{"meta":{"key":"s_mt--pass-01","task":"S_MT","title":"SMT Montana provider market access and consumer fees","parent_title":"Montana debt and debt relief law","edition":"pass-01","path":"/research/s_mt--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":6,"claims":30,"sources":16,"review_status":"revise","review_complete":true,"sha256":"5bc239e7d8b4299d2592c6adb91b7ddc6b020fa72a07f09fed46100777ed82f0","headings":["A. Substantive findings","1. Classification and market access","2. Consumer fees","3. Fee timing and refunds","4. Direct verification of current settlement fee law","5. Federal fee timing — directly checked","6. Operational permission and verification","B. Source register","C. Claim register","D. Worked examples and classification tests","Example 1 — Settlement ceiling, $20,000 enrolled","Example 2 — Lower enrolled debt","Example 3 — Partial settlement under a consistent TSR allocation","Example 4 — Debt-management monthly charge","Example 5 — Cancellation after two completed debts","Example 6 — Custody changes the classification","Component coverage and gap table","Remaining holds","Researcher self-check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_MT/pass-01","facets":{"geography":["us","us-mt"],"debt_type":["unknown"],"stage":[],"subject":["definitions-classification","fees-outcomes","provider-licensing"]},"scope":"FreshMontanaprovider-access/feescomponentonly; allbroaderstatecategoriesrequired","pending_corrections":0},"markdown":"# S_MT PASS-01 — Montana provider market access and consumer fees\n\nSettleADebt.com | Individual state investigation | Research access: October 24, 2026 | Baseline: October 22, 2026\n\nResearch status: PARTIAL — substantive statutory pathways identified; several current-law, fee-timing, regulatory and operational questions remain held.\n\n## A. Substantive findings\n\nMontana has two materially different regulatory pathways for consumer debt services. This distinction is fundamental to determining whether SettleADebt.com could lawfully refer consumers to, advertise for, or operate through a particular provider.\n\n| Business model | Montana regulatory pathway | Initial finding |\n| --- | --- | --- |\n| Noncustodial debt settlement or negotiation for compensation | MCA Title 30, chapter 14, part 21 | Annual registration with Montana Department of Justice, Office of Consumer Protection |\n| Custodial debt management plan, collecting consumer funds for creditor distribution | MCA Title 30, chapter 14, part 20 | Debt management licensing |\n| Credit counseling associated with debt management services | Part 20; coverage depends on actual activities | Licensing potentially required; standalone counseling boundaries need further examination |\n| Settlement company that also receives or distributes consumer funds | Cannot assume part 21 applies | Separate classification required |\n| Attorney, nonprofit, institutional or creditor-affiliated model | Activity-specific statutory exclusions | No blanket exemption established |\n| Pure lead generation, advertising or referral business | Classification unresolved | No affirmative exemption or permission established |\n\nThe Montana Department of Justice expressly distinguishes debt management licensing from debt settlement registration. Its operational guidance identifies a $1,000 annual debt management license fee and a $250 annual debt settlement registration fee. These are government charges to providers, not fees that providers may automatically collect from consumers. Montana Department of Justice+2\n\n### 1. Classification and market access\n\nNoncustodial settlement — Part 21. MCA §30-14-2101 defines a debt settlement provider by compensated settlement activity, including holding itself out as offering the activity, where the provider does not ordinarily hold, receive or disburse debtor funds. Debt settlement services include negotiation, adjustment or settlement of a consumer's debt without handling those funds.\n\nThe statute expressly excludes several categories, including specified professionals acting in the ordinary practice of their professions, enumerated financial institutions, certain employees, public officials, business liquidators and entities governed by Part 20. Those exclusions have factual conditions; an attorney connection or nonprofit corporate status alone does not establish one. Montana Code Annotated+1\n\nCustodial debt management — Part 20. MCA §30-14-2003 defines a debt management plan around a written arrangement in which a credit counseling service receives consumer money to distribute to creditors. Its consumer definition is tied to individual personal, family or household obligations. MCA §30-14-2002 expressly applies to providers offering plans to Montana residents, supporting application to out-of-state providers serving those residents. Montana Code Annotated+1\n\nPart 20 excludes certain financial institutions, qualified Montana-licensed attorneys and CPAs whose counseling services are incidental rather than their principal business, and debt collectors that do not present themselves as credit counseling services. Justia Law\n\nImportant boundary: A provider cannot obtain the benefit of Part 21's noncustodial classification merely by calling a custodial debt management arrangement a settlement program. Conversely, the mere fact that a provider negotiates a reduced payoff does not establish that it receives and distributes consumer funds.\n\n### 2. Consumer fees\n\nTwo distinct fee structures have been identified.\n\n| Category | Fee provision | Status |\n| --- | --- | --- |\n| Debt management initial consultation | Maximum $75 under ARM 23.19.1005(1) | Identified in published regulation; latest official operative version not fully checked |\n| Debt management monthly maintenance | Lesser of $50 or 15% of monthly payment | Identified in ARM 23.19.1005(2); exceptions require further verification |\n| Debt management additional one-time charges | Counted as consultation fees regardless of name | ARM 23.19.1005(3) |\n| Debt management recurring charges | Counted as monthly maintenance fees regardless of name | ARM 23.19.1005(3) |\n| Debt settlement setup fees | Historical enacted legislation establishes a 5%-of-principal ceiling | Current codified provision still requires direct confirmation |\n| Debt settlement other service fees | Historical enacted legislation establishes a 20%-of-principal aggregate ceiling, excluding setup fees | Current codified provision still requires direct confirmation |\n\nThe debt management figures appear in the published text of ARM 23.19.1005, which also requires unrelated service charges to be reasonable and not tied to debt management services. The source records a January 27, 2006 effective date and February 10, 2006 transfer, but the current official regulatory compilation and any later amendments remain to be verified. Justia+1\n\nFor settlement, Montana's enacted 2009 HB 318 contains the 5% setup and 20% other-fee limits. Its text must be reconciled against the operative 2025 MCA §30-14-2103 and any subsequent legislative amendments before those figures are treated as independently current-verified ceilings. Montana Legislature+1\n\n### 3. Fee timing and refunds\n\nMCA §30-14-2010 requires a signed, dated debt management plan before consideration may be required or accepted for covered services. Its subsection (4) imposes additional restrictions, including limits on initial fees, maintenance fees, bundled services and unauthorized charges.\n\nA material consequence is that, outside the statutory bona fide error qualification, unauthorized fees can void the plan and require return of all fees received from or on behalf of the consumer. Justia Law\n\nThe enacted debt settlement legislation separately requires a signed contract specifying actual fees and when they will be charged. It also contains a cancellation provision concerning 50% of certain collected, unrefunded service fees, calculated pro rata for accounts without settlement offers, on the debtor's request. Setup fees are treated differently. The exact current statutory text and interaction with federal advance-fee restrictions remain verification holds. Montana Legislative Archive\n\nA Montana fee ceiling is not permission to collect an advance fee. Federal Telemarketing Sales Rule debt-relief restrictions must be assessed independently for covered telemarketing transactions. Federal text and exemptions have not yet been fully read in this pass, so no final collection schedule is approved.\n\n### 4. Direct verification of current settlement fee law\n\nThe official 2025 Montana Code Annotated, opened during this research, confirms the settlement fee provisions in §30-14-2103(1)(b). The earlier historical-only hold can therefore be narrowed: the 5% and 20% figures are confirmed in the published 2025 code, although a separate post-codification legislative-effectiveness check remains open.\n\nCrucially, the text says that fees other than setup fees may not exceed 20% of the principal amount and setup fees may not exceed 5%. It does not say the two categories share one 20% aggregate cap. Nor does that wording independently authorize collecting the full combined ceiling. Montana Code Annotated\n\nAdditional prohibitions relevant to the business model include compensation from persons other than the debtor or someone acting on the debtor's behalf, restrictions on creditor and debtor information, and advertising before filing a financial statement with the attorney general. These provisions create a significant unresolved question for affiliate and lead-generation compensation arrangements. Montana Code Annotated\n\nThe official §30-14-2102 also confirms a $250 annual filing charge, required financial statement, specified provider-identification information, insurance with at least $100,000 coverage and a deductible not exceeding $10,000, and prescribed written disclosures before contracting. These are operative statutory requirements distinct from an agency's application checklist. Montana Code Annotated\n\n### 5. Federal fee timing — directly checked\n\nThe eCFR displays Title 16 as updated through October 22, 2026. The text of 16 CFR §310.4(a)(5)(i) was directly opened.\n\nFor a covered debt-relief telemarketing transaction, a fee cannot be requested or received until all relevant conditions are satisfied:\n\n1. At least one debt has been renegotiated, settled, reduced or otherwise altered under a qualifying executed agreement.\n2. The consumer has made at least one payment under that agreement.\n3. For individually resolved debts, the provider uses a compliant proportional-enrolled-debt or constant-percentage-of-savings fee allocation.\n\nA mere enrollment, creditor offer, signed settlement without the required payment, or consumer deposit into a dedicated account does not itself establish that a service fee has been earned.\n\nThe rule separately permits qualifying dedicated accounts subject to conditions concerning the financial institution, consumer ownership, account-administrator independence, referral compensation, withdrawal and refunds. eCFR\n\nFor telemarketed services represented to improve credit history or remove derogatory information, §310.4(a)(2) imposes a different credit-repair fee-timing rule involving the represented performance period and a qualifying consumer report issued more than six months after results are achieved. Its coverage cannot be inferred solely from a provider's debt settlement label. CROA and the TSR's exemptions remain separately held. eCFR\n\n### 6. Operational permission and verification\n\nMontana DOJ's Office of Consumer Protection provides separate debt management and debt settlement application processes. Its published debt settlement instructions require annual registration, a $250 filing fee and notarized compliance documentation; registration expires January 31. Debt management licenses expire February 1. Montana Department of Justice\n\nThe DOJ's debt settlement checklist asks for the provider's standard agreement, disclosures, cancellation/refund policy, qualification standards, internal do-not-call policy and all fees involving the provider and third-party designees. This is useful operational evidence, but it does not establish that any particular applicant has been registered. Montana Department of Justice\n\nThe DOJ also publishes a list of licensed debt management companies. That list is not interchangeable with a current debt settlement registration lookup. Montana Department of Justice\n\nMarket-access determination: Montana has an identifiable statutory registration pathway for qualifying noncustodial settlement providers and a licensing pathway for qualifying debt management providers. This is not a determination that SettleADebt.com or any partner currently holds the required authorization.\n\n## B. Source register\n\nAll source IDs are unique to this Montana PASS-01. Access date is October 24, 2026. “Read” means operative text was returned and inspected; “excerpt” means only the displayed passage was examined. A source's publication or crawl date is not treated as its legal effective date.\n\n| Source ID | Authority, literal URL and pinpoint | Verification and limitations |\n| --- | --- | --- |\n| S_MT-P1-S001 | Montana Legislature, MCA 2025, §30-14-2101. [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html?utm_source=chatgpt.com) | Official older 2023 version excerpt read; current 2025 URL not separately opened. Classification currentness hold. |\n| S_MT-P1-S002 | Montana Legislature, MCA 2025, §30-14-2102(1)–(3). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html?utm_source=chatgpt.com) | Official 2025 text directly opened and read. |\n| S_MT-P1-S003 | Montana Legislature, MCA 2025, §30-14-2103(1)(a)–(n), (2). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html?utm_source=chatgpt.com) | Official 2025 text directly opened and read. |\n| S_MT-P1-S004 | Montana Legislature, MCA 2025, §30-14-2104(1)–(3). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html?utm_source=chatgpt.com) | Official remedies excerpt read; full litigation implications deferred. |\n| S_MT-P1-S005 | Montana Legislature, MCA 2025, §30-14-2002(1)–(2). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html?utm_source=chatgpt.com) | 2025 secondary reproduction read; official 2025 section not directly opened. |\n| S_MT-P1-S006 | Montana Legislature, MCA 2025, §30-14-2003(1)–(4). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html?utm_source=chatgpt.com) | Official 2025 definitions excerpt read. |\n| S_MT-P1-S007 | Montana Legislature, MCA 2025, §30-14-2004(1)–(2). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html?utm_source=chatgpt.com) | Secondary 2025 reproduction partially read; full official licensing conditions held. |\n| S_MT-P1-S008 | Montana Legislature, MCA 2025, §30-14-2010(1), (4)(a)–(g). [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html?utm_source=chatgpt.com) | Secondary 2025 reproduction read; official page not separately opened. |\n| S_MT-P1-S009 | Montana administrative rule 23.19.1005(1)–(4). [https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005](https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005?utm_source=chatgpt.com) | Regulation reproduced and read; 2006 adoption/transfer history. Official 2026 amendment check held. |\n| S_MT-P1-S010 | Montana DOJ, Debt Management and Debt Settlement Businesses. [https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/](https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/?utm_source=chatgpt.com) | Agency operational page excerpt read; displayed update December 12, 2025. Not a statutory effective date. |\n| S_MT-P1-S011 | Montana DOJ, Debt Settlement Application and Registration Checklist, Form OCP-801, revision 02/19, page 3. [https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf](https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf?utm_source=chatgpt.com) | Application excerpt read; complete eight-page form not audited. |\n| S_MT-P1-S012 | Montana DOJ, Debt Relief, licensed debt management company list. [https://dojmt.gov/office-of-consumer-protection/debt-relief/](https://dojmt.gov/office-of-consumer-protection/debt-relief/?utm_source=chatgpt.com) | Agency listing excerpt read; no named provider verified. |\n| S_MT-P1-S013 | 61st Montana Legislature, HB 318 (2009), §§1–4. [https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf](https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf?utm_source=chatgpt.com) | Enacted historical text excerpts read; current provisions cross-checked selectively against S002/S003. |\n| S_MT-P1-S014 | FTC, 16 CFR §310.4(a)(2), (a)(5)(i)–(ii). [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com) | Federal operative text directly opened; eCFR Title 16 displayed through October 22, 2026. |\n| S_MT-P1-S015 | Montana DOJ Banking Division, overview. [https://banking.mt.gov/BFID/](https://banking.mt.gov/BFID/?utm_source=chatgpt.com) | Agency operational page read; relevant to distinct financial-service licensing, not proof of settlement authorization. |\n| S_MT-P1-S016 | Montana DOJ Banking Division, enforcement actions. [https://banking.mt.gov/BFID/enforcement-actions](https://banking.mt.gov/BFID/enforcement-actions?utm_source=chatgpt.com) | Agency enforcement index read; no controlling debt-settlement decision established from it. |\n\nThe directly opened official Montana provisions and federal text are supported by the corresponding primary-source results. Montana Code Annotated+3\n\nStill missing from the primary-source register: the full official current ARM chapter, relevant adoption/amendment notices, complete current application instructions for both programs, any controlling Montana judicial construction of ambiguous fee provisions, and a complete 2026 legislative-change check. Those sources are not silently treated as verified.\n\n## C. Claim register\n\nConfidence describes the strength of the evidence actually examined, not an independent legal opinion.\n\n| Claim ID | Precise finding | Sources / pinpoint | Status |\n| --- | --- | --- | --- |\n| S_MT-P1-C001 | Noncustodial compensated settlement falls within the Part 21 definition, subject to enumerated exclusions. | S001 §2101(1)–(2) | High for examined text; 2025 direct check held |\n| C002 | Part 21 defines principal as the individual's total debt when accepted into the program. | S001 §2101(3) | High for examined text; current direct check held |\n| C003 | Part 20 defines consumer debt by personal, family or household purpose. | S006 §2003(1) | High |\n| C004 | Receiving consumer money for distribution to creditors is central to the statutory DMP definition. | S006 §2003(4) | High |\n| C005 | Part 20 expressly reaches offers to Montana residents and contains activity-specific exclusions. | S005 §2002(1)–(2) | High for reproduced 2025 text |\n| C006 | Covered debt management and credit counseling activity requires licensing. | S007 §2004(1) | High for reproduced text; full scope held |\n| C007 | Noncustodial settlement providers must meet annual filing and financial-statement requirements. | S002 §2102(2) | High |\n| C008 | Settlement provider annual government filing charge is $250. | S002 §2102(2)(b); S010 | High |\n| C009 | Settlement insurance minimum is $100,000, deductible maximum $10,000. | S002 §2102(1) | High |\n| C010 | Settlement disclosures precede agreement and require at least 12-point type. | S002 §2102(3) | High |\n| C011 | Settlement nonsetup fees have a 20%-of-principal aggregate ceiling. | S003 §2103(1)(b) | High for published 2025 law |\n| C012 | Settlement setup fees have a separate 5%-of-principal ceiling. | S003 §2103(1)(b) | High for published 2025 law |\n| C013 | Written settlement contract and actual fee schedule precede fee collection. | S003 §2103(1)(a), (k) | High |\n| C014 | Settlement advertising requires prior financial-statement filing. | S003 §2103(1)(l) | High |\n| C015 | Third-party compensation for performing settlement services is restricted. | S003 §2103(1)(g) | High for wording; application to affiliate models held |\n| C016 | Qualifying cancellation requires a requested 50% refund on a pro rata basis for specified unsettled accounts. | S003 §2103(2) | High for text; allocation interpretation held |\n| C017 | DMP consultation ceiling is $75. | S009 ARM 23.19.1005(1) | Provisional currentness |\n| C018 | DMP maintenance ceiling is lesser of $50 or 15% of monthly payment. | S009 ARM 23.19.1005(2) | Provisional; exceptions held |\n| C019 | One-time and recurring charges cannot evade their respective DMP categories by relabeling. | S009 ARM 23.19.1005(3) | Provisional currentness |\n| C020 | Covered DMP fees require the statutory written-plan prerequisites. | S008 §2010(1), (4) | High for reproduced 2025 text |\n| C021 | Certain unauthorized DMP fees void the plan and require fee return, subject to bona fide error. | S008 §2010(4)(g) | High for reproduced text |\n| C022 | DOJ reports a $1,000 annual DMP license fee. | S010 | Operationally supported; controlling rule amount held |\n| C023 | DOJ describes separate annual registration and licensing procedures. | S010 | High for agency procedure |\n| C024 | The DOJ checklist requires disclosure of provider and third-party charges. | S011 p. 3, D8 | High for examined form |\n| C025 | Covered TSR debt-relief fees require an executed resolution agreement, at least one qualifying payment, and compliant allocation. | S014 §310.4(a)(5)(i) | High, conditional on federal coverage |\n| C026 | The TSR allows qualifying dedicated accounts without treating deposits as earned service fees. | S014 §310.4(a)(5)(ii) | High, conditional on coverage |\n| C027 | Telemarketed credit-improvement representations can invoke distinct fee-timing requirements. | S014 §310.4(a)(2) | High, conditional on coverage |\n| C028 | A named provider's current registration cannot be established from the existence of a registration procedure. | S010–S012 | High methodological conclusion |\n| C029 | Montana Part 21 does not establish a universal exemption for nonprofits, attorneys or lead generators. | S001 §2101; S003 §2103 | High as to lack of blanket exemption; particular models held |\n| C030 | The 2025 codification repeats the enacted 2009 settlement fee ceilings. | S003 §2103(1)(b); S013 §3 | High; post-2025 change check open |\n\nNo claim in this register asserts that the two settlement percentages may necessarily be added into a collectible 25% fee. C011 and C012 establish distinct statutory ceilings, not a completed federal or contractual permission analysis.\n\n## D. Worked examples and classification tests\n\nThese are arithmetic and statutory-boundary demonstrations, not approved Montana consumer fee schedules.\n\n### Example 1 — Settlement ceiling, $20,000 enrolled\n\nAssume an individual enrolls $20,000 in qualifying consumer debt with a provider covered by Part 21.\n\n- Setup ceiling: $20,000 × 0.05 = $1,000.\n- Other-fee aggregate ceiling: $20,000 × 0.20 = $4,000.\n- Arithmetic sum of separate ceilings: $5,000.\n\nAll amounts are dollars, calculated to the cent without intermediate rounding.\n\nThe $5,000 figure is not a determination that the provider may contract for or collect that sum. Actual fees must satisfy contract, state and applicable federal timing rules. If the TSR applies, a $1,000 upfront setup charge cannot be collected merely because Montana establishes a 5% ceiling.\n\nClaims: C002, C011–C013, C025.\n\n### Example 2 — Lower enrolled debt\n\nPrincipal amount at enrollment: $4,000.\n\n- 5% setup ceiling: $200.\n- 20% other-fee aggregate ceiling: $800.\n- Separate ceiling arithmetic: $1,000.\n\nThis illustrates that the state percentages are tied to the defined principal base, not automatically to settlement savings or the eventual amount paid to the creditor.\n\nClaims: C002, C011, C012.\n\n### Example 3 — Partial settlement under a consistent TSR allocation\n\nAssume the TSR applies and the provider uses the proportional-enrolled-balance method, with a hypothetical $3,000 total contracted service fee, excluding any separately discussed setup fee.\n\nEnrollment:\n\n| Debt | Enrollment balance | Allocation of $3,000 fee |\n| --- | --- | --- |\n| A | $4,000 | $600 |\n| B | $6,000 | $900 |\n| C | $10,000 | $1,500 |\n| Total | $20,000 | $3,000 |\n\nCalculation: Debt A fee = $3,000 × ($4,000 ÷ $20,000) = $600.\n\nSuppose Debt A is settled for $2,200, an executed settlement agreement exists, and the consumer makes the first required payment. The federal conditions could permit the allocated $600 to be requested, assuming all other legal requirements are satisfied.\n\nIf Debt B later reaches the same performance triggers, the additional allocated fee is $900. Cumulative potentially earned service fees become $1,500, leaving $\n\n\n\n…**$1,500 allocated to Debt C and still unearned.**\n\nThe same allocation and performance method must remain in place across all three debts:\n\n- Debt A: $600 allocated fee; earned only after Debt A satisfies the executed-resolution and qualifying-payment conditions.\n- Debt B: $900 allocated fee; earned only after Debt B separately satisfies those conditions.\n- Debt C: $1,500 allocated fee; not earned merely because the consumer made a payment on Debt A or Debt B.\n\nThus, after qualifying performance on Debts A and B, the internally consistent result is:\n\n$600+$900=$1,500 potentially earned\\$600+\\$900=\\$1,500\\text{ potentially earned}$600+$900=$1,500 potentially earned$3,000−$1,500=$1,500 remaining allocation to Debt C\\$3,000-\\$1,500=\\$1,500\\text{ remaining allocation to Debt C}$3,000−$1,500=$1,500 remaining allocation to Debt CIf Debt B merely receives an offer, but the consumer has not executed the qualifying agreement and made the required first payment under that agreement, only Debt A’s $600 could potentially be earned. The remaining $2,400 would not yet satisfy the stated federal performance method.\n\nThe hypothetical $3,000 total contracted service fee equals 15% of the same $20,000 enrolled principal:\n\n$3,000÷$20,000=15%\\$3,000\\div \\$20,000=15\\%$3,000÷$20,000=15%That is numerically below the examined Montana 20% ceiling for nonsetup fees. It does **not** by itself establish lawful collection. It does not resolve federal coverage, contract compliance, Montana registration, whether any separate setup fee was contracted, or cancellation and refund consequences. No percentage-of-savings method may be substituted midway merely because it would produce a more favorable result.\n\nClaims: S_MT-P1-C002, C011–C013, C025.\n\n### Example 4 — Debt-management monthly charge\n\nAssume a covered debt-management plan requires a $240 monthly consumer payment.\n\nUnder the examined ARM text:\n\n15%×$240=$3615\\%\\times \\$240=\\$3615%×$240=$36The lesser of $50 or $36 is **$36**. Therefore, the provisional monthly maintenance ceiling is $36.\n\nIf the provider charges:\n\n- $30 labeled “maintenance”; and\n- $10 labeled “monthly administration”;\n\nthe examined anti-relabeling provision treats both recurring charges as monthly maintenance charges. The combined $40 would exceed the $36 ceiling by $4.\n\nA separate initial consultation charge could not exceed the examined $75 ceiling, but it still would require compliance with the applicable written-plan and fee prerequisites. These results remain provisional because the official current ARM compilation, complete amendment history, and any operative exception or waiver branch were not fully verified.\n\nClaims: S_MT-P1-C017–C021.\n\n### Example 5 — Cancellation after two completed debts\n\nPreserve the Example 3 facts:\n\n- Debt A allocated fee: $600.\n- Debt B allocated fee: $900.\n- Debt C allocated fee: $1,500.\n- Total contracted service fee: $3,000.\n- Debts A and B have separately satisfied the stated performance conditions.\n- Debt C has not received a qualifying settlement offer and has not satisfied the federal collection trigger.\n\nOn those facts, $1,500 has potentially been earned under the consistent allocation method and $1,500 remains allocated to Debt C.\n\nNo exact Montana cancellation refund can be calculated from those facts alone. The examined state provision refers to a requested 50% refund of specified collected, unrefunded service fees, allocated pro rata to accounts without settlement offers. Applying it requires facts not supplied here, including:\n\n- Exactly which fees were collected.\n- Which debt each collection was allocated to.\n- Whether Debt C had any settlement offer.\n- Whether an amount was already refunded.\n- The contract’s lawful allocation terms.\n- Whether any collection for Debt C occurred before federal performance.\n\nIf no amount was collected for Debt C, there is no Debt C collection from which to calculate a numerical refund. If $1,500 had been collected for Debt C before its performance trigger, Montana’s refund language would not transform that premature collection into an earned fee; federal legality and available remedies would require separate analysis.\n\nClaims: S_MT-P1-C016, C025. The exact state cancellation allocation remains held.\n\n### Example 6 — Custody changes the classification\n\n**Model A:** A provider negotiates reductions but never receives, holds, or distributes the consumer’s money. That is a Part 21 candidate, subject to the actual statutory definition, exclusions, registration, contract, disclosure, fee, and advertising conditions.\n\n**Model B:** The same provider begins receiving monthly consumer funds and distributing them to creditors. The noncustodial assumption has failed. Part 20 debt-management coverage—or another hybrid classification—must be analyzed before fees are modeled.\n\nCalling Model B “debt settlement” does not preserve Model A’s classification. No lawful Model B fee scenario is established merely from the Part 21 percentages.\n\nClaims: S_MT-P1-C001, C004–C007.\n\n## Component coverage and gap table\n\n| Component | Status | Existing claim IDs | Exact unresolved question or next investigation |\n| --- | --- | --- | --- |\n| Noncustodial settlement definition | Answered for examined text | C001–C002 | Directly open and compare the official current §30-14-2101 version against the examined prior-version text. |\n| Custodial DMP definition | Answered for examined text | C003–C004 | Confirm the complete current official text and any definitions elsewhere incorporated by reference. |\n| Consumer versus business-purpose debt | Partial | C003 | Part 20’s personal, family, or household boundary was identified; confirm whether Part 21 independently limits the debtor or debt by purpose. |\n| Montana-resident and remote-provider nexus | Partial | C005 | Part 20 expressly addresses offers to Montana residents; determine Part 21’s complete territorial reach for remote providers, advertising, referrals, and contracting. |\n| Hybrid settlement provider handling funds | Unresolved | C001, C004 | Determine whether Part 20 displaces Part 21, whether both can apply, and how dedicated-account structures affect classification. |\n| Settlement registration pathway | Answered at statutory level | C007–C010, C023 | Obtain and verify the current complete application package and operative annual renewal instructions. |\n| Debt-management licensing pathway | Partial | C006, C022–C023 | Verify the full official licensing statute, rule chapter, application requirements, and controlling source for the $1,000 government fee. |\n| Attorney and professional exclusions | Partial | C001, C005, C029 | Test ordinary-practice, incidental-service, principal-business, compensation, and entity-structure conditions; no blanket attorney exemption established. |\n| Nonprofit status | Partial | C029 | Identify whether any separate Montana provision creates a qualified nonprofit exclusion; nonprofit status alone was not established as sufficient. |\n| Self-creditor and institutional exclusions | Partial | C001, C005 | Read each exclusion’s complete entity and activity conditions and determine treatment of affiliates, servicers, and agents. |\n| Lead generation, advertising, and referral activity | Unresolved | C014–C015, C029 | Determine when marketing, intake, referral compensation, qualification, or holding out constitutes covered service or prohibited third-party compensation. |\n| Settlement setup-fee ceiling | Answered for published 2025 text | C012, C030 | Check post-2025 amendments and whether any other provision narrows the base or collection method. |\n| Settlement nonsetup-fee ceiling | Answered for published 2025 text | C011, C030 | Resolve application to per-debt fees, savings-based fees, bundled fees, and fees paid to designees. |\n| Relationship between 5% and 20% ceilings | Partial | C011–C013 | The ceilings are textually separate; determine whether contract, agency, or judicial authority limits their combined use. No collectible 25% fee was established. |\n| Settlement fee base | Partial | C002, C011–C012 | Confirm treatment of debts added, removed, disputed, secured, previously settled, or rejected after initial acceptance. |\n| Settlement indexing or adjusted amounts | Unresolved | No verified original claim ID | Search current statutes, amendment acts, agency notices, and rules for indexing, adjustment, or superseding schedules. No CPI calculation may be invented. |\n| DMP consultation and maintenance amounts | Partial | C017–C019 | Verify the official current ARM text, all amendments, exceptions, waivers, and any no-agreement counseling branch. |\n| DMP anti-relabeling rule | Partial | C019 | Confirm current operative status and treatment of third-party, optional, technology, enrollment, and creditor-funded charges. |\n| State settlement fee timing | Partial | C013 | A written contract and fee schedule were identified; determine every state performance trigger and whether any fee category may lawfully precede performance. |\n| State DMP fee timing | Partial | C020–C021 | Confirm prerequisites for consultation before a plan, plan execution, recurring charges, failed enrollment, cancellation, and bona fide error. |\n| Federal TSR debt-relief timing | Answered conditionally | C025 | Determine transaction-specific TSR coverage, exemptions, inbound/outbound call path, seller/telemarketer roles, and allocation compliance. |\n| Federal dedicated-account provision | Answered conditionally | C026 | Verify actual account ownership, administrator independence, referral compensation, withdrawal, and refund facts for any proposed structure. |\n| TSR credit-repair timing | Partial | C027 | Determine whether actual representations concern credit-history improvement or removal of derogatory information; then apply the separate timing rule. |\n| CROA overlap | Unresolved | No verified original claim ID | Read the current CROA definitions, exclusions, advance-payment prohibition, contract and cancellation provisions, and controlling cases before asserting coverage. |\n| Settlement cancellation and refund | Partial | C016 | Resolve “collected,” “unrefunded,” “service fees,” “settlement offer,” pro rata allocation, setup-fee treatment, and interaction with federal premature collection. |\n| DMP voiding and fee return | Partial | C021 | Verify the complete bona fide error language, cure consequences, private enforcement, and scope of “all fees.” |\n| Government charges versus consumer fees | Answered as a boundary | C008, C022 | Confirm current government charges from controlling law; neither registration nor licensing charges were established as pass-through consumer fees. |\n| Agency application and instructions | Partial | C023–C024 | The examined checklist was revision 02/19 and not audited in full; obtain the current complete forms and revision history. |\n| Current settlement registry or provider lookup | Unresolved | C028 | Locate an official current settlement-registration roster, searchable database, public-record route, or agency instruction describing verification. |\n| Named provider authorization | Not established | C028 | Check each provider individually through an official current record; marketing claims or application eligibility are insufficient. |\n| Worked settlement examples | Answered as bounded demonstrations | C002, C011–C013, C025 | Recalculate only after actual contract, fee allocation, debt changes, performance, collections, and refunds are known. |\n| Worked DMP example | Partial | C017–C021 | Current official rule verification is required before using the example operationally. |\n| Contract-specific enforceability | Unresolved | C013, C016 | Review the actual agreement, disclosures, allocation method, cancellation language, third-party fees, and governing-law provisions. |\n| Controlling Montana court decisions | Unresolved | No verified original claim ID | Search for construction of Parts 20 and 21, fee bases, exemptions, remote nexus, refunds, and remedies. |\n| Official interpretations and adoption history | Unresolved | No verified original claim ID | Obtain full ARM adoption/amendment orders, DOJ interpretations, declaratory rulings, and superseded guidance. |\n| October 24, 2026 currentness | Partial | C030 | Complete a post-2025 session-law, future-effective-law, rulemaking, repeal, stay, and litigation-status check. |\n| Agreements, custody, bonds, insurance, and remedies beyond present necessity | Deferred | C009 only for examined insurance minimum | Full agreement, funds, bond, insurance, enforcement, restitution, civil-penalty, and private-remedy analysis belongs in later passes. |\n| Collections, litigation, limitations, exemptions, secured debt, sectors, local, tribal, and case-law coverage | Excluded from this component | No verified original claim ID | Conduct separate required passes; nothing here constitutes acceptance or closure of those categories. |\n\n## Remaining holds\n\nNo conclusion in this continuation establishes that:\n\n- A particular provider is registered or licensed.\n- Montana permits advance collection merely because a percentage ceiling exists.\n- A nonprofit, attorney-affiliated, creditor-affiliated, or referral model is exempt.\n- A dedicated account avoids Montana classification or federal timing.\n- The examined ARM amounts remain unchanged through October 24, 2026.\n- CROA does or does not apply to a particular marketing presentation.\n- The state cancellation provision yields a specific refund without account-level facts.\n- SettleADebt.com’s contemplated role is outside Parts 20 or 21.\n\nThe provider-access and fee component therefore remains **partial and unaccepted**, with all parent-dossier, A066, operational, and publication decisions reserved.\n\n## Researcher self-check\n\n**Actual research access date:** October 24, 2026. This continuation adds no new browsing or source access; it completes omitted output using the preserved PASS-01 record.\n\n**Actually opened and read in the preserved research:** official 2025 Montana pages for §§30-14-2102 and 30-14-2103; the operative displayed text of 16 CFR §310.4(a)(2) and (a)(5); selected statutory excerpts or reproductions for §§30-14-2101, 30-14-2002, 30-14-2003, 30-14-2004, and 30-14-2010; the reproduced ARM 23.19.1005 text; selected Montana DOJ operational-page and checklist passages; and selected enacted HB 318 passages.\n\n**Read only as excerpts, reproductions, or limited portions:** the current §30-14-2101 route, several Part 20 provisions, the DOJ application checklist, the debt-relief listing, and the historical bill. Those materials were not treated as complete operative verification where the full current official source was not opened.\n\n**Discovery or incomplete operational evidence:** agency page titles, available company-list material, form references, enforcement indexes, and search-rendered passages. They establish routes or limited procedure, not complete legal permission or a named provider’s current status.\n\n**Not fully read or verified:** the complete official current ARM chapter and adoption orders; all current application forms; a current settlement registry; post-2025 Montana legislative changes; future-effective or proposed provisions; controlling Montana decisions; complete TSR exemptions; CROA; FTC interpretive materials; and the later-pass agreement, funds, bond, remedies, collection, limitation, secured-debt, sector, local, and tribal issues.\n\nNo foundation cell was accepted as evidence-backed Montana coverage. No CAPTCHA workaround, contact, application, account change, private-data access, local write, publication, or independent review occurred. Search-rendered excerpts were not treated as complete operative verification.\n\n**REPORT PARTIAL — S_MT PASS-01 provider-access/fees component only.**\n\nEND S_MT PASS-01\n\nEND S_MT PASS-01-CONTINUATION-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Business model","Montana regulatory pathway","Initial finding"],["Noncustodial debt settlement or negotiation for compensation","MCA Title 30, chapter 14, part 21","Annual registration with Montana Department of Justice, Office of Consumer Protection"],["Custodial debt management plan, collecting consumer funds for creditor distribution","MCA Title 30, chapter 14, part 20","Debt management licensing"],["Credit counseling associated with debt management services","Part 20; coverage depends on actual activities","Licensing potentially required; standalone counseling boundaries need further examination"],["Settlement company that also receives or distributes consumer funds","Cannot assume part 21 applies","Separate classification required"],["Attorney, nonprofit, institutional or creditor-affiliated model","Activity-specific statutory exclusions","No blanket exemption established"],["Pure lead generation, advertising or referral business","Classification unresolved","No affirmative exemption or permission established"]],"segment":1,"original_table_index":0},{"headers":[],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Category","Fee provision","Status"],["Debt management initial consultation","Maximum $75 under ARM 23.19.1005(1)","Identified in published regulation; latest official operative version not fully checked"],["Debt management monthly maintenance","Lesser of $50 or 15% of monthly payment","Identified in ARM 23.19.1005(2); exceptions require further verification"],["Debt management additional one-time charges","Counted as consultation fees regardless of name","ARM 23.19.1005(3)"],["Debt management recurring charges","Counted as monthly maintenance fees regardless of name","ARM 23.19.1005(3)"],["Debt settlement setup fees","Historical enacted legislation establishes a 5%-of-principal ceiling","Current codified provision still requires direct confirmation"],["Debt settlement other service fees","Historical enacted legislation establishes a 20%-of-principal aggregate ceiling, excluding setup fees","Current codified provision still requires direct confirmation"]],"segment":1,"original_table_index":1},{"headers":[],"index":2,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html"},{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005"},{"href":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/?utm_source=chatgpt.com","text":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/"},{"href":"https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf?utm_source=chatgpt.com","text":"https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf"},{"href":"https://dojmt.gov/office-of-consumer-protection/debt-relief/?utm_source=chatgpt.com","text":"https://dojmt.gov/office-of-consumer-protection/debt-relief/"},{"href":"https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf?utm_source=chatgpt.com","text":"https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"},{"href":"https://banking.mt.gov/BFID/?utm_source=chatgpt.com","text":"https://banking.mt.gov/BFID/"},{"href":"https://banking.mt.gov/BFID/enforcement-actions?utm_source=chatgpt.com","text":"https://banking.mt.gov/BFID/enforcement-actions"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html?utm_source=chatgpt.com","text":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html"}],[{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005"}],[{"href":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/?utm_source=chatgpt.com","text":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/"}],[{"href":"https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf?utm_source=chatgpt.com","text":"https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf"}],[{"href":"https://dojmt.gov/office-of-consumer-protection/debt-relief/?utm_source=chatgpt.com","text":"https://dojmt.gov/office-of-consumer-protection/debt-relief/"}],[{"href":"https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf?utm_source=chatgpt.com","text":"https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com","text":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"}],[{"href":"https://banking.mt.gov/BFID/?utm_source=chatgpt.com","text":"https://banking.mt.gov/BFID/"}],[{"href":"https://banking.mt.gov/BFID/enforcement-actions?utm_source=chatgpt.com","text":"https://banking.mt.gov/BFID/enforcement-actions"}]],"rows":[["Source ID","Authority, literal URL and pinpoint","Verification and limitations"],["S_MT-P1-S001","Montana Legislature, MCA 2025, §30-14-2101. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html","Official older 2023 version excerpt read; current 2025 URL not separately opened. Classification currentness hold."],["S_MT-P1-S002","Montana Legislature, MCA 2025, §30-14-2102(1)–(3). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html","Official 2025 text directly opened and read."],["S_MT-P1-S003","Montana Legislature, MCA 2025, §30-14-2103(1)(a)–(n), (2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html","Official 2025 text directly opened and read."],["S_MT-P1-S004","Montana Legislature, MCA 2025, §30-14-2104(1)–(3). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html","Official remedies excerpt read; full litigation implications deferred."],["S_MT-P1-S005","Montana Legislature, MCA 2025, §30-14-2002(1)–(2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html","2025 secondary reproduction read; official 2025 section not directly opened."],["S_MT-P1-S006","Montana Legislature, MCA 2025, §30-14-2003(1)–(4). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html","Official 2025 definitions excerpt read."],["S_MT-P1-S007","Montana Legislature, MCA 2025, §30-14-2004(1)–(2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html","Secondary 2025 reproduction partially read; full official licensing conditions held."],["S_MT-P1-S008","Montana Legislature, MCA 2025, §30-14-2010(1), (4)(a)–(g). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html","Secondary 2025 reproduction read; official page not separately opened."],["S_MT-P1-S009","Montana administrative rule 23.19.1005(1)–(4). https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005","Regulation reproduced and read; 2006 adoption/transfer history. Official 2026 amendment check held."],["S_MT-P1-S010","Montana DOJ, Debt Management and Debt Settlement Businesses. https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/","Agency operational page excerpt read; displayed update December 12, 2025. Not a statutory effective date."],["S_MT-P1-S011","Montana DOJ, Debt Settlement Application and Registration Checklist, Form OCP-801, revision 02/19, page 3. https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf","Application excerpt read; complete eight-page form not audited."],["S_MT-P1-S012","Montana DOJ, Debt Relief, licensed debt management company list. https://dojmt.gov/office-of-consumer-protection/debt-relief/","Agency listing excerpt read; no named provider verified."],["S_MT-P1-S013","61st Montana Legislature, HB 318 (2009), §§1–4. https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf","Enacted historical text excerpts read; current provisions cross-checked selectively against S002/S003."],["S_MT-P1-S014","FTC, 16 CFR §310.4(a)(2), (a)(5)(i)–(ii). https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Federal operative text directly opened; eCFR Title 16 displayed through October 22, 2026."],["S_MT-P1-S015","Montana DOJ Banking Division, overview. https://banking.mt.gov/BFID/","Agency operational page read; relevant to distinct financial-service licensing, not proof of settlement authorization."],["S_MT-P1-S016","Montana DOJ Banking Division, enforcement actions. https://banking.mt.gov/BFID/enforcement-actions","Agency enforcement index read; no controlling debt-settlement decision established from it."]],"segment":1,"original_table_index":2},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise finding","Sources / pinpoint","Status"],["S_MT-P1-C001","Noncustodial compensated settlement falls within the Part 21 definition, subject to enumerated exclusions.","S001 §2101(1)–(2)","High for examined text; 2025 direct check held"],["C002","Part 21 defines principal as the individual's total debt when accepted into the program.","S001 §2101(3)","High for examined text; current direct check held"],["C003","Part 20 defines consumer debt by personal, family or household purpose.","S006 §2003(1)","High"],["C004","Receiving consumer money for distribution to creditors is central to the statutory DMP definition.","S006 §2003(4)","High"],["C005","Part 20 expressly reaches offers to Montana residents and contains activity-specific exclusions.","S005 §2002(1)–(2)","High for reproduced 2025 text"],["C006","Covered debt management and credit counseling activity requires licensing.","S007 §2004(1)","High for reproduced text; full scope held"],["C007","Noncustodial settlement providers must meet annual filing and financial-statement requirements.","S002 §2102(2)","High"],["C008","Settlement provider annual government filing charge is $250.","S002 §2102(2)(b); S010","High"],["C009","Settlement insurance minimum is $100,000, deductible maximum $10,000.","S002 §2102(1)","High"],["C010","Settlement disclosures precede agreement and require at least 12-point type.","S002 §2102(3)","High"],["C011","Settlement nonsetup fees have a 20%-of-principal aggregate ceiling.","S003 §2103(1)(b)","High for published 2025 law"],["C012","Settlement setup fees have a separate 5%-of-principal ceiling.","S003 §2103(1)(b)","High for published 2025 law"],["C013","Written settlement contract and actual fee schedule precede fee collection.","S003 §2103(1)(a), (k)","High"],["C014","Settlement advertising requires prior financial-statement filing.","S003 §2103(1)(l)","High"],["C015","Third-party compensation for performing settlement services is restricted.","S003 §2103(1)(g)","High for wording; application to affiliate models held"],["C016","Qualifying cancellation requires a requested 50% refund on a pro rata basis for specified unsettled accounts.","S003 §2103(2)","High for text; allocation interpretation held"],["C017","DMP consultation ceiling is $75.","S009 ARM 23.19.1005(1)","Provisional currentness"],["C018","DMP maintenance ceiling is lesser of $50 or 15% of monthly payment.","S009 ARM 23.19.1005(2)","Provisional; exceptions held"],["C019","One-time and recurring charges cannot evade their respective DMP categories by relabeling.","S009 ARM 23.19.1005(3)","Provisional currentness"],["C020","Covered DMP fees require the statutory written-plan prerequisites.","S008 §2010(1), (4)","High for reproduced 2025 text"],["C021","Certain unauthorized DMP fees void the plan and require fee return, subject to bona fide error.","S008 §2010(4)(g)","High for reproduced text"],["C022","DOJ reports a $1,000 annual DMP license fee.","S010","Operationally supported; controlling rule amount held"],["C023","DOJ describes separate annual registration and licensing procedures.","S010","High for agency procedure"],["C024","The DOJ checklist requires disclosure of provider and third-party charges.","S011 p. 3, D8","High for examined form"],["C025","Covered TSR debt-relief fees require an executed resolution agreement, at least one qualifying payment, and compliant allocation.","S014 §310.4(a)(5)(i)","High, conditional on federal coverage"],["C026","The TSR allows qualifying dedicated accounts without treating deposits as earned service fees.","S014 §310.4(a)(5)(ii)","High, conditional on coverage"],["C027","Telemarketed credit-improvement representations can invoke distinct fee-timing requirements.","S014 §310.4(a)(2)","High, conditional on coverage"],["C028","A named provider's current registration cannot be established from the existence of a registration procedure.","S010–S012","High methodological conclusion"],["C029","Montana Part 21 does not establish a universal exemption for nonprofits, attorneys or lead generators.","S001 §2101; S003 §2103","High as to lack of blanket exemption; particular models held"],["C030","The 2025 codification repeats the enacted 2009 settlement fee ceilings.","S003 §2103(1)(b); S013 §3","High; post-2025 change check open"]],"segment":1,"original_table_index":3},{"headers":[],"index":4,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Debt","Enrollment balance","Allocation of $3,000 fee"],["A","$4,000","$600"],["B","$6,000","$900"],["C","$10,000","$1,500"],["Total","$20,000","$3,000"]],"segment":1,"original_table_index":4},{"headers":["Component","Status","Existing claim IDs","Exact unresolved question or next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Existing claim IDs","Exact unresolved question or next investigation"],["Noncustodial settlement definition","Answered for examined text","C001–C002","Directly open and compare the official current §30-14-2101 version against the examined prior-version text."],["Custodial DMP definition","Answered for examined text","C003–C004","Confirm the complete current official text and any definitions elsewhere incorporated by reference."],["Consumer versus business-purpose debt","Partial","C003","Part 20’s personal, family, or household boundary was identified; confirm whether Part 21 independently limits the debtor or debt by purpose."],["Montana-resident and remote-provider nexus","Partial","C005","Part 20 expressly addresses offers to Montana residents; determine Part 21’s complete territorial reach for remote providers, advertising, referrals, and contracting."],["Hybrid settlement provider handling funds","Unresolved","C001, C004","Determine whether Part 20 displaces Part 21, whether both can apply, and how dedicated-account structures affect classification."],["Settlement registration pathway","Answered at statutory level","C007–C010, C023","Obtain and verify the current complete application package and operative annual renewal instructions."],["Debt-management licensing pathway","Partial","C006, C022–C023","Verify the full official licensing statute, rule chapter, application requirements, and controlling source for the $1,000 government fee."],["Attorney and professional exclusions","Partial","C001, C005, C029","Test ordinary-practice, incidental-service, principal-business, compensation, and entity-structure conditions; no blanket attorney exemption established."],["Nonprofit status","Partial","C029","Identify whether any separate Montana provision creates a qualified nonprofit exclusion; nonprofit status alone was not established as sufficient."],["Self-creditor and institutional exclusions","Partial","C001, C005","Read each exclusion’s complete entity and activity conditions and determine treatment of affiliates, servicers, and agents."],["Lead generation, advertising, and referral activity","Unresolved","C014–C015, C029","Determine when marketing, intake, referral compensation, qualification, or holding out constitutes covered service or prohibited third-party compensation."],["Settlement setup-fee ceiling","Answered for published 2025 text","C012, C030","Check post-2025 amendments and whether any other provision narrows the base or collection method."],["Settlement nonsetup-fee ceiling","Answered for published 2025 text","C011, C030","Resolve application to per-debt fees, savings-based fees, bundled fees, and fees paid to designees."],["Relationship between 5% and 20% ceilings","Partial","C011–C013","The ceilings are textually separate; determine whether contract, agency, or judicial authority limits their combined use. No collectible 25% fee was established."],["Settlement fee base","Partial","C002, C011–C012","Confirm treatment of debts added, removed, disputed, secured, previously settled, or rejected after initial acceptance."],["Settlement indexing or adjusted amounts","Unresolved","No verified original claim ID","Search current statutes, amendment acts, agency notices, and rules for indexing, adjustment, or superseding schedules. No CPI calculation may be invented."],["DMP consultation and maintenance amounts","Partial","C017–C019","Verify the official current ARM text, all amendments, exceptions, waivers, and any no-agreement counseling branch."],["DMP anti-relabeling rule","Partial","C019","Confirm current operative status and treatment of third-party, optional, technology, enrollment, and creditor-funded charges."],["State settlement fee timing","Partial","C013","A written contract and fee schedule were identified; determine every state performance trigger and whether any fee category may lawfully precede performance."],["State DMP fee timing","Partial","C020–C021","Confirm prerequisites for consultation before a plan, plan execution, recurring charges, failed enrollment, cancellation, and bona fide error."],["Federal TSR debt-relief timing","Answered conditionally","C025","Determine transaction-specific TSR coverage, exemptions, inbound/outbound call path, seller/telemarketer roles, and allocation compliance."],["Federal dedicated-account provision","Answered conditionally","C026","Verify actual account ownership, administrator independence, referral compensation, withdrawal, and refund facts for any proposed structure."],["TSR credit-repair timing","Partial","C027","Determine whether actual representations concern credit-history improvement or removal of derogatory information; then apply the separate timing rule."],["CROA overlap","Unresolved","No verified original claim ID","Read the current CROA definitions, exclusions, advance-payment prohibition, contract and cancellation provisions, and controlling cases before asserting coverage."],["Settlement cancellation and refund","Partial","C016","Resolve “collected,” “unrefunded,” “service fees,” “settlement offer,” pro rata allocation, setup-fee treatment, and interaction with federal premature collection."],["DMP voiding and fee return","Partial","C021","Verify the complete bona fide error language, cure consequences, private enforcement, and scope of “all fees.”"],["Government charges versus consumer fees","Answered as a boundary","C008, C022","Confirm current government charges from controlling law; neither registration nor licensing charges were established as pass-through consumer fees."],["Agency application and instructions","Partial","C023–C024","The examined checklist was revision 02/19 and not audited in full; obtain the current complete forms and revision history."],["Current settlement registry or provider lookup","Unresolved","C028","Locate an official current settlement-registration roster, searchable database, public-record route, or agency instruction describing verification."],["Named provider authorization","Not established","C028","Check each provider individually through an official current record; marketing claims or application eligibility are insufficient."],["Worked settlement examples","Answered as bounded demonstrations","C002, C011–C013, C025","Recalculate only after actual contract, fee allocation, debt changes, performance, collections, and refunds are known."],["Worked DMP example","Partial","C017–C021","Current official rule verification is required before using the example operationally."],["Contract-specific enforceability","Unresolved","C013, C016","Review the actual agreement, disclosures, allocation method, cancellation language, third-party fees, and governing-law provisions."],["Controlling Montana court decisions","Unresolved","No verified original claim ID","Search for construction of Parts 20 and 21, fee bases, exemptions, remote nexus, refunds, and remedies."],["Official interpretations and adoption history","Unresolved","No verified original claim ID","Obtain full ARM adoption/amendment orders, DOJ interpretations, declaratory rulings, and superseded guidance."],["October 24, 2026 currentness","Partial","C030","Complete a post-2025 session-law, future-effective-law, rulemaking, repeal, stay, and litigation-status check."],["Agreements, custody, bonds, insurance, and remedies beyond present necessity","Deferred","C009 only for examined insurance minimum","Full agreement, funds, bond, insurance, enforcement, restitution, civil-penalty, and private-remedy analysis belongs in later passes."],["Collections, litigation, limitations, exemptions, secured debt, sectors, local, tribal, and case-law coverage","Excluded from this component","No verified original claim ID","Conduct separate required passes; nothing here constitutes acceptance or closure of those categories."]],"segment":2,"original_table_index":0}],"claims":[{"claim_id":"S_MT-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P1-C001","Precise finding":"Noncustodial compensated settlement falls within the Part 21 definition, subject to enumerated exclusions.","Sources / pinpoint":"S001 §2101(1)–(2)","Status":"High for examined text; 2025 direct check held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise finding":"Part 21 defines principal as the individual's total debt when accepted into the program.","Sources / pinpoint":"S001 §2101(3)","Status":"High for examined text; current direct check held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise finding":"Part 20 defines consumer debt by personal, family or household purpose.","Sources / pinpoint":"S006 §2003(1)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise finding":"Receiving consumer money for distribution to creditors is central to the statutory DMP definition.","Sources / pinpoint":"S006 §2003(4)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise finding":"Part 20 expressly reaches offers to Montana residents and contains activity-specific exclusions.","Sources / pinpoint":"S005 §2002(1)–(2)","Status":"High for reproduced 2025 text"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise finding":"Covered debt management and credit counseling activity requires licensing.","Sources / pinpoint":"S007 §2004(1)","Status":"High for reproduced text; full scope held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise finding":"Noncustodial settlement providers must meet annual filing and financial-statement requirements.","Sources / pinpoint":"S002 §2102(2)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise finding":"Settlement provider annual government filing charge is $250.","Sources / pinpoint":"S002 §2102(2)(b); S010","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise finding":"Settlement insurance minimum is $100,000, deductible maximum $10,000.","Sources / pinpoint":"S002 §2102(1)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise finding":"Settlement disclosures precede agreement and require at least 12-point type.","Sources / pinpoint":"S002 §2102(3)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise finding":"Settlement nonsetup fees have a 20%-of-principal aggregate ceiling.","Sources / pinpoint":"S003 §2103(1)(b)","Status":"High for published 2025 law"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise finding":"Settlement setup fees have a separate 5%-of-principal ceiling.","Sources / pinpoint":"S003 §2103(1)(b)","Status":"High for published 2025 law"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise finding":"Written settlement contract and actual fee schedule precede fee collection.","Sources / pinpoint":"S003 §2103(1)(a), (k)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise finding":"Settlement advertising requires prior financial-statement filing.","Sources / pinpoint":"S003 §2103(1)(l)","Status":"High"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise finding":"Third-party compensation for performing settlement services is restricted.","Sources / pinpoint":"S003 §2103(1)(g)","Status":"High for wording; application to affiliate models held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise finding":"Qualifying cancellation requires a requested 50% refund on a pro rata basis for specified unsettled accounts.","Sources / pinpoint":"S003 §2103(2)","Status":"High for text; allocation interpretation held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise finding":"DMP consultation ceiling is $75.","Sources / pinpoint":"S009 ARM 23.19.1005(1)","Status":"Provisional currentness"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise finding":"DMP maintenance ceiling is lesser of $50 or 15% of monthly payment.","Sources / pinpoint":"S009 ARM 23.19.1005(2)","Status":"Provisional; exceptions held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise finding":"One-time and recurring charges cannot evade their respective DMP categories by relabeling.","Sources / pinpoint":"S009 ARM 23.19.1005(3)","Status":"Provisional currentness"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise finding":"Covered DMP fees require the statutory written-plan prerequisites.","Sources / pinpoint":"S008 §2010(1), (4)","Status":"High for reproduced 2025 text"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise finding":"Certain unauthorized DMP fees void the plan and require fee return, subject to bona fide error.","Sources / pinpoint":"S008 §2010(4)(g)","Status":"High for reproduced text"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise finding":"DOJ reports a $1,000 annual DMP license fee.","Sources / pinpoint":"S010","Status":"Operationally supported; controlling rule amount held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise finding":"DOJ describes separate annual registration and licensing procedures.","Sources / pinpoint":"S010","Status":"High for agency procedure"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise finding":"The DOJ checklist requires disclosure of provider and third-party charges.","Sources / pinpoint":"S011 p. 3, D8","Status":"High for examined form"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise finding":"Covered TSR debt-relief fees require an executed resolution agreement, at least one qualifying payment, and compliant allocation.","Sources / pinpoint":"S014 §310.4(a)(5)(i)","Status":"High, conditional on federal coverage"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise finding":"The TSR allows qualifying dedicated accounts without treating deposits as earned service fees.","Sources / pinpoint":"S014 §310.4(a)(5)(ii)","Status":"High, conditional on coverage"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise finding":"Telemarketed credit-improvement representations can invoke distinct fee-timing requirements.","Sources / pinpoint":"S014 §310.4(a)(2)","Status":"High, conditional on coverage"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise finding":"A named provider's current registration cannot be established from the existence of a registration procedure.","Sources / pinpoint":"S010–S012","Status":"High methodological conclusion"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise finding":"Montana Part 21 does not establish a universal exemption for nonprofits, attorneys or lead generators.","Sources / pinpoint":"S001 §2101; S003 §2103","Status":"High as to lack of blanket exemption; particular models held"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_MT-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise finding":"The 2025 codification repeats the enacted 2009 settlement fee ceilings.","Sources / pinpoint":"S003 §2103(1)(b); S013 §3","Status":"High; post-2025 change check open"},"coordinator_verification_status":"reviewed_with_current_rules_scope_sourceauthority_and_federal_precision_holds;originalcellunchanged","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_MT-P1-S001","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S001","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2101. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html","Verification and limitations":"Official older 2023 version excerpt read; current 2025 URL not separately opened. Classification currentness hold."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S002","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S002","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2102(1)–(3). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html","Verification and limitations":"Official 2025 text directly opened and read."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S003","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S003","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2103(1)(a)–(n), (2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html","Verification and limitations":"Official 2025 text directly opened and read."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S004","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S004","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2104(1)–(3). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html","Verification and limitations":"Official remedies excerpt read; full litigation implications deferred."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S005","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S005","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2002(1)–(2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html","Verification and limitations":"2025 secondary reproduction read; official 2025 section not directly opened."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S006","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S006","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2003(1)–(4). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html","Verification and limitations":"Official 2025 definitions excerpt read."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S007","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S007","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2004(1)–(2). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html","Verification and limitations":"Secondary 2025 reproduction partially read; full official licensing conditions held."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S008","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S008","Authority, literal URL and pinpoint":"Montana Legislature, MCA 2025, §30-14-2010(1), (4)(a)–(g). https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html","Verification and limitations":"Secondary 2025 reproduction read; official page not separately opened."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S009","urls":["https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005","https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S009","Authority, literal URL and pinpoint":"Montana administrative rule 23.19.1005(1)–(4). https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.1005","Verification and limitations":"Regulation reproduced and read; 2006 adoption/transfer history. Official 2026 amendment check held."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S010","urls":["https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/","https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S010","Authority, literal URL and pinpoint":"Montana DOJ, Debt Management and Debt Settlement Businesses. https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/","Verification and limitations":"Agency operational page excerpt read; displayed update December 12, 2025. Not a statutory effective date."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S011","urls":["https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf","https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S011","Authority, literal URL and pinpoint":"Montana DOJ, Debt Settlement Application and Registration Checklist, Form OCP-801, revision 02/19, page 3. https://dojmt.gov/wp-content/uploads/Debt-Settlement-Application-and-Registration-Checklist-.pdf","Verification and limitations":"Application excerpt read; complete eight-page form not audited."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S012","urls":["https://dojmt.gov/office-of-consumer-protection/debt-relief/","https://dojmt.gov/office-of-consumer-protection/debt-relief/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S012","Authority, literal URL and pinpoint":"Montana DOJ, Debt Relief, licensed debt management company list. https://dojmt.gov/office-of-consumer-protection/debt-relief/","Verification and limitations":"Agency listing excerpt read; no named provider verified."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S013","urls":["https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf","https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S013","Authority, literal URL and pinpoint":"61st Montana Legislature, HB 318 (2009), §§1–4. https://leg.mt.gov/bills/2009/BillPdf/HB0318.pdf","Verification and limitations":"Enacted historical text excerpts read; current provisions cross-checked selectively against S002/S003."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S014","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S014","Authority, literal URL and pinpoint":"FTC, 16 CFR §310.4(a)(2), (a)(5)(i)–(ii). https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Verification and limitations":"Federal operative text directly opened; eCFR Title 16 displayed through October 22, 2026."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S015","urls":["https://banking.mt.gov/BFID/","https://banking.mt.gov/BFID/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S015","Authority, literal URL and pinpoint":"Montana DOJ Banking Division, overview. https://banking.mt.gov/BFID/","Verification and limitations":"Agency operational page read; relevant to distinct financial-service licensing, not proof of settlement authorization."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_MT-P1-S016","urls":["https://banking.mt.gov/BFID/enforcement-actions","https://banking.mt.gov/BFID/enforcement-actions?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P1-S016","Authority, literal URL and pinpoint":"Montana DOJ Banking Division, enforcement actions. https://banking.mt.gov/BFID/enforcement-actions","Verification and limitations":"Agency enforcement index read; no controlling debt-settlement decision established from it."},"coordinator_verification_status":"see_exact_selected_primary_official_code_historical_rules_current_route_failures_search_only_and_explicit_reuse_in_reviews/S_MT-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Noncustodial settlement definition","researcher_record":{"Component":"Noncustodial settlement definition","Status":"Answered for examined text","Existing claim IDs":"C001–C002","Exact unresolved question or next investigation":"Directly open and compare the official current §30-14-2101 version against the examined prior-version text."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial DMP definition","researcher_record":{"Component":"Custodial DMP definition","Status":"Answered for examined text","Existing claim IDs":"C003–C004","Exact unresolved question or next investigation":"Confirm the complete current official text and any definitions elsewhere incorporated by reference."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer versus business-purpose debt","researcher_record":{"Component":"Consumer versus business-purpose debt","Status":"Partial","Existing claim IDs":"C003","Exact unresolved question or next investigation":"Part 20’s personal, family, or household boundary was identified; confirm whether Part 21 independently limits the debtor or debt by purpose."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Montana-resident and remote-provider nexus","researcher_record":{"Component":"Montana-resident and remote-provider nexus","Status":"Partial","Existing claim IDs":"C005","Exact unresolved question or next investigation":"Part 20 expressly addresses offers to Montana residents; determine Part 21’s complete territorial reach for remote providers, advertising, referrals, and contracting."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Hybrid settlement provider handling funds","researcher_record":{"Component":"Hybrid settlement provider handling funds","Status":"Unresolved","Existing claim IDs":"C001, C004","Exact unresolved question or next investigation":"Determine whether Part 20 displaces Part 21, whether both can apply, and how dedicated-account structures affect classification."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement registration pathway","researcher_record":{"Component":"Settlement registration pathway","Status":"Answered at statutory level","Existing claim IDs":"C007–C010, C023","Exact unresolved question or next investigation":"Obtain and verify the current complete application package and operative annual renewal instructions."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-management licensing pathway","researcher_record":{"Component":"Debt-management licensing pathway","Status":"Partial","Existing claim IDs":"C006, C022–C023","Exact unresolved question or next investigation":"Verify the full official licensing statute, rule chapter, application requirements, and controlling source for the $1,000 government fee."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney and professional exclusions","researcher_record":{"Component":"Attorney and professional exclusions","Status":"Partial","Existing claim IDs":"C001, C005, C029","Exact unresolved question or next investigation":"Test ordinary-practice, incidental-service, principal-business, compensation, and entity-structure conditions; no blanket attorney exemption established."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit status","researcher_record":{"Component":"Nonprofit status","Status":"Partial","Existing claim IDs":"C029","Exact unresolved question or next investigation":"Identify whether any separate Montana provision creates a qualified nonprofit exclusion; nonprofit status alone was not established as sufficient."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Self-creditor and institutional exclusions","researcher_record":{"Component":"Self-creditor and institutional exclusions","Status":"Partial","Existing claim IDs":"C001, C005","Exact unresolved question or next investigation":"Read each exclusion’s complete entity and activity conditions and determine treatment of affiliates, servicers, and agents."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Lead generation, advertising, and referral activity","researcher_record":{"Component":"Lead generation, advertising, and referral activity","Status":"Unresolved","Existing claim IDs":"C014–C015, C029","Exact unresolved question or next investigation":"Determine when marketing, intake, referral compensation, qualification, or holding out constitutes covered service or prohibited third-party compensation."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement setup-fee ceiling","researcher_record":{"Component":"Settlement setup-fee ceiling","Status":"Answered for published 2025 text","Existing claim IDs":"C012, C030","Exact unresolved question or next investigation":"Check post-2025 amendments and whether any other provision narrows the base or collection method."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement nonsetup-fee ceiling","researcher_record":{"Component":"Settlement nonsetup-fee ceiling","Status":"Answered for published 2025 text","Existing claim IDs":"C011, C030","Exact unresolved question or next investigation":"Resolve application to per-debt fees, savings-based fees, bundled fees, and fees paid to designees."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Relationship between 5% and 20% ceilings","researcher_record":{"Component":"Relationship between 5% and 20% ceilings","Status":"Partial","Existing claim IDs":"C011–C013","Exact unresolved question or next investigation":"The ceilings are textually separate; determine whether contract, agency, or judicial authority limits their combined use. No collectible 25% fee was established."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement fee base","researcher_record":{"Component":"Settlement fee base","Status":"Partial","Existing claim IDs":"C002, C011–C012","Exact unresolved question or next investigation":"Confirm treatment of debts added, removed, disputed, secured, previously settled, or rejected after initial acceptance."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement indexing or adjusted amounts","researcher_record":{"Component":"Settlement indexing or adjusted amounts","Status":"Unresolved","Existing claim IDs":"No verified original claim ID","Exact unresolved question or next investigation":"Search current statutes, amendment acts, agency notices, and rules for indexing, adjustment, or superseding schedules. No CPI calculation may be invented."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP consultation and maintenance amounts","researcher_record":{"Component":"DMP consultation and maintenance amounts","Status":"Partial","Existing claim IDs":"C017–C019","Exact unresolved question or next investigation":"Verify the official current ARM text, all amendments, exceptions, waivers, and any no-agreement counseling branch."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP anti-relabeling rule","researcher_record":{"Component":"DMP anti-relabeling rule","Status":"Partial","Existing claim IDs":"C019","Exact unresolved question or next investigation":"Confirm current operative status and treatment of third-party, optional, technology, enrollment, and creditor-funded charges."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State settlement fee timing","researcher_record":{"Component":"State settlement fee timing","Status":"Partial","Existing claim IDs":"C013","Exact unresolved question or next investigation":"A written contract and fee schedule were identified; determine every state performance trigger and whether any fee category may lawfully precede performance."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State DMP fee timing","researcher_record":{"Component":"State DMP fee timing","Status":"Partial","Existing claim IDs":"C020–C021","Exact unresolved question or next investigation":"Confirm prerequisites for consultation before a plan, plan execution, recurring charges, failed enrollment, cancellation, and bona fide error."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR debt-relief timing","researcher_record":{"Component":"Federal TSR debt-relief timing","Status":"Answered conditionally","Existing claim IDs":"C025","Exact unresolved question or next investigation":"Determine transaction-specific TSR coverage, exemptions, inbound/outbound call path, seller/telemarketer roles, and allocation compliance."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal dedicated-account provision","researcher_record":{"Component":"Federal dedicated-account provision","Status":"Answered conditionally","Existing claim IDs":"C026","Exact unresolved question or next investigation":"Verify actual account ownership, administrator independence, referral compensation, withdrawal, and refund facts for any proposed structure."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"TSR credit-repair timing","researcher_record":{"Component":"TSR credit-repair timing","Status":"Partial","Existing claim IDs":"C027","Exact unresolved question or next investigation":"Determine whether actual representations concern credit-history improvement or removal of derogatory information; then apply the separate timing rule."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"CROA overlap","researcher_record":{"Component":"CROA overlap","Status":"Unresolved","Existing claim IDs":"No verified original claim ID","Exact unresolved question or next investigation":"Read the current CROA definitions, exclusions, advance-payment prohibition, contract and cancellation provisions, and controlling cases before asserting coverage."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement cancellation and refund","researcher_record":{"Component":"Settlement cancellation and refund","Status":"Partial","Existing claim IDs":"C016","Exact unresolved question or next investigation":"Resolve “collected,” “unrefunded,” “service fees,” “settlement offer,” pro rata allocation, setup-fee treatment, and interaction with federal premature collection."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP voiding and fee return","researcher_record":{"Component":"DMP voiding and fee return","Status":"Partial","Existing claim IDs":"C021","Exact unresolved question or next investigation":"Verify the complete bona fide error language, cure consequences, private enforcement, and scope of “all fees.”"},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Government charges versus consumer fees","researcher_record":{"Component":"Government charges versus consumer fees","Status":"Answered as a boundary","Existing claim IDs":"C008, C022","Exact unresolved question or next investigation":"Confirm current government charges from controlling law; neither registration nor licensing charges were established as pass-through consumer fees."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Agency application and instructions","researcher_record":{"Component":"Agency application and instructions","Status":"Partial","Existing claim IDs":"C023–C024","Exact unresolved question or next investigation":"The examined checklist was revision 02/19 and not audited in full; obtain the current complete forms and revision history."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current settlement registry or provider lookup","researcher_record":{"Component":"Current settlement registry or provider lookup","Status":"Unresolved","Existing claim IDs":"C028","Exact unresolved question or next investigation":"Locate an official current settlement-registration roster, searchable database, public-record route, or agency instruction describing verification."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Component":"Named provider authorization","Status":"Not established","Existing claim IDs":"C028","Exact unresolved question or next investigation":"Check each provider individually through an official current record; marketing claims or application eligibility are insufficient."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Worked settlement examples","researcher_record":{"Component":"Worked settlement examples","Status":"Answered as bounded demonstrations","Existing claim IDs":"C002, C011–C013, C025","Exact unresolved question or next investigation":"Recalculate only after actual contract, fee allocation, debt changes, performance, collections, and refunds are known."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Worked DMP example","researcher_record":{"Component":"Worked DMP example","Status":"Partial","Existing claim IDs":"C017–C021","Exact unresolved question or next investigation":"Current official rule verification is required before using the example operationally."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Contract-specific enforceability","researcher_record":{"Component":"Contract-specific enforceability","Status":"Unresolved","Existing claim IDs":"C013, C016","Exact unresolved question or next investigation":"Review the actual agreement, disclosures, allocation method, cancellation language, third-party fees, and governing-law provisions."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling Montana court decisions","researcher_record":{"Component":"Controlling Montana court decisions","Status":"Unresolved","Existing claim IDs":"No verified original claim ID","Exact unresolved question or next investigation":"Search for construction of Parts 20 and 21, fee bases, exemptions, remote nexus, refunds, and remedies."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Official interpretations and adoption history","researcher_record":{"Component":"Official interpretations and adoption history","Status":"Unresolved","Existing claim IDs":"No verified original claim ID","Exact unresolved question or next investigation":"Obtain full ARM adoption/amendment orders, DOJ interpretations, declaratory rulings, and superseded guidance."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"October 24, 2026 currentness","researcher_record":{"Component":"October 24, 2026 currentness","Status":"Partial","Existing claim IDs":"C030","Exact unresolved question or next investigation":"Complete a post-2025 session-law, future-effective-law, rulemaking, repeal, stay, and litigation-status check."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Agreements, custody, bonds, insurance, and remedies beyond present necessity","researcher_record":{"Component":"Agreements, custody, bonds, insurance, and remedies beyond present necessity","Status":"Deferred","Existing claim IDs":"C009 only for examined insurance minimum","Exact unresolved question or next investigation":"Full agreement, funds, bond, insurance, enforcement, restitution, civil-penalty, and private-remedy analysis belongs in later passes."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collections, litigation, limitations, exemptions, secured debt, sectors, local, tribal, and case-law coverage","researcher_record":{"Component":"Collections, litigation, limitations, exemptions, secured debt, sectors, local, tribal, and case-law coverage","Status":"Excluded from this component","Existing claim IDs":"No verified original claim ID","Exact unresolved question or next investigation":"Conduct separate required passes; nothing here constitutes acceptance or closure of those categories."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}