{"meta":{"key":"s_mt--pass-07","task":"S_MT","title":"SMT Montana Part 20/Part 21 provider enforcement, private remedies, voidness, fee return, and remedy-specific limitations","parent_title":"Montana debt and debt relief law","edition":"pass-07","path":"/research/s_mt--pass-07/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":7,"claims":45,"sources":21,"review_status":"five_targeted_groups_resolved_with_limits_broad_report_unaccepted","review_complete":true,"sha256":"3661146fef89a6adc93c8b971c55b06925d152fa18dc02a77b5a3f238a858fff","headings":["Executive conclusions","A1. Part 20 coverage remains activity-based","Administrative licensing discipline","A2. Part 21 remains the noncustodial settlement branch","A3. Model-by-remedy matrix","B1. Exact trigger","B2. Exact consequences","B3. Bona fide error","B4. Relationship to the Part 20 private remedy","C1. Private claimant and predicates","C2. Available relief","C3. Public enforcement and specific fine","D1. Public enforcement","D2. Assurances of discontinuance","D3. Private debtor remedies","D4. Cancellation-service-fee refund","E1. Scope and regulated conduct","E2. Regulated-activity exemption is narrow","E3. Private standing, causation, and ascertainable loss","E4. Private MCPA damages and fees","E5. Public MCPA remedies","E6. Civil fines and criminal boundary","G1. Private MCPA claim","G2. Part 20 express damages and fee-return claims","G3. Part 21 private remedies","G4. Department and other public actions","G5. Criminal prosecution","G6. Administrative license proceedings and judicial review","G7. CID challenge","G8. Tolling and complaint filing","Limitation and trigger matrix","H1. Current OCP complaint route","H2. Controlling and materially relevant decisions located","Osterman v. Sears, 2003 MT 327","Anderson v. ReconTrust Co., 2017 MT 313","Morrow v. Bank of America, 2014 MT 117","Norris v. Olson, 2024 MT 123","Granbois v. Big Horn County Electric Cooperative, 1999 MT 249","H3. Provider-specific cases and orders not located","I1. Federal Telemarketing and Consumer Fraud and Abuse Prevention Act","I2. CROA","I3. CFPA","Example 1 — Unauthorized charge without bona fide error","Example 2 — Bona-fide-error branch","Branch A — provider proves a qualifying bona fide error","Branch B — error is not bona fide","Example 3 — Part 20 per-violation damages without automatic double counting","Violation A","Violation B","Total if the court treats them as separate, nonoverlapping violations","Example 4 — Fee return and damages overlap","Example 5 — Private MCPA enhancement and attorney-fee cap","Example 6 — Public restitution versus private recovery","Example 7 — Part 21 cancellation refund is not exclusive","Example 8 — Licensing discipline versus consumer damages","Example 9 — OCP complaint does not establish tolling","Example 10 — Excluded or expired branch","Coverage failure","Standing failure","Time failure"],"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-07","facets":{"geography":["us","us-mt"],"debt_type":["unknown"],"stage":[],"subject":["definitions-classification","fees-outcomes","provider-remedies","limitations-revival"]},"scope":"Exact reviewed P1 remaining remedies/enforcement/voidness gap; independent of unreviewed P4/P5/P6.","pending_corrections":0},"markdown":"# S_MT PASS-07 — Montana Part 20/Part 21 provider enforcement, private remedies, voidness, fee return, and remedy-specific limitations\n\n**Fresh research session:** October 26, 2026, Pacific / October 26, 2026, UTC\n**Actual model/mode:** GPT-5.6 Sol Pro, regular Chat\n**Relationship to prior work:** Distinct enforcement/remedies component following the reviewed P1–P3 record. This is not an independent review. The saved P4 funds, P5 security, and P6 agreements analyses remain unreviewed and are not treated as accepted premises.\n\n**Component status:** **PARTIAL.** The operative statutory enforcement routes, Part 20 voidness and express private remedy, Part 21 public and MCPA remedies, current core limitation provisions, administrative-review rules, and principal Montana appellate standards are established. The exact limitation applicable to an affirmative Part 20 fee-return claim, defensive voidness, Part 21 public actions, current administrative discipline, bond or policy claims, and several unit-of-violation and overlap questions remain unresolved.\n\n## Executive conclusions\n\n1. **Part 20 creates its own express private remedy.** A person harmed by a Part 20 violation may recover actual and consequential damages or $500, whichever is greater, **for each violation**, plus costs and attorney fees. Equitable relief and class actions are expressly authorized. These remedies are cumulative and nonexclusive. Every Part 20 violation is also an unfair or deceptive act under the Montana Consumer Protection Act, but the Part 20 and MCPA routes retain different standing, class, damages, enhancement, and limitation rules. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n2. **Part 20’s unauthorized-payment clause is narrower and more powerful than a simple overcharge refund.** If a covered service imposes any unauthorized fee or charge or receives unauthorized funds or payments—unless resulting from a bona fide error—the DMP is void and the service must return **all fees** received from or on behalf of the consumer. The text does not limit return to the unauthorized increment, but it also does not say “return all consumer principal.” No cure period, notice requirement, compliance-system defense, prompt-correction rule, or burden-of-proof standard for “bona fide error” appears in the section. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n3. **Part 21 does not create a separate fixed-damages private action.** The attorney general or an eligible county attorney may obtain injunctions, restitution, reasonable attorney fees, and investigation and litigation costs. A debtor receives the remedies available under Part 1 of the Montana Consumer Protection Act and other state law. Consequently, a private Part 21 damages claim ordinarily must satisfy the MCPA’s consumer, causation, and ascertainable-loss requirements unless another cause of action applies. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html)\n4. **Current private MCPA relief is sharply structured.** The consumer may recover ascertainable loss or $500, whichever is greater; may not proceed as a class under §30-14-133; may receive discretionary enhancement up to three times the ascertainable-loss amount when actual damages do not exceed $100,000; and may not recover punitive damages under that section. Attorney fees are discretionary, subject to a $250 hourly cap, and unavailable when actual damages recovered are at least $100,000. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html)\n5. **There is no single Montana enforcement deadline.** Private MCPA claims expressly use the two-year statutory-liability period. A Part 20 express damages action is also likely governed by that two-year period because it is a liability created by statute, but no controlling Part 20 decision was located. The Department’s specific §30-14-111 injunction route has a five-year discovery-based limit, while general Department enforcement actions are cross-referenced to the five-year residual period after accrual. Administrative review of a final contested-case order generally requires a petition within 30 days after service. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0110/0270-0020-0020-0110.html)\n6. **An OCP complaint is not a private lawsuit, exhaustion requirement, or verified tolling event.** The public materials describe a discretionary complaint-review and referral process, and the complaint form states that OCP is not the consumer’s attorney. No statute read in this pass makes filing an OCP complaint a prerequisite to suit or pauses a limitation period. [Montana Department of Justice+1](https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/)\n\n# A. Provider classification and enforcement architecture\n\n## A1. Part 20 coverage remains activity-based\n\nPart 20 reaches a person providing or offering a DMP to Montana residents. A DMP is the defined written arrangement under which a credit counseling service receives consumer funds to distribute to creditors. “Person” includes qualifying nonprofits. Montana attorneys and CPAs receive only the statute’s conditional incidental-service exclusion, and debt collectors are excluded only if they do not advertise or hold themselves out as credit counseling services. A nonprofit, attorney affiliation, remote headquarters, processor, or counseling label is therefore not itself a remedy exemption. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html)\n\nPart 20’s remedies expressly apply to licensed providers **and to unlicensed persons to whom Part 20 applies**. Thus, lack of a license does not avoid consumer liability. The claimant must still prove that the defendant and activity fall within Part 20. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n\n### Administrative licensing discipline\n\nThe Department of Justice may refuse, suspend, or revoke a Part 20 license when the applicant or licensee fails to satisfy the licensing conditions in §30-14-2004(1)–(3) or applicable departmental rules. The text does not say that every violation elsewhere in Part 20 automatically causes administrative suspension or revocation. Those other violations remain subject to the express private and public remedies in §30-14-2015 and Part 1 of the MCPA. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html)\n\nWhen a license action proceeds as a contested case, Montana’s Administrative Procedure Act supplies notice, hearing, final-order, emergency-suspension, and judicial-review rules. A timely and sufficient renewal application ordinarily continues the existing license until the agency’s final determination and expiration of the judicial-review period. Summary suspension is permitted only when the agency incorporates an imperative-public-welfare finding and promptly institutes proceedings. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html)\n\n## A2. Part 21 remains the noncustodial settlement branch\n\nPart 21 covers a compensated provider that provides or holds itself out as providing settlement services and that, in its usual and regular course, does not hold, receive, or disburse debtor funds in connection with the service. It excludes an entity subject to Part 20 and contains conditional professional and institutional exclusions. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html)\n\nPart 21 does not contain an express administrative license-suspension or revocation section comparable to §30-14-2004(4). It instead uses annual filing requirements, substantive prohibitions, direct attorney-general or county-attorney enforcement, assurances of discontinuance, and incorporation of Part 1 MCPA remedies. A provider’s absence from, or removal from, an operational registration list cannot be equated with a formal adjudication unless the governing order or procedure is actually read. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html)\n\n## A3. Model-by-remedy matrix\n\n| Model or status | Administrative or public route | Private route | Critical condition or hold |\n| --- | --- | --- | --- |\n| Licensed covered Part 20 provider | DOJ licensing conditions and rule compliance; Part 1 investigation and judicial remedies | Part 20 actual/consequential damages or $500 per violation, costs, attorney fees, equity, and class relief; MCPA route also possible | Claimant must prove Part 20 coverage, violation, harm, and nonduplicative relief |\n| Unlicensed person actually subject to Part 20 | Part 20 remedies apply; specific fine up to $5,000 for unlicensed credit counseling; Part 1 public relief | Same express Part 20 private remedy | “Unlicensed” does not eliminate coverage; exact unit of each violation held |\n| Genuine standalone counseling outside the DMP-provider entry point | No Part 20 route established solely from counseling | Other law may apply | Qualified boundary only; holding out, offers, compensation, and mixed services remain factual |\n| Qualifying Part 21 noncustodial settlement provider | AG or eligible county attorney may seek injunction, restitution, fees, and costs; assurance route | Debtor gets MCPA and other state-law remedies; no separate Part 21 $500 floor or class authorization | Private MCPA claimant must satisfy consumer, causation, and ascertainable-loss elements |\n| Entity actually subject to Part 20 but marketed as settlement | Part 20, not Part 21, controls the same entity’s statutory classification | Part 20 remedies if its predicates are met | Marketing label does not select the statute |\n| Attorney acting in ordinary professional practice within Part 21 exclusion | Part 21 remedy not established | MCPA, professional-duty, contract, or other claims remain possible depending on facts | Attorney title alone is insufficient; actual ordinary-practice facts required |\n| Montana attorney or CPA whose counseling is incidental under Part 20 exclusion | Part 20 remedy not established for excluded conduct | Other law may apply | Montana licensure and incidental/not-principal-business elements must both exist |\n| Affiliate, lead generator, processor, or administrator | Entity-specific; public MCPA route may apply to indirect trade or commerce | Depends on role, attribution, consumer loss, and provider-statute coverage | No automatic immunity or liability from corporate label |\n| No private ascertainable loss, but ongoing unlawful conduct | Public injunction or other public relief may remain available | Private §30-14-133 damages fail without ascertainable loss caused by the conduct | Part 20’s separate “person harmed” route must be analyzed independently |\n\nClaims: S_MT-P7-C001–C006, C021–C025, C038–C040.\n\n# B. Part 20 unauthorized-fee voidness and fee-return architecture\n\n## B1. Exact trigger\n\nSection 30-14-2010(4)(g) applies if a credit counseling service:\n\n- Imposes any fee or other charge not authorized by §30-14-2010; or\n- Receives any funds or other payments not authorized by that section;\n\nunless the event resulted from a bona fide error. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html)\n\nThe provision does not require, on its face:\n\n- Consumer reliance.\n- A minimum dollar amount.\n- A willful or knowing act.\n- Prior notice to the provider.\n- A demand for correction.\n- A chance to cure.\n- Proof of consequential damage.\n\n## B2. Exact consequences\n\nWhen the predicate is met and the bona-fide-error exception does not apply:\n\n1. The DMP is void.\n2. The service must return **all fees received from or on behalf of the consumer**.\n\n“All fees” is broader than merely refunding the unauthorized increment. A provider that collected five previously authorized monthly fees and then imposed an unauthorized charge cannot assume that only the final charge must be returned.\n\nBut the command says “all fees,” not “all funds.” It therefore does not itself answer the disposition of:\n\n- Consumer principal held for creditors.\n- Funds already remitted to creditors.\n- Interest or bank credits.\n- Reversed or rejected payments.\n- Third-party funds not characterized as provider fees.\n\nThose funds may be governed by trust, cancellation, restitution, contract, or other law, but that result cannot be imported into §30-14-2010(4)(g) without separate authority.\n\n## B3. Bona fide error\n\nThe subsection contains the phrase “except as a result of bona fide error,” but it does not define:\n\n- Whether the provider bears the burden.\n- Whether reasonable procedures are required.\n- Whether legal error qualifies.\n- Whether a recurring system configuration can qualify.\n- Whether prompt correction is necessary.\n- Whether the error must be clerical, mathematical, or technical.\n- Whether the exception prevents only voidness or every other remedy.\n\nNo controlling Montana opinion interpreting this Part 20 phrase was located in the targeted searches. Federal bona-fide-error doctrines from unrelated statutes may not be imported automatically.\n\nThe safest bounded construction is:\n\n- If the provider proves the event resulted from a qualifying bona fide error, the automatic voidness and all-fee-return consequence in subsection (4)(g) does not attach.\n- That does **not** establish that the provider may retain the erroneous payment.\n- It does not erase a contract correction obligation, actual loss, another Part 20 violation, MCPA liability, or public enforcement that independently satisfies its elements.\n\n## B4. Relationship to the Part 20 private remedy\n\nSection 30-14-2015 separately makes a violator liable to a person harmed for:\n\nmax⁡(actual damages+consequential damages, $500)\\max(\\text{actual damages}+\\text{consequential damages},\\ \\$500)max(actual damages+consequential damages, $500)for each violation, plus costs and attorney fees. It also permits equitable or injunctive relief and a class action. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n\nThe statutes do not expressly state how a court must combine:\n\n- Return of all fees under §30-14-2010(4)(g).\n- Actual damages that include those same fees.\n- Consequential damages.\n- The $500 statutory floor.\n- Public restitution.\n- Amounts recovered from a bond, insurer, processor, or creditor.\n\nThe remedies are cumulative and nonexclusive, but cumulative legal theories do not necessarily permit the same $1 of loss to be paid twice. Any adjudication must identify whether fee return is rescissionary or restorative and credit overlapping compensatory amounts. No Montana provider-statute decision resolving that accounting was found.\n\n# C. Part 20 express private and public remedies\n\n## C1. Private claimant and predicates\n\nThe statute uses **“person harmed”**, not only “consumer.” Part 20’s underlying consumer and DMP definitions still limit the regulated transaction, but no controlling decision was found defining the outer boundary of who may be a “person harmed.”\n\nA private claimant must establish:\n\n- The defendant was subject to Part 20.\n- A Part 20 violation occurred.\n- The claimant was harmed by that violation.\n- The claimed actual or consequential loss was causally connected.\n- The requested number of “violations” is supported rather than duplicative labeling of one act.\n\nThe section does not separately require common-law reliance. For a misrepresentation-based theory, however, the claimant may need to show that the representation caused the asserted harm.\n\n## C2. Available relief\n\nPart 20 provides:\n\n- Actual damages.\n- Consequential damages.\n- A $500 floor when actual plus consequential damages are less than $500.\n- The comparison separately “for each violation.”\n- Costs.\n- Attorney fees.\n- Equitable relief.\n- Injunctive relief.\n- Class-action relief.\n- Cumulative and nonexclusive remedies. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n\nThe section does not establish:\n\n- A punitive-damages award under Part 20 itself.\n- Treble damages.\n- A provider cure defense.\n- A pre-suit demand.\n- A mandatory OCP complaint.\n- A fixed attorney-fee hourly rate.\n- A statutory cap on Part 20 attorney fees.\n- A formula defining when multiple acts count as one or several violations.\n\nGeneral punitive damages might be available on a separately pleaded and proven tort involving actual fraud or actual malice, subject to Montana’s clear-and-convincing standard and punitive-damages limits. Part 20’s nonexclusive-remedy wording alone does not establish those tort predicates. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html)\n\n## C3. Public enforcement and specific fine\n\nEvery Part 20 violation is declared an unfair or deceptive act and a violation of §30-14-103. The Department, attorney general, or county attorney may act on behalf of Montana residents who suffered loss or harm and seek Part 1 remedies. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html)\n\nSection 30-14-2015(8) separately authorizes a fine of up to $5,000 **for each violation** for only three identified categories:\n\n1. Engaging in credit counseling in Montana without a license.\n2. Failing to maintain a separate trust account.\n3. Failing to maintain records required by Part 20 or departmental rule.\n\nThe provision calls this a “fine,” but it does not itself classify the fine as criminal, prescribe a mandatory amount, or expressly identify the collection procedure. It should not be conflated with the separate criminal provision in the general MCPA.\n\n# D. Part 21 enforcement and cancellation-refund boundary\n\n## D1. Public enforcement\n\nThe attorney general, or a county attorney where the provider does business or the debtor resides, may bring an action for violations of §§30-14-2102 and 2103. The court may issue any order necessary to remedy the violation, including:\n\n- Injunction.\n- Restitution.\n- Reasonable attorney fees.\n- Investigation costs.\n- Litigation costs. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html)\n\nNo fixed statutory cap is placed on restitution in §30-14-2104; the recoverable amount depends on the proven violation, loss, and remedy.\n\n## D2. Assurances of discontinuance\n\nThe attorney general or county attorney may accept an assurance of discontinuance. Under the Part 21 text, an assurance may include:\n\n- Investigation costs.\n- An escrow arrangement.\n- Restitution.\n\nViolation of the assurance can support a civil penalty of up to $10,000. The matter may be reopened at any time. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html)\n\nThe general Part 1 assurance statute says that a court-approved assurance under that statute is not an admission and may be reopened in the public interest. Part 21’s separate assurance provision does not itself repeat the “not an admission” wording. An actual assurance or consent judgment must therefore be read before describing it as containing or denying admissions. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0120/0300-0140-0010-0120.html)\n\n## D3. Private debtor remedies\n\nA Part 21 violation is a §30-14-103 violation, and the debtor is entitled to remedies under Part 1 and other Montana law. Part 21 does not itself provide:\n\n- A separate $500-per-violation floor.\n- Consequential damages as an express category.\n- A private Part 21 class action.\n- Automatic trebling.\n- Punitive damages.\n- Mandatory private attorney fees.\n\nA private MCPA claimant generally must satisfy §30-14-133’s separate elements and limits.\n\n## D4. Cancellation-service-fee refund\n\nWhen the debtor cancels before completion, §30-14-2103(2) requires, **on the debtor’s request**, a refund of 50% of collected but unrefunded service fees allocated pro rata to accounts without a settlement offer. Setup fees are excluded from that particular Montana refund requirement. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html)\n\nThat clause does not:\n\n- Establish that the fee was lawfully earned or collected.\n- Legalize a federally premature fee.\n- Make a setup fee nonrefundable under every other law.\n- Preclude restitution, MCPA damages, contract relief, or other state remedies.\n- Supply a refund deadline.\n- Define “settlement offer.”\n- Establish how to treat an expired, rejected, unaffordable, or conditional offer.\n- Establish that a refund under the subsection is the consumer’s exclusive remedy.\n\n# E. Montana Consumer Protection Act interaction\n\n## E1. Scope and regulated conduct\n\nThe MCPA defines a consumer as a person purchasing or leasing goods, services, real property, or information primarily for personal, family, or household purposes. “Trade” and “commerce” broadly include advertising, offering, sale, and distribution of services or property that directly or indirectly affect Montana people. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html)\n\nUnfair methods of competition and unfair or deceptive acts or practices in trade or commerce are unlawful. Montana gives due consideration and weight to FTC and federal-court interpretations, while the Department may adopt additional rules. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html)\n\nThe official current ARM search rendering for ARM 23.19.101 identifies as deceptive, among other things, misrepresenting affiliation, benefits, price, rights, remedies, or obligations; failing to disclose material conditions; and failing to disclose the seller’s legal identity and address. The official direct rule-body route returned HTTP 405, so that source remains search-rendered rather than a freshly opened authenticated body. [Montana Administrative Rules+1](https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be)\n\n## E2. Regulated-activity exemption is narrow\n\nSection 30-14-105 exempts actions or transactions permitted under laws administered by the Public Service Commission or state auditor, and innocent publication or dissemination of advertising. It is not a blanket exemption for every regulated business, professional, licensed entity, attorney, nonprofit, bank affiliate, or DOJ registrant. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html)\n\nIn *Granbois v. Big Horn County Electric Cooperative*, the Montana Supreme Court treated the exemption narrowly and rejected the proposition that merely being subject to some regulation automatically removes the conduct from the MCPA. The case remanded rather than finally adjudicating the underlying MCPA merits. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html)\n\n## E3. Private standing, causation, and ascertainable loss\n\nSection 30-14-133 requires:\n\n1. A consumer.\n2. An unlawful practice.\n3. An ascertainable loss of money or property.\n4. Loss resulting from the unlawful practice. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html)\n\nMontana decisions describe an unfair act as one that offends established public policy and is immoral, unethical, oppressive, unscrupulous, or substantially injurious. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html)\n\nIn *Anderson v. ReconTrust*, the court required factual allegations connecting the challenged conduct to an ascertainable loss. The statute does not use “reliance” as a universal standalone element, but where the theory is a deceptive representation, detrimental reliance or equivalent causal facts may be necessary to show that the representation produced the loss. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html)\n\n*Norris v. Olson* likewise identifies consumer status, an unlawful practice, causation, and ascertainable loss as the private MCPA elements. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html)\n\n## E4. Private MCPA damages and fees\n\nThe current statute provides:\n\nbase private award=max⁡(ascertainable loss,$500)\\text{base private award}=\\max(\\text{ascertainable loss},\\$500)base private award=max(ascertainable loss,$500)The court may, in its discretion, award up to three times the ascertainable-loss amount when actual damages do not exceed $100,000. The enhancement is not written as an additional three multiples added on top of the underlying award.\n\nThe statute now expressly provides:\n\n- No private MCPA class action under §30-14-133.\n- No punitive damages under that section.\n- Equitable relief may be granted.\n- Prevailing-party attorney fees are discretionary.\n- Attorney fees may not exceed $250 per hour.\n- No attorney-fee award when the consumer recovers actual damages of at least $100,000.\n- A court may award a pro se consumer fees at its discretion. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html)\n\nThese MCPA limits do not erase the separate Part 20 class-action and attorney-fee provisions when Part 20 independently applies.\n\n## E5. Public MCPA remedies\n\nThe Department may seek an injunction when it has reason to believe a person has knowingly used, is using, or is about to use an unlawful practice and the proceeding is in the public interest. The state need not post an injunction bond. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html)\n\nA court may restore money or property acquired through an unlawful practice, appoint a receiver, or revoke a license or certificate authorizing the defendant to engage in business. In a receivership, damaged persons who prove damage may participate with general creditors, but only to the extent of out-of-pocket losses. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0310/0300-0140-0010-0310.html)\n\nThe Department may issue civil investigative demands, subpoena documents and testimony, administer oaths, and conduct investigative hearings. A CID recipient seeking to extend, modify, or set aside the demand must petition by the return date or within 20 days after service, whichever period is shorter. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html)\n\nA county attorney may assist the Department or initiate and prosecute a Part 1 action in the same manner and must notify the Department of filing and disposition. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0210/0300-0140-0010-0210.html)\n\n## E6. Civil fines and criminal boundary\n\nThe MCPA provides distinct sanctions:\n\n| Conduct | Maximum stated sanction | Classification |\n| --- | --- | --- |\n| Violation of an injunction or TRO | $10,000 for each violation | Civil fine |\n| Willful use of an unlawful practice in a §30-14-111 action | $10,000 for each violation, in addition to other relief | Civil fine; “willful” means knew or should have known |\n| Fraudulent course of conduct resulting in conviction | $5,000 and/or imprisonment up to 1 year | Criminal |\n| Knowing or should-have-known exploitation of a vulnerable adult, subject to statutory factors | Additional $10,000 for each violation | Civil penalty; private damages receive priority |\n\nA one-year maximum sentence falls within Montana’s definition of a misdemeanor. The general criminal limitation is one year after commission for a misdemeanor, subject to the statute’s continuing-course and commencement provisions. This does not make every Part 20, Part 21, or MCPA violation criminal; the fraudulent-course and conviction predicates must be established. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html)\n\n# F. Auditable remedy and amount table\n\n| Remedy | Claimant or enforcer | Predicate | Amount or unit | Important boundary |\n| --- | --- | --- | --- | --- |\n| Part 20 all-fee return | Consumer under §2010(4)(g) | Unauthorized fee/charge or unauthorized funds/payment; no bona fide error | All fees received from or on behalf of consumer | Does not textually say all consumer principal |\n| Part 20 damages | Person harmed | Part 20 violation and harm | Greater of actual + consequential damages or $500, **for each violation** | Unit of violation and overlap require adjudication |\n| Part 20 costs and attorney fees | Successful harmed claimant | Liability under §2015(3) | Costs and attorney fees; no rate/cap specified in section | Exact fee reasonableness procedure not stated |\n| Part 20 equity/injunction | Person harmed | Part 20 violation | Court-determined | Separate from money damages |\n| Part 20 class action | Eligible representative/class | Part 20 violation and class prerequisites | Aggregate class relief | Distinct from MCPA’s no-class rule |\n| Part 20 enumerated fine | Public enforcement | Unlicensed counseling, no separate trust account, or missing required records | Up to $5,000 for each violation | Not automatically imposed; section does not call it criminal |\n| Part 21 public restitution | AG or eligible county attorney | Violation of §2102 or §2103 | Proven restorative amount; no stated numeric cap | Court discretion and causation |\n| Part 21 public fees/costs | AG or county attorney | Successful remedy action | Reasonable fees and investigation/litigation costs | Public, not consumer attorney fees |\n| Part 21 assurance violation | Public enforcer | Violation of assurance | Up to $10,000 | Reopening authority does not resolve every limitation question |\n| Part 21 cancellation refund | Debtor on request | Cancellation before completion; collected/unrefunded service fees; no offer on allocated account | 50% of qualifying service fees | Setup-fee exclusion only from this subsection |\n| Private MCPA base | Consumer | Unlawful act causing ascertainable loss | Greater of loss or $500 | Individual action only under §133 |\n| Private MCPA enhancement | Consumer | Court discretion; actual damages ≤$100,000 | Up to 3 × ascertainable loss | No punitive damages; not an automatic award |\n| Private MCPA attorney fees | Prevailing party | Court discretion | Maximum $250/hour | No fee award if consumer’s actual recovery ≥$100,000 |\n| MCPA injunction/TRO violation | State | Violation of court order | Up to $10,000 each | Civil fine |\n| MCPA willful violation | State | Knew/should have known; §111 action | Up to $10,000 each | In addition to other relief |\n| MCPA criminal fraudulent course | Prosecutor | Fraudulent course and conviction | Up to $5,000 and/or 1 year | Not every deceptive practice |\n| Vulnerable-adult enhancement | State | Statutory knowledge/loss factors | Up to $10,000 each | Additional civil penalty |\n| General punitive damages | Separate qualifying tort claimant | Actual fraud or actual malice, clear and convincing evidence | Subject to general statutory limits | Not available under private MCPA §133 itself |\n| TSR private action | Adversely affected person | Pattern or practice violating federal telemarketing rule; federal amount threshold | Actual damages; amount in controversy must exceed $50,000 for each person | Separate federal standing, notice, and three-year rules |\n| CROA private action | Covered consumer | CROA violation | Greater of actual damages or amount paid; punitive and fees may be available | Only if actual CROA coverage exists |\n\nClaims: S_MT-P7-C007–C020, C026–C037.\n\n# G. Remedy-specific limitations, accrual, and review deadlines\n\n## G1. Private MCPA claim\n\nSection 30-14-133 now expressly states that an action must be commenced within the period in §27-2-211. That provision supplies a two-year period for a liability created by statute. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html)\n\nThe general accrual rule provides that a claim accrues when all elements exist and the right to maintain the action is complete. Ignorance ordinarily does not delay accrual unless another statute provides otherwise. Discovery postponement for injury to person or property is limited to injuries that are self-concealing by nature or where the defendant took action preventing discovery. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html)\n\nIn *Osterman v. Sears*, the Montana Supreme Court held that an MCPA claim is a statutory liability governed by §27-2-211 and applied Montana’s inquiry-notice and concealment principles. The current statute now independently cross-references §27-2-211, making the two-year classification express. [Judicial Document Service+2](https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op)\n\n## G2. Part 20 express damages and fee-return claims\n\nSection 30-14-2015 contains no express limitation period. An affirmative action for statutory Part 20 damages is likely a liability created by statute and therefore subject to §27-2-211’s two-year period. That conclusion is strongly supported by *Osterman’s* statutory-liability analysis but was not located in a controlling case specifically construing §30-14-2015.\n\nThe following remain unresolved:\n\n- Whether an affirmative action solely to enforce the all-fee-return clause receives the same two-year treatment.\n- Whether voidness may be raised defensively after an affirmative recovery period expires.\n- Accrual when an unauthorized recurring charge is concealed.\n- Whether each charge creates a separate accrual date.\n- Class-action tolling.\n- Equitable tolling or estoppel in a provider-statute case.\n\nNo universal discovery rule should be assumed.\n\n## G3. Part 21 private remedies\n\nA debtor proceeding under private MCPA §30-14-133 has the same express two-year period. A separate contract, fraud, restitution, or other state-law claim could have a different period, but those causes are outside this pass.\n\nThe direct Part 21 cancellation-refund duty does not contain its own limitation provision. If enforced through §30-14-133, the two-year MCPA period applies; whether another theory is available, and when the refund claim accrues after cancellation and request, remain unresolved.\n\n## G4. Department and other public actions\n\nTwo current provisions must be kept distinct:\n\n- A Department injunction action under §30-14-111 may be brought within five years **on discovery** of the alleged violation.\n- Section 30-14-135 states that Department enforcement actions under Part 1 are subject to §27-2-231, the five-year residual period after accrual. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html)\n\nNo controlling decision reconciling every application of those provisions was located. The specific §111 discovery rule governs the action described in that section; other Department remedies require claim-specific analysis.\n\nPart 21’s direct attorney-general and county-attorney provision contains no express filing period. The five-year residual provision may be relevant, but no controlling Part 21 case was found. The phrase allowing a Part 21 matter to be reopened “at any time” after an assurance does not necessarily eliminate every limitation or due-process defense to a later penalty action.\n\n## G5. Criminal prosecution\n\nThe fraudulent-course offense under §30-14-142 allows up to one year of imprisonment and therefore falls within Montana’s misdemeanor definition. The general misdemeanor limitation is one year after commission, subject to the continuing-course rule and the statute’s commencement provisions. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html)\n\nNo standalone Part 20 or Part 21 criminal offense was identified.\n\n## G6. Administrative license proceedings and judicial review\n\nNo Part 20-specific deadline for commencing a license-denial, suspension, or revocation proceeding was located. Civil and criminal limitation periods may not be imported automatically into administrative discipline.\n\nFor a final written contested-case decision:\n\n- Administrative remedies generally must be exhausted.\n- An aggrieved party ordinarily must petition for judicial review within 30 days after service of the final decision.\n- A timely rehearing request changes the trigger as provided by §2-4-702.\n- Filing for review does not automatically stay the agency decision. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0070/section_0020/0020-0040-0070-0020.html)\n\n## G7. CID challenge\n\nA person served with a civil investigative demand must seek extension, modification, or set-aside relief by the return date or within 20 days after service, whichever is shorter. This is not the deadline for a private damages action. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html)\n\n## G8. Tolling and complaint filing\n\nMontana’s limitation title contains separate tolling provisions addressing disability, absence, death, stays, arbitration, and other circumstances, but those provisions were not comprehensively applied in this component. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0040/sections_index.html)\n\nNo provision read here establishes that any of the following tolls a private limitation period:\n\n- Filing an OCP complaint.\n- Contacting the provider.\n- Participating in informal mediation.\n- Waiting for an agency response.\n- A provider’s internal investigation.\n- A pending registration review.\n\n### Limitation and trigger matrix\n\n| Claim or proceeding | Initial period identified | Trigger | Discovery or tolling qualification | Status |\n| --- | --- | --- | --- | --- |\n| Private MCPA §133 | 2 years | When all elements exist, subject to §27-2-102 | Limited concealment/prevention rules; statute now expressly cites §211 | Answered |\n| Part 20 §2015 affirmative damages | Likely 2 years | Likely when violation and harm complete | No Part 20-specific appellate decision located | Partial |\n| Part 20 §2010(4)(g) fee-return action | Likely statutory-liability analysis, but exact period unresolved | Possibly unauthorized receipt or refusal to return | Defensive voidness and recurring-charge accrual unresolved | Unresolved |\n| Part 21 private MCPA remedy | 2 years | When unlawful act causes ascertainable loss | Same MCPA rules | Answered |\n| Part 21 cancellation refund under another theory | Unresolved | Cancellation, request, and failure to refund may all matter | No controlling construction located | Unresolved |\n| Department §111 injunction | 5 years on discovery | Department discovery of alleged violation | Statute-specific | Answered |\n| Other Department Part 1 enforcement | 5-year residual after accrual | Accrual under §27-2-231 | Relationship to specific provisions claim-dependent | Partial |\n| AG/county direct Part 21 action | No express Part 21 period | Claim-specific | Residual period potentially relevant; no case located | Unresolved |\n| MCPA fraudulent-course criminal prosecution | 1 year as misdemeanor | Commission; continuing course ends when conduct terminates | Statutory criminal tolling rules not fully audited | Answered in core |\n| Part 20 administrative discipline | No specific commencement period found | Agency action based on licensing conditions/rules | Due-process and laches questions held | Unresolved |\n| Judicial review of final contested order | 30 days after service | Service of final decision, subject to rehearing rule | Filing does not automatically stay | Answered |\n| CID challenge | Return date or 20 days after service, whichever shorter | Service/return date | Specific statutory mechanism | Answered |\n| Bond or policy claim | Not addressed | Actual instrument and claim terms | P5 unreviewed; no importation | Excluded |\n| Ordinary contract, fraud, debt, or collection claim | Not addressed | Cause-specific | Separate limitation analysis required | Excluded |\n\n# H. Operational complaint route, orders, and case-law search\n\n## H1. Current OCP complaint route\n\nThe current official search rendering for the Montana Office of Consumer Protection complaint page says consumers should first attempt to resolve the matter with the business, may submit an online or downloaded complaint, and that OCP evaluates whether it has authority, may provide the business an opportunity to respond, may refer the complaint, and retains complaint information for monitoring. The direct page was not successfully opened in this pass, so this is search-rendered operational evidence. [Montana Department of Justice](https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/)\n\nThe official complaint form, OCP-100 revision 8/07, asks for supporting agreements and advertisements, the consumer’s attempts to contact the business, desired relief, and other complaints or proceedings. It states that:\n\n- OCP has discretion to accept, investigate, or resolve a complaint.\n- OCP is not the consumer’s attorney.\n- No attorney-client relationship is created.\n- The consumer authorizes OCP to use the information in performing its duties. [Montana Department of Justice+2](https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf)\n\nThese instructions do not create a statutory pre-suit demand, cure period, exhaustion requirement, or tolling rule.\n\n## H2. Controlling and materially relevant decisions located\n\n### *Osterman v. Sears*, 2003 MT 327\n\n- **Posture:** Montana Supreme Court review of dismissal/limitation issues.\n- **Relevant holding:** An MCPA cause of action is a liability created by statute governed by §27-2-211; the court applied accrual and inquiry-notice principles.\n- **Current significance:** The current §30-14-133 now expressly cites §27-2-211, confirming the two-year category.\n- **Limit:** It did not construe Part 20 or Part 21. [Judicial Document Service+2](https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op)\n\n### *Anderson v. ReconTrust Co.*, 2017 MT 313\n\n- **Posture:** Montana Supreme Court review of dismissal.\n- **Relevant holding:** A private MCPA complaint must plead an unlawful practice that caused ascertainable financial or property loss; conclusory allegations without a causal link were inadequate.\n- **Limit:** It was not a debt-management or settlement-provider case. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html)\n\n### *Morrow v. Bank of America*, 2014 MT 117\n\n- **Posture:** Montana Supreme Court certified-question/appellate consideration involving mortgage servicing.\n- **Relevant holding:** MCPA coverage can extend to service-related conduct; the court applied Montana’s unfairness standard and recognized potentially ascertainable consumer injury.\n- **Limit:** It did not construe Parts 20 or 21. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html)\n\n### *Norris v. Olson*, 2024 MT 123\n\n- **Posture:** Montana Supreme Court appeal.\n- **Relevant holding:** Reiterated consumer status, unlawful conduct, causation, and ascertainable loss as private MCPA elements.\n- **Limit:** Not a provider-statute case. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html)\n\n### *Granbois v. Big Horn County Electric Cooperative*, 1999 MT 249\n\n- **Posture:** Montana Supreme Court review.\n- **Relevant holding:** The regulated-activity exemption is not a general immunity merely because an entity is regulated.\n- **Limit:** The court remanded and did not finally adjudicate the underlying consumer claim. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html)\n\n## H3. Provider-specific cases and orders not located\n\nTargeted searches were conducted for:\n\n- 30-14-2010(4)(g)\n- 30-14-2015\n- 30-14-2103(2)\n- 30-14-2104\n- Montana debt-management surety and fee-return litigation\n- Debt-settlement assurances of discontinuance\n- DOJ/OCP final orders and consent judgments\n- Bona fide error under the Montana Consumer Debt Management Services Act\n\nNo published Montana appellate opinion, publicly indexed final administrative order, assurance, or consent judgment construing those exact provider provisions was located. This is a bounded search result, **not proof that no district-court case, unpublished order, closed administrative file, consent matter, or nonindexed public record exists**.\n\nNo complete paid citator, all-county district docket review, or comprehensive administrative-file index was available.\n\n# I. Limited federal enforcement and private-right boundaries\n\n## I1. Federal Telemarketing and Consumer Fraud and Abuse Prevention Act\n\nThe federal private TSR route is much narrower than a Montana state claim. Section 6104 requires:\n\n- A pattern or practice violating an FTC telemarketing rule.\n- A person adversely affected.\n- More than $50,000 in actual damages for each person, exclusive of interest and costs.\n- Filing within three years after discovery.\n- Notice to the FTC unless prior notice is infeasible.\n- Coordination with a pending federal enforcement action.\n\nThe statute preserves other federal and state rights. A TSR violation does not automatically produce a small individual federal private action. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s6104/)\n\n## I2. CROA\n\nIf actual representations and activities bring the provider within CROA, federal civil liability can include the greater of actual damages or amounts paid, punitive damages, costs, and reasonable attorney fees. CROA also contains class relief. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679g/)\n\nThe limitation period is generally five years from the violation. A discovery-based extension applies only when a material and willful misrepresentation concerns information required to be disclosed and is material to establishing liability. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679i/)\n\nNo CROA coverage finding is made here.\n\n## I3. CFPA\n\nThe read Consumer Financial Protection Act provisions authorize Bureau civil actions and certain state attorney-general or regulator public-enforcement actions, subject to statutory coordination and limitation rules. Those provisions do not themselves supply the Montana private remedy analyzed in this report. A categorical conclusion about every possible implied or incorporated federal private claim is held absent a controlling case. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t12/s5564/)\n\n# J. Bounded examples\n\nAll amounts are U.S. dollars. These are statutory-mechanics demonstrations, not predictions of an actual judgment. They assume coverage and proof only where expressly stated.\n\n## Example 1 — Unauthorized charge without bona fide error\n\n**Facts**\n\n- Valid Part 20 DMP initially exists.\n- Initial fee collected: $75.\n- Six monthly fees collected: 6 × $30 = $180.\n- Provider then imposes an unauthorized $20 “processing charge.”\n- The charge is a provider fee.\n- No bona fide error is established.\n\n**Total fees received**\n\n$75+$180+$20=$275\\$75+\\$180+\\$20=\\$275$75+$180+$20=$275**Section 30-14-2010(4)(g) consequence**\n\n- DMP becomes void.\n- Required fee return: **$275**, not merely the unauthorized $20.\n\nThis calculation does not include consumer creditor-payment principal. The statute’s all-fee-return command does not state that principal is part of the $275.\n\nClaims: S_MT-P7-C007–C010.\n\n## Example 2 — Bona-fide-error branch\n\n**Facts**\n\n- Total previously authorized fees: $300.\n- Processor accidentally posts a duplicate $30 charge.\n- Provider claims bona fide error.\n\n### Branch A — provider proves a qualifying bona fide error\n\nThe automatic DMP voidness and all-fee-return consequence under subsection (4)(g) does not attach on the current text.\n\nThat does **not** mean the provider may keep the duplicate $30. Correction, contract, MCPA, actual-harm, and other remedies require separate analysis.\n\n### Branch B — error is not bona fide\n\nFor example, the charge results from a recurring configuration knowingly left in place.\n\nTotal fees received:\n\n$300+$30=$330\\$300+\\$30=\\$330$300+$30=$330The subsection’s mandatory consequence is return of **all $330 in fees**, not only the duplicate $30.\n\nClaims: S_MT-P7-C008–C011.\n\n## Example 3 — Part 20 per-violation damages without automatic double counting\n\nAssume a court finds two genuinely distinct Part 20 violations.\n\n### Violation A\n\n- Actual damages: $300.\n- Consequential damages: $100.\n\n$300+$100=$400\\$300+\\$100=\\$400$300+$100=$400Compare with statutory floor:\n\nmax⁡($400,$500)=$500\\max(\\$400,\\$500)=\\$500max($400,$500)=$500### Violation B\n\n- Actual damages: $700.\n- Consequential damages: $200.\n\n$700+$200=$900\\$700+\\$200=\\$900$700+$200=$900Compare with floor:\n\nmax⁡($900,$500)=$900\\max(\\$900,\\$500)=\\$900max($900,$500)=$900### Total if the court treats them as separate, nonoverlapping violations\n\n$500+$900=$1,400\\$500+\\$900=\\$1,400$500+$900=$1,400Costs and attorney fees are separate. If the same dollar loss was counted in both violation calculations, the $1,400 total would require adjustment. The statute does not define the unit of violation or authorize duplicate compensation.\n\nClaims: S_MT-P7-C012–C015.\n\n## Example 4 — Fee return and damages overlap\n\n**Facts**\n\n- Unauthorized-fee clause requires $275 in all-fee return.\n- Claimant proves $400 in actual and consequential damages.\n- The $400 includes the same $275 in fees plus $125 of separate consequential loss.\n\nPart 20 damages comparison:\n\nmax⁡($400,$500)=$500\\max(\\$400,\\$500)=\\$500max($400,$500)=$500It would be incorrect to announce a guaranteed recovery of:\n\n$275+$500=$775\\$275+\\$500=\\$775$275+$500=$775without deciding overlap. The court would need to determine whether the $275 fee return is separately restorative, whether the $500 floor replaces or supplements overlapping compensation, and how to credit the same $275. The exact combined award is held.\n\nClaims: S_MT-P7-C009, C013–C016, C036.\n\n## Example 5 — Private MCPA enhancement and attorney-fee cap\n\n**Assumptions**\n\n- Ascertainable loss: $2,000.\n- Consumer proves all private MCPA elements.\n- Actual damages do not exceed $100,000.\n- Court exercises maximum enhancement discretion.\n- Twenty compensable attorney hours are approved.\n- Claimed rate is $325 per hour.\n\nBase money damages:\n\nmax⁡($2,000,$500)=$2,000\\max(\\$2,000,\\$500)=\\$2,000max($2,000,$500)=$2,000Maximum enhanced money-damages figure:\n\n3×$2,000=$6,0003\\times \\$2,000=\\$6,0003×$2,000=$6,000The enhancement is not calculated as:\n\n$2,000+$6,000\\$2,000+\\$6,000$2,000+$6,000Attorney-fee hourly cap:\n\n20×$250=$5,00020\\times \\$250=\\$5,00020×$250=$5,000Potential structure, if fully awarded:\n\n- Money damages: up to $6,000.\n- Attorney fees: up to $5,000 for the approved 20 hours.\n- Taxable or allowable costs: separately determined.\n- Punitive damages under §30-14-133: $0.\n\nNone of those discretionary components is automatic.\n\nClaims: S_MT-P7-C025–C030.\n\n## Example 6 — Public restitution versus private recovery\n\n**Facts**\n\n- Ten consumers each paid $400 obtained through a proven unlawful practice.\n- State seeks restoration of those amounts.\n\nPotential public restitution:\n\n10×$400=$4,00010\\times \\$400=\\$4,00010×$400=$4,000Each consumer may separately analyze a private MCPA claim. If a consumer receives the $400 through public restitution, that same $400 generally cannot simply be counted again as unpaid ascertainable loss without an overlap analysis.\n\nA civil fine, if separately authorized and imposed, is payable as a public sanction rather than compensation to the consumer.\n\nClaims: S_MT-P7-C021–C027, C036.\n\n## Example 7 — Part 21 cancellation refund is not exclusive\n\n**Assumptions**\n\nCollected and unrefunded nonsetup service-fee allocations:\n\n- Debt A, settlement offer received: $300.\n- Debt B, no settlement offer: $300.\n- Debt C, no settlement offer: $200.\n\nQualifying no-offer fee base:\n\n$300+$200=$500\\$300+\\$200=\\$500$300+$200=$500Montana cancellation refund:\n\n50%×$500=$25050\\%\\times \\$500=\\$25050%×$500=$250The $300 allocated to Debt A is excluded from this subsection’s no-offer calculation. A setup fee is also excluded from this particular state calculation.\n\nThe $250 result does not determine whether any of the underlying fees were lawfully earned or collected. A premature federal collection, deceptive representation, or contract violation may support other relief.\n\nClaims: S_MT-P7-C017–C020.\n\n## Example 8 — Licensing discipline versus consumer damages\n\n**Facts**\n\n- A Part 20 licensee no longer satisfies a required licensing condition.\n- DOJ serves notice and starts a contested proceeding.\n- No consumer loss has yet been shown.\n\nPossible consequences:\n\n- Refusal, suspension, or revocation under §30-14-2004(4), subject to process.\n- No automatic private $500 award merely because a licensing condition failed; a Part 20 claimant must be a person harmed.\n- Public injunction may still be available if the separate public predicates are met.\n\nIf the agency serves a final contested-case decision on “Day 0,” the judicial-review petition ordinarily must be filed within 30 days after service, subject to the rehearing provisions. Filing does not automatically stay the order.\n\nClaims: S_MT-P7-C003–C006, C033–C035.\n\n## Example 9 — OCP complaint does not establish tolling\n\n**Sequence**\n\n- Day 0: Consumer’s private MCPA claim accrues.\n- Day 100: Consumer files an OCP complaint.\n- OCP requests a business response.\n- Consumer waits for the informal process.\n\nNo reviewed statute says the OCP filing pauses the two-year private period. Unless another tolling doctrine applies, the private claimant must calculate the court-filing deadline independently.\n\nNo exact calendar date is supplied because actual accrual, service, concealment, disability, weekends, holidays, and tolling facts are absent.\n\nClaims: S_MT-P7-C031–C035, C040.\n\n## Example 10 — Excluded or expired branch\n\n### Coverage failure\n\nA Montana-licensed attorney performs debt advice solely in ordinary professional practice and satisfies the complete Part 21 exclusion. Part 21 liability is not established merely because the advice concerned settlement. MCPA, professional-duty, or contract questions remain separate.\n\n### Standing failure\n\nA Part 21 disclosure violation occurs, but the private claimant alleges no loss of money or property caused by it. A private §30-14-133 damages claim is not established, although public enforcement may remain possible.\n\n### Time failure\n\nA private MCPA claim is filed after the two-year period with no applicable concealment or tolling facts. An OCP complaint or provider correspondence does not, on the current record, revive it. A public enforcement route may have a different period, but that does not revive the private action.\n\nClaims: S_MT-P7-C001–C002, C023–C025, C031–C040.\n\n# K. PASS-07 source register\n\n| Source ID | Instrument, issuer, full literal URL, and pinpoint | Version/status/access and limits |\n| --- | --- | --- |\n| **S_MT-P7-S001** | **Montana Consumer Debt Management Services Act**, Montana Legislature. Scope: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html, §30-14-2002. Definitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html, §2003. Licensing: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html, §2004. DMP/voidness: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html, §2010, especially (4)(g). Prohibitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html, §2013. Remedies: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html, §2015. | **Fresh direct official HTML read October 26, 2026.** MCA 2025 published text; no PDF page/index. No comprehensive post-2025 session or special-session audit. [Montana Code Annotated+5](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html) |\n| **S_MT-P7-S002** | **Regulation of Debt Settlement Providers**, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html, §2101. Requirements: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html, §2102. Prohibitions/refund: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html, §2103. Enforcement: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html, §2104. | **Fresh direct official HTML read October 26, 2026.** MCA 2025 published text. No comprehensive post-2025 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-P7-S003** | **Montana Consumer Protection Act—definitions, unlawful practices, and exemptions**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html, §103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0040/0300-0140-0010-0040.html, §104; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html, §105. | **Fresh direct official HTML read October 26, 2026.** MCA 2025. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html) |\n| **S_MT-P7-S004** | **Montana Consumer Protection Act—public enforcement and private remedies**, Montana Legislature. Injunction: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html, §111. Assurance: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0120/0300-0140-0010-0120.html, §112. CID: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html, §113. Investigations: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html, §114. County attorney: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0210/0300-0140-0010-0210.html, §121. Restoration: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0310/0300-0140-0010-0310.html, §131. Receiver: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0320/0300-0140-0010-0320.html, §132. Private action: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html, §133. Department limitation: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0350/0300-0140-0010-0350.html, §135. Penalties: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0420/0300-0140-0010-0420.html, §142. Vulnerable adult: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0440/0300-0140-0010-0440.html, §144. | **Fresh direct official HTML read October 26, 2026.** MCA 2025. Used only for remedies/enforcement. [Montana Code Annotated+10](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html) |\n| **S_MT-P7-S005** | **2025 Montana Senate Bill 488, Chapter 199**, Montana Legislature. https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf. Relevant current MCPA amendments at printed pp.2–3, zero-based PDF indices 1–2. | **Fresh official eight-page PDF read and relevant pages visually inspected October 26, 2026.** Enacted law; effective on passage and approval. Exact gubernatorial approval date was not exposed in the inspected segment and is not invented. Confirms §111 five-year discovery language and current §133 damages, class, punitive, and fee provisions. [Montana Legislative Archive+2](https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf) |\n| **S_MT-P7-S006** | **Montana civil limitation and accrual statutes**, Montana Legislature. Accrual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html, §27-2-102. Statutory liabilities: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0110/0270-0020-0020-0110.html, §27-2-211. Residual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0310/0270-0020-0020-0310.html, §27-2-231. Tolling index: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0040/sections_index.html. | **Fresh direct official HTML read October 26, 2026.** Tolling provisions were indexed but not comprehensively applied. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html) |\n| **S_MT-P7-S007** | **Montana Administrative Procedure Act**, Montana Legislature. Contested notice: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html, §2-4-601. Final orders: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0230/0020-0040-0060-0230.html, §623. License proceedings: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0310/0020-0040-0060-0310.html, §631. Judicial review: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0070/section_0020/0020-0040-0070-0020.html, §702. | **Fresh direct official HTML read October 26, 2026.** Application is conditional on a contested licensing proceeding and final written decision. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html) |\n| **S_MT-P7-S008** | **Montana criminal limitation and misdemeanor definition**, Montana Legislature. Limitation: https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html, §45-1-205. Definition: https://mca.legmt.gov/bills/mca/title_0450/chapter_0020/part_0010/section_0010/0450-0020-0010-0010.html, §45-2-101(42). | **Fresh official HTML/search-rendered text October 26, 2026.** Used only for the MCPA fraudulent-course offense. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html) |\n| **S_MT-P7-S009** | **ARM 23.19.101—Unfair or Deceptive Acts or Practices**, Montana Secretary of State. Status page: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be. Text route: https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d. | **Fresh official search rendering October 26, 2026; direct opens returned HTTP 405.** Status displayed “Effective,” and search rendering returned the enumerated acts. Not treated as a complete freshly opened rule body. [Montana Administrative Rules+1](https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be) |\n| **S_MT-P7-S010** | ***Osterman v. Sears, Roebuck & Co.*, 2003 MT 327**, Montana Supreme Court. Official PDF: https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op. Relevant limitation discussion at ¶¶21–30, approximately printed pp.7–12, zero-based PDF indices 6–11. | **Fresh full 17-page official opinion parse and relevant-page visual inspection October 26, 2026.** Precedential; predates the 2025 express §133 limitation reference but remains materially consistent. [Judicial Document Service+2](https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op) |\n| **S_MT-P7-S011** | ***Anderson v. ReconTrust Co.*, 2017 MT 313**, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html, especially ¶¶19–22. | **Fresh full HTML opinion read October 26, 2026.** Secondary host of primary judicial opinion; no official court PDF was located in the bounded search. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html) |\n| **S_MT-P7-S012** | ***Morrow v. Bank of America, N.A.*, 2014 MT 117**, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html, especially ¶¶67–70. | **Fresh full HTML opinion read October 26, 2026.** Secondary host of primary opinion. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html) |\n| **S_MT-P7-S013** | ***Norris v. Olson*, 2024 MT 123**, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html, especially ¶¶16–18. | **Fresh full HTML opinion read October 26, 2026.** Secondary host of primary opinion. [Justia Law](https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html) |\n| **S_MT-P7-S014** | ***Granbois v. Big Horn County Electric Cooperative*, 1999 MT 249**, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html. | **Fresh full HTML opinion read October 26, 2026.** Secondary host; used only for exemption boundary and posture. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html) |\n| **S_MT-P7-S015** | **Consumer Complaints**, Montana DOJ Office of Consumer Protection. https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/. | **Fresh official search-rendered operational material October 26, 2026; direct page not successfully opened.** Not legal tolling, exhaustion, or adjudication authority. [Montana Department of Justice](https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/) |\n| **S_MT-P7-S016** | **Consumer Complaint Form OCP-100**, Montana DOJ. https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf. Revision 8/07; relevant printed pp.1–2, zero-based PDF indices 0–1. | **Fresh official three-page PDF parsed and relevant pages visually inspected October 26, 2026.** Old revision; no current-version audit. [Montana Department of Justice+2](https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf) |\n| **S_MT-P7-S017** | **Federal private telemarketing action**, 15 U.S.C. §6104, U.S. House Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s6104/. | **Fresh direct official HTML read October 26, 2026.** Text through Public Law 119-124, October 15, 2026. Limited private-right boundary only. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s6104/) |\n| **S_MT-P7-S018** | **CROA civil liability and limitation**, 15 U.S.C. §§1679g and 1679i. https://uscode.house.gov/us/usc/119-124/t15/s1679g/; https://uscode.house.gov/us/usc/119-124/t15/s1679i/. | **Fresh direct official HTML read October 26, 2026.** Coverage remains unresolved. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1679g/) |\n| **S_MT-P7-S019** | **CFPA public enforcement**, 12 U.S.C. §§5564 and 5552. https://uscode.house.gov/us/usc/119-124/t12/s5564/; https://uscode.house.gov/us/usc/119-124/t12/s5552/. | **Fresh direct official HTML read October 26, 2026.** Used only to distinguish public federal enforcement; no full CFPA dossier. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t12/s5564/) |\n| **S_MT-P7-S020** | **General Montana punitive damages**, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html, §27-1-220; https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0210/0270-0010-0020-0210.html, §27-1-221. | **Fresh direct official HTML read October 26, 2026.** Used only to bound a separate tort route; private MCPA §133 expressly bars punitive damages. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html) |\n| **S_MT-P7-S021** | **Targeted public provider-order and case search log**, official Montana DOJ, Montana courts, and public case repositories; searches included the exact provider sections and quoted operative phrases. | **Fresh bounded searches October 26, 2026.** No exact Part 20/Part 21 merits order or appellate construction was located. This row is provenance, not authority and not proof of absence. [Montana Department of Justice+3](https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/) |\n\n# L. PASS-07 claim register\n\n| Claim ID | Precise claim | Source and pinpoint | Conditions, consequence, and confidence |\n| --- | --- | --- | --- |\n| **S_MT-P7-C001** | Part 20 applies to persons providing or offering DMPs to Montana residents, subject to its exact institutional/professional exclusions. | S001 §§2002–2003 | **High.** Actual activity and exclusion facts required. |\n| **S_MT-P7-C002** | Part 21 covers compensated, holding-out, ordinarily noncustodial settlement providers and excludes entities subject to Part 20. | S002 §2101 | **High.** Hybrid/affiliate facts held. |\n| **S_MT-P7-C003** | DOJ may refuse, suspend, or revoke a Part 20 license for failure to satisfy §2004(1)–(3) or departmental rules. | S001 §2004(4) | **High.** Not an express automatic discipline clause for every Part 20 violation. |\n| **S_MT-P7-C004** | Part 20 remedies apply to licensed and unlicensed persons to whom the Act applies. | S001 §2015(2) | **High.** |\n| **S_MT-P7-C005** | Part 21 contains no express administrative suspension/revocation section comparable to §2004(4). | S002 §§2101–2104 | **High bounded negative.** Operational registration procedures held. |\n| **S_MT-P7-C006** | Contested license proceedings may invoke APA notice, hearing, emergency-suspension, and 30-day judicial-review rules. | S007 §§601, 623, 631, 702 | **High conditionally.** Depends on actual contested-case posture. |\n| **S_MT-P7-C007** | Unauthorized Part 20 fees, charges, funds, or payments void the DMP unless resulting from bona fide error. | S001 §2010(4)(g) | **High.** |\n| **S_MT-P7-C008** | When subsection (4)(g) applies, the service must return all fees received from or on behalf of the consumer. | S001 §2010(4)(g) | **High.** Not limited to unauthorized increment. |\n| **S_MT-P7-C009** | The text orders return of all fees, not expressly all consumer principal or creditor funds. | S001 §2010(4)(g) | **High textual boundary.** Other law may govern principal. |\n| **S_MT-P7-C010** | No cure, notice, reliance, minimum amount, or intent predicate appears in §2010(4)(g). | S001 §2010(4)(g) | **High bounded negative.** |\n| **S_MT-P7-C011** | “Bona fide error” is undefined in the read statute, and no controlling provider-statute construction was located. | S001 §2010(4)(g); S021 | **High provenance; legal standard unresolved.** |\n| **S_MT-P7-C012** | A person harmed by a Part 20 violation may recover actual and consequential damages or $500, whichever greater, for each violation. | S001 §2015(3) | **High.** Harm and causation required. |\n| **S_MT-P7-C013** | Part 20 adds costs and attorney fees and permits equitable, injunctive, and class relief. | S001 §2015(3)–(5) | **High.** Exact fee calculation held. |\n| **S_MT-P7-C014** | Part 20 remedies are cumulative and nonexclusive. | S001 §2015(1), (6) | **High.** Does not itself authorize duplicate compensation. |\n| **S_MT-P7-C015** | Each Part 20 violation is also an MCPA §103 violation. | S001 §2015(2) | **High.** Separate MCPA private elements remain. |\n| **S_MT-P7-C016** | The statute does not define how to combine all-fee return, statutory damages, compensatory damages, public restitution, and third-party recovery. | S001 §§2010, 2015; S021 | **High unresolved boundary.** |\n| **S_MT-P7-C017** | Part 20 authorizes a fine up to $5,000 per violation only for the three enumerated licensing/trust/records categories. | S001 §2015(8) | **High.** Not automatic and not expressly criminal. |\n| **S_MT-P7-C018** | Part 21 public enforcement may include injunction, restitution, reasonable fees, and investigation/litigation costs. | S002 §2104(1) | **High.** Court-determined. |\n| **S_MT-P7-C019** | A Part 21 assurance may include costs, escrow, and restitution; violation may draw up to $10,000, and the matter may be reopened at any time. | S002 §2104(2) | **High.** Separate penalty limitation unresolved. |\n| **S_MT-P7-C020** | Part 21 cancellation requires, on request, 50% of qualifying collected/unrefunded service fees allocated to no-offer accounts; setup fees are excluded only from that subsection. | S002 §2103(2) | **High.** No legalization or exclusivity implication. |\n| **S_MT-P7-C021** | A Part 21 debtor receives Part 1 and other state-law remedies, not a separate Part 21 fixed-damages formula. | S002 §2104(3) | **High.** |\n| **S_MT-P7-C022** | MCPA trade/commerce is broad, but private §133 standing is limited to a consumer with causally resulting ascertainable loss. | S003 §102; S004 §133; S011–S013 | **High.** |\n| **S_MT-P7-C023** | Montana does not impose a universal reliance element, but representation-based claims may need reliance facts to prove causation. | S011; S013 | **High qualified case-law conclusion.** |\n| **S_MT-P7-C024** | The MCPA regulated-activity exemption is narrow and not a blanket immunity for regulated or licensed entities. | S003 §105; S014 | **High.** |\n| **S_MT-P7-C025** | Private MCPA base recovery is the greater of ascertainable loss or $500. | S004 §133(1) | **High.** |\n| **S_MT-P7-C026** | Current §133 permits discretionary enhancement up to three times ascertainable loss when actual damages do not exceed $100,000. | S004 §133; S005 | **High.** Not automatic or additive. |\n| **S_MT-P7-C027** | Private §133 prohibits punitive damages and class actions. | S004 §133; S005 | **High.** Separate Part 20 or CROA class routes differ. |\n| **S_MT-P7-C028** | Private MCPA fees are discretionary, capped at $250/hour, and unavailable when actual damages recovered are at least $100,000. | S004 §133(3); S005 | **High.** |\n| **S_MT-P7-C029** | Public MCPA relief includes injunction, restoration, receivership, and license revocation. | S004 §§111, 131–132 | **High.** |\n| **S_MT-P7-C030** | Public investigation tools include CIDs, subpoenas, testimony, and hearings. | S004 §§113–114 | **High.** |\n| **S_MT-P7-C031** | Private MCPA claims use the two-year period in §27-2-211. | S004 §133; S006 §211; S010 | **High.** |\n| **S_MT-P7-C032** | Accrual generally occurs when all elements exist; discovery postponement is limited by §27-2-102. | S006 §102; S010 | **High.** |\n| **S_MT-P7-C033** | An affirmative Part 20 §2015 claim is likely subject to the two-year statutory-liability period, but no Part 20-specific controlling case was located. | S001 §2015; S006 §211; S010; S021 | **Moderate-high.** |\n| **S_MT-P7-C034** | The limitation and accrual rules for affirmative fee return, defensive voidness, recurring charges, and Part 20 class claims remain unresolved. | S001 §2010(4)(g); S006; S021 | **Unresolved.** |\n| **S_MT-P7-C035** | Department §111 injunction actions have a five-year discovery period; general Department enforcement references the five-year residual period after accrual. | S004 §§111, 135; S006 §231 | **High for text; reconciliation claim-specific.** |\n| **S_MT-P7-C036** | A final contested-case decision ordinarily must be challenged within 30 days after service; filing does not automatically stay it. | S007 §702 | **High.** |\n| **S_MT-P7-C037** | A CID challenge must be brought by its return date or within 20 days after service, whichever is shorter. | S004 §113 | **High.** |\n| **S_MT-P7-C038** | OCP complaint filing is not established as exhaustion, cure, or tolling. | S015–S016; S001–S007 | **High bounded negative.** |\n| **S_MT-P7-C039** | The TSR private federal route requires a pattern or practice, more than $50,000 actual damages for each person, notice, and filing within three years after discovery. | S017 | **High, conditional on federal coverage.** |\n| **S_MT-P7-C040** | CROA conditionally provides broader federal damages and a five-year limitation, but actual CROA coverage remains held. | S018 | **High, conditional.** |\n| **S_MT-P7-C041** | The read CFPA provisions establish Bureau and state public-enforcement routes but do not themselves supply the Montana private remedy. | S019 | **High bounded conclusion.** |\n| **S_MT-P7-C042** | General punitive damages require a separate qualifying claim involving actual fraud or malice and clear-and-convincing proof; private MCPA punitive damages are barred. | S020; S004 §133 | **High boundary.** |\n| **S_MT-P7-C043** | No exact published appellate construction or publicly indexed final order for the core Part 20/21 remedy clauses was located. | S021 | **Bounded search result only.** |\n| **S_MT-P7-C044** | Bond or insurance existence does not establish a direct claimant right, covered loss, solvent issuer, exhaustion order, or recovery. | No accepted P5 premise; S001–S004 | **Held.** Full security litigation excluded. |\n| **S_MT-P7-C045** | Parallel causes may be pleaded, but the read statutes do not authorize compensating the same dollar loss twice. | S001 §2015; S004 §§131, 133 | **Reasoned accounting boundary; exact provider case absent.** |\n\n# M. Component coverage and gap table\n\n| Component | Status | Claim IDs | Exact missing evidence or next action |\n| --- | --- | --- | --- |\n| Part 20 scope and resident nexus | Answered textually | C001 | Apply actual offers, services, residence, and custody facts. |\n| Part 20 attorney/CPA exclusion | Partial | C001 | Verify Montana licensure and incidental/not-principal-business facts. |\n| Part 20 nonprofit treatment | Answered as no label immunity | C001 | Apply actual entity and activity. |\n| Part 20 standalone counseling branch | Partial | C001 | Current interpretation and actual holding-out/mixed-service facts. |\n| Part 21 noncustodial scope | Answered textually | C002 | Apply actual custody, agency, affiliate, and compensation facts. |\n| Part 21 professional exclusion | Partial | C002 | Verify ordinary-practice and actual entity facts. |\n| Hybrid Part 20/Part 21 model | Unresolved factually | C001–C002 | Full flow-of-services and custody record. |\n| Part 20 license refusal/suspension/revocation | Answered in statutory scope | C003, C006 | Current rules, actual notice, and contested-case posture. |\n| Part 21 registration discipline | No express statutory mechanism identified | C005 | Current DOJ procedure and any order/rule. |\n| Part 20 unauthorized-fee trigger | Answered | C007, C010 | Apply actual fee/payment and authorization facts. |\n| Part 20 all-fee return | Answered textually | C008–C009 | Allocation and overlap with damages/restoration unresolved. |\n| Bona fide error definition | Unresolved | C011 | Controlling case, order, or current rule. |\n| Bona fide error burden | Unresolved | C011 | Same. |\n| Bona fide error cure requirement | Unresolved | C011 | Same; no federal doctrine imported. |\n| Consumer-principal disposition after voidness | Excluded/unresolved | C009 | P4 funds review and controlling law. |\n| Part 20 actual damages | Answered | C012 | Prove causation and amount. |\n| Part 20 consequential damages | Answered | C012 | Prove foreseeability/causation under applicable law. |\n| Part 20 $500 per-violation floor | Answered textually | C012 | Unit-of-violation case law absent. |\n| Part 20 attorney fees and costs | Answered as available | C013 | Reasonableness procedure and amount unresolved. |\n| Part 20 equitable/injunctive relief | Answered | C013 | Actual standing and remedy facts. |\n| Part 20 class action | Answered | C013 | Rule 23/class requirements not reviewed. |\n| Part 20 cumulative remedies | Answered | C014–C016 | Overlap, election, setoff, and satisfaction rules unresolved. |\n| Part 20 enumerated $5,000 fine | Answered textually | C017 | Enforcer, procedure, and unit application require actual action. |\n| Part 20 criminal offense | No standalone offense identified | C017 | General MCPA criminal route remains separate. |\n| Part 21 AG/county authority | Answered | C018 | Actual jurisdiction, pleadings, and order. |\n| Part 21 restitution | Answered as available | C018 | Measure, causation, and recipient allocation. |\n| Part 21 assurance | Answered textually | C019 | Actual terms, admission clause, and enforcement history. |\n| Part 21 assurance penalty | Answered textually | C019 | Limitation and unit of violation unresolved. |\n| Part 21 cancellation refund | Answered in bounded form | C020 | Offer definition, request method, allocation, and deadline. |\n| Part 21 setup-fee treatment | Partial | C020 | Excluded only from subsection refund; other remedies preserved. |\n| Part 21 private fixed damages | None identified | C021 | Private MCPA/other law remains. |\n| MCPA consumer standing | Answered | C022 | Apply personal/family/household purpose. |\n| MCPA business-purpose claimant | No §133 consumer standing established | C022 | Part 20 “person harmed” or other law may differ. |\n| MCPA trade or commerce | Answered broadly | C022 | Apply actual indirect/direct conduct. |\n| MCPA regulated-activity exemption | Answered narrowly | C024 | Determine whether precise action was permitted by PSC/Auditor law. |\n| MCPA unfairness standard | Answered from cases | C022–C023 | Apply actual conduct and public policy. |\n| MCPA causation | Answered | C022–C023 | Evidence required. |\n| MCPA reliance | Partial/contextual | C023 | Representation theory and actual consumer conduct. |\n| MCPA ascertainable loss | Answered | C022, C025 | Quantify loss; statutory floor does not replace standing. |\n| MCPA base damages | Answered | C025 | Apply actual loss. |\n| MCPA enhancement | Answered textually | C026 | Post-2025 construction and judicial discretion remain. |\n| MCPA punitive damages | Answered as prohibited | C027 | Separate tort route held. |\n| MCPA private class action | Answered as prohibited | C027 | Part 20/CROA routes separate. |\n| MCPA private attorney fees | Answered | C028 | Court discretion, approved hours, and actual recovery. |\n| Public injunction | Answered | C029 | Knowledge/public-interest predicates and actual proof. |\n| Restoration/disgorgement boundary | Partial | C029, C045 | Exact measure and overlap with private recovery. |\n| Receivership | Answered in core | C029 | Bankruptcy/priority and actual estate excluded. |\n| CID and subpoenas | Answered | C030, C037 | Actual service and challenge. |\n| County-attorney route | Answered | C018, C030 | Actual venue and coordination. |\n| MCPA civil fines | Answered | C017, C019, C029 | Willfulness, order violation, and unit of violation. |\n| MCPA criminal route | Answered in core | C035 | Actual prosecution and criminal tolling beyond core not reviewed. |\n| Vulnerable-adult penalty | Answered textually | C029 | Actual age/status, knowledge, and loss facts. |\n| Private MCPA limitation | Answered | C031–C032 | Actual accrual/tolling facts. |\n| Part 20 damages limitation | Partial | C033 | Controlling Part 20 case still missing. |\n| Part 20 voidness/fee-return limitation | Unresolved | C034 | Affirmative versus defensive use and accrual authority. |\n| Part 21 private limitation | Answered for MCPA route | C031 | Other theories may differ. |\n| Part 21 public limitation | Unresolved | C035 | Controlling application of residual period. |\n| Department public limitation | Partial but bounded | C035 | Reconcile §111 and §135 for actual remedy. |\n| Administrative discipline commencement | Unresolved | C006 | No specific Part 20 filing period located. |\n| Administrative judicial review | Answered | C036 | Actual service/rehearing/stay facts. |\n| OCP complaint process | Answered operationally | C038 | Current form revision and actual agency handling remain. |\n| OCP complaint tolling | No tolling established | C038 | A specific tolling agreement or statute would be needed. |\n| Public Part 20/21 orders | Not located | C043 | Administrative-file, district-docket, and public-record review. |\n| Controlling Part 20/21 opinions | Not located | C043 | Full paid citator and trial-level search. |\n| TSR private action | Answered as conditional boundary | C039 | Actual coverage, pattern/practice, damages, and notice. |\n| CROA private action | Answered as conditional boundary | C040 | Actual representations and exclusions. |\n| CFPA public enforcement | Answered as boundary | C041 | Full federal enforcement dossier excluded. |\n| Bond or insurance claims | Excluded | C044 | P5 review, actual instrument, surety/insurer law. |\n| Double recovery/setoff | Partial | C016, C045 | Provider-specific judgment or controlling authority. |\n| Full post-2025 Montana currentness | Partial | All | Comprehensive later session, special-session, rule, and litigation audit. |\n| Actual provider, contract, account, policy, or fee earning | Excluded/unresolved | All | Entity-specific evidence required. |\n| Collections, ordinary debt limitations, garnishment, secured debt, bankruptcy, sectors, local, tribal, country, and seven parent dimensions | Excluded | — | All remain required; no closure by implication. |\n\n# N. Researcher self-check\n\n## Freshly and directly read on October 26, 2026\n\n- Complete materially relevant current published 2025 MCA Part 20 scope, definitions, licensing, DMP voidness, prohibited-practice, and remedy sections.\n- Complete materially relevant current published Part 21 definition, requirements, prohibitions, cancellation, and enforcement sections.\n- MCPA definitions, prohibited conduct, exemptions, injunction, assurance, CID, investigative power, county-attorney authority, restoration, receivership, private remedies, public limitation, civil and criminal sanctions, and vulnerable-adult provisions.\n- Official 2025 SB 488, Chapter 199, including the relevant amendment pages.\n- Montana accrual, statutory-liability limitation, residual limitation, administrative-license procedure, judicial-review, criminal-limitation, misdemeanor-definition, and general punitive-damages provisions.\n- The official *Osterman* opinion PDF and relevant pages.\n- Full public reproductions of *Anderson*, *Morrow*, *Norris*, and *Granbois*.\n- Federal private TSR, CROA, and limited CFPA enforcement provisions.\n- Official OCP complaint-form PDF.\n\n## Fresh but search-rendered or access-limited\n\n- ARM 23.19.101 was returned through the official search rendering and shown as effective; direct body routes returned HTTP 405.\n- The current OCP complaint page was available through official search rendering, not a successful direct page open.\n- Public order and case searches were bounded and did not locate an exact Part 20/Part 21 merits order or published construction.\n\n## Reused without changing historical provenance\n\n- Reviewed P1–P3 classification, fee-boundary, federal-timing, and date-correction context.\n- P1’s saved C021 as the starting incomplete voidness claim.\n- The prior provider-access and scope qualifications.\n- No old P1/P2 access was relabeled as fresh merely because the underlying section was revisited in PASS-07.\n\n## Expressly not treated as accepted authority\n\n- P4 funds interpretations.\n- P5 bond and insurance interpretations.\n- P6 agreement and electronic-execution interpretations.\n\nWhere a limited cross-reference was necessary, the underlying primary statute was read afresh rather than importing the unreviewed conclusion.\n\n## Not read or resolved\n\n- Any actual provider complaint, investigative file, CID, subpoena, assurance, consent judgment, administrative final order, license hearing, or judicial-review petition.\n- Any actual consumer contract, account, policy, bond, fee ledger, or provider authorization.\n- A complete paid citator, every Montana district-court docket, or every DOJ/OCP administrative file.\n- Complete post-2025 legislative, special-session, and rulemaking currentness.\n- Full general class-action, appellate, punitive-damages, setoff, satisfaction, receivership, bankruptcy, or surety procedure.\n- Exact Part 20 “bona fide error,” unit-of-violation, fee-return limitation, defensive voidness, and double-recovery construction.\n- Full TSR, CROA, CFPA, bankruptcy, or federal enforcement dossier.\n\nExact individual source-fetch timestamps were not exposed and are not invented. No filing, complaint submission, application, regulator contact, provider contact, purchase, account change, private-data access, browser control, other-chat access, local write, legal deadline opinion for an individual matter, provider approval, operational approval, independent review, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.\n\n**REPORT PARTIAL — the focused Montana Part 20/Part 21 enforcement, private-remedies, voidness, fee-return, and remedy-specific-limitations component is completed to the source, procedural, and currentness limits stated above.**\n\nEND S_MT PASS-07.\n\n","tables":[{"headers":["Model or status","Administrative or public route","Private route","Critical condition or hold"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or status","Administrative or public route","Private route","Critical condition or hold"],["Licensed covered Part 20 provider","DOJ licensing conditions and rule compliance; Part 1 investigation and judicial remedies","Part 20 actual/consequential damages or $500 per violation, costs, attorney fees, equity, and class relief; MCPA route also possible","Claimant must prove Part 20 coverage, violation, harm, and nonduplicative relief"],["Unlicensed person actually subject to Part 20","Part 20 remedies apply; specific fine up to $5,000 for unlicensed credit counseling; Part 1 public relief","Same express Part 20 private remedy","“Unlicensed” does not eliminate coverage; exact unit of each violation held"],["Genuine standalone counseling outside the DMP-provider entry point","No Part 20 route established solely from counseling","Other law may apply","Qualified boundary only; holding out, offers, compensation, and mixed services remain factual"],["Qualifying Part 21 noncustodial settlement provider","AG or eligible county attorney may seek injunction, restitution, fees, and costs; assurance route","Debtor gets MCPA and other state-law remedies; no separate Part 21 $500 floor or class authorization","Private MCPA claimant must satisfy consumer, causation, and ascertainable-loss elements"],["Entity actually subject to Part 20 but marketed as settlement","Part 20, not Part 21, controls the same entity’s statutory classification","Part 20 remedies if its predicates are met","Marketing label does not select the statute"],["Attorney acting in ordinary professional practice within Part 21 exclusion","Part 21 remedy not established","MCPA, professional-duty, contract, or other claims remain possible depending on facts","Attorney title alone is insufficient; actual ordinary-practice facts required"],["Montana attorney or CPA whose counseling is incidental under Part 20 exclusion","Part 20 remedy not established for excluded conduct","Other law may apply","Montana licensure and incidental/not-principal-business elements must both exist"],["Affiliate, lead generator, processor, or administrator","Entity-specific; public MCPA route may apply to indirect trade or commerce","Depends on role, attribution, consumer loss, and provider-statute coverage","No automatic immunity or liability from corporate label"],["No private ascertainable loss, but ongoing unlawful conduct","Public injunction or other public relief may remain available","Private §30-14-133 damages fail without ascertainable loss caused by the conduct","Part 20’s separate “person harmed” route must be analyzed independently"]]},{"headers":["Conduct","Maximum stated sanction","Classification"],"index":1,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Conduct","Maximum stated sanction","Classification"],["Violation of an injunction or TRO","$10,000 for each violation","Civil fine"],["Willful use of an unlawful practice in a §30-14-111 action","$10,000 for each violation, in addition to other relief","Civil fine; “willful” means knew or should have known"],["Fraudulent course of conduct resulting in conviction","$5,000 and/or imprisonment up to 1 year","Criminal"],["Knowing or should-have-known exploitation of a vulnerable adult, subject to statutory factors","Additional $10,000 for each violation","Civil penalty; private damages receive priority"]]},{"headers":["Remedy","Claimant or enforcer","Predicate","Amount or unit","Important boundary"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Remedy","Claimant or enforcer","Predicate","Amount or unit","Important boundary"],["Part 20 all-fee return","Consumer under §2010(4)(g)","Unauthorized fee/charge or unauthorized funds/payment; no bona fide error","All fees received from or on behalf of consumer","Does not textually say all consumer principal"],["Part 20 damages","Person harmed","Part 20 violation and harm","Greater of actual + consequential damages or $500, for each violation","Unit of violation and overlap require adjudication"],["Part 20 costs and attorney fees","Successful harmed claimant","Liability under §2015(3)","Costs and attorney fees; no rate/cap specified in section","Exact fee reasonableness procedure not stated"],["Part 20 equity/injunction","Person harmed","Part 20 violation","Court-determined","Separate from money damages"],["Part 20 class action","Eligible representative/class","Part 20 violation and class prerequisites","Aggregate class relief","Distinct from MCPA’s no-class rule"],["Part 20 enumerated fine","Public enforcement","Unlicensed counseling, no separate trust account, or missing required records","Up to $5,000 for each violation","Not automatically imposed; section does not call it criminal"],["Part 21 public restitution","AG or eligible county attorney","Violation of §2102 or §2103","Proven restorative amount; no stated numeric cap","Court discretion and causation"],["Part 21 public fees/costs","AG or county attorney","Successful remedy action","Reasonable fees and investigation/litigation costs","Public, not consumer attorney fees"],["Part 21 assurance violation","Public enforcer","Violation of assurance","Up to $10,000","Reopening authority does not resolve every limitation question"],["Part 21 cancellation refund","Debtor on request","Cancellation before completion; collected/unrefunded service fees; no offer on allocated account","50% of qualifying service fees","Setup-fee exclusion only from this subsection"],["Private MCPA base","Consumer","Unlawful act causing ascertainable loss","Greater of loss or $500","Individual action only under §133"],["Private MCPA enhancement","Consumer","Court discretion; actual damages ≤$100,000","Up to 3 × ascertainable loss","No punitive damages; not an automatic award"],["Private MCPA attorney fees","Prevailing party","Court discretion","Maximum $250/hour","No fee award if consumer’s actual recovery ≥$100,000"],["MCPA injunction/TRO violation","State","Violation of court order","Up to $10,000 each","Civil fine"],["MCPA willful violation","State","Knew/should have known; §111 action","Up to $10,000 each","In addition to other relief"],["MCPA criminal fraudulent course","Prosecutor","Fraudulent course and conviction","Up to $5,000 and/or 1 year","Not every deceptive practice"],["Vulnerable-adult enhancement","State","Statutory knowledge/loss factors","Up to $10,000 each","Additional civil penalty"],["General punitive damages","Separate qualifying tort claimant","Actual fraud or actual malice, clear and convincing evidence","Subject to general statutory limits","Not available under private MCPA §133 itself"],["TSR private action","Adversely affected person","Pattern or practice violating federal telemarketing rule; federal amount threshold","Actual damages; amount in controversy must exceed $50,000 for each person","Separate federal standing, notice, and three-year rules"],["CROA private action","Covered consumer","CROA violation","Greater of actual damages or amount paid; punitive and fees may be available","Only if actual CROA coverage exists"]]},{"headers":["Claim or proceeding","Initial period identified","Trigger","Discovery or tolling qualification","Status"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim or proceeding","Initial period identified","Trigger","Discovery or tolling qualification","Status"],["Private MCPA §133","2 years","When all elements exist, subject to §27-2-102","Limited concealment/prevention rules; statute now expressly cites §211","Answered"],["Part 20 §2015 affirmative damages","Likely 2 years","Likely when violation and harm complete","No Part 20-specific appellate decision located","Partial"],["Part 20 §2010(4)(g) fee-return action","Likely statutory-liability analysis, but exact period unresolved","Possibly unauthorized receipt or refusal to return","Defensive voidness and recurring-charge accrual unresolved","Unresolved"],["Part 21 private MCPA remedy","2 years","When unlawful act causes ascertainable loss","Same MCPA rules","Answered"],["Part 21 cancellation refund under another theory","Unresolved","Cancellation, request, and failure to refund may all matter","No controlling construction located","Unresolved"],["Department §111 injunction","5 years on discovery","Department discovery of alleged violation","Statute-specific","Answered"],["Other Department Part 1 enforcement","5-year residual after accrual","Accrual under §27-2-231","Relationship to specific provisions claim-dependent","Partial"],["AG/county direct Part 21 action","No express Part 21 period","Claim-specific","Residual period potentially relevant; no case located","Unresolved"],["MCPA fraudulent-course criminal prosecution","1 year as misdemeanor","Commission; continuing course ends when conduct terminates","Statutory criminal tolling rules not fully audited","Answered in core"],["Part 20 administrative discipline","No specific commencement period found","Agency action based on licensing conditions/rules","Due-process and laches questions held","Unresolved"],["Judicial review of final contested order","30 days after service","Service of final decision, subject to rehearing rule","Filing does not automatically stay","Answered"],["CID challenge","Return date or 20 days after service, whichever shorter","Service/return date","Specific statutory mechanism","Answered"],["Bond or policy claim","Not addressed","Actual instrument and claim terms","P5 unreviewed; no importation","Excluded"],["Ordinary contract, fraud, debt, or collection claim","Not addressed","Cause-specific","Separate limitation analysis required","Excluded"]]},{"headers":["Source ID","Instrument, issuer, full literal URL, and pinpoint","Version/status/access and limits"],"index":4,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.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_0020/0300-0140-0010-0020.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+10"},{"href":"https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf","text":"Montana Legislative Archive\n+2"},{"href":"https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html","text":"Montana Code Annotated\n+3"},{"href":"https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html","text":"Montana Code Annotated\n+3"},{"href":"https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html","text":"Montana Code Annotated\n+1"},{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be","text":"Montana Administrative Rules\n+1"},{"href":"https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op","text":"Judicial Document Service\n+2"},{"href":"https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html","text":"Justia Law\n+1"},{"href":"https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/","text":"Montana Department of Justice"},{"href":"https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf","text":"Montana Department of Justice\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s6104/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679g/","text":"U.S. Code\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s5564/","text":"U.S. Code\n+1"},{"href":"https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html","text":"Montana Code Annotated\n+1"},{"href":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/","text":"Montana Department of Justice\n+3"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.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_0020/0300-0140-0010-0020.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+10"}],[{"href":"https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf","text":"Montana Legislative Archive\n+2"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html","text":"Montana Code Annotated\n+3"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html","text":"Montana Code Annotated\n+3"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html","text":"Montana Code Annotated\n+1"}],[{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be","text":"Montana Administrative Rules\n+1"}],[{"href":"https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op","text":"Judicial Document Service\n+2"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html","text":"Justia Law\n+1"}],[{"href":"https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/","text":"Montana Department of Justice"}],[{"href":"https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf","text":"Montana Department of Justice\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s6104/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679g/","text":"U.S. Code\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t12/s5564/","text":"U.S. Code\n+1"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html","text":"Montana Code Annotated\n+1"}],[{"href":"https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/","text":"Montana Department of Justice\n+3"}]],"rows":[["Source ID","Instrument, issuer, full literal URL, and pinpoint","Version/status/access and limits"],["S_MT-P7-S001","Montana Consumer Debt Management Services Act, Montana Legislature. Scope: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html, §30-14-2002. Definitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html, §2003. Licensing: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html, §2004. DMP/voidness: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html, §2010, especially (4)(g). Prohibitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html, §2013. Remedies: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html, §2015.","Fresh direct official HTML read October 26, 2026. MCA 2025 published text; no PDF page/index. No comprehensive post-2025 session or special-session audit. \nMontana Code Annotated\n+5"],["S_MT-P7-S002","Regulation of Debt Settlement Providers, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html, §2101. Requirements: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html, §2102. Prohibitions/refund: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html, §2103. Enforcement: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html, §2104.","Fresh direct official HTML read October 26, 2026. MCA 2025 published text. No comprehensive post-2025 audit. \nMontana Code Annotated\n+3"],["S_MT-P7-S003","Montana Consumer Protection Act—definitions, unlawful practices, and exemptions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html, §103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0040/0300-0140-0010-0040.html, §104; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html, §105.","Fresh direct official HTML read October 26, 2026. MCA 2025. \nMontana Code Annotated\n+3"],["S_MT-P7-S004","Montana Consumer Protection Act—public enforcement and private remedies, Montana Legislature. Injunction: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html, §111. Assurance: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0120/0300-0140-0010-0120.html, §112. CID: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html, §113. Investigations: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html, §114. County attorney: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0210/0300-0140-0010-0210.html, §121. Restoration: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0310/0300-0140-0010-0310.html, §131. Receiver: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0320/0300-0140-0010-0320.html, §132. Private action: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html, §133. Department limitation: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0350/0300-0140-0010-0350.html, §135. Penalties: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0420/0300-0140-0010-0420.html, §142. Vulnerable adult: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0440/0300-0140-0010-0440.html, §144.","Fresh direct official HTML read October 26, 2026. MCA 2025. Used only for remedies/enforcement. \nMontana Code Annotated\n+10"],["S_MT-P7-S005","2025 Montana Senate Bill 488, Chapter 199, Montana Legislature. https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf. Relevant current MCPA amendments at printed pp.2–3, zero-based PDF indices 1–2.","Fresh official eight-page PDF read and relevant pages visually inspected October 26, 2026. Enacted law; effective on passage and approval. Exact gubernatorial approval date was not exposed in the inspected segment and is not invented. Confirms §111 five-year discovery language and current §133 damages, class, punitive, and fee provisions. \nMontana Legislative Archive\n+2"],["S_MT-P7-S006","Montana civil limitation and accrual statutes, Montana Legislature. Accrual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html, §27-2-102. Statutory liabilities: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0110/0270-0020-0020-0110.html, §27-2-211. Residual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0310/0270-0020-0020-0310.html, §27-2-231. Tolling index: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0040/sections_index.html.","Fresh direct official HTML read October 26, 2026. Tolling provisions were indexed but not comprehensively applied. \nMontana Code Annotated\n+3"],["S_MT-P7-S007","Montana Administrative Procedure Act, Montana Legislature. Contested notice: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html, §2-4-601. Final orders: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0230/0020-0040-0060-0230.html, §623. License proceedings: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0310/0020-0040-0060-0310.html, §631. Judicial review: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0070/section_0020/0020-0040-0070-0020.html, §702.","Fresh direct official HTML read October 26, 2026. Application is conditional on a contested licensing proceeding and final written decision. \nMontana Code Annotated\n+3"],["S_MT-P7-S008","Montana criminal limitation and misdemeanor definition, Montana Legislature. Limitation: https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html, §45-1-205. Definition: https://mca.legmt.gov/bills/mca/title_0450/chapter_0020/part_0010/section_0010/0450-0020-0010-0010.html, §45-2-101(42).","Fresh official HTML/search-rendered text October 26, 2026. Used only for the MCPA fraudulent-course offense. \nMontana Code Annotated\n+1"],["S_MT-P7-S009","ARM 23.19.101—Unfair or Deceptive Acts or Practices, Montana Secretary of State. Status page: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be. Text route: https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d.","Fresh official search rendering October 26, 2026; direct opens returned HTTP 405. Status displayed “Effective,” and search rendering returned the enumerated acts. Not treated as a complete freshly opened rule body. \nMontana Administrative Rules\n+1"],["S_MT-P7-S010","Osterman v. Sears, Roebuck & Co., 2003 MT 327, Montana Supreme Court. Official PDF: https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op. Relevant limitation discussion at ¶¶21–30, approximately printed pp.7–12, zero-based PDF indices 6–11.","Fresh full 17-page official opinion parse and relevant-page visual inspection October 26, 2026. Precedential; predates the 2025 express §133 limitation reference but remains materially consistent. \nJudicial Document Service\n+2"],["S_MT-P7-S011","Anderson v. ReconTrust Co., 2017 MT 313, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html, especially ¶¶19–22.","Fresh full HTML opinion read October 26, 2026. Secondary host of primary judicial opinion; no official court PDF was located in the bounded search. \nJustia Law"],["S_MT-P7-S012","Morrow v. Bank of America, N.A., 2014 MT 117, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html, especially ¶¶67–70.","Fresh full HTML opinion read October 26, 2026. Secondary host of primary opinion. \nJustia Law"],["S_MT-P7-S013","Norris v. Olson, 2024 MT 123, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html, especially ¶¶16–18.","Fresh full HTML opinion read October 26, 2026. Secondary host of primary opinion. \nJustia Law"],["S_MT-P7-S014","Granbois v. Big Horn County Electric Cooperative, 1999 MT 249, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html.","Fresh full HTML opinion read October 26, 2026. Secondary host; used only for exemption boundary and posture. \nJustia Law\n+1"],["S_MT-P7-S015","Consumer Complaints, Montana DOJ Office of Consumer Protection. https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/.","Fresh official search-rendered operational material October 26, 2026; direct page not successfully opened. Not legal tolling, exhaustion, or adjudication authority. \nMontana Department of Justice"],["S_MT-P7-S016","Consumer Complaint Form OCP-100, Montana DOJ. https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf. Revision 8/07; relevant printed pp.1–2, zero-based PDF indices 0–1.","Fresh official three-page PDF parsed and relevant pages visually inspected October 26, 2026. Old revision; no current-version audit. \nMontana Department of Justice\n+2"],["S_MT-P7-S017","Federal private telemarketing action, 15 U.S.C. §6104, U.S. House Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s6104/.","Fresh direct official HTML read October 26, 2026. Text through Public Law 119-124, October 15, 2026. Limited private-right boundary only. \nU.S. Code"],["S_MT-P7-S018","CROA civil liability and limitation, 15 U.S.C. §§1679g and 1679i. https://uscode.house.gov/us/usc/119-124/t15/s1679g/; https://uscode.house.gov/us/usc/119-124/t15/s1679i/.","Fresh direct official HTML read October 26, 2026. Coverage remains unresolved. \nU.S. Code\n+1"],["S_MT-P7-S019","CFPA public enforcement, 12 U.S.C. §§5564 and 5552. https://uscode.house.gov/us/usc/119-124/t12/s5564/; https://uscode.house.gov/us/usc/119-124/t12/s5552/.","Fresh direct official HTML read October 26, 2026. Used only to distinguish public federal enforcement; no full CFPA dossier. \nU.S. Code\n+1"],["S_MT-P7-S020","General Montana punitive damages, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html, §27-1-220; https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0210/0270-0010-0020-0210.html, §27-1-221.","Fresh direct official HTML read October 26, 2026. Used only to bound a separate tort route; private MCPA §133 expressly bars punitive damages. \nMontana Code Annotated\n+1"],["S_MT-P7-S021","Targeted public provider-order and case search log, official Montana DOJ, Montana courts, and public case repositories; searches included the exact provider sections and quoted operative phrases.","Fresh bounded searches October 26, 2026. No exact Part 20/Part 21 merits order or appellate construction was located. This row is provenance, not authority and not proof of absence. \nMontana Department of Justice\n+3"]]},{"headers":["Claim ID","Precise claim","Source and pinpoint","Conditions, consequence, and confidence"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise claim","Source and pinpoint","Conditions, consequence, and confidence"],["S_MT-P7-C001","Part 20 applies to persons providing or offering DMPs to Montana residents, subject to its exact institutional/professional exclusions.","S001 §§2002–2003","High. Actual activity and exclusion facts required."],["S_MT-P7-C002","Part 21 covers compensated, holding-out, ordinarily noncustodial settlement providers and excludes entities subject to Part 20.","S002 §2101","High. Hybrid/affiliate facts held."],["S_MT-P7-C003","DOJ may refuse, suspend, or revoke a Part 20 license for failure to satisfy §2004(1)–(3) or departmental rules.","S001 §2004(4)","High. Not an express automatic discipline clause for every Part 20 violation."],["S_MT-P7-C004","Part 20 remedies apply to licensed and unlicensed persons to whom the Act applies.","S001 §2015(2)","High."],["S_MT-P7-C005","Part 21 contains no express administrative suspension/revocation section comparable to §2004(4).","S002 §§2101–2104","High bounded negative. Operational registration procedures held."],["S_MT-P7-C006","Contested license proceedings may invoke APA notice, hearing, emergency-suspension, and 30-day judicial-review rules.","S007 §§601, 623, 631, 702","High conditionally. Depends on actual contested-case posture."],["S_MT-P7-C007","Unauthorized Part 20 fees, charges, funds, or payments void the DMP unless resulting from bona fide error.","S001 §2010(4)(g)","High."],["S_MT-P7-C008","When subsection (4)(g) applies, the service must return all fees received from or on behalf of the consumer.","S001 §2010(4)(g)","High. Not limited to unauthorized increment."],["S_MT-P7-C009","The text orders return of all fees, not expressly all consumer principal or creditor funds.","S001 §2010(4)(g)","High textual boundary. Other law may govern principal."],["S_MT-P7-C010","No cure, notice, reliance, minimum amount, or intent predicate appears in §2010(4)(g).","S001 §2010(4)(g)","High bounded negative."],["S_MT-P7-C011","“Bona fide error” is undefined in the read statute, and no controlling provider-statute construction was located.","S001 §2010(4)(g); S021","High provenance; legal standard unresolved."],["S_MT-P7-C012","A person harmed by a Part 20 violation may recover actual and consequential damages or $500, whichever greater, for each violation.","S001 §2015(3)","High. Harm and causation required."],["S_MT-P7-C013","Part 20 adds costs and attorney fees and permits equitable, injunctive, and class relief.","S001 §2015(3)–(5)","High. Exact fee calculation held."],["S_MT-P7-C014","Part 20 remedies are cumulative and nonexclusive.","S001 §2015(1), (6)","High. Does not itself authorize duplicate compensation."],["S_MT-P7-C015","Each Part 20 violation is also an MCPA §103 violation.","S001 §2015(2)","High. Separate MCPA private elements remain."],["S_MT-P7-C016","The statute does not define how to combine all-fee return, statutory damages, compensatory damages, public restitution, and third-party recovery.","S001 §§2010, 2015; S021","High unresolved boundary."],["S_MT-P7-C017","Part 20 authorizes a fine up to $5,000 per violation only for the three enumerated licensing/trust/records categories.","S001 §2015(8)","High. Not automatic and not expressly criminal."],["S_MT-P7-C018","Part 21 public enforcement may include injunction, restitution, reasonable fees, and investigation/litigation costs.","S002 §2104(1)","High. Court-determined."],["S_MT-P7-C019","A Part 21 assurance may include costs, escrow, and restitution; violation may draw up to $10,000, and the matter may be reopened at any time.","S002 §2104(2)","High. Separate penalty limitation unresolved."],["S_MT-P7-C020","Part 21 cancellation requires, on request, 50% of qualifying collected/unrefunded service fees allocated to no-offer accounts; setup fees are excluded only from that subsection.","S002 §2103(2)","High. No legalization or exclusivity implication."],["S_MT-P7-C021","A Part 21 debtor receives Part 1 and other state-law remedies, not a separate Part 21 fixed-damages formula.","S002 §2104(3)","High."],["S_MT-P7-C022","MCPA trade/commerce is broad, but private §133 standing is limited to a consumer with causally resulting ascertainable loss.","S003 §102; S004 §133; S011–S013","High."],["S_MT-P7-C023","Montana does not impose a universal reliance element, but representation-based claims may need reliance facts to prove causation.","S011; S013","High qualified case-law conclusion."],["S_MT-P7-C024","The MCPA regulated-activity exemption is narrow and not a blanket immunity for regulated or licensed entities.","S003 §105; S014","High."],["S_MT-P7-C025","Private MCPA base recovery is the greater of ascertainable loss or $500.","S004 §133(1)","High."],["S_MT-P7-C026","Current §133 permits discretionary enhancement up to three times ascertainable loss when actual damages do not exceed $100,000.","S004 §133; S005","High. Not automatic or additive."],["S_MT-P7-C027","Private §133 prohibits punitive damages and class actions.","S004 §133; S005","High. Separate Part 20 or CROA class routes differ."],["S_MT-P7-C028","Private MCPA fees are discretionary, capped at $250/hour, and unavailable when actual damages recovered are at least $100,000.","S004 §133(3); S005","High."],["S_MT-P7-C029","Public MCPA relief includes injunction, restoration, receivership, and license revocation.","S004 §§111, 131–132","High."],["S_MT-P7-C030","Public investigation tools include CIDs, subpoenas, testimony, and hearings.","S004 §§113–114","High."],["S_MT-P7-C031","Private MCPA claims use the two-year period in §27-2-211.","S004 §133; S006 §211; S010","High."],["S_MT-P7-C032","Accrual generally occurs when all elements exist; discovery postponement is limited by §27-2-102.","S006 §102; S010","High."],["S_MT-P7-C033","An affirmative Part 20 §2015 claim is likely subject to the two-year statutory-liability period, but no Part 20-specific controlling case was located.","S001 §2015; S006 §211; S010; S021","Moderate-high."],["S_MT-P7-C034","The limitation and accrual rules for affirmative fee return, defensive voidness, recurring charges, and Part 20 class claims remain unresolved.","S001 §2010(4)(g); S006; S021","Unresolved."],["S_MT-P7-C035","Department §111 injunction actions have a five-year discovery period; general Department enforcement references the five-year residual period after accrual.","S004 §§111, 135; S006 §231","High for text; reconciliation claim-specific."],["S_MT-P7-C036","A final contested-case decision ordinarily must be challenged within 30 days after service; filing does not automatically stay it.","S007 §702","High."],["S_MT-P7-C037","A CID challenge must be brought by its return date or within 20 days after service, whichever is shorter.","S004 §113","High."],["S_MT-P7-C038","OCP complaint filing is not established as exhaustion, cure, or tolling.","S015–S016; S001–S007","High bounded negative."],["S_MT-P7-C039","The TSR private federal route requires a pattern or practice, more than $50,000 actual damages for each person, notice, and filing within three years after discovery.","S017","High, conditional on federal coverage."],["S_MT-P7-C040","CROA conditionally provides broader federal damages and a five-year limitation, but actual CROA coverage remains held.","S018","High, conditional."],["S_MT-P7-C041","The read CFPA provisions establish Bureau and state public-enforcement routes but do not themselves supply the Montana private remedy.","S019","High bounded conclusion."],["S_MT-P7-C042","General punitive damages require a separate qualifying claim involving actual fraud or malice and clear-and-convincing proof; private MCPA punitive damages are barred.","S020; S004 §133","High boundary."],["S_MT-P7-C043","No exact published appellate construction or publicly indexed final order for the core Part 20/21 remedy clauses was located.","S021","Bounded search result only."],["S_MT-P7-C044","Bond or insurance existence does not establish a direct claimant right, covered loss, solvent issuer, exhaustion order, or recovery.","No accepted P5 premise; S001–S004","Held. Full security litigation excluded."],["S_MT-P7-C045","Parallel causes may be pleaded, but the read statutes do not authorize compensating the same dollar loss twice.","S001 §2015; S004 §§131, 133","Reasoned accounting boundary; exact provider case absent."]]},{"headers":["Component","Status","Claim IDs","Exact missing evidence or next action"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claim IDs","Exact missing evidence or next action"],["Part 20 scope and resident nexus","Answered textually","C001","Apply actual offers, services, residence, and custody facts."],["Part 20 attorney/CPA exclusion","Partial","C001","Verify Montana licensure and incidental/not-principal-business facts."],["Part 20 nonprofit treatment","Answered as no label immunity","C001","Apply actual entity and activity."],["Part 20 standalone counseling branch","Partial","C001","Current interpretation and actual holding-out/mixed-service facts."],["Part 21 noncustodial scope","Answered textually","C002","Apply actual custody, agency, affiliate, and compensation facts."],["Part 21 professional exclusion","Partial","C002","Verify ordinary-practice and actual entity facts."],["Hybrid Part 20/Part 21 model","Unresolved factually","C001–C002","Full flow-of-services and custody record."],["Part 20 license refusal/suspension/revocation","Answered in statutory scope","C003, C006","Current rules, actual notice, and contested-case posture."],["Part 21 registration discipline","No express statutory mechanism identified","C005","Current DOJ procedure and any order/rule."],["Part 20 unauthorized-fee trigger","Answered","C007, C010","Apply actual fee/payment and authorization facts."],["Part 20 all-fee return","Answered textually","C008–C009","Allocation and overlap with damages/restoration unresolved."],["Bona fide error definition","Unresolved","C011","Controlling case, order, or current rule."],["Bona fide error burden","Unresolved","C011","Same."],["Bona fide error cure requirement","Unresolved","C011","Same; no federal doctrine imported."],["Consumer-principal disposition after voidness","Excluded/unresolved","C009","P4 funds review and controlling law."],["Part 20 actual damages","Answered","C012","Prove causation and amount."],["Part 20 consequential damages","Answered","C012","Prove foreseeability/causation under applicable law."],["Part 20 $500 per-violation floor","Answered textually","C012","Unit-of-violation case law absent."],["Part 20 attorney fees and costs","Answered as available","C013","Reasonableness procedure and amount unresolved."],["Part 20 equitable/injunctive relief","Answered","C013","Actual standing and remedy facts."],["Part 20 class action","Answered","C013","Rule 23/class requirements not reviewed."],["Part 20 cumulative remedies","Answered","C014–C016","Overlap, election, setoff, and satisfaction rules unresolved."],["Part 20 enumerated $5,000 fine","Answered textually","C017","Enforcer, procedure, and unit application require actual action."],["Part 20 criminal offense","No standalone offense identified","C017","General MCPA criminal route remains separate."],["Part 21 AG/county authority","Answered","C018","Actual jurisdiction, pleadings, and order."],["Part 21 restitution","Answered as available","C018","Measure, causation, and recipient allocation."],["Part 21 assurance","Answered textually","C019","Actual terms, admission clause, and enforcement history."],["Part 21 assurance penalty","Answered textually","C019","Limitation and unit of violation unresolved."],["Part 21 cancellation refund","Answered in bounded form","C020","Offer definition, request method, allocation, and deadline."],["Part 21 setup-fee treatment","Partial","C020","Excluded only from subsection refund; other remedies preserved."],["Part 21 private fixed damages","None identified","C021","Private MCPA/other law remains."],["MCPA consumer standing","Answered","C022","Apply personal/family/household purpose."],["MCPA business-purpose claimant","No §133 consumer standing established","C022","Part 20 “person harmed” or other law may differ."],["MCPA trade or commerce","Answered broadly","C022","Apply actual indirect/direct conduct."],["MCPA regulated-activity exemption","Answered narrowly","C024","Determine whether precise action was permitted by PSC/Auditor law."],["MCPA unfairness standard","Answered from cases","C022–C023","Apply actual conduct and public policy."],["MCPA causation","Answered","C022–C023","Evidence required."],["MCPA reliance","Partial/contextual","C023","Representation theory and actual consumer conduct."],["MCPA ascertainable loss","Answered","C022, C025","Quantify loss; statutory floor does not replace standing."],["MCPA base damages","Answered","C025","Apply actual loss."],["MCPA enhancement","Answered textually","C026","Post-2025 construction and judicial discretion remain."],["MCPA punitive damages","Answered as prohibited","C027","Separate tort route held."],["MCPA private class action","Answered as prohibited","C027","Part 20/CROA routes separate."],["MCPA private attorney fees","Answered","C028","Court discretion, approved hours, and actual recovery."],["Public injunction","Answered","C029","Knowledge/public-interest predicates and actual proof."],["Restoration/disgorgement boundary","Partial","C029, C045","Exact measure and overlap with private recovery."],["Receivership","Answered in core","C029","Bankruptcy/priority and actual estate excluded."],["CID and subpoenas","Answered","C030, C037","Actual service and challenge."],["County-attorney route","Answered","C018, C030","Actual venue and coordination."],["MCPA civil fines","Answered","C017, C019, C029","Willfulness, order violation, and unit of violation."],["MCPA criminal route","Answered in core","C035","Actual prosecution and criminal tolling beyond core not reviewed."],["Vulnerable-adult penalty","Answered textually","C029","Actual age/status, knowledge, and loss facts."],["Private MCPA limitation","Answered","C031–C032","Actual accrual/tolling facts."],["Part 20 damages limitation","Partial","C033","Controlling Part 20 case still missing."],["Part 20 voidness/fee-return limitation","Unresolved","C034","Affirmative versus defensive use and accrual authority."],["Part 21 private limitation","Answered for MCPA route","C031","Other theories may differ."],["Part 21 public limitation","Unresolved","C035","Controlling application of residual period."],["Department public limitation","Partial but bounded","C035","Reconcile §111 and §135 for actual remedy."],["Administrative discipline commencement","Unresolved","C006","No specific Part 20 filing period located."],["Administrative judicial review","Answered","C036","Actual service/rehearing/stay facts."],["OCP complaint process","Answered operationally","C038","Current form revision and actual agency handling remain."],["OCP complaint tolling","No tolling established","C038","A specific tolling agreement or statute would be needed."],["Public Part 20/21 orders","Not located","C043","Administrative-file, district-docket, and public-record review."],["Controlling Part 20/21 opinions","Not located","C043","Full paid citator and trial-level search."],["TSR private action","Answered as conditional boundary","C039","Actual coverage, pattern/practice, damages, and notice."],["CROA private action","Answered as conditional boundary","C040","Actual representations and exclusions."],["CFPA public enforcement","Answered as boundary","C041","Full federal enforcement dossier excluded."],["Bond or insurance claims","Excluded","C044","P5 review, actual instrument, surety/insurer law."],["Double recovery/setoff","Partial","C016, C045","Provider-specific judgment or controlling authority."],["Full post-2025 Montana currentness","Partial","All","Comprehensive later session, special-session, rule, and litigation audit."],["Actual provider, contract, account, policy, or fee earning","Excluded/unresolved","All","Entity-specific evidence required."],["Collections, ordinary debt limitations, garnishment, secured debt, bankruptcy, sectors, local, tribal, country, and seven parent dimensions","Excluded","—","All remain required; no closure by implication."]]}],"claims":[{"claim_id":"S_MT-P7-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C001","Precise claim":"Part 20 applies to persons providing or offering DMPs to Montana residents, subject to its exact institutional/professional exclusions.","Source and pinpoint":"S001 §§2002–2003","Conditions, consequence, and confidence":"High. Actual activity and exclusion facts required."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C002","Precise claim":"Part 21 covers compensated, holding-out, ordinarily noncustodial settlement providers and excludes entities subject to Part 20.","Source and pinpoint":"S002 §2101","Conditions, consequence, and confidence":"High. Hybrid/affiliate facts held."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C003","Precise claim":"DOJ may refuse, suspend, or revoke a Part 20 license for failure to satisfy §2004(1)–(3) or departmental rules.","Source and pinpoint":"S001 §2004(4)","Conditions, consequence, and confidence":"High. Not an express automatic discipline clause for every Part 20 violation."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C004","Precise claim":"Part 20 remedies apply to licensed and unlicensed persons to whom the Act applies.","Source and pinpoint":"S001 §2015(2)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C005","Precise claim":"Part 21 contains no express administrative suspension/revocation section comparable to §2004(4).","Source and pinpoint":"S002 §§2101–2104","Conditions, consequence, and confidence":"High bounded negative. Operational registration procedures held."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C006","Precise claim":"Contested license proceedings may invoke APA notice, hearing, emergency-suspension, and 30-day judicial-review rules.","Source and pinpoint":"S007 §§601, 623, 631, 702","Conditions, consequence, and confidence":"High conditionally. Depends on actual contested-case posture."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C007","Precise claim":"Unauthorized Part 20 fees, charges, funds, or payments void the DMP unless resulting from bona fide error.","Source and pinpoint":"S001 §2010(4)(g)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C008","Precise claim":"When subsection (4)(g) applies, the service must return all fees received from or on behalf of the consumer.","Source and pinpoint":"S001 §2010(4)(g)","Conditions, consequence, and confidence":"High. Not limited to unauthorized increment."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C009","Precise claim":"The text orders return of all fees, not expressly all consumer principal or creditor funds.","Source and pinpoint":"S001 §2010(4)(g)","Conditions, consequence, and confidence":"High textual boundary. Other law may govern principal."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C010","Precise claim":"No cure, notice, reliance, minimum amount, or intent predicate appears in §2010(4)(g).","Source and pinpoint":"S001 §2010(4)(g)","Conditions, consequence, and confidence":"High bounded negative."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C011","Precise claim":"“Bona fide error” is undefined in the read statute, and no controlling provider-statute construction was located.","Source and pinpoint":"S001 §2010(4)(g); S021","Conditions, consequence, and confidence":"High provenance; legal standard unresolved."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C012","Precise claim":"A person harmed by a Part 20 violation may recover actual and consequential damages or $500, whichever greater, for each violation.","Source and pinpoint":"S001 §2015(3)","Conditions, consequence, and confidence":"High. Harm and causation required."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C013","Precise claim":"Part 20 adds costs and attorney fees and permits equitable, injunctive, and class relief.","Source and pinpoint":"S001 §2015(3)–(5)","Conditions, consequence, and confidence":"High. Exact fee calculation held."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C014","Precise claim":"Part 20 remedies are cumulative and nonexclusive.","Source and pinpoint":"S001 §2015(1), (6)","Conditions, consequence, and confidence":"High. Does not itself authorize duplicate compensation."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C015","Precise claim":"Each Part 20 violation is also an MCPA §103 violation.","Source and pinpoint":"S001 §2015(2)","Conditions, consequence, and confidence":"High. Separate MCPA private elements remain."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C016","Precise claim":"The statute does not define how to combine all-fee return, statutory damages, compensatory damages, public restitution, and third-party recovery.","Source and pinpoint":"S001 §§2010, 2015; S021","Conditions, consequence, and confidence":"High unresolved boundary."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C017","Precise claim":"Part 20 authorizes a fine up to $5,000 per violation only for the three enumerated licensing/trust/records categories.","Source and pinpoint":"S001 §2015(8)","Conditions, consequence, and confidence":"High. Not automatic and not expressly criminal."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C018","Precise claim":"Part 21 public enforcement may include injunction, restitution, reasonable fees, and investigation/litigation costs.","Source and pinpoint":"S002 §2104(1)","Conditions, consequence, and confidence":"High. Court-determined."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C019","Precise claim":"A Part 21 assurance may include costs, escrow, and restitution; violation may draw up to $10,000, and the matter may be reopened at any time.","Source and pinpoint":"S002 §2104(2)","Conditions, consequence, and confidence":"High. Separate penalty limitation unresolved."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C020","Precise claim":"Part 21 cancellation requires, on request, 50% of qualifying collected/unrefunded service fees allocated to no-offer accounts; setup fees are excluded only from that subsection.","Source and pinpoint":"S002 §2103(2)","Conditions, consequence, and confidence":"High. No legalization or exclusivity implication."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C021","Precise claim":"A Part 21 debtor receives Part 1 and other state-law remedies, not a separate Part 21 fixed-damages formula.","Source and pinpoint":"S002 §2104(3)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C022","Precise claim":"MCPA trade/commerce is broad, but private §133 standing is limited to a consumer with causally resulting ascertainable loss.","Source and pinpoint":"S003 §102; S004 §133; S011–S013","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C023","Precise claim":"Montana does not impose a universal reliance element, but representation-based claims may need reliance facts to prove causation.","Source and pinpoint":"S011; S013","Conditions, consequence, and confidence":"High qualified case-law conclusion."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C024","Precise claim":"The MCPA regulated-activity exemption is narrow and not a blanket immunity for regulated or licensed entities.","Source and pinpoint":"S003 §105; S014","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C025","Precise claim":"Private MCPA base recovery is the greater of ascertainable loss or $500.","Source and pinpoint":"S004 §133(1)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C026","Precise claim":"Current §133 permits discretionary enhancement up to three times ascertainable loss when actual damages do not exceed $100,000.","Source and pinpoint":"S004 §133; S005","Conditions, consequence, and confidence":"High. Not automatic or additive."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C027","Precise claim":"Private §133 prohibits punitive damages and class actions.","Source and pinpoint":"S004 §133; S005","Conditions, consequence, and confidence":"High. Separate Part 20 or CROA class routes differ."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C028","Precise claim":"Private MCPA fees are discretionary, capped at $250/hour, and unavailable when actual damages recovered are at least $100,000.","Source and pinpoint":"S004 §133(3); S005","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C029","Precise claim":"Public MCPA relief includes injunction, restoration, receivership, and license revocation.","Source and pinpoint":"S004 §§111, 131–132","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C030","Precise claim":"Public investigation tools include CIDs, subpoenas, testimony, and hearings.","Source and pinpoint":"S004 §§113–114","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C031","Precise claim":"Private MCPA claims use the two-year period in §27-2-211.","Source and pinpoint":"S004 §133; S006 §211; S010","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C032","Precise claim":"Accrual generally occurs when all elements exist; discovery postponement is limited by §27-2-102.","Source and pinpoint":"S006 §102; S010","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C033","Precise claim":"An affirmative Part 20 §2015 claim is likely subject to the two-year statutory-liability period, but no Part 20-specific controlling case was located.","Source and pinpoint":"S001 §2015; S006 §211; S010; S021","Conditions, consequence, and confidence":"Moderate-high."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C034","Precise claim":"The limitation and accrual rules for affirmative fee return, defensive voidness, recurring charges, and Part 20 class claims remain unresolved.","Source and pinpoint":"S001 §2010(4)(g); S006; S021","Conditions, consequence, and confidence":"Unresolved."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C035","Precise claim":"Department §111 injunction actions have a five-year discovery period; general Department enforcement references the five-year residual period after accrual.","Source and pinpoint":"S004 §§111, 135; S006 §231","Conditions, consequence, and confidence":"High for text; reconciliation claim-specific."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C036","Precise claim":"A final contested-case decision ordinarily must be challenged within 30 days after service; filing does not automatically stay it.","Source and pinpoint":"S007 §702","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C037","Precise claim":"A CID challenge must be brought by its return date or within 20 days after service, whichever is shorter.","Source and pinpoint":"S004 §113","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C038","Precise claim":"OCP complaint filing is not established as exhaustion, cure, or tolling.","Source and pinpoint":"S015–S016; S001–S007","Conditions, consequence, and confidence":"High bounded negative."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C039","Precise claim":"The TSR private federal route requires a pattern or practice, more than $50,000 actual damages for each person, notice, and filing within three years after discovery.","Source and pinpoint":"S017","Conditions, consequence, and confidence":"High, conditional on federal coverage."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C040","Precise claim":"CROA conditionally provides broader federal damages and a five-year limitation, but actual CROA coverage remains held.","Source and pinpoint":"S018","Conditions, consequence, and confidence":"High, conditional."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C041","Precise claim":"The read CFPA provisions establish Bureau and state public-enforcement routes but do not themselves supply the Montana private remedy.","Source and pinpoint":"S019","Conditions, consequence, and confidence":"High bounded conclusion."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C042","Precise claim":"General punitive damages require a separate qualifying claim involving actual fraud or malice and clear-and-convincing proof; private MCPA punitive damages are barred.","Source and pinpoint":"S020; S004 §133","Conditions, consequence, and confidence":"High boundary."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C043","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C043","Precise claim":"No exact published appellate construction or publicly indexed final order for the core Part 20/21 remedy clauses was located.","Source and pinpoint":"S021","Conditions, consequence, and confidence":"Bounded search result only."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C044","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C044","Precise claim":"Bond or insurance existence does not establish a direct claimant right, covered loss, solvent issuer, exhaustion order, or recovery.","Source and pinpoint":"No accepted P5 premise; S001–S004","Conditions, consequence, and confidence":"Held. Full security litigation excluded."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_MT-P7-C045","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P7-C045","Precise claim":"Parallel causes may be pleaded, but the read statutes do not authorize compensating the same dollar loss twice.","Source and pinpoint":"S001 §2015; S004 §§131, 133","Conditions, consequence, and confidence":"Reasoned accounting boundary; exact provider case absent."},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"S_MT-P7-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-P7-S001","Instrument, issuer, full literal URL, and pinpoint":"Montana Consumer Debt Management Services Act, Montana Legislature. Scope: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0020/0300-0140-0200-0020.html, §30-14-2002. Definitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0030/0300-0140-0200-0030.html, §2003. Licensing: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0040/0300-0140-0200-0040.html, §2004. DMP/voidness: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0100/0300-0140-0200-0100.html, §2010, especially (4)(g). Prohibitions: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html, §2013. Remedies: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0200/section_0150/0300-0140-0200-0150.html, §2015.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. MCA 2025 published text; no PDF page/index. No comprehensive post-2025 session or special-session audit. \nMontana Code Annotated\n+5"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-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-P7-S002","Instrument, issuer, full literal URL, and pinpoint":"Regulation of Debt Settlement Providers, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0010/0300-0140-0210-0010.html, §2101. Requirements: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0020/0300-0140-0210-0020.html, §2102. Prohibitions/refund: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0030/0300-0140-0210-0030.html, §2103. Enforcement: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0210/section_0040/0300-0140-0210-0040.html, §2104.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. MCA 2025 published text. No comprehensive post-2025 audit. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S003","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0040/0300-0140-0010-0040.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html"],"researcher_record":{"Source ID":"S_MT-P7-S003","Instrument, issuer, full literal URL, and pinpoint":"Montana Consumer Protection Act—definitions, unlawful practices, and exemptions, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §102; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html, §103; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0040/0300-0140-0010-0040.html, §104; https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html, §105.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. MCA 2025. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S004","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_0120/0300-0140-0010-0120.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","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0210/0300-0140-0010-0210.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0310/0300-0140-0010-0310.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0320/0300-0140-0010-0320.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0350/0300-0140-0010-0350.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0420/0300-0140-0010-0420.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0440/0300-0140-0010-0440.html"],"researcher_record":{"Source ID":"S_MT-P7-S004","Instrument, issuer, full literal URL, and pinpoint":"Montana Consumer Protection Act—public enforcement and private remedies, Montana Legislature. Injunction: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0110/0300-0140-0010-0110.html, §111. Assurance: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0120/0300-0140-0010-0120.html, §112. CID: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0130/0300-0140-0010-0130.html, §113. Investigations: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0140/0300-0140-0010-0140.html, §114. County attorney: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0210/0300-0140-0010-0210.html, §121. Restoration: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0310/0300-0140-0010-0310.html, §131. Receiver: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0320/0300-0140-0010-0320.html, §132. Private action: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0330/0300-0140-0010-0330.html, §133. Department limitation: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0350/0300-0140-0010-0350.html, §135. Penalties: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0420/0300-0140-0010-0420.html, §142. Vulnerable adult: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0440/0300-0140-0010-0440.html, §144.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. MCA 2025. Used only for remedies/enforcement. \nMontana Code Annotated\n+10"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S005","urls":["https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf"],"researcher_record":{"Source ID":"S_MT-P7-S005","Instrument, issuer, full literal URL, and pinpoint":"2025 Montana Senate Bill 488, Chapter 199, Montana Legislature. https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0199.pdf. Relevant current MCPA amendments at printed pp.2–3, zero-based PDF indices 1–2.","Version/status/access and limits":"Fresh official eight-page PDF read and relevant pages visually inspected October 26, 2026. Enacted law; effective on passage and approval. Exact gubernatorial approval date was not exposed in the inspected segment and is not invented. Confirms §111 five-year discovery language and current §133 damages, class, punitive, and fee provisions. \nMontana Legislative Archive\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S006","urls":["https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0110/0270-0020-0020-0110.html","https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0310/0270-0020-0020-0310.html","https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0040/sections_index.html"],"researcher_record":{"Source ID":"S_MT-P7-S006","Instrument, issuer, full literal URL, and pinpoint":"Montana civil limitation and accrual statutes, Montana Legislature. Accrual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0010/section_0020/0270-0020-0010-0020.html, §27-2-102. Statutory liabilities: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0110/0270-0020-0020-0110.html, §27-2-211. Residual: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0020/section_0310/0270-0020-0020-0310.html, §27-2-231. Tolling index: https://mca.legmt.gov/bills/mca/title_0270/chapter_0020/part_0040/sections_index.html.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Tolling provisions were indexed but not comprehensively applied. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S007","urls":["https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html","https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0230/0020-0040-0060-0230.html","https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0310/0020-0040-0060-0310.html","https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0070/section_0020/0020-0040-0070-0020.html"],"researcher_record":{"Source ID":"S_MT-P7-S007","Instrument, issuer, full literal URL, and pinpoint":"Montana Administrative Procedure Act, Montana Legislature. Contested notice: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0010/0020-0040-0060-0010.html, §2-4-601. Final orders: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0230/0020-0040-0060-0230.html, §623. License proceedings: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0060/section_0310/0020-0040-0060-0310.html, §631. Judicial review: https://mca.legmt.gov/bills/mca/title_0020/chapter_0040/part_0070/section_0020/0020-0040-0070-0020.html, §702.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Application is conditional on a contested licensing proceeding and final written decision. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S008","urls":["https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html","https://mca.legmt.gov/bills/mca/title_0450/chapter_0020/part_0010/section_0010/0450-0020-0010-0010.html"],"researcher_record":{"Source ID":"S_MT-P7-S008","Instrument, issuer, full literal URL, and pinpoint":"Montana criminal limitation and misdemeanor definition, Montana Legislature. Limitation: https://mca.legmt.gov/bills/mca/title_0450/chapter_0010/part_0020/section_0050/0450-0010-0020-0050.html, §45-1-205. Definition: https://mca.legmt.gov/bills/mca/title_0450/chapter_0020/part_0010/section_0010/0450-0020-0010-0010.html, §45-2-101(42).","Version/status/access and limits":"Fresh official HTML/search-rendered text October 26, 2026. Used only for the MCPA fraudulent-course offense. \nMontana Code Annotated\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S009","urls":["https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be","https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d"],"researcher_record":{"Source ID":"S_MT-P7-S009","Instrument, issuer, full literal URL, and pinpoint":"ARM 23.19.101—Unfair or Deceptive Acts or Practices, Montana Secretary of State. Status page: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/policies/f2f0794a-b27d-485f-a25c-baa187c5b4be. Text route: https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d.","Version/status/access and limits":"Fresh official search rendering October 26, 2026; direct opens returned HTTP 405. Status displayed “Effective,” and search rendering returned the enumerated acts. Not treated as a complete freshly opened rule body. \nMontana Administrative Rules\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S010","urls":["https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op"],"researcher_record":{"Source ID":"S_MT-P7-S010","Instrument, issuer, full literal URL, and pinpoint":"Osterman v. Sears, Roebuck & Co., 2003 MT 327, Montana Supreme Court. Official PDF: https://juddocumentservice.mt.gov/getDocByCTrackId?DocId=02-028op. Relevant limitation discussion at ¶¶21–30, approximately printed pp.7–12, zero-based PDF indices 6–11.","Version/status/access and limits":"Fresh full 17-page official opinion parse and relevant-page visual inspection October 26, 2026. Precedential; predates the 2025 express §133 limitation reference but remains materially consistent. \nJudicial Document Service\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S011","urls":["https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html"],"researcher_record":{"Source ID":"S_MT-P7-S011","Instrument, issuer, full literal URL, and pinpoint":"Anderson v. ReconTrust Co., 2017 MT 313, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2017/da-16-0618.html, especially ¶¶19–22.","Version/status/access and limits":"Fresh full HTML opinion read October 26, 2026. Secondary host of primary judicial opinion; no official court PDF was located in the bounded search. \nJustia Law"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S012","urls":["https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html"],"researcher_record":{"Source ID":"S_MT-P7-S012","Instrument, issuer, full literal URL, and pinpoint":"Morrow v. Bank of America, N.A., 2014 MT 117, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html, especially ¶¶67–70.","Version/status/access and limits":"Fresh full HTML opinion read October 26, 2026. Secondary host of primary opinion. \nJustia Law"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S013","urls":["https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html"],"researcher_record":{"Source ID":"S_MT-P7-S013","Instrument, issuer, full literal URL, and pinpoint":"Norris v. Olson, 2024 MT 123, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/2024/da-22-0729.html, especially ¶¶16–18.","Version/status/access and limits":"Fresh full HTML opinion read October 26, 2026. Secondary host of primary opinion. \nJustia Law"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S014","urls":["https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html"],"researcher_record":{"Source ID":"S_MT-P7-S014","Instrument, issuer, full literal URL, and pinpoint":"Granbois v. Big Horn County Electric Cooperative, 1999 MT 249, Montana Supreme Court opinion reproduction. https://law.justia.com/cases/montana/supreme-court/1999/acb6cc44-6fa4-4fb0-bdec-39bb94e164b9.html.","Version/status/access and limits":"Fresh full HTML opinion read October 26, 2026. Secondary host; used only for exemption boundary and posture. \nJustia Law\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S015","urls":["https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/"],"researcher_record":{"Source ID":"S_MT-P7-S015","Instrument, issuer, full literal URL, and pinpoint":"Consumer Complaints, Montana DOJ Office of Consumer Protection. https://www.dojmt.gov/office-of-consumer-protection/consumer-complaints/.","Version/status/access and limits":"Fresh official search-rendered operational material October 26, 2026; direct page not successfully opened. Not legal tolling, exhaustion, or adjudication authority. \nMontana Department of Justice"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S016","urls":["https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf"],"researcher_record":{"Source ID":"S_MT-P7-S016","Instrument, issuer, full literal URL, and pinpoint":"Consumer Complaint Form OCP-100, Montana DOJ. https://dojmt.gov/wp-content/uploads/2024/10/complaintform31.pdf. Revision 8/07; relevant printed pp.1–2, zero-based PDF indices 0–1.","Version/status/access and limits":"Fresh official three-page PDF parsed and relevant pages visually inspected October 26, 2026. Old revision; no current-version audit. \nMontana Department of Justice\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S017","urls":["https://uscode.house.gov/us/usc/119-124/t15/s6104/"],"researcher_record":{"Source ID":"S_MT-P7-S017","Instrument, issuer, full literal URL, and pinpoint":"Federal private telemarketing action, 15 U.S.C. §6104, U.S. House Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s6104/.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Text through Public Law 119-124, October 15, 2026. Limited private-right boundary only. \nU.S. Code"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S018","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679g/","https://uscode.house.gov/us/usc/119-124/t15/s1679i/"],"researcher_record":{"Source ID":"S_MT-P7-S018","Instrument, issuer, full literal URL, and pinpoint":"CROA civil liability and limitation, 15 U.S.C. §§1679g and 1679i. https://uscode.house.gov/us/usc/119-124/t15/s1679g/; https://uscode.house.gov/us/usc/119-124/t15/s1679i/.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Coverage remains unresolved. \nU.S. Code\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S019","urls":["https://uscode.house.gov/us/usc/119-124/t12/s5564/","https://uscode.house.gov/us/usc/119-124/t12/s5552/"],"researcher_record":{"Source ID":"S_MT-P7-S019","Instrument, issuer, full literal URL, and pinpoint":"CFPA public enforcement, 12 U.S.C. §§5564 and 5552. https://uscode.house.gov/us/usc/119-124/t12/s5564/; https://uscode.house.gov/us/usc/119-124/t12/s5552/.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Used only to distinguish public federal enforcement; no full CFPA dossier. \nU.S. Code\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S020","urls":["https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html","https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0210/0270-0010-0020-0210.html"],"researcher_record":{"Source ID":"S_MT-P7-S020","Instrument, issuer, full literal URL, and pinpoint":"General Montana punitive damages, Montana Legislature. https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0200/0270-0010-0020-0200.html, §27-1-220; https://mca.legmt.gov/bills/mca/title_0270/chapter_0010/part_0020/section_0210/0270-0010-0020-0210.html, §27-1-221.","Version/status/access and limits":"Fresh direct official HTML read October 26, 2026. Used only to bound a separate tort route; private MCPA §133 expressly bars punitive damages. \nMontana Code Annotated\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_MT-P7-S021","urls":["https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/"],"researcher_record":{"Source ID":"S_MT-P7-S021","Instrument, issuer, full literal URL, and pinpoint":"Targeted public provider-order and case search log, official Montana DOJ, Montana courts, and public case repositories; searches included the exact provider sections and quoted operative phrases.","Version/status/access and limits":"Fresh bounded searches October 26, 2026. No exact Part 20/Part 21 merits order or appellate construction was located. This row is provenance, not authority and not proof of absence. \nMontana Department of Justice\n+3"},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"Part 20 scope and resident nexus","researcher_record":{"Component":"Part 20 scope and resident nexus","Status":"Answered textually","Claim IDs":"C001","Exact missing evidence or next action":"Apply actual offers, services, residence, and custody facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 attorney/CPA exclusion","researcher_record":{"Component":"Part 20 attorney/CPA exclusion","Status":"Partial","Claim IDs":"C001","Exact missing evidence or next action":"Verify Montana licensure and incidental/not-principal-business facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 nonprofit treatment","researcher_record":{"Component":"Part 20 nonprofit treatment","Status":"Answered as no label immunity","Claim IDs":"C001","Exact missing evidence or next action":"Apply actual entity and activity."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 standalone counseling branch","researcher_record":{"Component":"Part 20 standalone counseling branch","Status":"Partial","Claim IDs":"C001","Exact missing evidence or next action":"Current interpretation and actual holding-out/mixed-service facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 noncustodial scope","researcher_record":{"Component":"Part 21 noncustodial scope","Status":"Answered textually","Claim IDs":"C002","Exact missing evidence or next action":"Apply actual custody, agency, affiliate, and compensation facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 professional exclusion","researcher_record":{"Component":"Part 21 professional exclusion","Status":"Partial","Claim IDs":"C002","Exact missing evidence or next action":"Verify ordinary-practice and actual entity facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Hybrid Part 20/Part 21 model","researcher_record":{"Component":"Hybrid Part 20/Part 21 model","Status":"Unresolved factually","Claim IDs":"C001–C002","Exact missing evidence or next action":"Full flow-of-services and custody record."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 license refusal/suspension/revocation","researcher_record":{"Component":"Part 20 license refusal/suspension/revocation","Status":"Answered in statutory scope","Claim IDs":"C003, C006","Exact missing evidence or next action":"Current rules, actual notice, and contested-case posture."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 registration discipline","researcher_record":{"Component":"Part 21 registration discipline","Status":"No express statutory mechanism identified","Claim IDs":"C005","Exact missing evidence or next action":"Current DOJ procedure and any order/rule."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 unauthorized-fee trigger","researcher_record":{"Component":"Part 20 unauthorized-fee trigger","Status":"Answered","Claim IDs":"C007, C010","Exact missing evidence or next action":"Apply actual fee/payment and authorization facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 all-fee return","researcher_record":{"Component":"Part 20 all-fee return","Status":"Answered textually","Claim IDs":"C008–C009","Exact missing evidence or next action":"Allocation and overlap with damages/restoration unresolved."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Bona fide error definition","researcher_record":{"Component":"Bona fide error definition","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"Controlling case, order, or current rule."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Bona fide error burden","researcher_record":{"Component":"Bona fide error burden","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"Same."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Bona fide error cure requirement","researcher_record":{"Component":"Bona fide error cure requirement","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"Same; no federal doctrine imported."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Consumer-principal disposition after voidness","researcher_record":{"Component":"Consumer-principal disposition after voidness","Status":"Excluded/unresolved","Claim IDs":"C009","Exact missing evidence or next action":"P4 funds review and controlling law."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 actual damages","researcher_record":{"Component":"Part 20 actual damages","Status":"Answered","Claim IDs":"C012","Exact missing evidence or next action":"Prove causation and amount."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 consequential damages","researcher_record":{"Component":"Part 20 consequential damages","Status":"Answered","Claim IDs":"C012","Exact missing evidence or next action":"Prove foreseeability/causation under applicable law."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 $500 per-violation floor","researcher_record":{"Component":"Part 20 $500 per-violation floor","Status":"Answered textually","Claim IDs":"C012","Exact missing evidence or next action":"Unit-of-violation case law absent."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 attorney fees and costs","researcher_record":{"Component":"Part 20 attorney fees and costs","Status":"Answered as available","Claim IDs":"C013","Exact missing evidence or next action":"Reasonableness procedure and amount unresolved."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 equitable/injunctive relief","researcher_record":{"Component":"Part 20 equitable/injunctive relief","Status":"Answered","Claim IDs":"C013","Exact missing evidence or next action":"Actual standing and remedy facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 class action","researcher_record":{"Component":"Part 20 class action","Status":"Answered","Claim IDs":"C013","Exact missing evidence or next action":"Rule 23/class requirements not reviewed."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 cumulative remedies","researcher_record":{"Component":"Part 20 cumulative remedies","Status":"Answered","Claim IDs":"C014–C016","Exact missing evidence or next action":"Overlap, election, setoff, and satisfaction rules unresolved."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 enumerated $5,000 fine","researcher_record":{"Component":"Part 20 enumerated $5,000 fine","Status":"Answered textually","Claim IDs":"C017","Exact missing evidence or next action":"Enforcer, procedure, and unit application require actual action."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 criminal offense","researcher_record":{"Component":"Part 20 criminal offense","Status":"No standalone offense identified","Claim IDs":"C017","Exact missing evidence or next action":"General MCPA criminal route remains separate."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 AG/county authority","researcher_record":{"Component":"Part 21 AG/county authority","Status":"Answered","Claim IDs":"C018","Exact missing evidence or next action":"Actual jurisdiction, pleadings, and order."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 restitution","researcher_record":{"Component":"Part 21 restitution","Status":"Answered as available","Claim IDs":"C018","Exact missing evidence or next action":"Measure, causation, and recipient allocation."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 assurance","researcher_record":{"Component":"Part 21 assurance","Status":"Answered textually","Claim IDs":"C019","Exact missing evidence or next action":"Actual terms, admission clause, and enforcement history."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 assurance penalty","researcher_record":{"Component":"Part 21 assurance penalty","Status":"Answered textually","Claim IDs":"C019","Exact missing evidence or next action":"Limitation and unit of violation unresolved."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 cancellation refund","researcher_record":{"Component":"Part 21 cancellation refund","Status":"Answered in bounded form","Claim IDs":"C020","Exact missing evidence or next action":"Offer definition, request method, allocation, and deadline."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 setup-fee treatment","researcher_record":{"Component":"Part 21 setup-fee treatment","Status":"Partial","Claim IDs":"C020","Exact missing evidence or next action":"Excluded only from subsection refund; other remedies preserved."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 private fixed damages","researcher_record":{"Component":"Part 21 private fixed damages","Status":"None identified","Claim IDs":"C021","Exact missing evidence or next action":"Private MCPA/other law remains."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA consumer standing","researcher_record":{"Component":"MCPA consumer standing","Status":"Answered","Claim IDs":"C022","Exact missing evidence or next action":"Apply personal/family/household purpose."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA business-purpose claimant","researcher_record":{"Component":"MCPA business-purpose claimant","Status":"No §133 consumer standing established","Claim IDs":"C022","Exact missing evidence or next action":"Part 20 “person harmed” or other law may differ."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA trade or commerce","researcher_record":{"Component":"MCPA trade or commerce","Status":"Answered broadly","Claim IDs":"C022","Exact missing evidence or next action":"Apply actual indirect/direct conduct."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA regulated-activity exemption","researcher_record":{"Component":"MCPA regulated-activity exemption","Status":"Answered narrowly","Claim IDs":"C024","Exact missing evidence or next action":"Determine whether precise action was permitted by PSC/Auditor law."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA unfairness standard","researcher_record":{"Component":"MCPA unfairness standard","Status":"Answered from cases","Claim IDs":"C022–C023","Exact missing evidence or next action":"Apply actual conduct and public policy."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA causation","researcher_record":{"Component":"MCPA causation","Status":"Answered","Claim IDs":"C022–C023","Exact missing evidence or next action":"Evidence required."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA reliance","researcher_record":{"Component":"MCPA reliance","Status":"Partial/contextual","Claim IDs":"C023","Exact missing evidence or next action":"Representation theory and actual consumer conduct."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA ascertainable loss","researcher_record":{"Component":"MCPA ascertainable loss","Status":"Answered","Claim IDs":"C022, C025","Exact missing evidence or next action":"Quantify loss; statutory floor does not replace standing."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA base damages","researcher_record":{"Component":"MCPA base damages","Status":"Answered","Claim IDs":"C025","Exact missing evidence or next action":"Apply actual loss."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA enhancement","researcher_record":{"Component":"MCPA enhancement","Status":"Answered textually","Claim IDs":"C026","Exact missing evidence or next action":"Post-2025 construction and judicial discretion remain."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA punitive damages","researcher_record":{"Component":"MCPA punitive damages","Status":"Answered as prohibited","Claim IDs":"C027","Exact missing evidence or next action":"Separate tort route held."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA private class action","researcher_record":{"Component":"MCPA private class action","Status":"Answered as prohibited","Claim IDs":"C027","Exact missing evidence or next action":"Part 20/CROA routes separate."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA private attorney fees","researcher_record":{"Component":"MCPA private attorney fees","Status":"Answered","Claim IDs":"C028","Exact missing evidence or next action":"Court discretion, approved hours, and actual recovery."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Public injunction","researcher_record":{"Component":"Public injunction","Status":"Answered","Claim IDs":"C029","Exact missing evidence or next action":"Knowledge/public-interest predicates and actual proof."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Restoration/disgorgement boundary","researcher_record":{"Component":"Restoration/disgorgement boundary","Status":"Partial","Claim IDs":"C029, C045","Exact missing evidence or next action":"Exact measure and overlap with private recovery."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Receivership","researcher_record":{"Component":"Receivership","Status":"Answered in core","Claim IDs":"C029","Exact missing evidence or next action":"Bankruptcy/priority and actual estate excluded."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"CID and subpoenas","researcher_record":{"Component":"CID and subpoenas","Status":"Answered","Claim IDs":"C030, C037","Exact missing evidence or next action":"Actual service and challenge."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"County-attorney route","researcher_record":{"Component":"County-attorney route","Status":"Answered","Claim IDs":"C018, C030","Exact missing evidence or next action":"Actual venue and coordination."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA civil fines","researcher_record":{"Component":"MCPA civil fines","Status":"Answered","Claim IDs":"C017, C019, C029","Exact missing evidence or next action":"Willfulness, order violation, and unit of violation."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"MCPA criminal route","researcher_record":{"Component":"MCPA criminal route","Status":"Answered in core","Claim IDs":"C035","Exact missing evidence or next action":"Actual prosecution and criminal tolling beyond core not reviewed."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Vulnerable-adult penalty","researcher_record":{"Component":"Vulnerable-adult penalty","Status":"Answered textually","Claim IDs":"C029","Exact missing evidence or next action":"Actual age/status, knowledge, and loss facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Private MCPA limitation","researcher_record":{"Component":"Private MCPA limitation","Status":"Answered","Claim IDs":"C031–C032","Exact missing evidence or next action":"Actual accrual/tolling facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 damages limitation","researcher_record":{"Component":"Part 20 damages limitation","Status":"Partial","Claim IDs":"C033","Exact missing evidence or next action":"Controlling Part 20 case still missing."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 20 voidness/fee-return limitation","researcher_record":{"Component":"Part 20 voidness/fee-return limitation","Status":"Unresolved","Claim IDs":"C034","Exact missing evidence or next action":"Affirmative versus defensive use and accrual authority."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 private limitation","researcher_record":{"Component":"Part 21 private limitation","Status":"Answered for MCPA route","Claim IDs":"C031","Exact missing evidence or next action":"Other theories may differ."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Part 21 public limitation","researcher_record":{"Component":"Part 21 public limitation","Status":"Unresolved","Claim IDs":"C035","Exact missing evidence or next action":"Controlling application of residual period."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Department public limitation","researcher_record":{"Component":"Department public limitation","Status":"Partial but bounded","Claim IDs":"C035","Exact missing evidence or next action":"Reconcile §111 and §135 for actual remedy."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Administrative discipline commencement","researcher_record":{"Component":"Administrative discipline commencement","Status":"Unresolved","Claim IDs":"C006","Exact missing evidence or next action":"No specific Part 20 filing period located."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Administrative judicial review","researcher_record":{"Component":"Administrative judicial review","Status":"Answered","Claim IDs":"C036","Exact missing evidence or next action":"Actual service/rehearing/stay facts."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"OCP complaint process","researcher_record":{"Component":"OCP complaint process","Status":"Answered operationally","Claim IDs":"C038","Exact missing evidence or next action":"Current form revision and actual agency handling remain."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"OCP complaint tolling","researcher_record":{"Component":"OCP complaint tolling","Status":"No tolling established","Claim IDs":"C038","Exact missing evidence or next action":"A specific tolling agreement or statute would be needed."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Public Part 20/21 orders","researcher_record":{"Component":"Public Part 20/21 orders","Status":"Not located","Claim IDs":"C043","Exact missing evidence or next action":"Administrative-file, district-docket, and public-record review."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Controlling Part 20/21 opinions","researcher_record":{"Component":"Controlling Part 20/21 opinions","Status":"Not located","Claim IDs":"C043","Exact missing evidence or next action":"Full paid citator and trial-level search."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"TSR private action","researcher_record":{"Component":"TSR private action","Status":"Answered as conditional boundary","Claim IDs":"C039","Exact missing evidence or next action":"Actual coverage, pattern/practice, damages, and notice."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"CROA private action","researcher_record":{"Component":"CROA private action","Status":"Answered as conditional boundary","Claim IDs":"C040","Exact missing evidence or next action":"Actual representations and exclusions."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"CFPA public enforcement","researcher_record":{"Component":"CFPA public enforcement","Status":"Answered as boundary","Claim IDs":"C041","Exact missing evidence or next action":"Full federal enforcement dossier excluded."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Bond or insurance claims","researcher_record":{"Component":"Bond or insurance claims","Status":"Excluded","Claim IDs":"C044","Exact missing evidence or next action":"P5 review, actual instrument, surety/insurer law."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Double recovery/setoff","researcher_record":{"Component":"Double recovery/setoff","Status":"Partial","Claim IDs":"C016, C045","Exact missing evidence or next action":"Provider-specific judgment or controlling authority."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Full post-2025 Montana currentness","researcher_record":{"Component":"Full post-2025 Montana currentness","Status":"Partial","Claim IDs":"All","Exact missing evidence or next action":"Comprehensive later session, special-session, rule, and litigation audit."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Actual provider, contract, account, policy, or fee earning","researcher_record":{"Component":"Actual provider, contract, account, policy, or fee earning","Status":"Excluded/unresolved","Claim IDs":"All","Exact missing evidence or next action":"Entity-specific evidence required."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Collections, ordinary debt limitations, garnishment, secured debt, bankruptcy, sectors, local, tribal, country, and seven parent dimensions","researcher_record":{"Component":"Collections, ordinary debt limitations, garnishment, secured debt, bankruptcy, sectors, local, tribal, country, and seven parent dimensions","Status":"Excluded","Claim IDs":"—","Exact missing evidence or next action":"All remain required; no closure by implication."},"coordinator_acceptance":"not_yet_reviewed"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}