provider-controlled accumulation of creditor-payment principal for months is not supported by the fifteen-business-day remittance text. | C003 and C006; S003 § 81-22-9. | **High textual conclusion for direct custody; partial for consumer-owned indirect-control accounts.** |\n| **C011** | A processor is functionally defined by holding, access, ability to effect possession, distribution, or participation in the distribution chain under contract. | S002, § 81-22-3(i), lines 98–99. | **High.** Actual system permissions and contracts control. |\n| **C012** | An entity solely providing electronic routing and settlement, and its sponsoring bank, is excluded from the Chapter 22 processor definition. | S002, § 81-22-3(i), line 99. | **High, narrow exclusion.** It is not a provider or money-transmission exemption. |\n| **C013** | Section 81-22-28 requires ten days’ notice and disclosure of processor identity, services, contract, and highest daily consumer-fund amount. | S002, § 81-22-28(1)–(2), lines 211–213; S003 printed page 12/PDF index 11. | **High as text.** “Another licensee’s consumers” remains an unresolved literal wording issue. |\n| **C014** | The processor ordinarily needs the specified $50,000/$50,000-per-additional-licensee security, capped at $150,000, and the provider cannot use it before DBCF’s written security confirmation. | S002, § 81-22-28(3)–(4), lines 214–215. | **High as architecture.** Full bond claims and beneficiaries excluded. |\n| **C015** | Before services, the processor must authorize DBCF examination of money-related records and receive confirmation that the authorization is sufficient; the licensee pays the examination cost. | S002, § 81-22-28(5), line 216. | **High.** No actual processor authorization was obtained. |\n| **C016** | Processor contracts must provide thirty days’ termination notice, and the licensee must immediately notify DBCF of that notice. | S002, § 81-22-28(6), line 217. | **High.** No consumer-return or migration deadline is supplied. |\n| **C017** | A processor’s separate bond/deposit is excused if the licensee elected the specified cash, CD, or government-bond deposit alternative. | S002, § 81-22-28(7), line 218. | **High as text.** Actual deposit election remains unverified. |\n| **C018** | Use of a processor does not expressly transfer or extinguish the provider’s § 81-22-9 duties. | Comparison of S003 § 81-22-9 and S002 § 81-22-28. | **Medium-high textual inference.** Complete agency/contract liability remains open. |\n| **C019** | A consumer-owned or federally compliant account label does not itself resolve Mississippi receipt, holding, direct/indirect control, processor status, or § 81-22-3(c)(xi). | S002 § 81-22-3(b), (c)(xi), and (i); S010 § 310.4(a)(5)(ii). | **High as boundary statement.** Exact state interpretation remains unresolved. |\n| **C020** | Chapter 22 requires a written cancellation right but the reviewed custody, agreement, records, and processor clauses contain no general cancellation-principal return deadline. | S003 §§ 81-22-9, -11, -15, -28. | **Medium-high bounded negative finding.** Other Mississippi law remains open. |\n| **C021** | Bankruptcy/reorganization must be reported within fifteen days and insolvency is a license-revocation ground, but the reviewed clauses do not create a complete consumer-funds wind-down process. | S003 § 81-22-15(4), lines 246–253; § 81-22-25(2)(c), lines 351–364. | Reporting/ground **high**; wind-down absence **medium-high bounded finding**. |\n| **C022** | Fair-share participants must credit the consumer for the full creditor payment, not the net amount after the creditor contribution. | S003 § 81-22-15(3), lines 241–245. | **High.** |\n| **C023** | Chapter 22 does not expressly state account title, interest ownership, FDIC/NCUA pass-through mechanics, consumer-creditor garnishment immunity, bank setoff treatment, or separate-account-per-consumer requirements. | S002/S003 §§ 81-22-3, -9, -11, -15, -28. | **Medium-high bounded negative finding.** Banking, bankruptcy, UCC, and garnishment law not audited. |\n| **C024** | DBCF’s public application instructions require third-party servicing contracts and a payment-processing narrative. | S004, lines 125–136. | **High as current public procedure.** Not legal approval or an actual provider record. |\n| **C025** | Rule 1.3(7) permits DBCF examination of licensees and suspected nonlicensees; its $300–$600 and outside-record amounts are government examination costs, not consumer-money deductions. | S005, printed pages 5–6/PDF indices 4–5, lines 171–198. | **High for passage read.** No exhaustive administrative-rule audit. |\n\n## D.2 Money-transmission and federal-overlay claims\n\n| Claim ID | Precise assertion | Source IDs and exact pinpoints | Predicates, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_MS-P3-C026** | Title 75-16 reaches receiving money or monetary value for transmission from a Mississippi person, and requires a license absent authorized-delegate or exemption status. | S006, definitions on printed pages 6–7/PDF indices 5–6, lines 161–167; license, printed page 20/index 19, lines 529–539. | **High as text.** Actual entity and transaction classification remain fact-dependent. |\n| **C027** | Chapter 22 processor compliance is not an express Title 75-16 exemption. | Comparison of S002 § 81-22-28 and S006 Sections 4 and 11. | **High textual conclusion.** |\n| **C028** | Agent-of-payee status requires written payee appointment, payee public holding-out, extinguishment of the payer’s obligation, and no payer risk of loss. | S006, Section 4(b), printed pages 10–11/PDF indices 9–10, lines 272–288. | **High.** No actual creditor agreement was reviewed. |\n| **C029** | Other potentially relevant exemptions—payment system, intermediary, depository institution, and service provider to an exempt institution—are condition-specific and do not arise merely from a bank or processor label. | S006, Section 4(a), (c), (g), and (m), printed pages 10–14/PDF indices 9–13. | **High.** |\n| **C030** | A current authorized-delegate contract must appoint the delegate, define rights and duties, govern handling/remittance, impose a trust for the licensee, require records, and consent to examination. | S007, § 75-16-51(2)–(4), lines 337–362. | **High as reproduced text with official agency effectiveness support.** |\n| **C031** | Delegate-held money net of fees is held in trust for the licensee; commingled property is impressed to that amount; no subdelegate may be used. | S007, § 75-16-51(6)–(7), lines 363–365. | **High.** This is not consumer ownership. |\n| **C032** | After suspension, revocation, surrender, or expiration, delegates must stop immediately and the licensee must document delegate notice to DBCF within five business days. | S007, § 75-16-51(5), line 363. | **High.** No complete consumer-funds wind-down rule follows from this clause. |\n| **C033** | Money-transmitter records include a monthly general ledger, bank statements/reconciliations, outstanding/paid obligations, and delegate records, retained for five years. | S006, Section 25, printed pages 45–46/PDF indices 44–45, lines 1187–1213. | **High.** |\n| **C034** | Covered money must be forwarded under the sender agreement unless a stated fraud/legal concern applies; the refund rule generally requires refund within ten days after sufficient written request, subject to exclusions and exceptions. | S006, Sections 28–29, printed pages 49–51/PDF indices 48–50, lines 1298–1347. | **High as conditional rule.** Debt-payment goods/services exclusion unresolved. |\n| **C035** | The receipt rule applies conditionally to covered personal/family/household transactions and requires specified transaction and licensee information. | S006, Section 30, printed pages 51–52/PDF indices 50–51, lines 1348–1387. | **High;** listed exclusions control. |\n| **C036** | A licensee must maintain permissible investments equal to outstanding obligations; specified triggering events create a statutory trust protected from nonbeneficiary attachment and administered pro rata. | S006 § 75-16-65/Section 33, printed pages 55–56/PDF indices 54–55; S007 carried-forward subsection. | **High.** This is not full-payment insurance or Chapter 22 escrow. |\n| **C037** | Effective July 1, 2026, delegates must provide principal/agent/contact/complaint disclosures and a fraud warning, and DBCF has prescribed Form 001. | S001 lines 28–31; S007 § 75-16-89; S008; S009. | **High.** No named processor status inferred. |\n| **C038** | When the TSR applies, qualifying dedicated-account funds must be customer-owned and independently administered, and withdrawal from the service requires return within seven business days of all funds except fees actually earned under the full federal trigger and allocation rule. | S010, § 310.4(a)(5)(i)–(ii), lines 115–131. | **High as conditional federal rule.** No universal coverage or Mississippi permission inferred. |\n| **C039** | Service withdrawal, bank-account closure, ACH revocation, pending creditor-payment cancellation, and statutory refund are distinct events. | Comparison of S003 § 81-22-11, S006 Section 29, and S010 § 310.4(a)(5)(ii)(E). | **High as analytical boundary;** actual procedures depend on contracts and transaction status. |\n| **C040** | No published DBCF interpretation or reported controlling decision was located in the bounded public search defining “supervised financial organization,” applying § 81-22-9 to an independent dedicated account, or construing the unusual “another licensee’s consumers” language. | Bounded official/public case and agency searches. | **Medium negative finding.** Not an exhaustive paid citator, docket, declaratory-order, or nonpublic agency-file search. |\n\n# E. PASS-03 component coverage and gap table\n\n| Component | Status | Claim IDs | Exact missing evidence / next investigation |\n| --- | --- | --- | --- |\n| Current continuation of relevant Chapter 22 clauses | **Supported with prior current-chain limit** | C001 | Obtain authenticated current code or signed/session-law chain and perform later-amendment check; do not repeat known failed HB 1265 routes absent a materially new route. |\n| Direct provider receipt and two-day deposit | **Answered textually** | C003 | Determine settled-funds convention and application to reversals or returned items through an official interpretation or actual examined practice. |\n| Federally insured institution requirement | **Answered at statutory level** | C003 | Obtain bank agreement, institution charter/insurance, account title, and pass-through deposit-insurance analysis. |\n| “Supervised financial organization” | **Unresolved definition/application** | C003, C023, C040 | Locate cross-code definition, DBCF interpretation, or controlling decision. |\n| Consumer-benefit designation | **Answered textually; legal ownership partial** | C003, C023 | Determine title, beneficial ownership, interest ownership, UCC status, and bankruptcy treatment. |\n| Trustee-process/provider-creditor protection | **Answered narrowly** | C004 | Research Mississippi trustee process, consumer-creditor garnishment, processor creditors, bank setoff, and bankruptcy interaction. |\n| Separate consumer records | **Answered** | C005, C009 | Examine actual subledger schema, opening balance, transaction IDs, pending items, and reconciliation controls. |\n| Separate bank account per consumer | **Unresolved / not expressly required** | C005, C023 | Obtain DBCF interpretation and actual pooled-account structure. |\n| Operating-account commingling | **Answered** | C005 | Determine treatment of fees, reimbursements, chargebacks, interest, and settlement adjustments in actual ledgers. |\n| Fifteen-business-day creditor remittance | **Answered textually** | C006, C010 | Resolve receipt/good-funds date, consumer stop instructions, rejected transfers, and independent-account application. |\n| Months-long principal accumulation | **Not established for direct custody; state dedicated-account application partial** | C010, C019 | Obtain DBCF or controlling authority on independent debt-settlement accounts and inspect actual control rights. |\n| Provider-caused misdirection | **Answered at duty level** | C007 | Determine correction mechanism, duplicate-payment risk, processor attribution, consequential losses, and recovery rights. |\n| Written account/institution disclosure | **Answered** | C008 | Full agreement-form audit remains later. |\n| Cancellation right | **Answered** | C008, C020 | Determine effectiveness, pending-payment handling, return recipient, and contractual notice mechanics. |\n| General state cancellation-return deadline | **Unresolved / none located in reviewed clauses** | C020 | Research general contract, restitution, MCPA, unclaimed-property, insolvency, and remedies law. |\n| Fee refund on cancellation | **Excluded/open** | C020, C038 | Analyze actual earning history, contract, state consumer law, TSR facts, and remedies. No automatic refund or no-refund conclusion. |\n| Quarterly consumer statements | **Answered** | C009 | Review actual content, delivery, error correction, electronic consent, and statement reconciliation. |\n| Six-year Chapter 22 records | **Answered** | C009 | Determine record destruction, processor custody, and successor obligations after cessation. |\n| Daily reconciliation and shortage cure | **Partial/unresolved** | C005, C009, C023 | Chapter 22 is nonspecific; obtain examination manual, order, interpretation, or actual processor requirements. |\n| Fair-share gross credit | **Answered** | C022 | Actual creditor and consumer statements needed for provider-level verification. |\n| Processor functional boundary | **Answered at text level** | C011, C012 | Inspect contract, bank/API permissions, ACH roles, affiliations, compensation, and sponsor-bank functions. |\n| Ten-day processor notice | **Answered** | C013 | Obtain actual DBCF notice and receipt. |\n| Highest-daily-funds reporting | **Answered** | C013 | Obtain actual monthly calculation and methodology. |\n| Processor security and pre-use confirmation | **Answered architecturally** | C014, C015, C017 | Actual bond/deposit, confirmation, term, cancellation, claims, and beneficiary analysis remain open. |\n| Processor examination authorization | **Answered** | C015 | Obtain actual authorization and DBCF sufficiency confirmation. |\n| Processor termination | **Answered at contract/agency-notice level** | C016 | Consumer notice, migration, reconciliation, return, bank closure, and successor duties remain open. |\n| Provider liability for processor failures | **Partial** | C018 | Research agency, contract, negligence, statutory remedies, processor bond, and controlling decisions. |\n| Provider/affiliate indirect control | **Partial** | C002, C019 | Inspect actual transfer and account permissions; seek authoritative state interpretation. |\n| Consumer-owned dedicated account | **Federal predicates answered; state treatment unresolved** | C019, C038 | Determine state receipt/holding/control and § 81-22-3(c)(xi) treatment from actual architecture and authority. |\n| Truly noncustodial consumer-paid model | **Partial** | C002, C019 | Prove no provider/affiliate access, custody, control, account compensation, or payment-chain role. |\n| Provider bankruptcy report | **Answered** | C021 | Full funds disposition, notice, successor servicing, bond and priority remain open. |\n| Chapter 22 insolvency wind-down | **Unresolved** | C021, C023 | Research receivership, bankruptcy, bond, trust, bank, restitution, and regulatory-order authority. |\n| Separate money-transmission gateway | **Answered at framework level** | C026, C027 | Apply to actual legal entities, account flows, consumer location, and transaction purpose. |\n| Agent-of-payee exemption | **Answered at predicate level; application unresolved** | C028 | Obtain creditor-written appointment, public holding-out, debt extinguishment, and risk-of-loss proof. |\n| Payment-system/intermediary/institution exemptions | **Answered at predicate level** | C029 | Obtain exact agreements, entity status, receipts, loss allocation, and functional scope. |\n| Authorized-delegate contract | **Answered at current-text level** | C030, C031 | Obtain principal license, delegate record, actual contract, scope, and DBCF/NMLS status. |\n| Authorized-delegate cessation | **Answered** | C032 | Consumer notice and fund disposition remain unresolved. |\n| Money-transmitter records/reconciliation | **Answered** | C033 | Actual books, monthly reconciliations, exceptions, and examination findings unavailable. |\n| Money-transmitter ten-day refund | **Answered conditionally** | C034 | Determine exclusions, commitment status, sender agreement, sufficient request, and whether debt payment is covered. |\n| Money-transmitter receipts | **Answered conditionally** | C035 | Apply transaction-purpose and payee-agreement exclusions. |\n| Money-transmitter statutory trust | **Answered textually** | C036 | Full claims, valuation, priority, administration, letters of credit, multistate allocation, and recovery later. |\n| 2026 delegate disclosures | **Answered** | C037 | Actual processor display and online implementation not checked. |\n| Federal seven-business-day return | **Answered conditionally** | C038, C039 | Establish actual TSR coverage, qualifying account, service-withdrawal request, and lawfully earned fees. |\n| Withdrawal versus ACH/account closure | **Distinguished; operational facts unresolved** | C039 | Obtain consumer request, ACH authorization, bank rules, pending-transfer status, and account agreement. |\n| Actual provider, processor, or bank authorization | **Unresolved** | C024, C026–C030 | Search named legal entity/NMLS IDs and retrieve public regulator records when an actual operator is supplied. |\n| Full bond claims and recovery | **Excluded/open** | C014, C017, C036 | Later bond component. |\n| Full agreement, MCPA, restitution, remedies, private actions, and limitations | **Excluded/open** | C020–C021 | Later components. |\n| Collection, secured/sector debt, local, and tribal issues | **Excluded/open** | None cleared | Later components. |\n| “Regulated by FTC,” settlement approval, DMP-as-settlement, and one-debt/full-fee theories | **Unchanged and unresolved** | Preserved P1/P2 IDs | No implication from this funds pass. |\n| State, parent, A066, operational, or publication acceptance | **Not given** | Entire table | All preserved open categories remain required. |\n\n# F. Researcher self-check\n\n## Actually read in this pass\n\n- The complete relevant carried-forward portions of the 2026 HB 1265 “As Sent to Governor” reproduction: §§ 81-22-3, -9, -11, -15, -25, and -28.\n- The complete corresponding clauses in DBCF’s thirteen-page historical Chapter 22 compilation, including visual page inspection.\n- DBCF’s official 2026 legislative summary for HB 1265 and HB 1596.\n- The complete materially relied-on sections of the DBCF-hosted seventy-five-page HB 1428 SG:Definitions.Exemptions.Licensing gateway.Event reports.Records.Authorized-delegate architecture.Unauthorized activity.Timely transmission.Refunds.Receipts.Permissible investments and statutory trust.Transition and effective clauses.\n- The relevant current-readable HB 1596 amendments to §§ 75-16-51, 75-16-65, and new § 75-16-89.\n- DBCF’s June 12, 2026 authorized-delegate memorandum and Form 001, including visual inspection.\n- The relevant DBCF application-page payment-processing requirements.\n- Rule 1.3(6) and Rule 1.3(7)(a)–(d) on printed pages 5–6/PDF indices 4–5 of the organizational rules.\n- The preserved operative federal dedicated-account clauses in 16 C.F.R. § 310.4(a)(5)(i)–(ii).\n\n## Reused with preserved limits\n\n- PASS-02’s conclusion that Chapter 22 continuation after July 1, 2026 is strongly supported but the full official signed/current-codification chain remains incomplete.\n- PASS-01/PASS-02 classifications, fee rules, federal coverage limitations, and prior examples.\n- The for-profit exclusion continues to require for-profit status plus **all** statutory conditions. Nothing in this pass defines “regulated by the FTC,” turns the exclusion into a license, or establishes an unlimited-fee path.\n\n## Not read or not established\n\n- No official signed HB 1265 image, complete official bill-status record, authenticated current-code page, or complete later-amendment chain was recovered. Previously failed HB 1265 routes were not retried.\n- No actual provider, bank, processor, administrator, sponsoring-bank, ACH, NMLS, bond, or account record was examined.\n- No private contract, consumer statement, ledger, bank statement, reconciliation, processor confirmation, or regulator examination report was accessed.\n- No exhaustive administrative-order, declaratory-ruling, unpublished agency-letter, trial-court, bankruptcy-docket, or paid-citator search was performed.\n- No published authoritative construction was located for “supervised financial organization,” independent dedicated accounts under § 81-22-9, or “another licensee’s consumers.”\n- No FDIC or NCUA pass-through determination was made.\n- No bankruptcy ownership, garnishment, bank-setoff, UCC, unclaimed-property, restitution, MCPA, or bond-priority conclusion was made.\n- No conclusion was made about an actual provider’s or processor’s license, exemption, delegate status, solvency, custody, fee earning, or compliance.\n- No application, filing, contact, account change, private-data access, site action, or publication action occurred.\n\n## Process\n\nThis was completed in the original regular Chat using public web research. No Deep Research, Work mode, Codex research generation, Chrome control, other Chat, API, purchase, CAPTCHA workaround, security bypass, filing, contact, private borrower data, or local-write/publication-readiness claim was used.\n\n**END S_MS PASS-03.**\n\n","tables":[{"headers":["Account or flow model","Mississippi Chapter 22 result","Processor / money-transmission / federal overlay","Proof still required"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Account or flow model","Mississippi Chapter 22 result","Processor / money-transmission / federal overlay","Proof still required"],["Provider directly receives periodic creditor-payment money","Covered custody model. Deposit within two business days into the specified federally insured escrow structure; remit to creditors within fifteen business days; maintain separate consumer records; do not commingle escrow with operating accounts. S_MS-P3-C003–C008","Separate money-transmission analysis may also be material if the provider is receiving money for transmission and cannot establish an exemption.","Actual bank title, deposit agreement, funds-flow map, receipt date, good-funds convention, disbursement ledger, license, and consumer agreement."],["Contracted processor holds, accesses, initiates, or distributes the money","Potential statutory “third-party payment processor.” Section 81-22-28 imposes advance notice, contract disclosure, security, pre-use confirmation, examination authorization, and termination duties. C013–C018","Processor may independently be a licensed money transmitter, an authorized delegate, or within a narrow exemption; Chapter 22 processor compliance is not itself a money-transmission exemption.","Processor legal entity, exact contract, bank/ACH authority, account access, sponsor bank, DBCF confirmations, bond/deposit evidence, and money-transmitter status."],["Consumer-owned dedicated account, but provider or affiliate can issue transfer instructions or cause payments","Consumer ownership does not establish noncontrol. Direct or indirect control and processor-chain language remain material. Whether those rights amount to provider “receipt” or “holding” for § 81-22-3(c)(xi) was not authoritatively resolved. C002, C011, C019","If the TSR applies, customer ownership, independent administration, no referral compensation, and seven-business-day return are required. Those federal conditions do not decide Mississippi indirect control or the meaning of “regulated by the FTC.”","Account agreement, administrator ownership, all affiliates, API/portal permissions, ACH roles, debit authority, who can change payees, who can stop or redirect transfers, and compensation relationships."],["Consumer controls an ordinary bank account; provider has no access, authority, instruction right, or place in the payment chain; consumer pays creditors directly","Section 81-22-9 custody duties may not be triggered on those narrow facts, but arranging payments, negotiating, or settling can still be debt-management service. The for-profit exclusion still requires actual for-profit status plus every statutory condition. C002, C019","No processor or money-transmission conclusion can be drawn merely because funds move through a consumer bank.","Evidence that the provider and every affiliate truly lack access, control, payment initiation, custody, and indirect compensation tied to the account."],["Entity solely supplies electronic routing and settlement; sponsoring bank performs the regulated settlement function","Expressly excluded from Chapter 22’s definition of “third-party payment processor” only when its role is truly limited to electronic routing and settlement. That exclusion does not remove the debt-management provider’s own obligations. C012","A separate payment-system or financial-institution exemption may apply under Title 75-16, but only within its exact scope.","Technical service description, sponsor-bank agreement, settlement accounts, loss allocation, authority over transactions, and proof the entity does not exercise broader control."],["Processor operates as authorized delegate of a Mississippi money-transmitter licensee","Authorized-delegate status does not replace Chapter 22 duties if the same entity is also a Chapter 22 processor.","Written appointment and scope are required. Delegate-held money net of fees is held in trust for the licensee, not expressly for the consumer. No subdelegate is allowed. C026–C028","Principal license, delegate listing, written contract, remittance terms, posted disclosure, actual scope, and whether debt-management processing falls within the appointment."],["Processor claims agent-of-payee exemption","No automatic Chapter 22 effect.","Title 75-16’s exemption requires a written appointment by the payee, public holding-out by that payee, and treatment of the consumer’s payment as received so the obligation is extinguished and the consumer bears no loss if the agent fails to remit. C025","Creditor/payee-signed agreement, creditor public representations, debt-crediting rule, risk-of-loss provision, and transaction-level treatment."],["Provider or processor accumulates creditor-payment principal for several months before a settlement or creditor payment","For funds received for creditor payment, the fifteen-business-day remittance command is facially inconsistent with months-long accumulation. A consumer-owned account with no provider receipt but some indirect influence remains fact- and interpretation-dependent. C006, C010, C019","TSR-compliant accumulation is not Mississippi authorization. A federal dedicated account may be permissible federally while still presenting an unresolved state-control or exclusion issue.","Exact custody/control facts and a primary DBCF interpretation or controlling decision addressing dedicated settlement accounts."]]},{"headers":["Exemption","Required predicates","Why a label is insufficient"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Exemption","Required predicates","Why a label is insufficient"],["Payment-system operator","Processing, clearing, or settlement between exempt persons or licensees in connection with specified payment rails.","A platform doing custody, account administration, consumer contracting, or transfer discretion may exceed mere system operation."],["Agent of payee","Written payee appointment; payee publicly holds the agent out; payment is treated as received and extinguishes the payer’s obligation; payer bears no loss if the agent fails to remit.","Calling a processor “agent” or listing a creditor as payee does not prove these terms."],["Intermediary","The entity with the underlying obligation is licensed or exempt, the sender’s confirmation identifies it as the transmission provider, and it bears sole responsibility to make the sender whole.","A downstream processor cannot simply borrow the upstream entity’s status."],["Federally insured depository institution","The legal entity itself must fall within the institutional exemption.","A bank relationship does not exempt an unaffiliated program manager or processor."],["Third-party service provider or agent of an exempt institution","Written contract specifying functions and the exempt institution assumes all risk of loss and legal responsibility upon the service provider’s receipt.","Sponsorship alone is insufficient."],["Commissioner exemption","Actual regulation or order and the precise facts covered by it.","No such order was located for debt-management processors in this pass."]]},{"headers":["Question","Chapter 22","Conditional federal TSR account rule","Result"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Question","Chapter 22","Conditional federal TSR account rule","Result"],["Who owns the money?","Account is for the consumer’s benefit; the statute does not expressly state complete legal title or interest ownership.","Customer owns the funds and any interest.","Federal ownership does not resolve Mississippi receipt, holding, or indirect control."],["Who may administer it?","Provider may use a qualifying Chapter 22 processor after the statutory notice/security/examination steps.","Administrator must be independent, unaffiliated, and free of referral compensation.","A processor can satisfy one regime and fail the other."],["How quickly is principal moved?","Creditor-payment funds must be deposited within two business days and remitted within fifteen business days.","The rule permits deposits in a qualifying dedicated account, but governs fee timing and withdrawal rather than creating a Mississippi long-hold authorization.","Months-long accumulation in a direct Chapter 22 escrow is not established as lawful."],["What happens on withdrawal?","Written cancellation right; no general principal-return deadline found in the reviewed clauses.","Remaining funds, less only lawfully earned fees, within seven business days.","Seven days applies only if federal coverage and every account predicate are established."],["Does federal compliance establish § 81-22-3(c)(xi)?","No. The state exclusion independently requires for-profit status, no receipt or holding, delayed fee receipt, and FTC regulation.","Federal compliance may be relevant evidence but is not the state test.","“TSR-compliant account” is not a Mississippi exclusion or license."],["Can the provider deduct a fee?","Only a separately lawful state fee with contractual and earning support; Chapter 22’s funds provision does not itself authorize deductions from principal.","Only fees earned under the complete debt-level trigger and allocation conditions.","Contracted amount, arithmetic equality, and account availability are not earning permission."]]},{"headers":["Source ID","Title, issuer, and direct literal URL","Exact passage/version/effective status","Actual access and limitations"],"index":3,"links":[{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf","text":"MS Banking & Consumer Finance"},{"href":"https://legiscan.com/MS/text/HB1265/id/3401614","text":"LegiScan\n+2"},{"href":"https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf","text":"MS Banking & Consumer Finance\n+4"},{"href":"https://dbcf.ms.gov/consumer-finance/","text":"MS Banking & Consumer Finance"},{"href":"https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf","text":"Mississippi Secretary of State"},{"href":"https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf","text":"MS Banking & Consumer Finance\n+3"},{"href":"https://legiscan.com/MS/text/HB1596/id/3411125","text":"LegiScan\n+1"},{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf","text":"MS Banking & Consumer Finance"},{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf","text":"MS Banking & Consumer Finance"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],"row_links":[[],[{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf","text":"MS Banking & Consumer Finance"}],[{"href":"https://legiscan.com/MS/text/HB1265/id/3401614","text":"LegiScan\n+2"}],[{"href":"https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf","text":"MS Banking & Consumer Finance\n+4"}],[{"href":"https://dbcf.ms.gov/consumer-finance/","text":"MS Banking & Consumer Finance"}],[{"href":"https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf","text":"Mississippi Secretary of State"}],[{"href":"https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf","text":"MS Banking & Consumer Finance\n+3"}],[{"href":"https://legiscan.com/MS/text/HB1596/id/3411125","text":"LegiScan\n+1"}],[{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf","text":"MS Banking & Consumer Finance"}],[{"href":"https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf","text":"MS Banking & Consumer Finance"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}]],"rows":[["Source ID","Title, issuer, and direct literal URL","Exact passage/version/effective status","Actual access and limitations"],["S_MS-P3-S001","Legislative Updates: 2026 Regular Session, Mississippi Department of Banking and Consumer Finance. https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf","Three-page PDF. PDF page 1/index 0, lines 9–11: HB 1265 removes the July 1, 2026 repeal date and is effective July 1, 2026. Lines 12–31 summarize HB 1596 and its July 1, 2026 effectiveness.","Freshly read; previously read in P2. Official agency enactment summary, not full enacted wording or current-code audit. Metadata wording referring to 2019 does not match the visible 2026 body. \nMS Banking & Consumer Finance"],["S_MS-P3-S002","HB 1265 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1265/id/3401614","Reproduced document identifies itself as Mississippi Legislature, 2026 Regular Session, HB 1265, “As Sent to Governor.” Lines 60–99: § 81-22-3; lines 106–115: § 81-22-9; lines 116–133: § 81-22-11; lines 146–155: § 81-22-15; lines 211–218: § 81-22-28; line 220: July 1, 2026 effective clause.","Freshly read in P3. Nonofficial host. Host “Enrolled/Passed” labels were not used as status authority. Used to compare complete carried-forward wording with S003. \nLegiScan\n+2"],["S_MS-P3-S003","Mississippi Debt Management Services Act, DBCF-hosted compilation. https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf","Thirteen PDF pages. § 81-22-9 on printed pages 5–6/PDF indices 4–5; § 81-22-11 on printed pages 6–7/indices 5–6; § 81-22-15 on printed page 8/index 7; § 81-22-25 on printed page 11/index 10; § 81-22-28 on printed pages 12–13/indices 11–12.","Relevant complete clauses freshly read and page images inspected. Agency-hosted primary-text compilation but historically stale: histories run through 2019 and headings carry an obsolete 2022 repeal date. Used with S001/S002, not alone for 2026 effectiveness. \nMS Banking & Consumer Finance\n+4"],["S_MS-P3-S004","DBCF Consumer Finance page. https://dbcf.ms.gov/consumer-finance/","Debt-management body at lines 113–136. Requires NMLS filing, security, agreement, fee schedule, third-party servicing/outsourcing contracts, and payment-processing narrative. Page also links current money-transmission materials.","Freshly read. Current public procedure only. Actual NMLS checklist, applicant materials, processor confirmation, and provider record were not read. \nMS Banking & Consumer Finance"],["S_MS-P3-S005","Mississippi Administrative Code, Title 5, Part 4, Organizational Rules, Mississippi Secretary of State. https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf","Twenty PDF pages. Rule 1.3(6) and 1.3(7)(a)–(d), printed pages 5–6/PDF indices 4–5, parsed lines 161–198.","Freshly reread; page images inspected. Confirms examination/investigation powers and government examination costs. It adds no detailed debt-management custody rule. No exhaustive rulemaking/adoption/current-version audit. \nMississippi Secretary of State"],["S_MS-P3-S006","Mississippi HB 1428 SG, Money Transmission Modernization Act, official DBCF-hosted legislative PDF. https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf","Seventy-five PDF pages. Definitions on printed pages 5–10; exemptions pp. 10–14; license p. 20; records pp. 45–46; delegate relationship pp. 46–49; refunds pp. 49–51; receipts pp. 51–52; permissible investments/trust pp. 55–56; transition pp. 74–75; effective July 1, 2025.","Freshly read in all materially relied-on sections; relevant page images inspected. DBCF-hosted “As Sent to Governor” text with official page markings. DBCF’s current page identifies the act as effective July 1, 2025. Licensee-specific transition timing can depend on renewal and was not resolved for a named entity. \nMS Banking & Consumer Finance\n+3"],["S_MS-P3-S007","Mississippi HB 1596 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1596/id/3411125","Reproduced “As Sent to Governor” text. Lines 337–372 amend § 75-16-51; lines 373–379 carry forward § 75-16-65; lines 381–407 create § 75-16-89 and set July 1, 2026 effectiveness.","Freshly read. Nonofficial host; editorial enactment labels not treated as primary status proof. Currentness supported separately by S001, S008, and S009. \nLegiScan\n+1"],["S_MS-P3-S008","Memo to Industry — HB1596 Authorized Delegate Disclosure Requirements, DBCF, June 12, 2026. https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf","One-page PDF. Lines 9–28 explain § 75-16-89 delegate disclosures, website treatment, fraud warning, and July 1, 2026 effective date.","Freshly read; page image inspected. Official operational implementation memo. It does not interpret debt-management custody or Title 75-16 exemptions. \nMS Banking & Consumer Finance"],["S_MS-P3-S009","DBCF MTMA Form 001, Authorized Delegate Disclosures. https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf","One-page form, effective July 1, 2026. Identifies delegate, principal licensed money transmitter, agency status, and complaint information.","Freshly read; page image inspected. Demonstrates prescribed public disclosure, not proof that any particular processor is an authorized delegate. \nMS Banking & Consumer Finance"],["S_MS-P3-S010","16 C.F.R. § 310.4, Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§ 310.4(a)(5)(i)(A)–(C), lines 115–122; dedicated-account requirements at § 310.4(a)(5)(ii)(A)–(E), lines 123–131. eCFR displayed Title 16 current through October 22, 2026.","Freshly read in P2 and relied upon here as the preserved conditional overlay. Authoritative but unofficial eCFR. No universal TSR coverage inferred. \neCFR"]]},{"headers":["Claim ID","Precise assertion","Source IDs and exact pinpoints","Predicates, exceptions, currentness, confidence"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source IDs and exact pinpoints","Predicates, exceptions, currentness, confidence"],["S_MS-P3-C001","Chapter 22’s continuation beyond July 1, 2026 remains strongly supported, and the 2026 carried-forward text reproduces the relevant custody, reporting, and processor clauses without an observed operative change from the DBCF compilation.","S001, page 1/index 0, lines 9–11; S002 §§ 5, 6, 9, and 16; S003 corresponding sections.","High for continuation and comparison performed; medium-high for complete current official codification. Signed/current official chain remains held."],["C002","Debt-management service reaches receiving money, arranging payments, and exercising or arranging direct or indirect control over consumer funds.","S002, § 81-22-3(b)(i)–(iii), lines 65–70.","High as text. Application depends on actual rights, not account labels."],["C003","All consumer money received for creditor payment must be deposited within two business days into a federally insured escrow account for the consumer’s benefit in a supervised financial organization.","S003, § 81-22-9(1), printed page 5/PDF index 4, lines 146–152; S002 corresponding § 81-22-9.","High as text. “Receipt,” “supervised financial organization,” and insurance mechanics remain undefined or unresolved."],["C004","The escrow account is free from trustee process and unavailable to provider creditors.","S003, § 81-22-9(1), lines 149–152.","High, narrowly stated. No broader garnishment, setoff, bankruptcy, processor-creditor, or pass-through-insurance protection inferred."],["C005","The provider must keep a separate account record for each consumer and cannot commingle consumer-benefit escrow with provider operating accounts.","S003, § 81-22-9(2)(a), (3), lines 153–162.","High. Separate subledgers do not necessarily mean separate bank accounts."],["C006","Creditor-payment money must be remitted to creditors within fifteen business days after receipt.","S003, § 81-22-9(2)(b), lines 153–157.","High for direct covered funds. Effect of reversals, changed instructions, and independent dedicated accounts remains unresolved."],["C007","Provider-caused misdirection must be corrected or remedied, and the consumer must be reimbursed for actual resulting creditor costs or fees.","S003, § 81-22-9(2)(c), lines 158–160.","High. Exact correction method and downstream recovery are fact-dependent."],["C008","The consumer agreement must identify the institution, contain written-cancellation rights, list obligations and creditors, state payment schedules, and permit DBCF examination access to escrow records.","S003, § 81-22-11(2)(d)–(h), printed pages 6–7/PDF indices 5–6, lines 183–195.","High. Agreement-form completeness remains a later pass."],["C009","Chapter 22 requires at least quarterly consumer receipt/disbursement reports, separate compliance records, and six-year consumer record retention.","S003, § 81-22-15(1)–(2), printed page 8/PDF index 7, lines 225–240.","High. No explicit daily reconciliation or online-access rule found."],["C010","Direct or provider-controlled accumulation of creditor-payment principal for months is not supported by the fifteen-business-day remittance text.","C003 and C006; S003 § 81-22-9.","High textual conclusion for direct custody; partial for consumer-owned indirect-control accounts."],["C011","A processor is functionally defined by holding, access, ability to effect possession, distribution, or participation in the distribution chain under contract.","S002, § 81-22-3(i), lines 98–99.","High. Actual system permissions and contracts control."],["C012","An entity solely providing electronic routing and settlement, and its sponsoring bank, is excluded from the Chapter 22 processor definition.","S002, § 81-22-3(i), line 99.","High, narrow exclusion. It is not a provider or money-transmission exemption."],["C013","Section 81-22-28 requires ten days’ notice and disclosure of processor identity, services, contract, and highest daily consumer-fund amount.","S002, § 81-22-28(1)–(2), lines 211–213; S003 printed page 12/PDF index 11.","High as text. “Another licensee’s consumers” remains an unresolved literal wording issue."],["C014","The processor ordinarily needs the specified $50,000/$50,000-per-additional-licensee security, capped at $150,000, and the provider cannot use it before DBCF’s written security confirmation.","S002, § 81-22-28(3)–(4), lines 214–215.","High as architecture. Full bond claims and beneficiaries excluded."],["C015","Before services, the processor must authorize DBCF examination of money-related records and receive confirmation that the authorization is sufficient; the licensee pays the examination cost.","S002, § 81-22-28(5), line 216.","High. No actual processor authorization was obtained."],["C016","Processor contracts must provide thirty days’ termination notice, and the licensee must immediately notify DBCF of that notice.","S002, § 81-22-28(6), line 217.","High. No consumer-return or migration deadline is supplied."],["C017","A processor’s separate bond/deposit is excused if the licensee elected the specified cash, CD, or government-bond deposit alternative.","S002, § 81-22-28(7), line 218.","High as text. Actual deposit election remains unverified."],["C018","Use of a processor does not expressly transfer or extinguish the provider’s § 81-22-9 duties.","Comparison of S003 § 81-22-9 and S002 § 81-22-28.","Medium-high textual inference. Complete agency/contract liability remains open."],["C019","A consumer-owned or federally compliant account label does not itself resolve Mississippi receipt, holding, direct/indirect control, processor status, or § 81-22-3(c)(xi).","S002 § 81-22-3(b), (c)(xi), and (i); S010 § 310.4(a)(5)(ii).","High as boundary statement. Exact state interpretation remains unresolved."],["C020","Chapter 22 requires a written cancellation right but the reviewed custody, agreement, records, and processor clauses contain no general cancellation-principal return deadline.","S003 §§ 81-22-9, -11, -15, -28.","Medium-high bounded negative finding. Other Mississippi law remains open."],["C021","Bankruptcy/reorganization must be reported within fifteen days and insolvency is a license-revocation ground, but the reviewed clauses do not create a complete consumer-funds wind-down process.","S003 § 81-22-15(4), lines 246–253; § 81-22-25(2)(c), lines 351–364.","Reporting/ground high; wind-down absence medium-high bounded finding."],["C022","Fair-share participants must credit the consumer for the full creditor payment, not the net amount after the creditor contribution.","S003 § 81-22-15(3), lines 241–245.","High."],["C023","Chapter 22 does not expressly state account title, interest ownership, FDIC/NCUA pass-through mechanics, consumer-creditor garnishment immunity, bank setoff treatment, or separate-account-per-consumer requirements.","S002/S003 §§ 81-22-3, -9, -11, -15, -28.","Medium-high bounded negative finding. Banking, bankruptcy, UCC, and garnishment law not audited."],["C024","DBCF’s public application instructions require third-party servicing contracts and a payment-processing narrative.","S004, lines 125–136.","High as current public procedure. Not legal approval or an actual provider record."],["C025","Rule 1.3(7) permits DBCF examination of licensees and suspected nonlicensees; its $300–$600 and outside-record amounts are government examination costs, not consumer-money deductions.","S005, printed pages 5–6/PDF indices 4–5, lines 171–198.","High for passage read. No exhaustive administrative-rule audit."]]},{"headers":["Claim ID","Precise assertion","Source IDs and exact pinpoints","Predicates, exceptions, currentness, confidence"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source IDs and exact pinpoints","Predicates, exceptions, currentness, confidence"],["S_MS-P3-C026","Title 75-16 reaches receiving money or monetary value for transmission from a Mississippi person, and requires a license absent authorized-delegate or exemption status.","S006, definitions on printed pages 6–7/PDF indices 5–6, lines 161–167; license, printed page 20/index 19, lines 529–539.","High as text. Actual entity and transaction classification remain fact-dependent."],["C027","Chapter 22 processor compliance is not an express Title 75-16 exemption.","Comparison of S002 § 81-22-28 and S006 Sections 4 and 11.","High textual conclusion."],["C028","Agent-of-payee status requires written payee appointment, payee public holding-out, extinguishment of the payer’s obligation, and no payer risk of loss.","S006, Section 4(b), printed pages 10–11/PDF indices 9–10, lines 272–288.","High. No actual creditor agreement was reviewed."],["C029","Other potentially relevant exemptions—payment system, intermediary, depository institution, and service provider to an exempt institution—are condition-specific and do not arise merely from a bank or processor label.","S006, Section 4(a), (c), (g), and (m), printed pages 10–14/PDF indices 9–13.","High."],["C030","A current authorized-delegate contract must appoint the delegate, define rights and duties, govern handling/remittance, impose a trust for the licensee, require records, and consent to examination.","S007, § 75-16-51(2)–(4), lines 337–362.","High as reproduced text with official agency effectiveness support."],["C031","Delegate-held money net of fees is held in trust for the licensee; commingled property is impressed to that amount; no subdelegate may be used.","S007, § 75-16-51(6)–(7), lines 363–365.","High. This is not consumer ownership."],["C032","After suspension, revocation, surrender, or expiration, delegates must stop immediately and the licensee must document delegate notice to DBCF within five business days.","S007, § 75-16-51(5), line 363.","High. No complete consumer-funds wind-down rule follows from this clause."],["C033","Money-transmitter records include a monthly general ledger, bank statements/reconciliations, outstanding/paid obligations, and delegate records, retained for five years.","S006, Section 25, printed pages 45–46/PDF indices 44–45, lines 1187–1213.","High."],["C034","Covered money must be forwarded under the sender agreement unless a stated fraud/legal concern applies; the refund rule generally requires refund within ten days after sufficient written request, subject to exclusions and exceptions.","S006, Sections 28–29, printed pages 49–51/PDF indices 48–50, lines 1298–1347.","High as conditional rule. Debt-payment goods/services exclusion unresolved."],["C035","The receipt rule applies conditionally to covered personal/family/household transactions and requires specified transaction and licensee information.","S006, Section 30, printed pages 51–52/PDF indices 50–51, lines 1348–1387.","High; listed exclusions control."],["C036","A licensee must maintain permissible investments equal to outstanding obligations; specified triggering events create a statutory trust protected from nonbeneficiary attachment and administered pro rata.","S006 § 75-16-65/Section 33, printed pages 55–56/PDF indices 54–55; S007 carried-forward subsection.","High. This is not full-payment insurance or Chapter 22 escrow."],["C037","Effective July 1, 2026, delegates must provide principal/agent/contact/complaint disclosures and a fraud warning, and DBCF has prescribed Form 001.","S001 lines 28–31; S007 § 75-16-89; S008; S009.","High. No named processor status inferred."],["C038","When the TSR applies, qualifying dedicated-account funds must be customer-owned and independently administered, and withdrawal from the service requires return within seven business days of all funds except fees actually earned under the full federal trigger and allocation rule.","S010, § 310.4(a)(5)(i)–(ii), lines 115–131.","High as conditional federal rule. No universal coverage or Mississippi permission inferred."],["C039","Service withdrawal, bank-account closure, ACH revocation, pending creditor-payment cancellation, and statutory refund are distinct events.","Comparison of S003 § 81-22-11, S006 Section 29, and S010 § 310.4(a)(5)(ii)(E).","High as analytical boundary; actual procedures depend on contracts and transaction status."],["C040","No published DBCF interpretation or reported controlling decision was located in the bounded public search defining “supervised financial organization,” applying § 81-22-9 to an independent dedicated account, or construing the unusual “another licensee’s consumers” language.","Bounded official/public case and agency searches.","Medium negative finding. Not an exhaustive paid citator, docket, declaratory-order, or nonpublic agency-file search."]]},{"headers":["Component","Status","Claim IDs","Exact missing evidence / next investigation"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claim IDs","Exact missing evidence / next investigation"],["Current continuation of relevant Chapter 22 clauses","Supported with prior current-chain limit","C001","Obtain authenticated current code or signed/session-law chain and perform later-amendment check; do not repeat known failed HB 1265 routes absent a materially new route."],["Direct provider receipt and two-day deposit","Answered textually","C003","Determine settled-funds convention and application to reversals or returned items through an official interpretation or actual examined practice."],["Federally insured institution requirement","Answered at statutory level","C003","Obtain bank agreement, institution charter/insurance, account title, and pass-through deposit-insurance analysis."],["“Supervised financial organization”","Unresolved definition/application","C003, C023, C040","Locate cross-code definition, DBCF interpretation, or controlling decision."],["Consumer-benefit designation","Answered textually; legal ownership partial","C003, C023","Determine title, beneficial ownership, interest ownership, UCC status, and bankruptcy treatment."],["Trustee-process/provider-creditor protection","Answered narrowly","C004","Research Mississippi trustee process, consumer-creditor garnishment, processor creditors, bank setoff, and bankruptcy interaction."],["Separate consumer records","Answered","C005, C009","Examine actual subledger schema, opening balance, transaction IDs, pending items, and reconciliation controls."],["Separate bank account per consumer","Unresolved / not expressly required","C005, C023","Obtain DBCF interpretation and actual pooled-account structure."],["Operating-account commingling","Answered","C005","Determine treatment of fees, reimbursements, chargebacks, interest, and settlement adjustments in actual ledgers."],["Fifteen-business-day creditor remittance","Answered textually","C006, C010","Resolve receipt/good-funds date, consumer stop instructions, rejected transfers, and independent-account application."],["Months-long principal accumulation","Not established for direct custody; state dedicated-account application partial","C010, C019","Obtain DBCF or controlling authority on independent debt-settlement accounts and inspect actual control rights."],["Provider-caused misdirection","Answered at duty level","C007","Determine correction mechanism, duplicate-payment risk, processor attribution, consequential losses, and recovery rights."],["Written account/institution disclosure","Answered","C008","Full agreement-form audit remains later."],["Cancellation right","Answered","C008, C020","Determine effectiveness, pending-payment handling, return recipient, and contractual notice mechanics."],["General state cancellation-return deadline","Unresolved / none located in reviewed clauses","C020","Research general contract, restitution, MCPA, unclaimed-property, insolvency, and remedies law."],["Fee refund on cancellation","Excluded/open","C020, C038","Analyze actual earning history, contract, state consumer law, TSR facts, and remedies. No automatic refund or no-refund conclusion."],["Quarterly consumer statements","Answered","C009","Review actual content, delivery, error correction, electronic consent, and statement reconciliation."],["Six-year Chapter 22 records","Answered","C009","Determine record destruction, processor custody, and successor obligations after cessation."],["Daily reconciliation and shortage cure","Partial/unresolved","C005, C009, C023","Chapter 22 is nonspecific; obtain examination manual, order, interpretation, or actual processor requirements."],["Fair-share gross credit","Answered","C022","Actual creditor and consumer statements needed for provider-level verification."],["Processor functional boundary","Answered at text level","C011, C012","Inspect contract, bank/API permissions, ACH roles, affiliations, compensation, and sponsor-bank functions."],["Ten-day processor notice","Answered","C013","Obtain actual DBCF notice and receipt."],["Highest-daily-funds reporting","Answered","C013","Obtain actual monthly calculation and methodology."],["Processor security and pre-use confirmation","Answered architecturally","C014, C015, C017","Actual bond/deposit, confirmation, term, cancellation, claims, and beneficiary analysis remain open."],["Processor examination authorization","Answered","C015","Obtain actual authorization and DBCF sufficiency confirmation."],["Processor termination","Answered at contract/agency-notice level","C016","Consumer notice, migration, reconciliation, return, bank closure, and successor duties remain open."],["Provider liability for processor failures","Partial","C018","Research agency, contract, negligence, statutory remedies, processor bond, and controlling decisions."],["Provider/affiliate indirect control","Partial","C002, C019","Inspect actual transfer and account permissions; seek authoritative state interpretation."],["Consumer-owned dedicated account","Federal predicates answered; state treatment unresolved","C019, C038","Determine state receipt/holding/control and § 81-22-3(c)(xi) treatment from actual architecture and authority."],["Truly noncustodial consumer-paid model","Partial","C002, C019","Prove no provider/affiliate access, custody, control, account compensation, or payment-chain role."],["Provider bankruptcy report","Answered","C021","Full funds disposition, notice, successor servicing, bond and priority remain open."],["Chapter 22 insolvency wind-down","Unresolved","C021, C023","Research receivership, bankruptcy, bond, trust, bank, restitution, and regulatory-order authority."],["Separate money-transmission gateway","Answered at framework level","C026, C027","Apply to actual legal entities, account flows, consumer location, and transaction purpose."],["Agent-of-payee exemption","Answered at predicate level; application unresolved","C028","Obtain creditor-written appointment, public holding-out, debt extinguishment, and risk-of-loss proof."],["Payment-system/intermediary/institution exemptions","Answered at predicate level","C029","Obtain exact agreements, entity status, receipts, loss allocation, and functional scope."],["Authorized-delegate contract","Answered at current-text level","C030, C031","Obtain principal license, delegate record, actual contract, scope, and DBCF/NMLS status."],["Authorized-delegate cessation","Answered","C032","Consumer notice and fund disposition remain unresolved."],["Money-transmitter records/reconciliation","Answered","C033","Actual books, monthly reconciliations, exceptions, and examination findings unavailable."],["Money-transmitter ten-day refund","Answered conditionally","C034","Determine exclusions, commitment status, sender agreement, sufficient request, and whether debt payment is covered."],["Money-transmitter receipts","Answered conditionally","C035","Apply transaction-purpose and payee-agreement exclusions."],["Money-transmitter statutory trust","Answered textually","C036","Full claims, valuation, priority, administration, letters of credit, multistate allocation, and recovery later."],["2026 delegate disclosures","Answered","C037","Actual processor display and online implementation not checked."],["Federal seven-business-day return","Answered conditionally","C038, C039","Establish actual TSR coverage, qualifying account, service-withdrawal request, and lawfully earned fees."],["Withdrawal versus ACH/account closure","Distinguished; operational facts unresolved","C039","Obtain consumer request, ACH authorization, bank rules, pending-transfer status, and account agreement."],["Actual provider, processor, or bank authorization","Unresolved","C024, C026–C030","Search named legal entity/NMLS IDs and retrieve public regulator records when an actual operator is supplied."],["Full bond claims and recovery","Excluded/open","C014, C017, C036","Later bond component."],["Full agreement, MCPA, restitution, remedies, private actions, and limitations","Excluded/open","C020–C021","Later components."],["Collection, secured/sector debt, local, and tribal issues","Excluded/open","None cleared","Later components."],["“Regulated by FTC,” settlement approval, DMP-as-settlement, and one-debt/full-fee theories","Unchanged and unresolved","Preserved P1/P2 IDs","No implication from this funds pass."],["State, parent, A066, operational, or publication acceptance","Not given","Entire table","All preserved open categories remain required."]]}],"claims":[{"claim_id":"S_MS-P3-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MS-P3-C001","Precise assertion":"Chapter 22’s continuation beyond July 1, 2026 remains strongly supported, and the 2026 carried-forward text reproduces the relevant custody, reporting, and processor clauses without an observed operative change from the DBCF compilation.","Source IDs and exact pinpoints":"S001, page 1/index 0, lines 9–11; S002 §§ 5, 6, 9, and 16; S003 corresponding sections.","Predicates, exceptions, currentness, confidence":"High for continuation and comparison performed; medium-high for complete current official codification. Signed/current official chain remains held."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","coordinator_canonical_scoped_claim_id":"S_MS-P3-C001","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"Debt-management service reaches receiving money, arranging payments, and exercising or arranging direct or indirect control over consumer funds.","Source IDs and exact pinpoints":"S002, § 81-22-3(b)(i)–(iii), lines 65–70.","Predicates, exceptions, currentness, confidence":"High as text. Application depends on actual rights, not account labels."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C002","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"All consumer money received for creditor payment must be deposited within two business days into a federally insured escrow account for the consumer’s benefit in a supervised financial organization.","Source IDs and exact pinpoints":"S003, § 81-22-9(1), printed page 5/PDF index 4, lines 146–152; S002 corresponding § 81-22-9.","Predicates, exceptions, currentness, confidence":"High as text. “Receipt,” “supervised financial organization,” and insurance mechanics remain undefined or unresolved."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C003","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"The escrow account is free from trustee process and unavailable to provider creditors.","Source IDs and exact pinpoints":"S003, § 81-22-9(1), lines 149–152.","Predicates, exceptions, currentness, confidence":"High, narrowly stated. No broader garnishment, setoff, bankruptcy, processor-creditor, or pass-through-insurance protection inferred."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C004","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"The provider must keep a separate account record for each consumer and cannot commingle consumer-benefit escrow with provider operating accounts.","Source IDs and exact pinpoints":"S003, § 81-22-9(2)(a), (3), lines 153–162.","Predicates, exceptions, currentness, confidence":"High. Separate subledgers do not necessarily mean separate bank accounts."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C005","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Creditor-payment money must be remitted to creditors within fifteen business days after receipt.","Source IDs and exact pinpoints":"S003, § 81-22-9(2)(b), lines 153–157.","Predicates, exceptions, currentness, confidence":"High for direct covered funds. Effect of reversals, changed instructions, and independent dedicated accounts remains unresolved."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C006","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"Provider-caused misdirection must be corrected or remedied, and the consumer must be reimbursed for actual resulting creditor costs or fees.","Source IDs and exact pinpoints":"S003, § 81-22-9(2)(c), lines 158–160.","Predicates, exceptions, currentness, confidence":"High. Exact correction method and downstream recovery are fact-dependent."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C007","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"The consumer agreement must identify the institution, contain written-cancellation rights, list obligations and creditors, state payment schedules, and permit DBCF examination access to escrow records.","Source IDs and exact pinpoints":"S003, § 81-22-11(2)(d)–(h), printed pages 6–7/PDF indices 5–6, lines 183–195.","Predicates, exceptions, currentness, confidence":"High. Agreement-form completeness remains a later pass."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C008","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"Chapter 22 requires at least quarterly consumer receipt/disbursement reports, separate compliance records, and six-year consumer record retention.","Source IDs and exact pinpoints":"S003, § 81-22-15(1)–(2), printed page 8/PDF index 7, lines 225–240.","Predicates, exceptions, currentness, confidence":"High. No explicit daily reconciliation or online-access rule found."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C009","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"Direct or provider-controlled accumulation of creditor-payment principal for months is not supported by the fifteen-business-day remittance text.","Source IDs and exact pinpoints":"C003 and C006; S003 § 81-22-9.","Predicates, exceptions, currentness, confidence":"High textual conclusion for direct custody; partial for consumer-owned indirect-control accounts."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C010","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"A processor is functionally defined by holding, access, ability to effect possession, distribution, or participation in the distribution chain under contract.","Source IDs and exact pinpoints":"S002, § 81-22-3(i), lines 98–99.","Predicates, exceptions, currentness, confidence":"High. Actual system permissions and contracts control."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C011","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"An entity solely providing electronic routing and settlement, and its sponsoring bank, is excluded from the Chapter 22 processor definition.","Source IDs and exact pinpoints":"S002, § 81-22-3(i), line 99.","Predicates, exceptions, currentness, confidence":"High, narrow exclusion. It is not a provider or money-transmission exemption."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C012","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"Section 81-22-28 requires ten days’ notice and disclosure of processor identity, services, contract, and highest daily consumer-fund amount.","Source IDs and exact pinpoints":"S002, § 81-22-28(1)–(2), lines 211–213; S003 printed page 12/PDF index 11.","Predicates, exceptions, currentness, confidence":"High as text. “Another licensee’s consumers” remains an unresolved literal wording issue."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C013","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"The processor ordinarily needs the specified $50,000/$50,000-per-additional-licensee security, capped at $150,000, and the provider cannot use it before DBCF’s written security confirmation.","Source IDs and exact pinpoints":"S002, § 81-22-28(3)–(4), lines 214–215.","Predicates, exceptions, currentness, confidence":"High as architecture. Full bond claims and beneficiaries excluded."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C014","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Before services, the processor must authorize DBCF examination of money-related records and receive confirmation that the authorization is sufficient; the licensee pays the examination cost.","Source IDs and exact pinpoints":"S002, § 81-22-28(5), line 216.","Predicates, exceptions, currentness, confidence":"High. No actual processor authorization was obtained."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C015","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"Processor contracts must provide thirty days’ termination notice, and the licensee must immediately notify DBCF of that notice.","Source IDs and exact pinpoints":"S002, § 81-22-28(6), line 217.","Predicates, exceptions, currentness, confidence":"High. No consumer-return or migration deadline is supplied."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C016","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"A processor’s separate bond/deposit is excused if the licensee elected the specified cash, CD, or government-bond deposit alternative.","Source IDs and exact pinpoints":"S002, § 81-22-28(7), line 218.","Predicates, exceptions, currentness, confidence":"High as text. Actual deposit election remains unverified."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C017","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"Use of a processor does not expressly transfer or extinguish the provider’s § 81-22-9 duties.","Source IDs and exact pinpoints":"Comparison of S003 § 81-22-9 and S002 § 81-22-28.","Predicates, exceptions, currentness, confidence":"Medium-high textual inference. Complete agency/contract liability remains open."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C018","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"A consumer-owned or federally compliant account label does not itself resolve Mississippi receipt, holding, direct/indirect control, processor status, or § 81-22-3(c)(xi).","Source IDs and exact pinpoints":"S002 § 81-22-3(b), (c)(xi), and (i); S010 § 310.4(a)(5)(ii).","Predicates, exceptions, currentness, confidence":"High as boundary statement. Exact state interpretation remains unresolved."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C019","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"Chapter 22 requires a written cancellation right but the reviewed custody, agreement, records, and processor clauses contain no general cancellation-principal return deadline.","Source IDs and exact pinpoints":"S003 §§ 81-22-9, -11, -15, -28.","Predicates, exceptions, currentness, confidence":"Medium-high bounded negative finding. Other Mississippi law remains open."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C020","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"Bankruptcy/reorganization must be reported within fifteen days and insolvency is a license-revocation ground, but the reviewed clauses do not create a complete consumer-funds wind-down process.","Source IDs and exact pinpoints":"S003 § 81-22-15(4), lines 246–253; § 81-22-25(2)(c), lines 351–364.","Predicates, exceptions, currentness, confidence":"Reporting/ground high; wind-down absence medium-high bounded finding."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C021","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"Fair-share participants must credit the consumer for the full creditor payment, not the net amount after the creditor contribution.","Source IDs and exact pinpoints":"S003 § 81-22-15(3), lines 241–245.","Predicates, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C022","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"Chapter 22 does not expressly state account title, interest ownership, FDIC/NCUA pass-through mechanics, consumer-creditor garnishment immunity, bank setoff treatment, or separate-account-per-consumer requirements.","Source IDs and exact pinpoints":"S002/S003 §§ 81-22-3, -9, -11, -15, -28.","Predicates, exceptions, currentness, confidence":"Medium-high bounded negative finding. Banking, bankruptcy, UCC, and garnishment law not audited."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C023","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"DBCF’s public application instructions require third-party servicing contracts and a payment-processing narrative.","Source IDs and exact pinpoints":"S004, lines 125–136.","Predicates, exceptions, currentness, confidence":"High as current public procedure. Not legal approval or an actual provider record."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C024","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"Rule 1.3(7) permits DBCF examination of licensees and suspected nonlicensees; its $300–$600 and outside-record amounts are government examination costs, not consumer-money deductions.","Source IDs and exact pinpoints":"S005, printed pages 5–6/PDF indices 4–5, lines 171–198.","Predicates, exceptions, currentness, confidence":"High for passage read. No exhaustive administrative-rule audit."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C025","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-P3-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MS-P3-C026","Precise assertion":"Title 75-16 reaches receiving money or monetary value for transmission from a Mississippi person, and requires a license absent authorized-delegate or exemption status.","Source IDs and exact pinpoints":"S006, definitions on printed pages 6–7/PDF indices 5–6, lines 161–167; license, printed page 20/index 19, lines 529–539.","Predicates, exceptions, currentness, confidence":"High as text. Actual entity and transaction classification remain fact-dependent."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","coordinator_canonical_scoped_claim_id":"S_MS-P3-C026","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise assertion":"Chapter 22 processor compliance is not an express Title 75-16 exemption.","Source IDs and exact pinpoints":"Comparison of S002 § 81-22-28 and S006 Sections 4 and 11.","Predicates, exceptions, currentness, confidence":"High textual conclusion."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C027","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise assertion":"Agent-of-payee status requires written payee appointment, payee public holding-out, extinguishment of the payer’s obligation, and no payer risk of loss.","Source IDs and exact pinpoints":"S006, Section 4(b), printed pages 10–11/PDF indices 9–10, lines 272–288.","Predicates, exceptions, currentness, confidence":"High. No actual creditor agreement was reviewed."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C028","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00","coordinator_scope_qualification":"Agent-of-payee threshold also requires payee goods/services other than money transmission itself; actual debt-payment applicability unresolved."},{"claim_id":"S_MS-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise assertion":"Other potentially relevant exemptions—payment system, intermediary, depository institution, and service provider to an exempt institution—are condition-specific and do not arise merely from a bank or processor label.","Source IDs and exact pinpoints":"S006, Section 4(a), (c), (g), and (m), printed pages 10–14/PDF indices 9–13.","Predicates, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C029","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise assertion":"A current authorized-delegate contract must appoint the delegate, define rights and duties, govern handling/remittance, impose a trust for the licensee, require records, and consent to examination.","Source IDs and exact pinpoints":"S007, § 75-16-51(2)–(4), lines 337–362.","Predicates, exceptions, currentness, confidence":"High as reproduced text with official agency effectiveness support."},"coordinator_verification_status":"2025_baseline_selected_text_checked_2026_amendment_body_held","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C030","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C031","Precise assertion":"Delegate-held money net of fees is held in trust for the licensee; commingled property is impressed to that amount; no subdelegate may be used.","Source IDs and exact pinpoints":"S007, § 75-16-51(6)–(7), lines 363–365.","Predicates, exceptions, currentness, confidence":"High. This is not consumer ownership."},"coordinator_verification_status":"2025_baseline_selected_text_checked_2026_amendment_body_held","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C031","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C032","Precise assertion":"After suspension, revocation, surrender, or expiration, delegates must stop immediately and the licensee must document delegate notice to DBCF within five business days.","Source IDs and exact pinpoints":"S007, § 75-16-51(5), line 363.","Predicates, exceptions, currentness, confidence":"High. No complete consumer-funds wind-down rule follows from this clause."},"coordinator_verification_status":"2025_baseline_selected_text_checked_2026_amendment_body_held","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C032","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C033","Precise assertion":"Money-transmitter records include a monthly general ledger, bank statements/reconciliations, outstanding/paid obligations, and delegate records, retained for five years.","Source IDs and exact pinpoints":"S006, Section 25, printed pages 45–46/PDF indices 44–45, lines 1187–1213.","Predicates, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C033","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C034","Precise assertion":"Covered money must be forwarded under the sender agreement unless a stated fraud/legal concern applies; the refund rule generally requires refund within ten days after sufficient written request, subject to exclusions and exceptions.","Source IDs and exact pinpoints":"S006, Sections 28–29, printed pages 49–51/PDF indices 48–50, lines 1298–1347.","Predicates, exceptions, currentness, confidence":"High as conditional rule. Debt-payment goods/services exclusion unresolved."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C034","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C035","Precise assertion":"The receipt rule applies conditionally to covered personal/family/household transactions and requires specified transaction and licensee information.","Source IDs and exact pinpoints":"S006, Section 30, printed pages 51–52/PDF indices 50–51, lines 1348–1387.","Predicates, exceptions, currentness, confidence":"High; listed exclusions control."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C035","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C036","Precise assertion":"A licensee must maintain permissible investments equal to outstanding obligations; specified triggering events create a statutory trust protected from nonbeneficiary attachment and administered pro rata.","Source IDs and exact pinpoints":"S006 § 75-16-65/Section 33, printed pages 55–56/PDF indices 54–55; S007 carried-forward subsection.","Predicates, exceptions, currentness, confidence":"High. This is not full-payment insurance or Chapter 22 escrow."},"coordinator_verification_status":"2025_baseline_selected_text_checked_2026_amendment_body_held","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C036","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C037","Precise assertion":"Effective July 1, 2026, delegates must provide principal/agent/contact/complaint disclosures and a fraud warning, and DBCF has prescribed Form 001.","Source IDs and exact pinpoints":"S001 lines 28–31; S007 § 75-16-89; S008; S009.","Predicates, exceptions, currentness, confidence":"High. No named processor status inferred."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C037","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C038","Precise assertion":"When the TSR applies, qualifying dedicated-account funds must be customer-owned and independently administered, and withdrawal from the service requires return within seven business days of all funds except fees actually earned under the full federal trigger and allocation rule.","Source IDs and exact pinpoints":"S010, § 310.4(a)(5)(i)–(ii), lines 115–131.","Predicates, exceptions, currentness, confidence":"High as conditional federal rule. No universal coverage or Mississippi permission inferred."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C038","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C039","Precise assertion":"Service withdrawal, bank-account closure, ACH revocation, pending creditor-payment cancellation, and statutory refund are distinct events.","Source IDs and exact pinpoints":"Comparison of S003 § 81-22-11, S006 Section 29, and S010 § 310.4(a)(5)(ii)(E).","Predicates, exceptions, currentness, confidence":"High as analytical boundary; actual procedures depend on contracts and transaction status."},"coordinator_verification_status":"selected_text_checked_version_and_application_holds_remain","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C039","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"claim_id":"S_MS-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C040","Precise assertion":"No published DBCF interpretation or reported controlling decision was located in the bounded public search defining “supervised financial organization,” applying § 81-22-9 to an independent dedicated account, or construing the unusual “another licensee’s consumers” language.","Source IDs and exact pinpoints":"Bounded official/public case and agency searches.","Predicates, exceptions, currentness, confidence":"Medium negative finding. Not an exhaustive paid citator, docket, declaratory-order, or nonpublic agency-file search."},"coordinator_verification_status":"researcher_bounded_negative_search_not_reperformed_not_absence_proof","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_canonical_scoped_claim_id":"S_MS-P3-C040","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"}],"sources":[{"source_id":"S_MS-P3-S001","urls":["https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S001","Title, issuer, and direct literal URL":"Legislative Updates: 2026 Regular Session, Mississippi Department of Banking and Consumer Finance. https://dbcf.ms.gov/wp-content/uploads/2026/05/Legislative-Update-for-Website.2026-Regular-Session.Revised.pdf","Exact passage/version/effective status":"Three-page PDF. PDF page 1/index 0, lines 9–11: HB 1265 removes the July 1, 2026 repeal date and is effective July 1, 2026. Lines 12–31 summarize HB 1596 and its July 1, 2026 effectiveness.","Actual access and limitations":"Freshly read; previously read in P2. Official agency enactment summary, not full enacted wording or current-code audit. Metadata wording referring to 2019 does not match the visible 2026 body. \nMS Banking & Consumer Finance"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S002","urls":["https://legiscan.com/MS/text/HB1265/id/3401614"],"researcher_record":{"Source ID":"S_MS-P3-S002","Title, issuer, and direct literal URL":"HB 1265 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1265/id/3401614","Exact passage/version/effective status":"Reproduced document identifies itself as Mississippi Legislature, 2026 Regular Session, HB 1265, “As Sent to Governor.” Lines 60–99: § 81-22-3; lines 106–115: § 81-22-9; lines 116–133: § 81-22-11; lines 146–155: § 81-22-15; lines 211–218: § 81-22-28; line 220: July 1, 2026 effective clause.","Actual access and limitations":"Freshly read in P3. Nonofficial host. Host “Enrolled/Passed” labels were not used as status authority. Used to compare complete carried-forward wording with S003. \nLegiScan\n+2"},"coordinator_verification_status":"fresh_primary_legislative_text_nonofficial_host_signed_current_chain_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S003","urls":["https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S003","Title, issuer, and direct literal URL":"Mississippi Debt Management Services Act, DBCF-hosted compilation. https://dbcf.ms.gov/wp-content/uploads/2020/11/Mississippi-Debt-Management-Services-Act.pdf","Exact passage/version/effective status":"Thirteen PDF pages. § 81-22-9 on printed pages 5–6/PDF indices 4–5; § 81-22-11 on printed pages 6–7/indices 5–6; § 81-22-15 on printed page 8/index 7; § 81-22-25 on printed page 11/index 10; § 81-22-28 on printed pages 12–13/indices 11–12.","Actual access and limitations":"Relevant complete clauses freshly read and page images inspected. Agency-hosted primary-text compilation but historically stale: histories run through 2019 and headings carry an obsolete 2022 repeal date. Used with S001/S002, not alone for 2026 effectiveness. \nMS Banking & Consumer Finance\n+4"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S004","urls":["https://dbcf.ms.gov/consumer-finance/"],"researcher_record":{"Source ID":"S_MS-P3-S004","Title, issuer, and direct literal URL":"DBCF Consumer Finance page. https://dbcf.ms.gov/consumer-finance/","Exact passage/version/effective status":"Debt-management body at lines 113–136. Requires NMLS filing, security, agreement, fee schedule, third-party servicing/outsourcing contracts, and payment-processing narrative. Page also links current money-transmission materials.","Actual access and limitations":"Freshly read. Current public procedure only. Actual NMLS checklist, applicant materials, processor confirmation, and provider record were not read. \nMS Banking & Consumer Finance"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S005","urls":["https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S005","Title, issuer, and direct literal URL":"Mississippi Administrative Code, Title 5, Part 4, Organizational Rules, Mississippi Secretary of State. https://www.sos.ms.gov/adminsearch/ACCode/00000217c.pdf","Exact passage/version/effective status":"Twenty PDF pages. Rule 1.3(6) and 1.3(7)(a)–(d), printed pages 5–6/PDF indices 4–5, parsed lines 161–198.","Actual access and limitations":"Freshly reread; page images inspected. Confirms examination/investigation powers and government examination costs. It adds no detailed debt-management custody rule. No exhaustive rulemaking/adoption/current-version audit. \nMississippi Secretary of State"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S006","urls":["https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S006","Title, issuer, and direct literal URL":"Mississippi HB 1428 SG, Money Transmission Modernization Act, official DBCF-hosted legislative PDF. https://dbcf.ms.gov/wp-content/uploads/2025/07/HB1428SG.pdf","Exact passage/version/effective status":"Seventy-five PDF pages. Definitions on printed pages 5–10; exemptions pp. 10–14; license p. 20; records pp. 45–46; delegate relationship pp. 46–49; refunds pp. 49–51; receipts pp. 51–52; permissible investments/trust pp. 55–56; transition pp. 74–75; effective July 1, 2025.","Actual access and limitations":"Freshly read in all materially relied-on sections; relevant page images inspected. DBCF-hosted “As Sent to Governor” text with official page markings. DBCF’s current page identifies the act as effective July 1, 2025. Licensee-specific transition timing can depend on renewal and was not resolved for a named entity. \nMS Banking & Consumer Finance\n+3"},"coordinator_verification_status":"fresh_selected_2025_SG_text_2026_amendment_currency_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S007","urls":["https://legiscan.com/MS/text/HB1596/id/3411125"],"researcher_record":{"Source ID":"S_MS-P3-S007","Title, issuer, and direct literal URL":"Mississippi HB 1596 complete legislative-text reproduction, LegiScan host. https://legiscan.com/MS/text/HB1596/id/3411125","Exact passage/version/effective status":"Reproduced “As Sent to Governor” text. Lines 337–372 amend § 75-16-51; lines 373–379 carry forward § 75-16-65; lines 381–407 create § 75-16-89 and set July 1, 2026 effectiveness.","Actual access and limitations":"Freshly read. Nonofficial host; editorial enactment labels not treated as primary status proof. Currentness supported separately by S001, S008, and S009. \nLegiScan\n+1"},"coordinator_verification_status":"fresh_access_failed_current_amendment_body_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S008","urls":["https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S008","Title, issuer, and direct literal URL":"Memo to Industry — HB1596 Authorized Delegate Disclosure Requirements, DBCF, June 12, 2026. https://dbcf.ms.gov/wp-content/uploads/2026/06/Memo-to-Industry.Money-Transmitters.New-Disclosures.2026June12.pdf","Exact passage/version/effective status":"One-page PDF. Lines 9–28 explain § 75-16-89 delegate disclosures, website treatment, fraud warning, and July 1, 2026 effective date.","Actual access and limitations":"Freshly read; page image inspected. Official operational implementation memo. It does not interpret debt-management custody or Title 75-16 exemptions. \nMS Banking & Consumer Finance"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S009","urls":["https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf"],"researcher_record":{"Source ID":"S_MS-P3-S009","Title, issuer, and direct literal URL":"DBCF MTMA Form 001, Authorized Delegate Disclosures. https://dbcf.ms.gov/wp-content/uploads/2026/06/Authorized-Delegate-Disclosures.2026June12.pdf","Exact passage/version/effective status":"One-page form, effective July 1, 2026. Identifies delegate, principal licensed money transmitter, agency status, and complaint information.","Actual access and limitations":"Freshly read; page image inspected. Demonstrates prescribed public disclosure, not proof that any particular processor is an authorized delegate. \nMS Banking & Consumer Finance"},"coordinator_verification_status":"fresh_selected_primary_text_with_version_scope_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"},{"source_id":"S_MS-P3-S010","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_MS-P3-S010","Title, issuer, and direct literal URL":"16 C.F.R. § 310.4, Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact passage/version/effective status":"§ 310.4(a)(5)(i)(A)–(C), lines 115–122; dedicated-account requirements at § 310.4(a)(5)(ii)(A)–(E), lines 123–131. eCFR displayed Title 16 current through October 22, 2026.","Actual access and limitations":"Freshly read in P2 and relied upon here as the preserved conditional overlay. Authoritative but unofficial eCFR. No universal TSR coverage inferred. \neCFR"},"coordinator_verification_status":"fresh_selected_authoritative_unofficial_eCFR_body_coverage_held","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_verified_at":"2026-10-29T02:31:23.663853+00:00"}],"coverage":[{"topic":"Current continuation of relevant Chapter 22 clauses","researcher_record":{"Component":"Current continuation of relevant Chapter 22 clauses","Status":"Supported with prior current-chain limit","Claim IDs":"C001","Exact missing evidence / next investigation":"Obtain authenticated current code or signed/session-law chain and perform later-amendment check; do not repeat known failed HB 1265 routes absent a materially new route."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Direct provider receipt and two-day deposit","researcher_record":{"Component":"Direct provider receipt and two-day deposit","Status":"Answered textually","Claim IDs":"C003","Exact missing evidence / next investigation":"Determine settled-funds convention and application to reversals or returned items through an official interpretation or actual examined practice."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Federally insured institution requirement","researcher_record":{"Component":"Federally insured institution requirement","Status":"Answered at statutory level","Claim IDs":"C003","Exact missing evidence / next investigation":"Obtain bank agreement, institution charter/insurance, account title, and pass-through deposit-insurance analysis."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"“Supervised financial organization”","researcher_record":{"Component":"“Supervised financial organization”","Status":"Unresolved definition/application","Claim IDs":"C003, C023, C040","Exact missing evidence / next investigation":"Locate cross-code definition, DBCF interpretation, or controlling decision."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Consumer-benefit designation","researcher_record":{"Component":"Consumer-benefit designation","Status":"Answered textually; legal ownership partial","Claim IDs":"C003, C023","Exact missing evidence / next investigation":"Determine title, beneficial ownership, interest ownership, UCC status, and bankruptcy treatment."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Trustee-process/provider-creditor protection","researcher_record":{"Component":"Trustee-process/provider-creditor protection","Status":"Answered narrowly","Claim IDs":"C004","Exact missing evidence / next investigation":"Research Mississippi trustee process, consumer-creditor garnishment, processor creditors, bank setoff, and bankruptcy interaction."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Separate consumer records","researcher_record":{"Component":"Separate consumer records","Status":"Answered","Claim IDs":"C005, C009","Exact missing evidence / next investigation":"Examine actual subledger schema, opening balance, transaction IDs, pending items, and reconciliation controls."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Separate bank account per consumer","researcher_record":{"Component":"Separate bank account per consumer","Status":"Unresolved / not expressly required","Claim IDs":"C005, C023","Exact missing evidence / next investigation":"Obtain DBCF interpretation and actual pooled-account structure."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Operating-account commingling","researcher_record":{"Component":"Operating-account commingling","Status":"Answered","Claim IDs":"C005","Exact missing evidence / next investigation":"Determine treatment of fees, reimbursements, chargebacks, interest, and settlement adjustments in actual ledgers."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Fifteen-business-day creditor remittance","researcher_record":{"Component":"Fifteen-business-day creditor remittance","Status":"Answered textually","Claim IDs":"C006, C010","Exact missing evidence / next investigation":"Resolve receipt/good-funds date, consumer stop instructions, rejected transfers, and independent-account application."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Months-long principal accumulation","researcher_record":{"Component":"Months-long principal accumulation","Status":"Not established for direct custody; state dedicated-account application partial","Claim IDs":"C010, C019","Exact missing evidence / next investigation":"Obtain DBCF or controlling authority on independent debt-settlement accounts and inspect actual control rights."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Provider-caused misdirection","researcher_record":{"Component":"Provider-caused misdirection","Status":"Answered at duty level","Claim IDs":"C007","Exact missing evidence / next investigation":"Determine correction mechanism, duplicate-payment risk, processor attribution, consequential losses, and recovery rights."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Written account/institution disclosure","researcher_record":{"Component":"Written account/institution disclosure","Status":"Answered","Claim IDs":"C008","Exact missing evidence / next investigation":"Full agreement-form audit remains later."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Cancellation right","researcher_record":{"Component":"Cancellation right","Status":"Answered","Claim IDs":"C008, C020","Exact missing evidence / next investigation":"Determine effectiveness, pending-payment handling, return recipient, and contractual notice mechanics."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"General state cancellation-return deadline","researcher_record":{"Component":"General state cancellation-return deadline","Status":"Unresolved / none located in reviewed clauses","Claim IDs":"C020","Exact missing evidence / next investigation":"Research general contract, restitution, MCPA, unclaimed-property, insolvency, and remedies law."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Fee refund on cancellation","researcher_record":{"Component":"Fee refund on cancellation","Status":"Excluded/open","Claim IDs":"C020, C038","Exact missing evidence / next investigation":"Analyze actual earning history, contract, state consumer law, TSR facts, and remedies. No automatic refund or no-refund conclusion."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Quarterly consumer statements","researcher_record":{"Component":"Quarterly consumer statements","Status":"Answered","Claim IDs":"C009","Exact missing evidence / next investigation":"Review actual content, delivery, error correction, electronic consent, and statement reconciliation."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Six-year Chapter 22 records","researcher_record":{"Component":"Six-year Chapter 22 records","Status":"Answered","Claim IDs":"C009","Exact missing evidence / next investigation":"Determine record destruction, processor custody, and successor obligations after cessation."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Daily reconciliation and shortage cure","researcher_record":{"Component":"Daily reconciliation and shortage cure","Status":"Partial/unresolved","Claim IDs":"C005, C009, C023","Exact missing evidence / next investigation":"Chapter 22 is nonspecific; obtain examination manual, order, interpretation, or actual processor requirements."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Fair-share gross credit","researcher_record":{"Component":"Fair-share gross credit","Status":"Answered","Claim IDs":"C022","Exact missing evidence / next investigation":"Actual creditor and consumer statements needed for provider-level verification."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Processor functional boundary","researcher_record":{"Component":"Processor functional boundary","Status":"Answered at text level","Claim IDs":"C011, C012","Exact missing evidence / next investigation":"Inspect contract, bank/API permissions, ACH roles, affiliations, compensation, and sponsor-bank functions."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Ten-day processor notice","researcher_record":{"Component":"Ten-day processor notice","Status":"Answered","Claim IDs":"C013","Exact missing evidence / next investigation":"Obtain actual DBCF notice and receipt."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Highest-daily-funds reporting","researcher_record":{"Component":"Highest-daily-funds reporting","Status":"Answered","Claim IDs":"C013","Exact missing evidence / next investigation":"Obtain actual monthly calculation and methodology."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Processor security and pre-use confirmation","researcher_record":{"Component":"Processor security and pre-use confirmation","Status":"Answered architecturally","Claim IDs":"C014, C015, C017","Exact missing evidence / next investigation":"Actual bond/deposit, confirmation, term, cancellation, claims, and beneficiary analysis remain open."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Processor examination authorization","researcher_record":{"Component":"Processor examination authorization","Status":"Answered","Claim IDs":"C015","Exact missing evidence / next investigation":"Obtain actual authorization and DBCF sufficiency confirmation."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Processor termination","researcher_record":{"Component":"Processor termination","Status":"Answered at contract/agency-notice level","Claim IDs":"C016","Exact missing evidence / next investigation":"Consumer notice, migration, reconciliation, return, bank closure, and successor duties remain open."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Provider liability for processor failures","researcher_record":{"Component":"Provider liability for processor failures","Status":"Partial","Claim IDs":"C018","Exact missing evidence / next investigation":"Research agency, contract, negligence, statutory remedies, processor bond, and controlling decisions."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Provider/affiliate indirect control","researcher_record":{"Component":"Provider/affiliate indirect control","Status":"Partial","Claim IDs":"C002, C019","Exact missing evidence / next investigation":"Inspect actual transfer and account permissions; seek authoritative state interpretation."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Consumer-owned dedicated account","researcher_record":{"Component":"Consumer-owned dedicated account","Status":"Federal predicates answered; state treatment unresolved","Claim IDs":"C019, C038","Exact missing evidence / next investigation":"Determine state receipt/holding/control and § 81-22-3(c)(xi) treatment from actual architecture and authority."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Truly noncustodial consumer-paid model","researcher_record":{"Component":"Truly noncustodial consumer-paid model","Status":"Partial","Claim IDs":"C002, C019","Exact missing evidence / next investigation":"Prove no provider/affiliate access, custody, control, account compensation, or payment-chain role."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Provider bankruptcy report","researcher_record":{"Component":"Provider bankruptcy report","Status":"Answered","Claim IDs":"C021","Exact missing evidence / next investigation":"Full funds disposition, notice, successor servicing, bond and priority remain open."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Chapter 22 insolvency wind-down","researcher_record":{"Component":"Chapter 22 insolvency wind-down","Status":"Unresolved","Claim IDs":"C021, C023","Exact missing evidence / next investigation":"Research receivership, bankruptcy, bond, trust, bank, restitution, and regulatory-order authority."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Separate money-transmission gateway","researcher_record":{"Component":"Separate money-transmission gateway","Status":"Answered at framework level","Claim IDs":"C026, C027","Exact missing evidence / next investigation":"Apply to actual legal entities, account flows, consumer location, and transaction purpose."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Agent-of-payee exemption","researcher_record":{"Component":"Agent-of-payee exemption","Status":"Answered at predicate level; application unresolved","Claim IDs":"C028","Exact missing evidence / next investigation":"Obtain creditor-written appointment, public holding-out, debt extinguishment, and risk-of-loss proof."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Payment-system/intermediary/institution exemptions","researcher_record":{"Component":"Payment-system/intermediary/institution exemptions","Status":"Answered at predicate level","Claim IDs":"C029","Exact missing evidence / next investigation":"Obtain exact agreements, entity status, receipts, loss allocation, and functional scope."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Authorized-delegate contract","researcher_record":{"Component":"Authorized-delegate contract","Status":"Answered at current-text level","Claim IDs":"C030, C031","Exact missing evidence / next investigation":"Obtain principal license, delegate record, actual contract, scope, and DBCF/NMLS status."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Authorized-delegate cessation","researcher_record":{"Component":"Authorized-delegate cessation","Status":"Answered","Claim IDs":"C032","Exact missing evidence / next investigation":"Consumer notice and fund disposition remain unresolved."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Money-transmitter records/reconciliation","researcher_record":{"Component":"Money-transmitter records/reconciliation","Status":"Answered","Claim IDs":"C033","Exact missing evidence / next investigation":"Actual books, monthly reconciliations, exceptions, and examination findings unavailable."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Money-transmitter ten-day refund","researcher_record":{"Component":"Money-transmitter ten-day refund","Status":"Answered conditionally","Claim IDs":"C034","Exact missing evidence / next investigation":"Determine exclusions, commitment status, sender agreement, sufficient request, and whether debt payment is covered."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Money-transmitter receipts","researcher_record":{"Component":"Money-transmitter receipts","Status":"Answered conditionally","Claim IDs":"C035","Exact missing evidence / next investigation":"Apply transaction-purpose and payee-agreement exclusions."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Money-transmitter statutory trust","researcher_record":{"Component":"Money-transmitter statutory trust","Status":"Answered textually","Claim IDs":"C036","Exact missing evidence / next investigation":"Full claims, valuation, priority, administration, letters of credit, multistate allocation, and recovery later."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"2026 delegate disclosures","researcher_record":{"Component":"2026 delegate disclosures","Status":"Answered","Claim IDs":"C037","Exact missing evidence / next investigation":"Actual processor display and online implementation not checked."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Federal seven-business-day return","researcher_record":{"Component":"Federal seven-business-day return","Status":"Answered conditionally","Claim IDs":"C038, C039","Exact missing evidence / next investigation":"Establish actual TSR coverage, qualifying account, service-withdrawal request, and lawfully earned fees."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Withdrawal versus ACH/account closure","researcher_record":{"Component":"Withdrawal versus ACH/account closure","Status":"Distinguished; operational facts unresolved","Claim IDs":"C039","Exact missing evidence / next investigation":"Obtain consumer request, ACH authorization, bank rules, pending-transfer status, and account agreement."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Actual provider, processor, or bank authorization","researcher_record":{"Component":"Actual provider, processor, or bank authorization","Status":"Unresolved","Claim IDs":"C024, C026–C030","Exact missing evidence / next investigation":"Search named legal entity/NMLS IDs and retrieve public regulator records when an actual operator is supplied."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Full bond claims and recovery","researcher_record":{"Component":"Full bond claims and recovery","Status":"Excluded/open","Claim IDs":"C014, C017, C036","Exact missing evidence / next investigation":"Later bond component."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Full agreement, MCPA, restitution, remedies, private actions, and limitations","researcher_record":{"Component":"Full agreement, MCPA, restitution, remedies, private actions, and limitations","Status":"Excluded/open","Claim IDs":"C020–C021","Exact missing evidence / next investigation":"Later components."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"Collection, secured/sector debt, local, and tribal issues","researcher_record":{"Component":"Collection, secured/sector debt, local, and tribal issues","Status":"Excluded/open","Claim IDs":"None cleared","Exact missing evidence / next investigation":"Later components."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"“Regulated by FTC,” settlement approval, DMP-as-settlement, and one-debt/full-fee theories","researcher_record":{"Component":"“Regulated by FTC,” settlement approval, DMP-as-settlement, and one-debt/full-fee theories","Status":"Unchanged and unresolved","Claim IDs":"Preserved P1/P2 IDs","Exact missing evidence / next investigation":"No implication from this funds pass."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"},{"topic":"State, parent, A066, operational, or publication acceptance","researcher_record":{"Component":"State, parent, A066, operational, or publication acceptance","Status":"Not given","Claim IDs":"Entire table","Exact missing evidence / next investigation":"All preserved open categories remain required."},"coordinator_acceptance":"scoped_review_with_source_version_and_actual_application_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:31:23.663853+00:00"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_MS-P3-scoped-review-20261029","status":"reviewed_with_currentness_and_application_holds","at":null}]}