{"meta":{"key":"s_mt--pass-04","task":"S_MT","title":"SMT Montana consumer-money custody, trust-account, and refund architecture","parent_title":"Montana debt and debt relief law","edition":"pass-04","path":"/research/s_mt--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":6,"claims":31,"sources":7,"review_status":"accepted_with_limits_checked_core_E3_material_patch_resolved","review_complete":true,"sha256":"272cd6cf7bee7ad4df1c7a5d5e9e7e9e6b99ee7809c86b56a5d945ea3a95ea86","headings":["Core determination","1. Custody entry point and hybrid arrangements","Part 20 custody","Part 21 noncustody","Same-entity displacement versus unresolved hybrid","Account/model matrix","2. Part 20 account duties","Verified account architecture","Account-duty matrix","Provider fees and combined receipts","3. Statements, records, oversight, closure, and payment-processing gateway","Consumer reporting and account access","Records and audit","Investigative authority","Relocation, closure, cessation, and insolvency","Money transmission and escrow gateway","4. Cancellation, termination, failed plans, and refund architecture","Part 20 DMP","Failed enrollment or unsigned DMP","Part 21 settlement cancellation","Already remitted money","5. Montana funds rules versus preserved federal account overlay","Example 1 — Ordinary Part 20 custodial cycle","Example 2 — Part 20 consumer cancellation without double subtraction","Example 3 — Receipt before a valid signed DMP","Example 4 — Part 21 external-account comparison","Branch A — every applicable federal and state fee condition is satisfied","Branch B — the customer deposited money, but a required performance condition is absent","Example 5 — Part 21 cancellation fee refund with explicit allocation","Example 6 — Hybrid processor held-gap classification","Freshly read on October 25, 2026, Pacific","Expressly reused, not freshly fetched","Discovery or failed routes","Not read or resolved"],"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-04","facets":{"geography":["us","us-mt"],"debt_type":[],"stage":[],"subject":["client-money"]},"scope":"Reviewed remaining consumer-money custody/trust-account/hybrid/refund component; currentARM/fee/provider/fullstateholds retained.","pending_corrections":0},"markdown":"# S_MT PASS-04 — Montana consumer-money custody, trust-account, and refund architecture\n\n**Actual fresh-access date:** October 25, 2026, Pacific\n**Mode:** GPT-5.6 Sol Pro, regular Chat\n**Relationship to prior work:** Distinct funds/custody component. The preserved P1–P3 provider-access, fee, historical-rule, federal-timing, and provenance work is not regenerated. This is not an independent review.\n\n**Component status:** **PARTIAL.** Montana’s affirmative Part 20 trust-account architecture and the Part 21 noncustodial boundary are established from the official 2025 code. Third-party, affiliate, processor, external-account, cessation, and several account-operation details remain fact- or source-dependent.\n\n## Core determination\n\nWithin Montana’s two debt-services statutes:\n\n1. **Part 20 is the verified custodial pathway.** A debt management plan is a written arrangement under which a credit counseling service receives consumer money for distribution to creditors. A covered service must maintain a specially designated trust account at a federally insured financial institution. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html)\n2. **Part 21 is expressly noncustodial.** A Part 21 debt settlement provider ordinarily does not hold, receive, or disburse debtor funds in connection with settlement services, and its precontract disclosure must state that it will not use a debtor payment to pay a creditor. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html)\n3. **For the same entity, Part 20 textually displaces Part 21.** Part 21 excludes any for-profit or nonprofit entity subject to Part 20. But a settlement company that begins handling money does not automatically become a lawful Part 20 provider: the actual arrangement must independently satisfy the Part 20 DMP definition and licensing requirements. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html)\n4. A debtor-owned external account, “independent administrator,” affiliate, processor, or escrow label does **not** by itself prove Part 21 status, Part 20 exemption, or legal custody. Actual control, agency, contractual authority, signatory rights, fee pulls, and creditor-payment instructions remain decisive factual gaps.\n5. No Montana statutory basis was found for importing the federal TSR’s seven-business-day dedicated-account return period into Montana law. The federal provision remains the previously preserved conditional overlay, not a Montana deadline.\n\n# A. Substantive findings\n\n## 1. Custody entry point and hybrid arrangements\n\n### Part 20 custody\n\nPart 20 applies to persons providing or offering DMPs to Montana residents. Its central custody trigger is a written agreement under which a credit counseling service is to **receive consumer money to distribute to one or more creditors** as full or partial payment. The definition of “person” expressly includes qualifying nonprofit entities, so nonprofit status does not remove the custodial model from the statute. Remote headquarters also do not remove a provider serving Montana residents from the textual scope. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html)\n\nThe attorney and CPA exclusions are conditional: the professional must be Montana-licensed, and credit counseling must be incidental rather than the professional’s principal business. Debt collectors are excluded only when they do not advertise or hold themselves out as credit counseling services. An account, law-firm relationship, or nonprofit label cannot substitute for those elements. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html)\n\n### Part 21 noncustody\n\nPart 21 defines both the provider and the service by the absence of ordinary-course custody. The provider must not, in its usual and regular course, hold, receive, or disburse debtor funds in connection with the settlement service. Its disclosure must say that the provider will not use a debtor payment to pay a creditor. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html)\n\nPart 21 separately regulates the provider’s compensation. The coherent statutory distinction is therefore between:\n\n- Receiving provider compensation under the fee provisions; and\n- Holding or moving the debtor’s settlement principal for creditor payment.\n\nNo controlling Montana interpretation was recovered that defines the exact boundary when a provider pulls a fee from the same external account that accumulates settlement savings.\n\n### Same-entity displacement versus unresolved hybrid\n\nSection 30-14-2101(1)(b)(vi) excludes an entity subject to Part 20 from Part 21. That resolves the prior overlap question for an entity that actually meets Part 20: it is not simultaneously a Part 21 provider merely because it also negotiates concessions. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html)\n\nThe statute does **not** fully resolve:\n\n- A nominal Part 21 provider whose affiliate owns or controls the account administrator.\n- A processor acting as the provider’s agent.\n- A provider with contractual authority to direct creditor payments but no formal bank signatory right.\n- A provider that receives consumer money briefly before forwarding it to an external administrator.\n- A settlement arrangement involving custody that does not satisfy the Part 20 DMP definition.\n\nIn those settings, loss of Part 21’s noncustodial classification does not itself create Part 20 permission. It may instead reveal an unclassified or unlawfully structured model until Part 20, another licensing statute, and the contracts are applied.\n\n## Account/model matrix\n\n| Model | Montana classification result | Account duties established | Material hold |\n| --- | --- | --- | --- |\n| Provider receives monthly consumer money under a written plan and distributes it to creditors | Part 20 DMP candidate; license required unless an actual exclusion applies | Part 20 trust account, federally insured institution, special designation, creditor-disbursement-only funds, quarterly consumer reports | Actual license, contract, exclusions, and account compliance |\n| Provider negotiates settlement; debtor pays creditor directly | Part 21 candidate | No Montana Part 21 trust-account architecture | Fee timing, actual federal coverage, contract, and provider registration |\n| Debtor-owned external savings account with genuinely independent administrator | May remain compatible with Part 21, but account form alone is insufficient | Montana Part 21 supplies no account-location, ownership, interest, statement, or return architecture | Provider control, agency, affiliate relationships, signers, fee pulls, and federal conditions |\n| Provider affiliate or processor receives and transmits consumer funds | Part 21 status is at risk; Part 20 applies only if its DMP elements are independently met | No safe harbor from affiliate or processor naming | Constructive receipt, agency, common control, contract, and separate entity licensing |\n| Part 21 provider pulls only an actually lawful service fee from an external account | Fee receipt is governed by Part 21 contract/cancellation rules and any applicable federal performance trigger | No authority to take settlement principal or use consumer payment to pay creditors | Actual fee allocation, earning event, account authorization, and federal coverage |\n| Actual Title 32 escrow business | Part 20 lists escrow businesses among its exclusions, but Title 32’s specific definition must be satisfied | Separate escrow law may apply | A “trust,” “escrow,” or “FBO” account label is not enough |\n| Entity performs only money transmission | Montana BFID presently says Montana does not regulate money transmitters as such | No Montana money-transmitter custody regime established | Other Montana licenses and Parts 20/21 remain activity-dependent |\n\nClaims: S_MT-P4-C001–C009, C027–C030.\n\n## 2. Part 20 account duties\n\n### Verified account architecture\n\nThe Part 20 trust account must be:\n\n- Established by the credit counseling service.\n- At a **federally insured financial institution**.\n- Designated as a trust account, or with another designation indicating that the funds are not funds of the service or its directors, officers, employees, or agents.\n- Used exclusively for funds consumers pay to the service for disbursement to their creditors.\n- Unavailable to creditors of the credit counseling service. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html)\n\nA license applicant must provide evidence that it maintains that trust account. It must also contract, at its own expense, for an independent CPA audit every year, conducted within six months after fiscal-year close. The audit clause is provider-wide; the statute does not expressly prescribe a trust-account reconciliation procedure within the audit. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html)\n\n### Account-duty matrix\n\n| Account feature | Verified Montana rule | What is not established |\n| --- | --- | --- |\n| Institution | Federally insured financial institution | Specific federal insurer, pass-through coverage, insurance limits, or treatment of pooled beneficiaries |\n| Geographic location | No Montana-location clause appears in the statute | Whether an inaccessible rule, license condition, or contract imposes one |\n| Account title | “Trust account” or another designation indicating funds are not provider/insider funds | Exact caption, FBO wording, subaccount naming, or consumer names |\n| Legal ownership | Funds must be designated as not belonging to provider, directors, officers, employees, or agents | Express statutory declaration that each consumer owns the deposit account or has a particular beneficial interest |\n| Segregation | A separate trust account is required, and account funds are restricted to consumer creditor-disbursement money | Separate bank account for each consumer |\n| Commingling | Provider operating money and insider funds are incompatible with the required designation and exclusive purpose | De minimis bank balances, sweep mechanics, or temporary processing tolerances |\n| Permissible deposits | Consumer funds paid to the service for creditor disbursement | Express permission for provider fees, affiliate fees, reserves, investment income, or processor charges to be deposited in the trust account |\n| Permissible disbursements | Creditor payments under covered plans | Bank charges, provider fees, affiliate charges, refunds, or transfers among accounts are not expressly itemized |\n| Service fees | Part 20 separately authorizes qualifying fees after statutory prerequisites | Withdrawal of service fees from creditor trust principal is not established |\n| Signers and control | Account is established and maintained by the credit counseling service | Required signers, dual controls, administrator independence, consumer withdrawal rights, or power-of-attorney limits |\n| Deposit timing | No numeric statutory deposit deadline was identified | Same-day, next-day, or other deadline |\n| Creditor-remittance timing | No numeric statutory remittance deadline was identified | A quarterly statement is not a quarterly remittance authorization |\n| Interest | No Part 20 interest-allocation clause was identified | Whether interest must accrue, who owns it, or whether it may offset costs |\n| Reserves and shortages | No statutory reserve amount or shortage-cure deadline was identified | Required reserve, overdraft treatment, chargeback allocation, or replenishment deadline |\n| Per-consumer bank accounts | Not expressly required | Whether pooled trust accounts are permitted under all operative rules and contracts |\n| Per-consumer accounting | Quarterly reports must show each consumer’s receipts and creditor-level disbursements | Prescribed ledger form, daily posting, monthly reconciliation, or audit sampling method |\n| Reconciliation cadence | No numeric cadence was identified | Daily, monthly, quarterly, or annual trust reconciliation |\n| Current balance disclosure | Quarterly report must state receipts and creditor disbursements | Express requirement to state current balance, pending ACHs, fees, interest, or shortages |\n\nThe statute’s use of “an account” and “a separate trust account” does not affirmatively require a separate bank account for every consumer. Conversely, it does not by itself certify every pooled-account arrangement. Consumer-specific transaction records must at least be sufficient to produce the required quarterly reports, but no statutory ledger format or reconciliation interval was identified. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html)\n\n### Provider fees and combined receipts\n\nBecause the trust account is for consumer funds destined for creditors, no verified Montana authority allows the provider to treat the account as an operating or fee account. A separately paid lawful fee need not enter that trust account. If the consumer sends one combined payment containing creditor funds and a provider fee, the statute does not specify:\n\n- Where the combined payment must initially land.\n- How quickly the two components must be separated.\n- Whether a processor may split them before deposit.\n- Whether any bank or processing charge may be deducted from creditor principal.\n\nNo deduction from trust principal is treated as lawful in the examples below unless the source expressly authorizes it.\n\n## 3. Statements, records, oversight, closure, and payment-processing gateway\n\n### Consumer reporting and account access\n\nA Part 20 provider must give each DMP consumer a report showing:\n\n1. Funds received from that consumer since the prior report; and\n2. Disbursements made to each creditor.\n\nThe report must be provided at least quarterly. The statute does not require consumer online bank access, real-time balance access, monthly statements, or direct access to the underlying pooled account. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n\n### Records and audit\n\nPart 20 expressly requires annual independent CPA audits within six months after fiscal-year close. It also authorizes a penalty of up to $5,000 per violation for failing to maintain a separate trust account or records required by Part 20 or department rule. No numeric records-retention period appears in the freshly read statutory sections. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html)\n\nPart 21 separately requires GAAP books and records and an annual financial statement. The attorney general may require an independent CPA audit or review of that statement. Because Part 21 is noncustodial, those provisions do not create a debtor-savings trust-account regime. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html)\n\n### Investigative authority\n\nViolations of either debt-services part are tied to Montana’s Consumer Protection Act. In an investigation, the department may issue a written investigative demand requiring reports, testimony, documents, or physical evidence. It may also issue subpoenas, administer oaths, and conduct investigative hearings. Those are enforcement-investigation powers, not a verified routine bank-account examination schedule. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n\n### Relocation, closure, cessation, and insolvency\n\nNo operative statutory clause was identified that specifies:\n\n- Advance notice before relocating or closing a Part 20 trust account.\n- A mandatory successor-account procedure.\n- A deadline for transferring balances after provider cessation.\n- An insolvency receiver or account custodian.\n- A consumer-notification form for bank failure.\n- A provider-initiated account wind-down schedule.\n\nThe trust account must be unavailable to provider creditors. That is a direct Montana statutory duty, but it is **not** treated here as a judicial determination of bankruptcy priority, perfection, tracing rights, or FDIC pass-through coverage. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html)\n\nThe current official ARM consumer-debt-management index rendered only rules 23.19.1001 through 23.19.1005; the direct current-body route returned HTTP 405. Therefore, this pass does not make the categorical claim that no separate rule, license condition, or unpublished operational requirement addresses closure or reconciliation. [Montana Administrative Rules](https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132?utm_source=chatgpt.com)\n\n### Money transmission and escrow gateway\n\nMontana BFID’s current official page states that Montana does not regulate money transmitters as such and that “money transmission” is not defined under Montana law. The same page warns that other Montana licenses may apply, including escrow, consumer finance, loan collection, and other activity-based regimes. This does not exempt a debt-management provider, debt-settlement provider, affiliate, or processor from Parts 20 or 21. [Montana Department of Administration+1](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\nMontana’s escrow statute defines escrow by reference to holding money or instruments to effect a sale, transfer, encumbrance, lease, or payments under an encumbrance of property. That is narrower and more fact-specific than merely calling a debt-settlement savings account “escrow.” An account administrator does not become an exempt escrow business through nomenclature alone. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html)\n\nNo full Title 32 escrow or federal money-services-business analysis is attempted in this component.\n\n## 4. Cancellation, termination, failed plans, and refund architecture\n\n### Part 20 DMP\n\nA DMP must prominently state that either party may cancel without penalty at any time upon **10 days’ notice**. It must also state that a consumer who cancels is entitled to a refund of all unexpended funds paid to the service **as of the date of notice**. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n\nImportant boundaries:\n\n- The 10 days is the specified **notice period**. The statute does not say that the refund must be paid within 10 days.\n- The balance snapshot is tied to the date of notice.\n- The statute does not state whether scheduled creditor payments may continue during the notice period.\n- Money already remitted to creditors is no longer a current held balance and is not refunded again by the provider under this clause.\n- The treatment of a previously earned and expended lawful service fee under the phrase “all unexpended funds” was not resolved by a primary interpretation.\n- The express refund entitlement is phrased for a **consumer who cancels**. Although either party may cancel on notice, the statute does not give an equally explicit disposition procedure for provider-initiated cancellation.\n- No separate refund-delivery deadline, check method, ACH procedure, or abandoned-property process appears in the section.\n\nIf a service imposes an unauthorized fee or charge or receives unauthorized funds or other payments—other than through bona fide error—the DMP is void and the service must return all fees received from or on behalf of the consumer. The remedy expressly says “all fees”; it does not provide a complete principal-return procedure for creditor money that remains in trust. The trust restrictions and cancellation clause still prevent treating that principal as provider property. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n\n### Failed enrollment or unsigned DMP\n\nThe service may not require or accept consideration unless a compliant written and dated DMP has been signed and provided to the consumer. A pre-plan fee or payment therefore has no established lawful acceptance pathway under the examined text. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n\nIf creditor money is transmitted before a valid plan:\n\n- It does not become provider operating money.\n- No fee may be assumed earned.\n- The exact deadline and mechanism for returning the principal are not supplied by §30-14-2010.\n- Contract, electronic-transfer, trust, restitution, and enforcement questions remain outside this bounded finding.\n\n### Part 21 settlement cancellation\n\nIf a debtor cancels before the service contract is completed, the provider must, **on the debtor’s request**, refund 50% of collected but unrefunded service fees on a pro rata basis for accounts that have not received a settlement offer by cancellation. Setup fees are not required by this Montana subsection to be refunded. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html)\n\nThat language does not establish:\n\n- A deadline for issuing the state refund.\n- A definition of a qualifying “settlement offer.”\n- Treatment of an expired, rejected, unaffordable, or conditional offer.\n- A formula where the contract does not allocate fees among debts.\n- A refund of debtor savings held by an external administrator.\n- Permission to retain a fee collected prematurely under independently applicable federal law.\n\nThe nonrefund treatment of setup fees under state law is not advance-fee permission under the TSR. A partial Montana refund cannot cure an unlawful federal collection.\n\n### Already remitted money\n\nFor both models, a creditor payment already completed before cancellation is different from money still held:\n\n- Under Part 20, the completed remittance should appear in the creditor-level quarterly report.\n- It is not subtracted again from the trust balance.\n- The provider does not refund the same creditor remittance as unexpended funds.\n- A mistaken, rejected, reversed, or unauthorized creditor payment would require facts and authority not supplied here.\n\n## 5. Montana funds rules versus preserved federal account overlay\n\nThe following federal points are expressly **reused from S_MT PASS-02** and were not freshly fetched in PASS-04: the customer-executed resolution agreement, customer payment under the customer-creditor or customer-debt-collector agreement, consistent per-debt allocation, and the five dedicated-account conditions in 16 CFR §310.4(a)(5).\n\n| Issue | Montana Part 20 | Montana Part 21 | Conditional TSR overlay |\n| --- | --- | --- | --- |\n| Basic model | Provider receives money for creditor distribution | Provider ordinarily does not hold, receive, or disburse settlement principal | Permits qualifying debtor-owned dedicated account without treating deposit as earned fee |\n| Institution | Federally insured financial institution | No state account specification | Insured financial institution |\n| Ownership | Designation must show funds are not provider/insider funds | No state external-account ownership rule | Customer owns funds and receives accrued interest |\n| Interest | No allocation rule identified | No state rule identified | Customer receives accrued interest |\n| Administrator independence | No express independent-administrator requirement | No state account rule | Administrator cannot be owned, controlled by, or affiliated with service |\n| Referral compensation | No trust-account-specific clause identified | Part 21 has separate compensation restrictions | Administrator and provider cannot exchange referral compensation |\n| Withdrawal | Consumer may cancel DMP on 10 days’ notice; refund of unexpended funds as of notice | State cancellation addresses service fees | Customer may withdraw from service without penalty |\n| Return deadline | No Montana numeric deadline identified | No state external-principal deadline | Remaining account funds, less lawfully earned fees, within seven business days |\n| Fee earning | Montana plan, fee, and trust conditions | Montana contract, fee, and cancellation rules | Deposit is not earning; federal performance and allocation conditions must be satisfied |\n| Bank closure | Not specified | Not specified | Federal service withdrawal does not itself establish closure of the bank account |\n| ACH revocation | Not specified | Not specified | Service withdrawal does not necessarily revoke every ACH authorization |\n\nThe federal seven-business-day period is **not** a Montana refund deadline. Ending debt-relief services, returning account funds, closing the deposit account, stopping future deposits, and revoking provider or creditor ACH authority are separate acts.\n\nClaims: S_MT-P4-C021–C028.\n\n# B. Bounded funds-ledger examples\n\nAll examples use U.S. dollars, exact arithmetic to the cent, and no assumed interest, bank fees, pending ACH items, reversals, chargebacks, reserves, or undisclosed third-party charges.\n\n## Example 1 — Ordinary Part 20 custodial cycle\n\n**Assumptions**\n\n- Valid signed Part 20 DMP.\n- Provider is licensed.\n- Creditor money goes into the compliant trust account.\n- A separate $30 provider fee is lawful under the preserved fee analysis and is paid through a separate channel.\n- No opening trust balance.\n\n**Ledger**\n\nStarting trust balance:\n$0.00\n\nConsumer creditor-payment receipt:\n+$620.00\n\nCreditor A remittance:\n-$250.00\n\nCreditor B remittance:\n-$200.00\n\nCreditor C remittance:\n-$120.00\n\nCurrent held trust balance:\n\n$620.00 − $250.00 − $200.00 − $120.00 = $50.00\n\nThe separate $30 fee never enters this trust ledger. The next required consumer report must show the $620 received and each creditor disbursement. The $50 is the current held balance, not the original receipt.\n\n## Example 2 — Part 20 consumer cancellation without double subtraction\n\n**Assumptions**\n\n- Opening trust balance from the prior period: $50.\n- New creditor-money receipt: $400.\n- One completed creditor remittance of $300 occurs before cancellation notice.\n- No activity occurs after notice for purposes of the illustration.\n\n**Ledger**\n\nOpening balance:\n$50.00\n\nNew receipt:\n+$400.00\n\nAvailable before remittance:\n$450.00\n\nCompleted creditor remittance:\n-$300.00\n\nUnexpended balance as of notice:\n\n$450.00 − $300.00 = $150.00\n\nThe consumer’s conditional statutory refund base is $150. The completed $300 creditor remittance is not deducted again and is not treated as still held.\n\nThe ten-day notice requirement is not converted into a ten-day refund deadline.\n\n## Example 3 — Receipt before a valid signed DMP\n\n**Assumptions**\n\n- No compliant signed DMP yet exists.\n- Provider receives $500 described as creditor money.\n- Provider also receives a $75 purported setup or consultation fee.\n- No bona fide-error determination has been made.\n\n**Ledger**\n\nCreditor-purpose money received:\n$500.00\n\nPurported fee received:\n+$75.00\n\nTotal received:\n$575.00\n\nNo lawful fee earning is established.\n\nUnder the unauthorized-fee consequence, the fee return is:\n\n$75.00\n\nCreditor-purpose principal remaining:\n\n$575.00 − $75.00 = $500.00\n\nThe $500 cannot be relabeled as a fee or operating asset. Its exact return deadline and transfer route remain unresolved; this example does not invent one.\n\n## Example 4 — Part 21 external-account comparison\n\n**Assumptions**\n\n- Account is debtor-owned and externally administered.\n- Opening account balance: $1,000.\n- Consumer adds $500.\n- A valid customer-executed settlement agreement covers one debt.\n- Customer makes a $900 creditor payment under that agreement.\n- Exactly $180 of the total contracted service fee was consistently allocated to that debt.\n- No provider custody of principal is assumed.\n\n**Before any fee pull**\n\nOpening balance:\n$1,000.00\n\nNew consumer deposit:\n+$500.00\n\nCreditor payment:\n-$900.00\n\nBalance after creditor payment:\n\n$1,500.00 − $900.00 = $600.00\n\n### Branch A — every applicable federal and state fee condition is satisfied\n\nAllocated provider fee:\n-$180.00\n\nRemaining account balance:\n\n$600.00 − $180.00 = $420.00\n\n### Branch B — the customer deposited money, but a required performance condition is absent\n\nLawfully collectible fee in this example:\n$0.00\n\nRemaining balance:\n\n$600.00\n\nThe $500 deposit itself earns no service fee. Montana Part 21 does not supply the external account’s ownership, withdrawal, closure, or return terms.\n\n## Example 5 — Part 21 cancellation fee refund with explicit allocation\n\n**Assumptions**\n\n- Three debts.\n- Collected, unrefunded nonsetup service fee: $600.\n- Contract consistently allocates $200 to each debt.\n- Debt A received a settlement offer.\n- Debts B and C received no settlement offer.\n- Debtor cancels before completion and requests the statutory refund.\n- No prior refund and no setup fee.\n\nFee allocated to no-offer debts:\n\n$200.00 + $200.00 = $400.00\n\nCandidate Montana refund arithmetic:\n\n50% × $400.00 = $200.00\n\nRemaining collected service fee after that arithmetic:\n\n$600.00 − $200.00 = $400.00\n\nThis is a bounded illustration of one explicit allocation. It is not a holding that Montana’s “pro rata” wording must be applied this way in every contract. If any amount was collected prematurely under federal law, the Montana $200 result does not cure the premature collection or cap another required refund.\n\n## Example 6 — Hybrid processor held-gap classification\n\n**Assumptions**\n\n- Consumer sends $800 to a processor.\n- Processor sends $650 to creditors.\n- Processor still holds $150.\n- Provider or affiliate can issue payment instructions.\n- No fee deduction is assumed.\n- Agency, ownership, signatory, and account contracts are unavailable.\n\n**Ledger**\n\nConsumer receipt:\n$800.00\n\nCompleted creditor remittances:\n-$650.00\n\nCurrent held amount:\n\n$800.00 − $650.00 = $150.00\n\nThe arithmetic is certain; the legal architecture is not.\n\n- If the processor is acting for a covered Part 20 service under a DMP, the $150 may be subject to Part 20 trust duties and cancellation treatment.\n- If the account is genuinely debtor-owned and independently administered for a noncustodial Part 21 provider, Montana’s Part 20 trust rules may not govern that account.\n- If the arrangement falls outside both definitions, no lawful Montana custody pathway has been established.\n\nNo return deadline, fee deduction, or provider authorization may be inferred until classification is resolved.\n\n# C. Focused source table\n\nEach source ID represents one instrument or source family; separate statutory webpages are not counted as independent authorities merely because sections appear on different pages.\n\n| Source ID | Instrument, issuer, literal URL, and pinpoint | Status and actual access |\n| --- | --- | --- |\n| **S_MT-P4-S001** | **Montana Code Annotated 2025, Part 20, Montana Consumer Debt Management Services Act**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html §§2002(1)–(2); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html §§2003(1)–(7); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html §§2004(1)–(4); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html §§2010(1)–(6); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html §2013; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html §2015. | **Fresh, complete direct read of relevant current sections on October 25, 2026, Pacific.** Official 2025 codification; printed-code disclaimer applies. Relevant histories show the trust/DMP provisions originating in 2005. No comprehensive post-2025 session-law audit performed. [Montana Code Annotated+5](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html) |\n| **S_MT-P4-S002** | **Montana Code Annotated 2025, Part 21, Regulation of Debt Settlement Providers**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html §2101; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html §2102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html §2103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html §2104. | **Fresh, complete direct read on October 25, 2026, Pacific.** Official 2025 codification; Part 21 history identifies 2009 enactment. No comprehensive post-2025 session-law audit. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html) |\n| **S_MT-P4-S003** | **Montana Consumer Protection Act investigative provisions**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html §30-14-111; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html §30-14-113; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html §30-14-114. | **Fresh direct read October 25, 2026.** Used only for bounded investigative-demand, subpoena, and injunctive-authority crossreferences; not a full remedies pass. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html) |\n| **S_MT-P4-S004** | **ARM Subchapter 23.19.10, Consumer Debt Management**, Montana Secretary of State. https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132 | **Fresh official search rendering October 25, 2026; direct open failed HTTP 405.** Rendering lists rules 23.19.1001–1005. No complete current account-operation rule body was recovered. The unchanged fee-body failures were not rerun. [Montana Administrative Rules](https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132?utm_source=chatgpt.com) |\n| **S_MT-P4-S005** | **Mortgage and Consumer Finance — “Montana Does Not Regulate Money Transmitters,”** Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/ lines 216–229; parallel division page https://banking.mt.gov/. | **Fresh direct read October 25, 2026.** Current agency operational guidance, not an enacted money-transmission statute or safe harbor. It expressly warns that other Montana licenses may apply. [Montana Department of Administration+1](https://doa.mt.gov/BFID/mortgage-consumer-finance/) |\n| **S_MT-P4-S006** | **Montana Escrow Business Act definitions and exemptions**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html §32-7-102; https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0030/0320-0070-0010-0030.html §32-7-103. | **Fresh direct read October 25, 2026.** Used only to test whether an “escrow” label establishes an exclusion. Full escrow licensing, records, examination, and disbursement requirements remain excluded. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html) |\n| **S_MT-P4-S007** | **16 CFR §310.4(a)(5)(i)–(ii)**, Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | **Explicitly reused from S_MT-P2-S001; not freshly fetched in PASS-04.** Prior coordinator read covered the complete relevant performance and dedicated-account clauses. Federal coverage, exemptions, actual administrator facts, and contracts remain held.  |\n\n# D. Focused claim table\n\n| Claim ID | Precise assertion | Source and pinpoint | Conditions, limits, and confidence |\n| --- | --- | --- | --- |\n| **S_MT-P4-C001** | Part 20 applies to persons providing or offering DMPs to Montana residents. | S001, §2002(1) | High for 2025 text; exclusions remain fact-specific. |\n| **S_MT-P4-C002** | The Part 20 custody entry point is a written agreement under which the service receives consumer money to distribute to creditors. | S001, §2003(4) | High. |\n| **S_MT-P4-C003** | A Part 20 trust account must be established at a federally insured financial institution, specially designated, restricted to consumer creditor-disbursement money, and unavailable to provider creditors. | S001, §2003(7)(a)–(d) | High; no bankruptcy or deposit-insurance priority conclusion. |\n| **S_MT-P4-C004** | A Part 20 applicant must show that it maintains the trust account and contracts for annual independent CPA audits within six months after fiscal-year close. | S001, §2004(2)(a), (e) | High; audit scope is not expressly limited to or defined as trust reconciliation. |\n| **S_MT-P4-C005** | Nonprofit status and remote headquarters do not by themselves remove a Montana-resident DMP from Part 20. | S001, §§2002(1), 2003(6) | High textual result. |\n| **S_MT-P4-C006** | A Part 21 provider and service are defined as noncustodial in the usual and regular course. | S002, §2101(1)(a), (2) | High. |\n| **S_MT-P4-C007** | An entity subject to Part 20 is expressly excluded from Part 21. | S002, §2101(1)(b)(vi) | High for same-entity statutory displacement. |\n| **S_MT-P4-C008** | A Part 21 provider must disclose that it will not use a debtor payment to make a creditor payment. | S002, §2102(3)(a)(ix) | High. |\n| **S_MT-P4-C009** | A custody model that falls outside Part 21 does not automatically obtain Part 20 authorization. | S001 §§2002–2004; S002 §2101 | High as a classification limit; exact hybrid result remains factual. |\n| **S_MT-P4-C010** | The Part 20 statute requires a federally insured institution but contains no Montana-location clause. | S001, §2003(7)(a) | High as to statutory text; rules/contract overlay held. |\n| **S_MT-P4-C011** | Account designation must indicate that funds are not provider or insider funds. | S001, §2003(7)(b) | High; precise legal title and beneficial ownership are unresolved. |\n| **S_MT-P4-C012** | Trust funds are restricted to consumer creditor-disbursement money and unavailable to provider creditors. | S001, §2003(7)(c)–(d) | High; no bankruptcy, tracing, or FDIC pass-through holding. |\n| **S_MT-P4-C013** | The statute does not expressly require a separate bank account for each consumer. | S001, §2003(7); §2010(3) | Moderate-high bounded negative; complete current rules inaccessible. |\n| **S_MT-P4-C014** | No verified provision authorizes provider operating fees or affiliate charges to be deducted from Part 20 trust principal. | S001, §§2003(7), 2010(4) | High-confidence boundary; combined-payment mechanics unresolved. |\n| **S_MT-P4-C015** | No numeric deposit deadline, creditor-remittance deadline, reconciliation cadence, reserve, shortage-cure period, signer rule, or state interest-allocation rule was identified in the read provisions. | S001; S004 | Qualified negative only; no categorical claim beyond read statutes and accessible rule index. |\n| **S_MT-P4-C016** | Part 20 consumers must receive at least quarterly reports showing receipts since the prior report and creditor-level disbursements. | S001, §2010(3) | High; current balance and online access are not expressly required. |\n| **S_MT-P4-C017** | Failure to maintain a separate trust account or required records may draw a penalty up to $5,000 per violation. | S001, §2015(8) | High; full remedies analysis deferred. |\n| **S_MT-P4-C018** | Consumer Protection Act investigative demands and subpoenas can reach relevant records in a violation investigation. | S003 §§111, 113, 114; S001 §2015; S002 §2104 | High; not a routine examination schedule. |\n| **S_MT-P4-C019** | Part 21 requires GAAP books and records and an annual financial statement; the attorney general may require CPA audit or review. | S002, §2102(2)(a) | High; does not create an external savings-account trust regime. |\n| **S_MT-P4-C020** | No specific Part 20 or Part 21 statutory account-relocation, closure, succession, or insolvency-transfer procedure was identified. | S001–S004 | Qualified; current complete rule body not recovered. |\n| **S_MT-P4-C021** | A Part 20 DMP must permit either party to cancel without penalty on 10 days’ notice; a consumer canceler is entitled to all unexpended funds as of notice. | S001, §2010(2)(d) | High; no refund-delivery deadline established. |\n| **S_MT-P4-C022** | Provider-initiated cancellation uses the same notice statement, but the express refund entitlement is written for a consumer who cancels. | S001, §2010(2)(d) | High textual observation; disposition procedure unresolved. |\n| **S_MT-P4-C023** | Unauthorized fees, charges, funds, or payments can void the DMP and require return of all fees, subject to bona fide error. | S001, §2010(4)(g) | High; principal-return mechanism not fully specified. |\n| **S_MT-P4-C024** | Part 21 cancellation requires, on debtor request, a 50% pro rata refund of collected, unrefunded service fees allocated to accounts without a settlement offer; setup fees are excluded from this state refund. | S002, §2103(2) | High for text; formula, offer definition, and deadline unresolved. |\n| **S_MT-P4-C025** | Completed creditor remittances and current held balances must not be counted twice in a refund ledger. | S001, §§2003(7), 2010(2)(d), (3) | High accounting consequence; error/reversal scenarios held. |\n| **S_MT-P4-C026** | Part 21 supplies no affirmative Montana account-location, ownership, interest, statement, closure, or principal-return architecture for external dedicated accounts. | S002 §§2101–2103 | High bounded conclusion from complete Part 21; other law/contracts held. |\n| **S_MT-P4-C027** | The preserved TSR dedicated-account conditions are cumulative and separate from Montana trust compliance. | S007, §310.4(a)(5)(ii) | High only when the federal rule covers the transaction. |\n| **S_MT-P4-C028** | Federal service withdrawal, return of account funds, bank-account closure, and ACH revocation are distinct acts; the federal seven-business-day period is not Montana law. | S001, S002, S007 | High boundary; actual bank contract held. |\n| **S_MT-P4-C029** | Montana BFID currently states that Montana does not regulate money transmitters, while warning that other activity-based licenses may apply. | S005, lines 216–229 | High for agency position; not a statutory safe harbor. |\n| **S_MT-P4-C030** | An “escrow” label does not establish a Title 32 escrow business or Part 20 exclusion. | S001 §2002(2)(a); S006 §§32-7-102, 103 | High; full escrow classification held. |\n| **S_MT-P4-C031** | The current official ARM subchapter index was found, but the direct rule-body route failed; no complete current account-specific rule text was authenticated in PASS-04. | S004 | High provenance statement. |\n\n# E. Component coverage and gap table\n\n| Component | Status | Claim IDs | Exact remaining evidence or next action |\n| --- | --- | --- | --- |\n| Part 20 custody entry point | Answered | C001–C002 | Apply to actual agreement and money flow. |\n| Part 20 Montana-resident nexus | Answered textually | C001, C005 | Determine actual solicitation, offer, and consumer residence facts. |\n| Part 21 noncustodial definition | Answered | C006, C008 | Apply to actual provider control and account authority. |\n| Same-entity Part 20/Part 21 overlap | Answered textually | C007 | Entity subject to Part 20 is excluded from Part 21. |\n| Custodial settlement model not satisfying DMP definition | Unresolved | C009 | Determine whether another Montana regime applies; no lawful gap-filling assumption. |\n| Affiliate/processor custody | Partial | C009, C026–C030 | Obtain ownership chart, service agreements, payment instructions, signatory rights, and flow-of-funds diagram. |\n| Constructive receipt or agency | Unresolved | C009 | Locate controlling Montana interpretation and apply actual agency/control facts. |\n| Federally insured institution | Answered | C003, C010 | Verify actual institution and insurance status. |\n| Montana account location | Partial | C010, C031 | Recover complete current rules and review actual license conditions. |\n| Account designation | Answered | C003, C011 | Inspect actual account title and bank agreement. |\n| Consumer legal ownership/beneficial interest | Unresolved | C011–C012 | Review account agreement, trust terms, and controlling property law. |\n| Provider-creditor unavailability | Answered textually | C012 | Bankruptcy priority, tracing, and insolvency treatment remain separate. |\n| Segregation from operating funds | Answered | C003, C012, C017 | Inspect bank records and actual commingling. |\n| Per-consumer bank account | Unresolved/not expressly required | C013 | Complete official rule and licensing-condition review. |\n| Per-consumer transaction records | Partial | C016–C018 | Obtain ledger format, audit workpapers, and reporting system. |\n| Permissible deposits | Partial | C003, C014 | Resolve combined payments, reversals, and processor staging. |\n| Permissible disbursements | Partial | C003, C014 | Determine bank charges, refunds, rejected payments, and processor deductions. |\n| Provider fee pull from Part 20 trust | No permission established | C014 | Obtain controlling interpretation or a legally separate fee flow. |\n| Deposit timing | Unresolved | C015 | Recover complete current rules and actual contract/license terms. |\n| Creditor-remittance timing | Unresolved | C015 | Same; quarterly reporting does not answer timing. |\n| Signer/control rights | Unresolved | C015 | Obtain signature card, administrator agreement, and access-control matrix. |\n| Interest allocation | Unresolved under Montana | C015, C027 | Review actual account terms; apply TSR only if covered. |\n| Reserves and shortages | Unresolved | C015 | Review complete current rules, bond pass, contract, and audit practice. |\n| Reconciliation frequency | Unresolved | C015–C017, C031 | Recover current rules and inspect audit/account procedures. |\n| Quarterly consumer statement | Answered | C016 | Verify actual reports and creditor-level detail. |\n| Direct consumer account access | Not required by identified state text | C016 | Contract and federal account facts remain. |\n| Annual independent audit | Answered | C004, C017 | Audit scope, exceptions, and actual reports remain held. |\n| Records retention period | Unresolved | C017, C019, C031 | Recover complete current rules and licensing instructions. |\n| Regulator investigative access | Answered, bounded | C018 | Routine examination procedure and actual demand remain outside this pass. |\n| Part 21 GAAP records | Answered | C019 | Actual records and annual filing remain entity-specific. |\n| Account relocation or closure | Unresolved | C020 | Locate current rules, license conditions, and bank agreement. |\n| Provider cessation | Unresolved | C020–C022 | Determine successor custodian, notice, and balance disposition. |\n| Provider insolvency | Partial | C012, C020 | Separate bankruptcy, tracing, receiver, and bond analysis required. |\n| Part 20 consumer cancellation | Answered in part | C021 | Refund-delivery timing, post-notice remittances, and earned-fee treatment unresolved. |\n| Part 20 provider cancellation | Partial | C022 | Disposition of held money and notice mechanics unresolved. |\n| Failed/unsigned DMP | Partial | C023 | Principal-return route and timing require further authority. |\n| Unauthorized fee return | Answered textually | C023 | Bona fide error, cure, and full remedies remain later work. |\n| Already remitted creditor funds | Answered as ledger boundary | C025 | Reversal, rejection, and mistaken payment scenarios remain. |\n| Part 21 debtor cancellation | Answered in part | C024 | “Offer,” pro rata allocation, request method, and deadline unresolved. |\n| External savings principal on Part 21 cancellation | Unresolved under state law | C026–C028 | Apply account contract and conditional federal rule. |\n| Federal dedicated-account overlay | Reused, conditional | C027–C028 | Complete TSR coverage/exemptions and actual account facts remain open. |\n| ACH revocation/account closure | Unresolved | C028 | Review bank and processor authorizations. |\n| Money-transmission gateway | Bounded | C029 | No separate Montana MT regime identified; other licensing and federal MSB issues remain. |\n| Escrow-business gateway | Partial | C030 | Full Title 32 classification only if actual property/encumbrance escrow facts exist. |\n| Current ARM account rules | Unresolved | C031 | Obtain authenticated current bodies or certified official export. |\n| Post-2025 currentness | Partial | All | Conduct comprehensive session-law, future-effective-law, rulemaking, and litigation review. |\n| Named provider/account compliance | Excluded/unresolved | All | Check official status and actual documents in a later entity-specific pass. |\n| Bonds, provider insurance, and recovery claims | Deferred | — | Separate required pass. |\n| Full agreements and enforceability | Deferred | — | Separate contract pass. |\n| Full remedies, restitution, civil penalties, and private actions | Deferred except necessary crossreferences | C017–C018 | Separate remedies pass. |\n| Collections, litigation, limitations, garnishment, secured debt, sectors, local, tribal, and remaining parent-state dimensions | Excluded | — | All remain required; no closure by implication. |\n\n# F. Researcher self-check\n\n## Freshly read on October 25, 2026, Pacific\n\n- Complete relevant official 2025 MCA Part 20 sections: §§30-14-2002, 2003, 2004, 2010, 2013, and 2015.\n- Complete official 2025 MCA Part 21: §§30-14-2101 through 2104.\n- Official Part 20 and Part 21 section indexes.\n- Consumer Protection Act §§30-14-111, 113, and 114, only for bounded investigative authority.\n- Current Montana Department of Administration BFID money-transmitter guidance.\n- Current 2025 escrow definitions and exemptions, only for the account-label boundary.\n- Official current ARM subchapter search rendering; the direct body failed with HTTP 405.\n\n## Expressly reused, not freshly fetched\n\n- S_MT PASS-02’s complete reading of 16 CFR §310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E).\n- P1–P3 provider-access, fee, refund, ordinary ARM fee, and provenance findings.\n- The six prior fee examples and their checked arithmetic.\n- Historical adoption evidence from prior passes, except where the current code’s own history was read.\n\n## Discovery or failed routes\n\n- The official current ARM consumer-debt-management index was discoverable, but its direct body route failed.\n- Targeted official-domain searches did not recover a Montana AG interpretation or court decision resolving affiliate, processor, constructive-custody, “unexpended funds,” or Part 20/Part 21 hybrid classification. That search result is not proof that no such authority exists.\n- No current DMP application or license condition was treated as operative law.\n- No secondary chart, marketing statement, or provider description was used as legal permission.\n\n## Not read or resolved\n\n- Complete current ARM bodies and complete post-2009 amendment history affecting account operations.\n- Comprehensive post-2025 Montana session-law or special-session audit.\n- Any actual provider’s registration, license, bank account, processor contract, audit, trust ledger, or consumer statement.\n- Actual bank signature cards, beneficial-ownership terms, pass-through insurance treatment, ACH authorizations, or administrator independence.\n- Complete Montana escrow licensing law.\n- Federal MSB/BSA classification.\n- Complete TSR coverage and exemptions, CROA, or broader federal framework.\n- Bankruptcy priority, receivership, tracing, bond claims, insurance claims, and full remedies.\n- A complete Montana judicial citator or trial-court docket review.\n\nExact individual source-fetch timestamps were not exposed and are not invented. No independent review, application, filing, contact, account change, purchase, browser control, private-data access, local write, provider approval, operational approval, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.\n\n**REPORT PARTIAL — the bounded Montana funds/custody component is completed to the source limits stated above.**\n\nEND S_MT PASS-04.\n\n","tables":[{"headers":["Model","Montana classification result","Account duties established","Material hold"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Model","Montana classification result","Account duties established","Material hold"],["Provider receives monthly consumer money under a written plan and distributes it to creditors","Part 20 DMP candidate; license required unless an actual exclusion applies","Part 20 trust account, federally insured institution, special designation, creditor-disbursement-only funds, quarterly consumer reports","Actual license, contract, exclusions, and account compliance"],["Provider negotiates settlement; debtor pays creditor directly","Part 21 candidate","No Montana Part 21 trust-account architecture","Fee timing, actual federal coverage, contract, and provider registration"],["Debtor-owned external savings account with genuinely independent administrator","May remain compatible with Part 21, but account form alone is insufficient","Montana Part 21 supplies no account-location, ownership, interest, statement, or return architecture","Provider control, agency, affiliate relationships, signers, fee pulls, and federal conditions"],["Provider affiliate or processor receives and transmits consumer funds","Part 21 status is at risk; Part 20 applies only if its DMP elements are independently met","No safe harbor from affiliate or processor naming","Constructive receipt, agency, common control, contract, and separate entity licensing"],["Part 21 provider pulls only an actually lawful service fee from an external account","Fee receipt is governed by Part 21 contract/cancellation rules and any applicable federal performance trigger","No authority to take settlement principal or use consumer payment to pay creditors","Actual fee allocation, earning event, account authorization, and federal coverage"],["Actual Title 32 escrow business","Part 20 lists escrow businesses among its exclusions, but Title 32’s specific definition must be satisfied","Separate escrow law may apply","A “trust,” “escrow,” or “FBO” account label is not enough"],["Entity performs only money transmission","Montana BFID presently says Montana does not regulate money transmitters as such","No Montana money-transmitter custody regime established","Other Montana licenses and Parts 20/21 remain activity-dependent"]]},{"headers":["Account feature","Verified Montana rule","What is not established"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Account feature","Verified Montana rule","What is not established"],["Institution","Federally insured financial institution","Specific federal insurer, pass-through coverage, insurance limits, or treatment of pooled beneficiaries"],["Geographic location","No Montana-location clause appears in the statute","Whether an inaccessible rule, license condition, or contract imposes one"],["Account title","“Trust account” or another designation indicating funds are not provider/insider funds","Exact caption, FBO wording, subaccount naming, or consumer names"],["Legal ownership","Funds must be designated as not belonging to provider, directors, officers, employees, or agents","Express statutory declaration that each consumer owns the deposit account or has a particular beneficial interest"],["Segregation","A separate trust account is required, and account funds are restricted to consumer creditor-disbursement money","Separate bank account for each consumer"],["Commingling","Provider operating money and insider funds are incompatible with the required designation and exclusive purpose","De minimis bank balances, sweep mechanics, or temporary processing tolerances"],["Permissible deposits","Consumer funds paid to the service for creditor disbursement","Express permission for provider fees, affiliate fees, reserves, investment income, or processor charges to be deposited in the trust account"],["Permissible disbursements","Creditor payments under covered plans","Bank charges, provider fees, affiliate charges, refunds, or transfers among accounts are not expressly itemized"],["Service fees","Part 20 separately authorizes qualifying fees after statutory prerequisites","Withdrawal of service fees from creditor trust principal is not established"],["Signers and control","Account is established and maintained by the credit counseling service","Required signers, dual controls, administrator independence, consumer withdrawal rights, or power-of-attorney limits"],["Deposit timing","No numeric statutory deposit deadline was identified","Same-day, next-day, or other deadline"],["Creditor-remittance timing","No numeric statutory remittance deadline was identified","A quarterly statement is not a quarterly remittance authorization"],["Interest","No Part 20 interest-allocation clause was identified","Whether interest must accrue, who owns it, or whether it may offset costs"],["Reserves and shortages","No statutory reserve amount or shortage-cure deadline was identified","Required reserve, overdraft treatment, chargeback allocation, or replenishment deadline"],["Per-consumer bank accounts","Not expressly required","Whether pooled trust accounts are permitted under all operative rules and contracts"],["Per-consumer accounting","Quarterly reports must show each consumer’s receipts and creditor-level disbursements","Prescribed ledger form, daily posting, monthly reconciliation, or audit sampling method"],["Reconciliation cadence","No numeric cadence was identified","Daily, monthly, quarterly, or annual trust reconciliation"],["Current balance disclosure","Quarterly report must state receipts and creditor disbursements","Express requirement to state current balance, pending ACHs, fees, interest, or shortages"]]},{"headers":["Issue","Montana Part 20","Montana Part 21","Conditional TSR overlay"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Issue","Montana Part 20","Montana Part 21","Conditional TSR overlay"],["Basic model","Provider receives money for creditor distribution","Provider ordinarily does not hold, receive, or disburse settlement principal","Permits qualifying debtor-owned dedicated account without treating deposit as earned fee"],["Institution","Federally insured financial institution","No state account specification","Insured financial institution"],["Ownership","Designation must show funds are not provider/insider funds","No state external-account ownership rule","Customer owns funds and receives accrued interest"],["Interest","No allocation rule identified","No state rule identified","Customer receives accrued interest"],["Administrator independence","No express independent-administrator requirement","No state account rule","Administrator cannot be owned, controlled by, or affiliated with service"],["Referral compensation","No trust-account-specific clause identified","Part 21 has separate compensation restrictions","Administrator and provider cannot exchange referral compensation"],["Withdrawal","Consumer may cancel DMP on 10 days’ notice; refund of unexpended funds as of notice","State cancellation addresses service fees","Customer may withdraw from service without penalty"],["Return deadline","No Montana numeric deadline identified","No state external-principal deadline","Remaining account funds, less lawfully earned fees, within seven business days"],["Fee earning","Montana plan, fee, and trust conditions","Montana contract, fee, and cancellation rules","Deposit is not earning; federal performance and allocation conditions must be satisfied"],["Bank closure","Not specified","Not specified","Federal service withdrawal does not itself establish closure of the bank account"],["ACH revocation","Not specified","Not specified","Service withdrawal does not necessarily revoke every ACH authorization"]]},{"headers":["Source ID","Instrument, issuer, literal URL, and pinpoint","Status and actual access"],"index":3,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html","text":"Montana Code Annotated\n+5"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html","text":"Montana Code Annotated\n+3"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html","text":"Montana Code Annotated\n+2"},{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132?utm_source=chatgpt.com","text":"Montana Administrative Rules"},{"href":"https://doa.mt.gov/BFID/mortgage-consumer-finance/","text":"Montana Department of Administration\n+1"},{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html","text":"Montana Code Annotated\n+1"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html","text":"Montana Code Annotated\n+5"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html","text":"Montana Code Annotated\n+3"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html","text":"Montana Code Annotated\n+2"}],[{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132?utm_source=chatgpt.com","text":"Montana Administrative Rules"}],[{"href":"https://doa.mt.gov/BFID/mortgage-consumer-finance/","text":"Montana Department of Administration\n+1"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html","text":"Montana Code Annotated\n+1"}],[]],"rows":[["Source ID","Instrument, issuer, literal URL, and pinpoint","Status and actual access"],["S_MT-P4-S001","Montana Code Annotated 2025, Part 20, Montana Consumer Debt Management Services Act, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html §§2002(1)–(2); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html §§2003(1)–(7); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html §§2004(1)–(4); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html §§2010(1)–(6); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html §2013; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html §2015.","Fresh, complete direct read of relevant current sections on October 25, 2026, Pacific. Official 2025 codification; printed-code disclaimer applies. Relevant histories show the trust/DMP provisions originating in 2005. No comprehensive post-2025 session-law audit performed. \nMontana Code Annotated\n+5"],["S_MT-P4-S002","Montana Code Annotated 2025, Part 21, Regulation of Debt Settlement Providers, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html §2101; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html §2102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html §2103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html §2104.","Fresh, complete direct read on October 25, 2026, Pacific. Official 2025 codification; Part 21 history identifies 2009 enactment. No comprehensive post-2025 session-law audit. \nMontana Code Annotated\n+3"],["S_MT-P4-S003","Montana Consumer Protection Act investigative provisions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html §30-14-111; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html §30-14-113; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html §30-14-114.","Fresh direct read October 25, 2026. Used only for bounded investigative-demand, subpoena, and injunctive-authority crossreferences; not a full remedies pass. \nMontana Code Annotated\n+2"],["S_MT-P4-S004","ARM Subchapter 23.19.10, Consumer Debt Management, Montana Secretary of State. https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132","Fresh official search rendering October 25, 2026; direct open failed HTTP 405. Rendering lists rules 23.19.1001–1005. No complete current account-operation rule body was recovered. The unchanged fee-body failures were not rerun. \nMontana Administrative Rules"],["S_MT-P4-S005","Mortgage and Consumer Finance — “Montana Does Not Regulate Money Transmitters,” Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/ lines 216–229; parallel division page https://banking.mt.gov/.","Fresh direct read October 25, 2026. Current agency operational guidance, not an enacted money-transmission statute or safe harbor. It expressly warns that other Montana licenses may apply. \nMontana Department of Administration\n+1"],["S_MT-P4-S006","Montana Escrow Business Act definitions and exemptions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html §32-7-102; https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0030/0320-0070-0010-0030.html §32-7-103.","Fresh direct read October 25, 2026. Used only to test whether an “escrow” label establishes an exclusion. Full escrow licensing, records, examination, and disbursement requirements remain excluded. \nMontana Code Annotated\n+1"],["S_MT-P4-S007","16 CFR §310.4(a)(5)(i)–(ii), Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Explicitly reused from S_MT-P2-S001; not freshly fetched in PASS-04. Prior coordinator read covered the complete relevant performance and dedicated-account clauses. Federal coverage, exemptions, actual administrator facts, and contracts remain held."]]},{"headers":["Claim ID","Precise assertion","Source and pinpoint","Conditions, limits, and confidence"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source and pinpoint","Conditions, limits, and confidence"],["S_MT-P4-C001","Part 20 applies to persons providing or offering DMPs to Montana residents.","S001, §2002(1)","High for 2025 text; exclusions remain fact-specific."],["S_MT-P4-C002","The Part 20 custody entry point is a written agreement under which the service receives consumer money to distribute to creditors.","S001, §2003(4)","High."],["S_MT-P4-C003","A Part 20 trust account must be established at a federally insured financial institution, specially designated, restricted to consumer creditor-disbursement money, and unavailable to provider creditors.","S001, §2003(7)(a)–(d)","High; no bankruptcy or deposit-insurance priority conclusion."],["S_MT-P4-C004","A Part 20 applicant must show that it maintains the trust account and contracts for annual independent CPA audits within six months after fiscal-year close.","S001, §2004(2)(a), (e)","High; audit scope is not expressly limited to or defined as trust reconciliation."],["S_MT-P4-C005","Nonprofit status and remote headquarters do not by themselves remove a Montana-resident DMP from Part 20.","S001, §§2002(1), 2003(6)","High textual result."],["S_MT-P4-C006","A Part 21 provider and service are defined as noncustodial in the usual and regular course.","S002, §2101(1)(a), (2)","High."],["S_MT-P4-C007","An entity subject to Part 20 is expressly excluded from Part 21.","S002, §2101(1)(b)(vi)","High for same-entity statutory displacement."],["S_MT-P4-C008","A Part 21 provider must disclose that it will not use a debtor payment to make a creditor payment.","S002, §2102(3)(a)(ix)","High."],["S_MT-P4-C009","A custody model that falls outside Part 21 does not automatically obtain Part 20 authorization.","S001 §§2002–2004; S002 §2101","High as a classification limit; exact hybrid result remains factual."],["S_MT-P4-C010","The Part 20 statute requires a federally insured institution but contains no Montana-location clause.","S001, §2003(7)(a)","High as to statutory text; rules/contract overlay held."],["S_MT-P4-C011","Account designation must indicate that funds are not provider or insider funds.","S001, §2003(7)(b)","High; precise legal title and beneficial ownership are unresolved."],["S_MT-P4-C012","Trust funds are restricted to consumer creditor-disbursement money and unavailable to provider creditors.","S001, §2003(7)(c)–(d)","High; no bankruptcy, tracing, or FDIC pass-through holding."],["S_MT-P4-C013","The statute does not expressly require a separate bank account for each consumer.","S001, §2003(7); §2010(3)","Moderate-high bounded negative; complete current rules inaccessible."],["S_MT-P4-C014","No verified provision authorizes provider operating fees or affiliate charges to be deducted from Part 20 trust principal.","S001, §§2003(7), 2010(4)","High-confidence boundary; combined-payment mechanics unresolved."],["S_MT-P4-C015","No numeric deposit deadline, creditor-remittance deadline, reconciliation cadence, reserve, shortage-cure period, signer rule, or state interest-allocation rule was identified in the read provisions.","S001; S004","Qualified negative only; no categorical claim beyond read statutes and accessible rule index."],["S_MT-P4-C016","Part 20 consumers must receive at least quarterly reports showing receipts since the prior report and creditor-level disbursements.","S001, §2010(3)","High; current balance and online access are not expressly required."],["S_MT-P4-C017","Failure to maintain a separate trust account or required records may draw a penalty up to $5,000 per violation.","S001, §2015(8)","High; full remedies analysis deferred."],["S_MT-P4-C018","Consumer Protection Act investigative demands and subpoenas can reach relevant records in a violation investigation.","S003 §§111, 113, 114; S001 §2015; S002 §2104","High; not a routine examination schedule."],["S_MT-P4-C019","Part 21 requires GAAP books and records and an annual financial statement; the attorney general may require CPA audit or review.","S002, §2102(2)(a)","High; does not create an external savings-account trust regime."],["S_MT-P4-C020","No specific Part 20 or Part 21 statutory account-relocation, closure, succession, or insolvency-transfer procedure was identified.","S001–S004","Qualified; current complete rule body not recovered."],["S_MT-P4-C021","A Part 20 DMP must permit either party to cancel without penalty on 10 days’ notice; a consumer canceler is entitled to all unexpended funds as of notice.","S001, §2010(2)(d)","High; no refund-delivery deadline established."],["S_MT-P4-C022","Provider-initiated cancellation uses the same notice statement, but the express refund entitlement is written for a consumer who cancels.","S001, §2010(2)(d)","High textual observation; disposition procedure unresolved."],["S_MT-P4-C023","Unauthorized fees, charges, funds, or payments can void the DMP and require return of all fees, subject to bona fide error.","S001, §2010(4)(g)","High; principal-return mechanism not fully specified."],["S_MT-P4-C024","Part 21 cancellation requires, on debtor request, a 50% pro rata refund of collected, unrefunded service fees allocated to accounts without a settlement offer; setup fees are excluded from this state refund.","S002, §2103(2)","High for text; formula, offer definition, and deadline unresolved."],["S_MT-P4-C025","Completed creditor remittances and current held balances must not be counted twice in a refund ledger.","S001, §§2003(7), 2010(2)(d), (3)","High accounting consequence; error/reversal scenarios held."],["S_MT-P4-C026","Part 21 supplies no affirmative Montana account-location, ownership, interest, statement, closure, or principal-return architecture for external dedicated accounts.","S002 §§2101–2103","High bounded conclusion from complete Part 21; other law/contracts held."],["S_MT-P4-C027","The preserved TSR dedicated-account conditions are cumulative and separate from Montana trust compliance.","S007, §310.4(a)(5)(ii)","High only when the federal rule covers the transaction."],["S_MT-P4-C028","Federal service withdrawal, return of account funds, bank-account closure, and ACH revocation are distinct acts; the federal seven-business-day period is not Montana law.","S001, S002, S007","High boundary; actual bank contract held."],["S_MT-P4-C029","Montana BFID currently states that Montana does not regulate money transmitters, while warning that other activity-based licenses may apply.","S005, lines 216–229","High for agency position; not a statutory safe harbor."],["S_MT-P4-C030","An “escrow” label does not establish a Title 32 escrow business or Part 20 exclusion.","S001 §2002(2)(a); S006 §§32-7-102, 103","High; full escrow classification held."],["S_MT-P4-C031","The current official ARM subchapter index was found, but the direct rule-body route failed; no complete current account-specific rule text was authenticated in PASS-04.","S004","High provenance statement."]]},{"headers":["Component","Status","Claim IDs","Exact remaining evidence or next action"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claim IDs","Exact remaining evidence or next action"],["Part 20 custody entry point","Answered","C001–C002","Apply to actual agreement and money flow."],["Part 20 Montana-resident nexus","Answered textually","C001, C005","Determine actual solicitation, offer, and consumer residence facts."],["Part 21 noncustodial definition","Answered","C006, C008","Apply to actual provider control and account authority."],["Same-entity Part 20/Part 21 overlap","Answered textually","C007","Entity subject to Part 20 is excluded from Part 21."],["Custodial settlement model not satisfying DMP definition","Unresolved","C009","Determine whether another Montana regime applies; no lawful gap-filling assumption."],["Affiliate/processor custody","Partial","C009, C026–C030","Obtain ownership chart, service agreements, payment instructions, signatory rights, and flow-of-funds diagram."],["Constructive receipt or agency","Unresolved","C009","Locate controlling Montana interpretation and apply actual agency/control facts."],["Federally insured institution","Answered","C003, C010","Verify actual institution and insurance status."],["Montana account location","Partial","C010, C031","Recover complete current rules and review actual license conditions."],["Account designation","Answered","C003, C011","Inspect actual account title and bank agreement."],["Consumer legal ownership/beneficial interest","Unresolved","C011–C012","Review account agreement, trust terms, and controlling property law."],["Provider-creditor unavailability","Answered textually","C012","Bankruptcy priority, tracing, and insolvency treatment remain separate."],["Segregation from operating funds","Answered","C003, C012, C017","Inspect bank records and actual commingling."],["Per-consumer bank account","Unresolved/not expressly required","C013","Complete official rule and licensing-condition review."],["Per-consumer transaction records","Partial","C016–C018","Obtain ledger format, audit workpapers, and reporting system."],["Permissible deposits","Partial","C003, C014","Resolve combined payments, reversals, and processor staging."],["Permissible disbursements","Partial","C003, C014","Determine bank charges, refunds, rejected payments, and processor deductions."],["Provider fee pull from Part 20 trust","No permission established","C014","Obtain controlling interpretation or a legally separate fee flow."],["Deposit timing","Unresolved","C015","Recover complete current rules and actual contract/license terms."],["Creditor-remittance timing","Unresolved","C015","Same; quarterly reporting does not answer timing."],["Signer/control rights","Unresolved","C015","Obtain signature card, administrator agreement, and access-control matrix."],["Interest allocation","Unresolved under Montana","C015, C027","Review actual account terms; apply TSR only if covered."],["Reserves and shortages","Unresolved","C015","Review complete current rules, bond pass, contract, and audit practice."],["Reconciliation frequency","Unresolved","C015–C017, C031","Recover current rules and inspect audit/account procedures."],["Quarterly consumer statement","Answered","C016","Verify actual reports and creditor-level detail."],["Direct consumer account access","Not required by identified state text","C016","Contract and federal account facts remain."],["Annual independent audit","Answered","C004, C017","Audit scope, exceptions, and actual reports remain held."],["Records retention period","Unresolved","C017, C019, C031","Recover complete current rules and licensing instructions."],["Regulator investigative access","Answered, bounded","C018","Routine examination procedure and actual demand remain outside this pass."],["Part 21 GAAP records","Answered","C019","Actual records and annual filing remain entity-specific."],["Account relocation or closure","Unresolved","C020","Locate current rules, license conditions, and bank agreement."],["Provider cessation","Unresolved","C020–C022","Determine successor custodian, notice, and balance disposition."],["Provider insolvency","Partial","C012, C020","Separate bankruptcy, tracing, receiver, and bond analysis required."],["Part 20 consumer cancellation","Answered in part","C021","Refund-delivery timing, post-notice remittances, and earned-fee treatment unresolved."],["Part 20 provider cancellation","Partial","C022","Disposition of held money and notice mechanics unresolved."],["Failed/unsigned DMP","Partial","C023","Principal-return route and timing require further authority."],["Unauthorized fee return","Answered textually","C023","Bona fide error, cure, and full remedies remain later work."],["Already remitted creditor funds","Answered as ledger boundary","C025","Reversal, rejection, and mistaken payment scenarios remain."],["Part 21 debtor cancellation","Answered in part","C024","“Offer,” pro rata allocation, request method, and deadline unresolved."],["External savings principal on Part 21 cancellation","Unresolved under state law","C026–C028","Apply account contract and conditional federal rule."],["Federal dedicated-account overlay","Reused, conditional","C027–C028","Complete TSR coverage/exemptions and actual account facts remain open."],["ACH revocation/account closure","Unresolved","C028","Review bank and processor authorizations."],["Money-transmission gateway","Bounded","C029","No separate Montana MT regime identified; other licensing and federal MSB issues remain."],["Escrow-business gateway","Partial","C030","Full Title 32 classification only if actual property/encumbrance escrow facts exist."],["Current ARM account rules","Unresolved","C031","Obtain authenticated current bodies or certified official export."],["Post-2025 currentness","Partial","All","Conduct comprehensive session-law, future-effective-law, rulemaking, and litigation review."],["Named provider/account compliance","Excluded/unresolved","All","Check official status and actual documents in a later entity-specific pass."],["Bonds, provider insurance, and recovery claims","Deferred","—","Separate required pass."],["Full agreements and enforceability","Deferred","—","Separate contract pass."],["Full remedies, restitution, civil penalties, and private actions","Deferred except necessary crossreferences","C017–C018","Separate remedies pass."],["Collections, litigation, limitations, garnishment, secured debt, sectors, local, tribal, and remaining parent-state dimensions","Excluded","—","All remain required; no closure by implication."]]}],"claims":[{"claim_id":"S_MT-P4-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C001","Precise assertion":"Part 20 applies to persons providing or offering DMPs to Montana residents.","Source and pinpoint":"S001, §2002(1)","Conditions, limits, and confidence":"High for 2025 text; exclusions remain fact-specific."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C002","Precise assertion":"The Part 20 custody entry point is a written agreement under which the service receives consumer money to distribute to creditors.","Source and pinpoint":"S001, §2003(4)","Conditions, limits, and confidence":"High."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C003","Precise assertion":"A Part 20 trust account must be established at a federally insured financial institution, specially designated, restricted to consumer creditor-disbursement money, and unavailable to provider creditors.","Source and pinpoint":"S001, §2003(7)(a)–(d)","Conditions, limits, and confidence":"High; no bankruptcy or deposit-insurance priority conclusion."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C004","Precise assertion":"A Part 20 applicant must show that it maintains the trust account and contracts for annual independent CPA audits within six months after fiscal-year close.","Source and pinpoint":"S001, §2004(2)(a), (e)","Conditions, limits, and confidence":"High; audit scope is not expressly limited to or defined as trust reconciliation."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C005","Precise assertion":"Nonprofit status and remote headquarters do not by themselves remove a Montana-resident DMP from Part 20.","Source and pinpoint":"S001, §§2002(1), 2003(6)","Conditions, limits, and confidence":"High textual result."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C006","Precise assertion":"A Part 21 provider and service are defined as noncustodial in the usual and regular course.","Source and pinpoint":"S002, §2101(1)(a), (2)","Conditions, limits, and confidence":"High."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C007","Precise assertion":"An entity subject to Part 20 is expressly excluded from Part 21.","Source and pinpoint":"S002, §2101(1)(b)(vi)","Conditions, limits, and confidence":"High for same-entity statutory displacement."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C008","Precise assertion":"A Part 21 provider must disclose that it will not use a debtor payment to make a creditor payment.","Source and pinpoint":"S002, §2102(3)(a)(ix)","Conditions, limits, and confidence":"High."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C009","Precise assertion":"A custody model that falls outside Part 21 does not automatically obtain Part 20 authorization.","Source and pinpoint":"S001 §§2002–2004; S002 §2101","Conditions, limits, and confidence":"High as a classification limit; exact hybrid result remains factual."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C010","Precise assertion":"The Part 20 statute requires a federally insured institution but contains no Montana-location clause.","Source and pinpoint":"S001, §2003(7)(a)","Conditions, limits, and confidence":"High as to statutory text; rules/contract overlay held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C011","Precise assertion":"Account designation must indicate that funds are not provider or insider funds.","Source and pinpoint":"S001, §2003(7)(b)","Conditions, limits, and confidence":"High; precise legal title and beneficial ownership are unresolved."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C012","Precise assertion":"Trust funds are restricted to consumer creditor-disbursement money and unavailable to provider creditors.","Source and pinpoint":"S001, §2003(7)(c)–(d)","Conditions, limits, and confidence":"High; no bankruptcy, tracing, or FDIC pass-through holding."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C013","Precise assertion":"The statute does not expressly require a separate bank account for each consumer.","Source and pinpoint":"S001, §2003(7); §2010(3)","Conditions, limits, and confidence":"Moderate-high bounded negative; complete current rules inaccessible."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C014","Precise assertion":"No verified provision authorizes provider operating fees or affiliate charges to be deducted from Part 20 trust principal.","Source and pinpoint":"S001, §§2003(7), 2010(4)","Conditions, limits, and confidence":"High-confidence boundary; combined-payment mechanics unresolved."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C015","Precise assertion":"No numeric deposit deadline, creditor-remittance deadline, reconciliation cadence, reserve, shortage-cure period, signer rule, or state interest-allocation rule was identified in the read provisions.","Source and pinpoint":"S001; S004","Conditions, limits, and confidence":"Qualified negative only; no categorical claim beyond read statutes and accessible rule index."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C016","Precise assertion":"Part 20 consumers must receive at least quarterly reports showing receipts since the prior report and creditor-level disbursements.","Source and pinpoint":"S001, §2010(3)","Conditions, limits, and confidence":"High; current balance and online access are not expressly required."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C017","Precise assertion":"Failure to maintain a separate trust account or required records may draw a penalty up to $5,000 per violation.","Source and pinpoint":"S001, §2015(8)","Conditions, limits, and confidence":"High; full remedies analysis deferred."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C018","Precise assertion":"Consumer Protection Act investigative demands and subpoenas can reach relevant records in a violation investigation.","Source and pinpoint":"S003 §§111, 113, 114; S001 §2015; S002 §2104","Conditions, limits, and confidence":"High; not a routine examination schedule."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C019","Precise assertion":"Part 21 requires GAAP books and records and an annual financial statement; the attorney general may require CPA audit or review.","Source and pinpoint":"S002, §2102(2)(a)","Conditions, limits, and confidence":"High; does not create an external savings-account trust regime."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C020","Precise assertion":"No specific Part 20 or Part 21 statutory account-relocation, closure, succession, or insolvency-transfer procedure was identified.","Source and pinpoint":"S001–S004","Conditions, limits, and confidence":"Qualified; current complete rule body not recovered."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C021","Precise assertion":"A Part 20 DMP must permit either party to cancel without penalty on 10 days’ notice; a consumer canceler is entitled to all unexpended funds as of notice.","Source and pinpoint":"S001, §2010(2)(d)","Conditions, limits, and confidence":"High; no refund-delivery deadline established."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C022","Precise assertion":"Provider-initiated cancellation uses the same notice statement, but the express refund entitlement is written for a consumer who cancels.","Source and pinpoint":"S001, §2010(2)(d)","Conditions, limits, and confidence":"High textual observation; disposition procedure unresolved."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C023","Precise assertion":"Unauthorized fees, charges, funds, or payments can void the DMP and require return of all fees, subject to bona fide error.","Source and pinpoint":"S001, §2010(4)(g)","Conditions, limits, and confidence":"High; principal-return mechanism not fully specified."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C024","Precise assertion":"Part 21 cancellation requires, on debtor request, a 50% pro rata refund of collected, unrefunded service fees allocated to accounts without a settlement offer; setup fees are excluded from this state refund.","Source and pinpoint":"S002, §2103(2)","Conditions, limits, and confidence":"High for text; formula, offer definition, and deadline unresolved."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C025","Precise assertion":"Completed creditor remittances and current held balances must not be counted twice in a refund ledger.","Source and pinpoint":"S001, §§2003(7), 2010(2)(d), (3)","Conditions, limits, and confidence":"High accounting consequence; error/reversal scenarios held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C026","Precise assertion":"Part 21 supplies no affirmative Montana account-location, ownership, interest, statement, closure, or principal-return architecture for external dedicated accounts.","Source and pinpoint":"S002 §§2101–2103","Conditions, limits, and confidence":"High bounded conclusion from complete Part 21; other law/contracts held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C027","Precise assertion":"The preserved TSR dedicated-account conditions are cumulative and separate from Montana trust compliance.","Source and pinpoint":"S007, §310.4(a)(5)(ii)","Conditions, limits, and confidence":"High only when the federal rule covers the transaction."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C028","Precise assertion":"Federal service withdrawal, return of account funds, bank-account closure, and ACH revocation are distinct acts; the federal seven-business-day period is not Montana law.","Source and pinpoint":"S001, S002, S007","Conditions, limits, and confidence":"High boundary; actual bank contract held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C029","Precise assertion":"Montana BFID currently states that Montana does not regulate money transmitters, while warning that other activity-based licenses may apply.","Source and pinpoint":"S005, lines 216–229","Conditions, limits, and confidence":"High for agency position; not a statutory safe harbor."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C030","Precise assertion":"An “escrow” label does not establish a Title 32 escrow business or Part 20 exclusion.","Source and pinpoint":"S001 §2002(2)(a); S006 §§32-7-102, 103","Conditions, limits, and confidence":"High; full escrow classification held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"claim_id":"S_MT-P4-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P4-C031","Precise assertion":"The current official ARM subchapter index was found, but the direct rule-body route failed; no complete current account-specific rule text was authenticated in PASS-04.","Source and pinpoint":"S004","Conditions, limits, and confidence":"High provenance statement."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_MT-P4-S001","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_0030/0300-0140-0200-0030.html","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_0100/0300-0140-0200-0100.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html"],"researcher_record":{"Source ID":"S_MT-P4-S001","Instrument, issuer, literal URL, and pinpoint":"Montana Code Annotated 2025, Part 20, Montana Consumer Debt Management Services Act, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html §§2002(1)–(2); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html §§2003(1)–(7); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html §§2004(1)–(4); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html §§2010(1)–(6); https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html §2013; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html §2015.","Status and actual access":"Fresh, complete direct read of relevant current sections on October 25, 2026, Pacific. Official 2025 codification; printed-code disclaimer applies. Relevant histories show the trust/DMP provisions originating in 2005. No comprehensive post-2025 session-law audit performed. \nMontana Code Annotated\n+5"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S002","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_0020/0300-0140-0210-0020.html","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_0040/0300-0140-0210-0040.html"],"researcher_record":{"Source ID":"S_MT-P4-S002","Instrument, issuer, literal URL, and pinpoint":"Montana Code Annotated 2025, Part 21, Regulation of Debt Settlement Providers, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html §2101; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html §2102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html §2103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html §2104.","Status and actual access":"Fresh, complete direct read on October 25, 2026, Pacific. Official 2025 codification; Part 21 history identifies 2009 enactment. No comprehensive post-2025 session-law audit. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S003","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html"],"researcher_record":{"Source ID":"S_MT-P4-S003","Instrument, issuer, literal URL, and pinpoint":"Montana Consumer Protection Act investigative provisions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html §30-14-111; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html §30-14-113; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html §30-14-114.","Status and actual access":"Fresh direct read October 25, 2026. Used only for bounded investigative-demand, subpoena, and injunctive-authority crossreferences; not a full remedies pass. \nMontana Code Annotated\n+2"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S004","urls":["https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132","https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P4-S004","Instrument, issuer, literal URL, and pinpoint":"ARM Subchapter 23.19.10, Consumer Debt Management, Montana Secretary of State. https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/9b0fc2a6-9f15-4e47-820e-026674139132","Status and actual access":"Fresh official search rendering October 25, 2026; direct open failed HTTP 405. Rendering lists rules 23.19.1001–1005. No complete current account-operation rule body was recovered. The unchanged fee-body failures were not rerun. \nMontana Administrative Rules"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S005","urls":["https://doa.mt.gov/BFID/mortgage-consumer-finance/","https://banking.mt.gov/"],"researcher_record":{"Source ID":"S_MT-P4-S005","Instrument, issuer, literal URL, and pinpoint":"Mortgage and Consumer Finance — “Montana Does Not Regulate Money Transmitters,” Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/ lines 216–229; parallel division page https://banking.mt.gov/.","Status and actual access":"Fresh direct read October 25, 2026. Current agency operational guidance, not an enacted money-transmission statute or safe harbor. It expressly warns that other Montana licenses may apply. \nMontana Department of Administration\n+1"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S006","urls":["https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0030/0320-0070-0010-0030.html"],"researcher_record":{"Source ID":"S_MT-P4-S006","Instrument, issuer, literal URL, and pinpoint":"Montana Escrow Business Act definitions and exemptions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0020/0320-0070-0010-0020.html §32-7-102; https://mca.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0030/0320-0070-0010-0030.html §32-7-103.","Status and actual access":"Fresh direct read October 25, 2026. Used only to test whether an “escrow” label establishes an exclusion. Full escrow licensing, records, examination, and disbursement requirements remain excluded. \nMontana Code Annotated\n+1"},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"source_id":"S_MT-P4-S007","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_MT-P4-S007","Instrument, issuer, literal URL, and pinpoint":"16 CFR §310.4(a)(5)(i)–(ii), Federal Trade Commission/eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Status and actual access":"Explicitly reused from S_MT-P2-S001; not freshly fetched in PASS-04. Prior coordinator read covered the complete relevant performance and dedicated-account clauses. Federal coverage, exemptions, actual administrator facts, and contracts remain held."},"coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"}],"coverage":[{"topic":"Part 20 custody entry point","researcher_record":{"Component":"Part 20 custody entry point","Status":"Answered","Claim IDs":"C001–C002","Exact remaining evidence or next action":"Apply to actual agreement and money flow."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 20 Montana-resident nexus","researcher_record":{"Component":"Part 20 Montana-resident nexus","Status":"Answered textually","Claim IDs":"C001, C005","Exact remaining evidence or next action":"Determine actual solicitation, offer, and consumer residence facts."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 21 noncustodial definition","researcher_record":{"Component":"Part 21 noncustodial definition","Status":"Answered","Claim IDs":"C006, C008","Exact remaining evidence or next action":"Apply to actual provider control and account authority."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Same-entity Part 20/Part 21 overlap","researcher_record":{"Component":"Same-entity Part 20/Part 21 overlap","Status":"Answered textually","Claim IDs":"C007","Exact remaining evidence or next action":"Entity subject to Part 20 is excluded from Part 21."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Custodial settlement model not satisfying DMP definition","researcher_record":{"Component":"Custodial settlement model not satisfying DMP definition","Status":"Unresolved","Claim IDs":"C009","Exact remaining evidence or next action":"Determine whether another Montana regime applies; no lawful gap-filling assumption."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Affiliate/processor custody","researcher_record":{"Component":"Affiliate/processor custody","Status":"Partial","Claim IDs":"C009, C026–C030","Exact remaining evidence or next action":"Obtain ownership chart, service agreements, payment instructions, signatory rights, and flow-of-funds diagram."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Constructive receipt or agency","researcher_record":{"Component":"Constructive receipt or agency","Status":"Unresolved","Claim IDs":"C009","Exact remaining evidence or next action":"Locate controlling Montana interpretation and apply actual agency/control facts."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Federally insured institution","researcher_record":{"Component":"Federally insured institution","Status":"Answered","Claim IDs":"C003, C010","Exact remaining evidence or next action":"Verify actual institution and insurance status."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Montana account location","researcher_record":{"Component":"Montana account location","Status":"Partial","Claim IDs":"C010, C031","Exact remaining evidence or next action":"Recover complete current rules and review actual license conditions."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Account designation","researcher_record":{"Component":"Account designation","Status":"Answered","Claim IDs":"C003, C011","Exact remaining evidence or next action":"Inspect actual account title and bank agreement."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Consumer legal ownership/beneficial interest","researcher_record":{"Component":"Consumer legal ownership/beneficial interest","Status":"Unresolved","Claim IDs":"C011–C012","Exact remaining evidence or next action":"Review account agreement, trust terms, and controlling property law."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Provider-creditor unavailability","researcher_record":{"Component":"Provider-creditor unavailability","Status":"Answered textually","Claim IDs":"C012","Exact remaining evidence or next action":"Bankruptcy priority, tracing, and insolvency treatment remain separate."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Segregation from operating funds","researcher_record":{"Component":"Segregation from operating funds","Status":"Answered","Claim IDs":"C003, C012, C017","Exact remaining evidence or next action":"Inspect bank records and actual commingling."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Per-consumer bank account","researcher_record":{"Component":"Per-consumer bank account","Status":"Unresolved/not expressly required","Claim IDs":"C013","Exact remaining evidence or next action":"Complete official rule and licensing-condition review."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Per-consumer transaction records","researcher_record":{"Component":"Per-consumer transaction records","Status":"Partial","Claim IDs":"C016–C018","Exact remaining evidence or next action":"Obtain ledger format, audit workpapers, and reporting system."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Permissible deposits","researcher_record":{"Component":"Permissible deposits","Status":"Partial","Claim IDs":"C003, C014","Exact remaining evidence or next action":"Resolve combined payments, reversals, and processor staging."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Permissible disbursements","researcher_record":{"Component":"Permissible disbursements","Status":"Partial","Claim IDs":"C003, C014","Exact remaining evidence or next action":"Determine bank charges, refunds, rejected payments, and processor deductions."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Provider fee pull from Part 20 trust","researcher_record":{"Component":"Provider fee pull from Part 20 trust","Status":"No permission established","Claim IDs":"C014","Exact remaining evidence or next action":"Obtain controlling interpretation or a legally separate fee flow."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Deposit timing","researcher_record":{"Component":"Deposit timing","Status":"Unresolved","Claim IDs":"C015","Exact remaining evidence or next action":"Recover complete current rules and actual contract/license terms."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Creditor-remittance timing","researcher_record":{"Component":"Creditor-remittance timing","Status":"Unresolved","Claim IDs":"C015","Exact remaining evidence or next action":"Same; quarterly reporting does not answer timing."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Signer/control rights","researcher_record":{"Component":"Signer/control rights","Status":"Unresolved","Claim IDs":"C015","Exact remaining evidence or next action":"Obtain signature card, administrator agreement, and access-control matrix."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Interest allocation","researcher_record":{"Component":"Interest allocation","Status":"Unresolved under Montana","Claim IDs":"C015, C027","Exact remaining evidence or next action":"Review actual account terms; apply TSR only if covered."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Reserves and shortages","researcher_record":{"Component":"Reserves and shortages","Status":"Unresolved","Claim IDs":"C015","Exact remaining evidence or next action":"Review complete current rules, bond pass, contract, and audit practice."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Reconciliation frequency","researcher_record":{"Component":"Reconciliation frequency","Status":"Unresolved","Claim IDs":"C015–C017, C031","Exact remaining evidence or next action":"Recover current rules and inspect audit/account procedures."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Quarterly consumer statement","researcher_record":{"Component":"Quarterly consumer statement","Status":"Answered","Claim IDs":"C016","Exact remaining evidence or next action":"Verify actual reports and creditor-level detail."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Direct consumer account access","researcher_record":{"Component":"Direct consumer account access","Status":"Not required by identified state text","Claim IDs":"C016","Exact remaining evidence or next action":"Contract and federal account facts remain."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Annual independent audit","researcher_record":{"Component":"Annual independent audit","Status":"Answered","Claim IDs":"C004, C017","Exact remaining evidence or next action":"Audit scope, exceptions, and actual reports remain held."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Records retention period","researcher_record":{"Component":"Records retention period","Status":"Unresolved","Claim IDs":"C017, C019, C031","Exact remaining evidence or next action":"Recover complete current rules and licensing instructions."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Regulator investigative access","researcher_record":{"Component":"Regulator investigative access","Status":"Answered, bounded","Claim IDs":"C018","Exact remaining evidence or next action":"Routine examination procedure and actual demand remain outside this pass."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 21 GAAP records","researcher_record":{"Component":"Part 21 GAAP records","Status":"Answered","Claim IDs":"C019","Exact remaining evidence or next action":"Actual records and annual filing remain entity-specific."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Account relocation or closure","researcher_record":{"Component":"Account relocation or closure","Status":"Unresolved","Claim IDs":"C020","Exact remaining evidence or next action":"Locate current rules, license conditions, and bank agreement."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Provider cessation","researcher_record":{"Component":"Provider cessation","Status":"Unresolved","Claim IDs":"C020–C022","Exact remaining evidence or next action":"Determine successor custodian, notice, and balance disposition."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Provider insolvency","researcher_record":{"Component":"Provider insolvency","Status":"Partial","Claim IDs":"C012, C020","Exact remaining evidence or next action":"Separate bankruptcy, tracing, receiver, and bond analysis required."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 20 consumer cancellation","researcher_record":{"Component":"Part 20 consumer cancellation","Status":"Answered in part","Claim IDs":"C021","Exact remaining evidence or next action":"Refund-delivery timing, post-notice remittances, and earned-fee treatment unresolved."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 20 provider cancellation","researcher_record":{"Component":"Part 20 provider cancellation","Status":"Partial","Claim IDs":"C022","Exact remaining evidence or next action":"Disposition of held money and notice mechanics unresolved."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Failed/unsigned DMP","researcher_record":{"Component":"Failed/unsigned DMP","Status":"Partial","Claim IDs":"C023","Exact remaining evidence or next action":"Principal-return route and timing require further authority."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Unauthorized fee return","researcher_record":{"Component":"Unauthorized fee return","Status":"Answered textually","Claim IDs":"C023","Exact remaining evidence or next action":"Bona fide error, cure, and full remedies remain later work."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Already remitted creditor funds","researcher_record":{"Component":"Already remitted creditor funds","Status":"Answered as ledger boundary","Claim IDs":"C025","Exact remaining evidence or next action":"Reversal, rejection, and mistaken payment scenarios remain."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Part 21 debtor cancellation","researcher_record":{"Component":"Part 21 debtor cancellation","Status":"Answered in part","Claim IDs":"C024","Exact remaining evidence or next action":"“Offer,” pro rata allocation, request method, and deadline unresolved."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"External savings principal on Part 21 cancellation","researcher_record":{"Component":"External savings principal on Part 21 cancellation","Status":"Unresolved under state law","Claim IDs":"C026–C028","Exact remaining evidence or next action":"Apply account contract and conditional federal rule."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Federal dedicated-account overlay","researcher_record":{"Component":"Federal dedicated-account overlay","Status":"Reused, conditional","Claim IDs":"C027–C028","Exact remaining evidence or next action":"Complete TSR coverage/exemptions and actual account facts remain open."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"ACH revocation/account closure","researcher_record":{"Component":"ACH revocation/account closure","Status":"Unresolved","Claim IDs":"C028","Exact remaining evidence or next action":"Review bank and processor authorizations."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Money-transmission gateway","researcher_record":{"Component":"Money-transmission gateway","Status":"Bounded","Claim IDs":"C029","Exact remaining evidence or next action":"No separate Montana MT regime identified; other licensing and federal MSB issues remain."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Escrow-business gateway","researcher_record":{"Component":"Escrow-business gateway","Status":"Partial","Claim IDs":"C030","Exact remaining evidence or next action":"Full Title 32 classification only if actual property/encumbrance escrow facts exist."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Current ARM account rules","researcher_record":{"Component":"Current ARM account rules","Status":"Unresolved","Claim IDs":"C031","Exact remaining evidence or next action":"Obtain authenticated current bodies or certified official export."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Post-2025 currentness","researcher_record":{"Component":"Post-2025 currentness","Status":"Partial","Claim IDs":"All","Exact remaining evidence or next action":"Conduct comprehensive session-law, future-effective-law, rulemaking, and litigation review."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Named provider/account compliance","researcher_record":{"Component":"Named provider/account compliance","Status":"Excluded/unresolved","Claim IDs":"All","Exact remaining evidence or next action":"Check official status and actual documents in a later entity-specific pass."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Bonds, provider insurance, and recovery claims","researcher_record":{"Component":"Bonds, provider insurance, and recovery claims","Status":"Deferred","Claim IDs":"—","Exact remaining evidence or next action":"Separate required pass."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Full agreements and enforceability","researcher_record":{"Component":"Full agreements and enforceability","Status":"Deferred","Claim IDs":"—","Exact remaining evidence or next action":"Separate contract pass."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Full remedies, restitution, civil penalties, and private actions","researcher_record":{"Component":"Full remedies, restitution, civil penalties, and private actions","Status":"Deferred except necessary crossreferences","Claim IDs":"C017–C018","Exact remaining evidence or next action":"Separate remedies pass."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"},{"topic":"Collections, litigation, limitations, garnishment, secured debt, sectors, local, tribal, and remaining parent-state dimensions","researcher_record":{"Component":"Collections, litigation, limitations, garnishment, secured debt, sectors, local, tribal, and remaining parent-state dimensions","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"All remain required; no closure by implication."},"coordinator_acceptance":"partial_checked_core_all_recorded_holds_no_component_acceptance","coordinator_review":"[internal evidence reference]","coordinator_verification_status":"checked_with_limits_E3_material_correction_resolved","parent_assignment_complete":false,"correction_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}