{"meta":{"key":"s_mt--pass-08","task":"S_MT","title":"SMT Montana collection-agency/debt-buyer licensing, original-creditor coverage, and state-specific collection conduct","parent_title":"Montana debt and debt relief law","edition":"pass-08","path":"/research/s_mt--pass-08/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":5,"claims":54,"sources":26,"review_status":"revise_bounded_example_claim_links_and_frequency_premise_pending","review_complete":true,"sha256":"1bb06d684e79b4f597774e172be6cb088d9d5f25b2aef0d46b6971cb8ed42282","headings":["I. Executive determination","1. No general standalone Montana “collection agency” license was identified","2. The central Montana licensing trigger is the debt’s legal origin and the collector’s activity","3. A debt buyer’s title to the account does not answer either state licensing or FDCPA coverage","4. Montana does not appear to have a comprehensive state “mini-FDCPA”","A. Montana Consumer Loan Act","Consumer-purpose threshold","Making versus servicing","Statutory exemptions","Transfer consequence","Unlicensed collection consequence","B. Retail installment contract buyers","C. Model-by-license, exemption, and nexus matrix","A. Consumer Loan License","B. Sales Finance License","C. Public complaint and regulator routes","D. Discipline sufficient to explain market entry","A. Consumer Loan Act charges and payment handling","B. Retail installment contract conduct","C. Montana Consumer Protection Act","D. Specialized collection restrictions","Deferred-deposit obligations","Repossession","Ambulance-bill furnishing boundary","Attorney acquisition of claims","E. State-conduct-by-actor/event matrix","A. FDCPA coverage","B. Debt buyers","Henson v. Santander","McAdory v. DNF Associates","C. Attorneys","D. Security-interest enforcement","E. Communications and conduct","F. State-law preservation","A. McCollough v. Johnson, Rodenburg & Lauinger","B. Jacobson v. Bayview Loan Servicing","C. Baird v. Norwest Bank","D. Historical BFID order — Westgate","E. Search limitation","Example 1 — Nonbank original creditor collecting its own MCLA loan","Example 2 — Original creditor using a collection-company identity","Example 3 — Transferred Montana Consumer Loan Act loan","Example 4 — Bank-originated credit-card debt purchased after default","Example 5 — Passive debt buyer with no consumer communications","Example 6 — Remote agency collecting medical debt","Example 7 — Represented consumer and workplace contact","Example 8 — Call frequency and text-message opt-out","Example 9 — MCLA late-charge arithmetic","Example 10 — Retail installment delinquency alternatives","Flat method","Alternative 15% calculation","Example 11 — Attorney filing a time-barred collection suit","Example 12 — Repossession at a residence","Example 13 — Commercial debt","Freshly read or directly inspected on October 26, 2026","Fresh but access-limited","Bounded negative searches","Not read or resolved"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_MT/pass-08","facets":{"geography":["us","us-mt"],"debt_type":[],"stage":["collection"],"subject":["provider-licensing"]},"scope":"Distinct required registry dimension2: collector licensing/model coverage and state-specific conduct only; detailed validation/reporting/litigation/remedies later.","pending_corrections":2},"markdown":"# S_MT PASS-08 — Montana collection-agency/debt-buyer licensing, original-creditor coverage, and state-specific collection conduct\n\n**Fresh research session:** October 26, 2026, Pacific / October 26, 2026, UTC\n**Mode:** GPT-5.6 Sol Pro, regular Chat\n**Relationship to earlier work:** Distinct collection-licensing/classification and state-conduct component. This is not an independent review. Nothing below accepts or regenerates the earlier debt-adjustment, DMP, settlement, fee, funds, security, agreement, or provider-remedies work.\n\n**Component status:** **PARTIAL.** Montana’s principal activity-specific licensing routes, original-creditor/debt-buyer boundaries, current public verification process, loan-specific conduct restrictions, general state unfair-practices layer, and necessary FDCPA/Regulation F gateways are substantially resolved. Detailed validation, documentation, furnishing, account-level proof, limitations/revival, collection litigation, judgments, garnishment, and full remedies remain open.\n\n## I. Executive determination\n\n### 1. No general standalone Montana “collection agency” license was identified\n\nThe current official Montana licensing inventory, published 2025 Code, administrative-rule searches, and regulator materials did **not** reveal a generally applicable statewide license titled “collection agency license” or “debt buyer license.”\n\nThat is a bounded research conclusion, not proof that every debt collector is unlicensed:\n\n- Montana licenses **consumer-loan lenders and servicers** under the Montana Consumer Loan Act.\n- Montana licenses businesses purchasing Montana retail installment contracts as **sales finance companies**.\n- Mortgage servicing, deferred-deposit lending, escrow, and other sectors have separate activity-specific regimes.\n- A collector may also need a telemarketing registration, foreign-entity registration, professional license, or another sector license based on its actual conduct.\n- Federal FDCPA status does not determine Montana licensing.\n- NMLS business-activity labels such as “first-party debt collection” or “third-party debt collection” are not themselves Montana licenses.\n\nThe current private-investigator statute’s reference to a “collection agency” merely exempts a collection agency’s incidental investigations from the private-investigator chapter; it does not create or identify a general collection-agency license. Likewise, the foreign-LLC statute’s treatment of collecting debts as an activity that does not alone constitute “transacting business” is a corporate-registration rule, not permission to collect or a substantive exemption from financial-services law. [Montana Department of Administration+3](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\n### 2. The central Montana licensing trigger is the debt’s legal origin and the collector’s activity\n\nA nonexempt entity receiving or accepting payments on a loan originated under the Montana Consumer Loan Act—and keeping the payments or directing them to someone else—is treated by the Montana Division of Banking and Financial Institutions as a consumer-loan servicer requiring a license. Montana’s statute also says transferred Consumer Loan Act contracts remain governed by that chapter and that a loan “made or collected” in violation by an unlicensed, nonexempt person is void, with no right to collect or retain principal, interest, fees, or charges. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\nThat does **not** mean every account collected from a Montana resident is a Montana Consumer Loan Act loan. BFID currently states that its servicing interpretation applies to loans originated under that Act and not to loans originated by banks or credit unions. BFID also states that utilities, service providers such as doctors and hospitals, and estates are outside the Act. Those are agency interpretations delimiting this particular license; other state and federal collection law can still apply. [Montana Department of Administration+1](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\n### 3. A debt buyer’s title to the account does not answer either state licensing or FDCPA coverage\n\nA buyer of a Montana Consumer Loan Act loan may inherit continuing chapter restrictions and, if it receives or directs payments, the Montana servicing-license requirement. A company that regularly purchases Montana retail installment contracts may instead require a sales-finance-company license. A passive buyer of bank-originated credit-card accounts does not become a Montana Consumer Loan Act licensee solely because it owns the accounts, but it may qualify as a federal “debt collector” under the FDCPA’s principal-purpose definition even if it outsources all direct collection. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\n### 4. Montana does not appear to have a comprehensive state “mini-FDCPA”\n\nNo generally applicable Montana enactment was located that independently establishes all of the familiar federal debt-collection communication rules—such as the 8 a.m.–9 p.m. presumption, the Regulation F seven-calls-in-seven-days presumptions, third-party contact restrictions, represented-consumer restrictions, written cease-contact effect, or electronic opt-out requirements.\n\nMontana’s substantive state layer instead consists principally of:\n\n- Loan-specific charges, receipts, records, payoff, advertising, and licensing rules.\n- Retail installment sales restrictions.\n- Montana Consumer Protection Act prohibitions against unfair or deceptive conduct.\n- Specialized sector statutes.\n- Contract, UCC, professional, and general tort law.\n\nThe federal FDCPA and Regulation F rules apply only when their own federal definitions and exceptions are met; they are not converted into Montana statutes merely because the consumer lives in Montana. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0030/0300-0140-0010-0030.html)\n\n# II. Montana licensing and classification\n\n## A. Montana Consumer Loan Act\n\n### Consumer-purpose threshold\n\nA Montana “consumer loan” is credit offered or extended to an individual primarily for personal, family, or household purposes, generally excluding deferred-deposit loans and residential mortgage loans. Commercial, investment, organizational, or business-purpose obligations are not brought into the Consumer Loan Act merely because the obligor is an individual or later uses a personal account to make payments. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html)\n\n### Making versus servicing\n\nThe licensing prohibition in §32-5-103(1) is written around engaging in the business of making consumer loans for compensation. But three connected authorities support BFID’s servicing interpretation:\n\n1. Transferred Consumer Loan Act contracts remain governed by the chapter.\n2. A loan “made or collected” in violation by an unlicensed, nonexempt person is void.\n3. BFID’s 2016 memorandum and current guidance say receiving or accepting payments and retaining or directing them is servicing requiring a consumer-loan license. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\nThe servicing conclusion is therefore a combination of statutory text and current agency interpretation. It should not be recast as if the statute expressly defines every possible servicing activity.\n\n### Statutory exemptions\n\nThe Consumer Loan Act exempts:\n\n- Banks.\n- Building and loan associations.\n- Savings and loan associations.\n- Trust companies.\n- Credit unions.\n- A person making fewer than four consumer loans annually with the person’s own funds, provided the person does not represent that it is licensed and complies with the identified Title 31 provisions. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\nBFID further states that its Act does not apply to utility providers, medical and similar service providers, estates, or loans originated by depository institutions. That clarification is operational agency guidance and not an amendment to the statutory exemption list. [Montana Department of Administration+1](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\n### Transfer consequence\n\nA loan contract made under the Act remains governed by the chapter after an authorized transfer. This prevents an acquiring organization from assuming that assignment strips away the Act’s interest, fee, receipt, record, and payoff restrictions. It does not, without more facts, answer whether a passive owner that never receives or directs payments must itself be licensed. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\n### Unlicensed collection consequence\n\nSection 32-5-103(4) states that a loan made or collected in violation by an unlicensed, nonexempt person is void, and that person has no right to collect, receive, or retain principal, interest, fees, or charges. This is a severe loan-specific consequence; it is not a general declaration that every unlicensed third-party collector in Montana loses every debt. The underlying obligation must fall within the Act and the licensing violation must be established. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\n## B. Retail installment contract buyers\n\nA “sales finance company” includes a person engaged in the business of purchasing Montana retail installment contracts. An isolated purchase from the same seller does not necessarily make the purchaser a sales finance company, but regularly acquiring such contracts can require a sales-finance license. Banks and certain institutional entities are exempt from the license requirement while remaining subject to other substantive provisions. [Montana Legislature+1](https://leg.mt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html)\n\nThe license:\n\n- Is required for each covered principal or branch location.\n- Costs $100 for the principal license and each branch.\n- Expires December 31.\n- Is nontransferable and nonassignable.\n- Does not require a physical Montana office.\n- Does not authorize business under an unlicensed alternate name. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html)\n\nA buyer of installment contracts therefore cannot decide licensing solely by asking whether it is collecting “its own” accounts. The acquisition model itself may be the licensed activity.\n\n## C. Model-by-license, exemption, and nexus matrix\n\n| Model | Montana licensing result | Federal FDCPA boundary | Evidence that must be retained or checked |\n| --- | --- | --- | --- |\n| Nonbank original lender making and collecting its own Montana Consumer Loan Act loans | Consumer Loan License required unless an express exemption applies | Usually creditor, not FDCPA debt collector, when collecting in own name | Loan purpose, originator identity, original license, NMLS record, loan date, payment history |\n| Bank or credit union collecting its own originated loan | Exempt from Montana Consumer Loan Act license | Usually original-creditor exclusion if using own name | Charter/depository status, account origin, collector identity, DBA |\n| Nonbank original creditor using a different name suggesting a third party | Montana activity-specific license still depends on debt type | FDCPA can include creditor collecting own debt under another name suggesting third-party collection | Call scripts, letterhead, domains, caller ID, legal names, DBAs |\n| Ordinary third-party contingency agency collecting a medical, utility, or trade debt | No general Montana collection-agency license identified; other activity-specific law may apply | Usually FDCPA debt collector if regularly collecting another’s consumer debts | Debt purpose, creditor type, agency agreement, collector role, communication logs |\n| Servicer receiving payments on a Montana Consumer Loan Act loan | BFID says Consumer Loan License required | FDCPA depends partly on when debt was acquired and principal purpose | Originating license, transfer history, default date, servicing agreement, payment-routing authority |\n| Servicer of a bank-originated consumer loan | BFID says the 2016 MCLA memo does not apply to bank-originated loans | May be excluded federally if obtained before default; otherwise fact-dependent | Bank origin, acquisition/default timing, servicing contract, federal status |\n| Buyer of Montana Consumer Loan Act loan that collects or directs payments | Strong license trigger under continuing-governance text and BFID servicing interpretation | Ownership does not preclude principal-purpose FDCPA coverage | Loan-origin proof, assignment chain, money flow, NMLS license |\n| Passive buyer of defaulted bank credit-card accounts using outside agencies | No Montana Consumer Loan Act license established solely by ownership; no generic debt-buyer license found | Can qualify under principal-purpose prong under *McAdory* | Revenue model, portfolio composition, collection contracts, acquisition/default status |\n| Business purchasing Montana retail installment contracts | Sales Finance License generally required unless exempt/isolated | FDCPA depends on purpose, default status, and collection model | Contract type, Montana formation, acquisition frequency, NMLS sales-finance record |\n| Seller retaining its own retail installment contracts | Sales-finance purchaser license may not apply to the original seller merely as seller; substantive Retail Installment Sales Act still applies | Usually original creditor federally | Seller identity, contract, assignment status |\n| Attorney or law firm regularly collecting consumer debts through litigation | No general Montana collection-agency license located solely because it litigates; bar/professional rules remain | FDCPA applies to attorneys regularly collecting through litigation | Engagement, volume, pleadings, debt purpose, claim ownership, bar status |\n| Attorney buying claims for the purpose of filing suit | Montana professional statute prohibits buying a claim with intent and purpose of bringing an action, subject to specified exceptions | Federal coverage separately analyzed | Purchase documents, intent, prior services or antecedent debt, litigation plan |\n| Affiliate collecting for related creditor | No broad Montana affiliate exemption identified; activity-specific license may apply | Narrow FDCPA affiliate exclusion requires common ownership/control, collection only for affiliates, and no principal collection business | Ownership chart, clients, revenues, shared names, collection scope |\n| Employee collecting solely for own creditor-employer | Employees do not receive individual Montana consumer-loan licenses; entity/branch licensing controls | Creditor employee generally excluded federally when collecting in creditor’s name | Employment relationship, employer identity, scripts, location |\n| Nonprofit collection operation | No general Montana nonprofit exemption from collection/activity-specific licensing | Federal nonprofit DMP exclusion is narrow and not a generic nonprofit-collector exemption | Legal status, actual services, compensation, clients, collection purpose |\n| Out-of-state digital agency with Montana accounts | No Montana physical office required for Consumer Loan license; nexus follows covered Montana activity, not headquarters | FDCPA applies to covered interstate collection | Consumer residence, loan origin, remote location, branch activity, NMLS records |\n| Repossession company enforcing security interest only | No generic collector license identified; UCC and professional/business rules apply | Limited-purpose debt collector for §1692f(6) when doing no more than security-interest enforcement | Contract, right to possession, default, instructions, conduct at repossession |\n| Government officer collecting in official capacity | No general private collection license | Federal statutory exclusion for government officer performing official duties | Agency authority and employment |\n| Commercial-debt collector | MCLA and Retail Installment consumer provisions generally do not apply merely because debtor is in Montana | FDCPA excludes business-purpose debt | Contract purpose, entity borrower, use of proceeds |\n| Mortgage owner or servicer | Separate Montana Mortgage Act licensing analysis; not resolved here | Federal mortgage-servicing and FDCPA status are default- and activity-dependent | Mortgage type, servicing rights, default/acquisition timing, mortgage license |\n\nThe state classifications above derive from the Consumer Loan Act, BFID’s current servicing interpretation, the Retail Installment Sales Act, and the bounded absence of a general collector-license route. The federal column derives from the FDCPA definitions and controlling federal cases addressed below. [Montana Code Annotated+7](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html)\n\n# III. Entry, renewal, continuity, and public verification\n\n## A. Consumer Loan License\n\nThe current Montana statutory and BFID operational requirements establish:\n\n- Each covered place of business must be licensed.\n- Licenses are nontransferable and nonassignable.\n- Initial and renewal fee: **$500 per company or branch license**.\n- License year: calendar year.\n- Expiration: December 31.\n- Applications and renewals are submitted through NMLS.\n- The applicant is subject to general-character and fitness review and specified financial-services licensing and fraud-history criteria.\n- Employees do not receive separate Consumer Loan licenses; Montana licenses entities and branches.\n- A physical Montana office is not required.\n- BFID says there is no Consumer Loan License bond.\n- Annual reporting is due February 15, and financial statements are submitted through NMLS after fiscal-year end.\n- Consumer document samples and fee disclosures are requested at application and renewal. [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html)\n\nThe current public NMLS checklist compiler is the application-requirements route, and NMLS Consumer Access is the public verification route. No named provider was searched in this pass. Montana does not issue a paper Consumer Loan license, and BFID says there is no requirement to display one. [Nationwide Licensing System+2](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx?utm_source=chatgpt.com)\n\nThe precise current late-renewal, reinstatement, deficiency, control-person, and document-upload requirements should be confirmed from the generated Montana Consumer Loan License checklist at the time of an actual application. The public compiler route was located, but a company-specific checklist was not generated or treated as filed.\n\n## B. Sales Finance License\n\nBFID likewise routes Sales Finance License applications through NMLS. The statutory fee is $100 for the principal location and each branch; the license expires December 31 and is nontransferable. No named purchaser or account buyer was checked. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html)\n\n## C. Public complaint and regulator routes\n\nTwo regulators have materially different roles:\n\n- The **Montana Department of Administration, Division of Banking and Financial Institutions** administers Consumer Loan and Sales Finance licensing and examinations.\n- The **Montana Department of Justice, Office of Consumer Protection** receives consumer complaints and administers Montana’s general consumer-protection framework.\n\nNMLS Consumer Access can verify the existence and displayed status of a state financial-services license. An OCP complaint page is not a licensing roster, and a BFID license does not establish compliance with the FDCPA or Montana collection conduct law. [Montana Department of Administration+2](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\nBFID’s public enforcement index includes consumer-loan licensing matters but is not an exhaustive debt-collection order database. Older actions may be located through NMLS or historical agency materials. [Montana Department of Administration](https://doa.mt.gov/BFID/enforcement-actions)\n\n## D. Discipline sufficient to explain market entry\n\nFor a licensed or unlicensed person violating the Consumer Loan Act, a rule, or a department order, BFID may:\n\n- Issue notice based on probable cause.\n- Provide 14 days from mailing to request an administrative hearing.\n- Impose up to $1,000 per violation after admission, noncontest, or finding.\n- Order borrower restitution and reimbursement of agency costs.\n- Suspend or revoke the right to operate.\n- Preserve liability for pre-suspension or pre-revocation conduct. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html)\n\nThis is a bounded licensing consequence, not a full private-remedy or limitations analysis.\n\n# IV. Montana-specific collection conduct\n\n## A. Consumer Loan Act charges and payment handling\n\nFor covered Consumer Loan Act loans:\n\n- Interest may not exceed 36% annually, excluding specified authorized charges.\n- A deferral charge may be the greater of $15 or 5% of the amount due, capped at $50.\n- A late charge may be the greater of $15 or 5% of the past-due amount, capped at $50.\n- A late charge may be imposed only once on the same past-due amount.\n- No other default fee may be imposed.\n- Other fees are forbidden unless the chapter authorizes them, subject to the limited voluntary post-consummation-service provision.\n- Splitting a contract to obtain excess fees is forbidden.\n- Charging or receiving an excess amount results in forfeiture to the borrower of twice the excess amount. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html)\n\nA licensee must provide a plain, dated, complete receipt for each cash payment, maintain reliable payment records, and, within ten days after full repayment, memorialize satisfaction, release security, and return or mail the canceled note or equivalent instrument as prescribed. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html)\n\nThe Act also prohibits false, misleading, or deceptive advertising concerning loan rates, terms, or conditions. It restricts confessions of judgment and incomplete loan instruments and limits contractual attorney fees and dishonored-payment charges. [Montana Code Annotated+2](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html)\n\nThese requirements follow a transferred Consumer Loan Act contract. They are not automatically applicable to medical bills, utility debts, bank-issued cards, or commercial accounts merely because a collection agency is involved.\n\n## B. Retail installment contract conduct\n\nFor a Montana retail installment contract or retail charge account:\n\n- A delinquency charge may be imposed only after an installment has been in default at least ten days.\n- The holder may charge up to $10 per defaulted installment or, alternatively, calculate a fixed delinquency charge expressed as a rate not exceeding 15% of that installment.\n- The two methods are alternatives; they are not automatically cumulative.\n- Regular contract interest may continue only under the specified simple-interest condition.\n- A contract may allow outside-attorney fees up to 15% of the amount due, plus court costs and actual reasonable out-of-pocket delinquency expenses.\n- On written request, the holder must provide the prescribed account statement.\n- Cash payments require receipts, and full payment triggers acknowledgment and release of security. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html)\n\nViolations of specified Retail Installment Sales Act provisions can restrict the holder’s ability to collect finance, delinquency, or collection charges. Full remedy and limitation treatment is reserved for a later pass. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html)\n\n## C. Montana Consumer Protection Act\n\nThe Montana Consumer Protection Act broadly prohibits unfair or deceptive acts or practices in trade or commerce. “Trade” and “commerce” encompass the offering or distribution of services or property directly or indirectly affecting Montana residents. Private “consumer” status is tied to personal, family, or household purposes. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html)\n\nThe Montana Supreme Court has held that lending and collecting consumer loans are within the MCPA’s trade-or-commerce scope, including collection activity by a bank. Thus, the original-creditor label is not a blanket MCPA exemption. [Justia Law](https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html)\n\nThe Act’s regulated-activity exemption is narrow: it covers actions or transactions permitted under laws administered by the Public Service Commission or the state auditor and innocent media dissemination. It does not create a general exemption for banks, attorneys, nonprofits, licensed collectors, debt buyers, or regulated businesses. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0050/0300-0140-0010-0050.html)\n\nThe official current ARM search rendering for ARM 23.19.101 identifies conduct such as misstating transaction rights, remedies, or obligations and failing to disclose specified business identity information in advertising as deceptive. The direct official rule body returned HTTP 405, so the complete current text was not independently authenticated through that route. [Montana Administrative Rules+1](https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d)\n\n## D. Specialized collection restrictions\n\n### Deferred-deposit obligations\n\nFor a covered deferred-deposit loan:\n\n- Unauthorized interest or fees are prohibited.\n- A returned-check charge is capped at $30 and may be imposed only once.\n- That charge is the only permitted late or delinquency charge.\n- A collection agency, holder, or agent may not collect the separate bad-check statutory damages identified by the statute.\n- Attorney fees and costs are limited to the prevailing-party arrangement stated in the statute. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html)\n\nBFID currently states that Montana has no licensed payday lenders. That operational statement does not resolve whether an old account, an online out-of-state transaction, or an illegally originated account is enforceable. [Montana Department of Administration](https://doa.mt.gov/BFID/mortgage-consumer-finance/)\n\n### Repossession\n\nAfter default, a secured party may proceed judicially or take possession without judicial process only if it can do so without breach of the peace. An agreed assembly demand must designate a reasonably convenient place. This is a state repossession rule, not a comprehensive communications statute. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html)\n\n### Ambulance-bill furnishing boundary\n\nFor certain ambulance bills transferred to a collection agency, the ambulance service must inform the agency that the bill may not be reported as delinquent. The complete furnishing, dispute, and credit-reporting procedure remains for the later reporting pass. [Montana Code Annotated+1](https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html)\n\n### Attorney acquisition of claims\n\nA Montana attorney may not buy a claim with the intent and purpose of bringing an action on it. The law preserves specified situations such as receipt of a claim in payment for services or an antecedent debt where the prohibited purpose is absent. This is a professional-conduct boundary, not a general exemption from the FDCPA. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0370/chapter_0610/part_0040/section_0080/0370-0610-0040-0080.html)\n\n## E. State-conduct-by-actor/event matrix\n\n| Conduct or event | Montana state rule located | Covered actor or debt | Federal overlay, if applicable | Remaining hold |\n| --- | --- | --- | --- | --- |\n| Calls before 8 a.m. or after 9 p.m. | No general Montana debt-collection time window located | — | FDCPA/Reg F presumption for federally covered collectors | Actual federal coverage and consumer location |\n| Known inconvenient time or place | MCPA can reach unfair conduct, but no collection-specific Montana test located | Any covered consumer transaction under MCPA | FDCPA/Reg F explicit restriction | Specific notice and collector knowledge |\n| Workplace contact | No general Montana workplace-contact prohibition located | — | FDCPA prohibits known/prohibited employer contact in covered cases | Employer rule and collector knowledge |\n| Contact with represented consumer | No general Montana collection statute located | MCPA may reach deceptive or oppressive conduct | FDCPA restriction applies to covered collector with attorney knowledge and accessible attorney information | Exact notice and representation scope |\n| Third-party disclosure | No general Montana mini-FDCPA provision located | Other privacy law may apply | FDCPA generally limits communications to third parties | Identity of contact, purpose, consent |\n| Repeated calls | No state numeric cap located | MCPA potentially applies to oppressive conduct | Reg F seven-in-seven and post-conversation presumptions; FDCPA intent-to-harass rule | Debt count, connected calls, exceptions |\n| Obscene, threatening, or abusive language | MCPA potentially reaches unfair conduct | Consumer trade/commerce | FDCPA expressly prohibits violence, obscenity, harassment | Exact words and actor status |\n| Threat of arrest or criminal action | MCPA deceptive-practice route | Consumer transaction | FDCPA false-threat and misrepresentation provisions | Truth, legal authority, intent |\n| False threat to sue, garnish, seize, or report | MCPA and loan-advertising rules may apply | Consumer transaction; specific loan laws | FDCPA expressly addresses unlawful or unintended legal/credit consequences | Legal right, intent, applicable procedure |\n| False creditor or owner identity | MCPA prohibits deceptive conduct | Original creditor, servicer, buyer, collector | FDCPA false-representation provisions | Assignment evidence and materiality |\n| Failure to state collector identity on call | No general Montana call-opening formula located | — | FDCPA prohibits failure to disclose caller identity where applicable | Federal status and communication purpose |\n| Business legal name/address in advertising | ARM search rendering and MCPA support identity transparency | Advertising in trade/commerce | Federal law may add collector identification | Complete current official ARM body inaccessible |\n| Written cease request | No general Montana cease-contact rule located | — | FDCPA restricts further communication after qualifying written notice, subject to three exceptions | Receipt, address, communication type |\n| Electronic-message opt-out | No Montana-specific general opt-out rule located | — | Reg F requires simple electronic opt-out in covered messages | Federal status and message type |\n| Social-media contact | No general Montana debt-specific rule located | MCPA/privacy law potentially relevant | Reg F restricts public-viewable messages and requires private-message opt-out | Platform settings and content |\n| Unauthorized fee or interest | MCLA, Retail Installment, Deferred Deposit, contract, and MCPA provisions | Depends on account origin/type | FDCPA prohibits amounts not authorized by agreement or law | Contract, originating statute, assignment |\n| Payment receipt | MCLA requires receipt for cash and records; retail installment statute has receipt duties | Covered licensee or holder | Federal law may add periodic/validation duties | Payment method and account type |\n| Payment allocation | No general Montana debt-collection allocation rule established in this pass | Loan-specific contracts may control | Federal law can impose allocation duties in specified multiple-debt situations, deferred to later pass | Multiple accounts and consumer instruction |\n| Payoff/release | MCLA and Retail Installment Sales Act impose account-specific duties | Covered loan/contract holder | Other law may apply to mortgages and security interests | Debt type and full-payment date |\n| Repossession | UCC prohibits nonjudicial repossession involving breach of peace | Secured party and agent | FDCPA §1692f(6) may apply to security-interest enforcer | Default, right to possession, conduct |\n| Contact after bankruptcy filing | No complete state bankruptcy-contact rule analyzed | — | Federal automatic stay/discharge law controls; later pass | Filing, notice, debt type, stay status |\n| Deceased consumer | No general Montana collection-contact rule located | Estate and probate law potentially controls | FDCPA defines “consumer” broadly for §1692c to include executor/administrator | Appointment and communication target |\n| Commercial debt | Consumer-specific Montana and federal statutes generally inapplicable | Business-purpose obligation | FDCPA does not cover business debt | Purpose at origination, guarantor status |\n| Credit reporting of covered ambulance bill | Specific Montana prohibition route | Specified ambulance account and agency | FCRA/Reg V later | Account qualification and furnishing event |\n\n# V. Necessary federal gateway\n\n## A. FDCPA coverage\n\nThe FDCPA defines a covered “debt” as an obligation arising from a transaction primarily for personal, family, or household purposes. It defines “debt collector” through two independent principal routes:\n\n1. A person whose principal business purpose is collecting debts.\n2. A person who regularly collects debts owed or due another.\n\nIt also includes a creditor collecting its own debt under a name suggesting that a third person is collecting. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1692a/)\n\nMaterial exclusions include:\n\n- Officers or employees collecting in the creditor’s own name.\n- A narrow affiliate-collection arrangement.\n- Government officers performing official duties.\n- Process servers performing service.\n- A qualifying bona fide nonprofit credit-counseling organization.\n- Certain fiduciary, escrow, originator, pre-default assignee, and commercial-credit situations. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1692a/)\n\nThe old blanket attorney exemption no longer exists.\n\n## B. Debt buyers\n\n### *Henson v. Santander*\n\nThe Supreme Court held that a company collecting debts it purchased for its own account did not fall within the statutory prong covering a person who regularly collects debts “owed or due another.” The Court expressly did **not** decide whether Santander qualified under the separate principal-purpose prong. Ownership therefore defeats neither every FDCPA theory nor every state licensing theory. [Supreme Court](https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf)\n\n### *McAdory v. DNF Associates*\n\nThe Ninth Circuit held at the pleading stage that a passive debt buyer can fall under the principal-purpose definition even if it outsources all direct interaction. A company cannot necessarily avoid that prong by hiring others to perform the communications. The case reversed dismissal and remanded; it did not establish final trial-level facts about every debt buyer. It is controlling federal appellate authority for Montana federal courts. [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf)\n\n## C. Attorneys\n\nIn *Heintz v. Jenkins*, the Supreme Court held that the FDCPA applies to attorneys who regularly engage in consumer-debt collection activity, including litigation. Being a law firm is not a categorical federal exemption. [GovInfo](https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf?ref=hoaweekly.com)\n\n## D. Security-interest enforcement\n\nIn *Obduskey v. McCarthy & Holthus LLP*, the Supreme Court held that a business engaged in no more than nonjudicial foreclosure is generally treated as a debt collector only for §1692f(6). The Court did not create blanket immunity for conduct beyond pure security-interest enforcement or for entities independently satisfying the general debt-collector definition. [Supreme Court](https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf)\n\n## E. Communications and conduct\n\nFor a federally covered collector:\n\n- Communications at unusual or inconvenient times or places are restricted; 8 a.m.–9 p.m. local time is the statutory presumption.\n- Known workplace restrictions and represented-consumer contacts are limited.\n- Communications with third parties are generally restricted.\n- A qualifying written refusal-to-pay or cease-contact request limits further contact to specified exceptions.\n- Harassing, abusive, threatening, and repeatedly ringing conduct undertaken with intent to annoy, abuse, or harass is prohibited.\n- False representations about the creditor, debt amount, legal status, attorney involvement, arrest, seizure, garnishment, credit reporting, or legal process are prohibited.\n- Unauthorized interest, fees, and other amounts are prohibited.\n- Certain repossession and communication-privacy practices are prohibited. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1692c/)\n\nRegulation F adds operational presumptions and electronic rules. It generally presumes a violation for more than seven telephone calls concerning a particular debt within seven consecutive days or a call within seven days after a telephone conversation about that debt, subject to stated exclusions and rebuttal. It also requires simple electronic opt-out mechanisms and restricts public social-media communications. These are federal requirements—not Montana’s own call-frequency law. [eCFR+4](https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-B/section-1006.14)\n\n## F. State-law preservation\n\nThe FDCPA preserves state law except to the extent of an actual inconsistency; greater state protection is not inconsistent. Therefore, Montana loan-specific fee restrictions, UCC restrictions, and MCPA standards can coexist with federal FDCPA duties. Montana’s lack of a duplicate federal communication rule does not eliminate the federal rule. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1692n/)\n\n# VI. Controlling and materially relevant opinions and orders\n\n## A. *McCollough v. Johnson, Rodenburg & Lauinger*\n\nThe Ninth Circuit affirmed FDCPA liability arising from a Montana collection lawsuit on a time-barred debt, pursuit of unauthorized attorney fees, and false requests for admission. The opinion confirms that litigation documents and litigation conduct are not categorically outside the FDCPA. Detailed limitations, pleading proof, and collection-litigation procedure remain for later passes. [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf)\n\n## B. *Jacobson v. Bayview Loan Servicing*\n\nIn a mortgage-servicing and foreclosure setting, the Montana Supreme Court addressed direct communications despite known attorney representation and materially misleading claims about the beneficiary, ownership, and ability to resolve or cure. The opinion supports applying federal collection restrictions and the MCPA to deceptive servicing and collection conduct. It does not enact a free-standing Montana represented-consumer contact rule applicable to every original creditor. [Justia Law](https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520)\n\n## C. *Baird v. Norwest Bank*\n\nThe Montana Supreme Court held that Montana’s Consumer Protection Act applies to the lending and collection of consumer loans by banks. The case is especially important because it rejects the idea that original-creditor or bank status categorically removes collection activity from Montana’s unfair-practices law. It is not a collector-licensing decision. [Justia Law](https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html)\n\n## D. Historical BFID order — Westgate\n\nA 2014 BFID cease-and-desist order alleged and determined for that administrative posture that Westgate made consumer loans to Montana residents without the required license. The order cited §32-5-103 and treated the loans as void with no right to collect principal, interest, fees, or charges. The second page provided a 14-day hearing-request route. This was a party-specific historical order involving unlicensed lending; it is not proof that every remote debt collector is a Montana consumer lender. [Montana Department of Administration+2](https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf)\n\n## E. Search limitation\n\nTargeted official and public case searches did not locate:\n\n- A controlling Montana appellate decision defining when a passive owner must obtain a Consumer Loan License.\n- A controlling Montana decision establishing a general collection-agency license.\n- A current published Montana appellate construction of BFID’s 2016 servicing memorandum.\n- A comprehensive current DOJ/BFID debt-buyer order series.\n- A Montana mini-FDCPA communication statute.\n\nThat is a bounded search result, not proof no trial-court order, unpublished administrative matter, consent order, or nonindexed decision exists.\n\n# VII. Bounded operational examples\n\nThese examples classify activity and illustrate statutory arithmetic. They do not approve an actual provider, account, contract, fee, communication, or lawsuit.\n\n## Example 1 — Nonbank original creditor collecting its own MCLA loan\n\n**Facts**\n\n- Company made a $4,000 personal-purpose unsecured loan to a Montana resident.\n- Company is not a bank, credit union, or other exempt institution.\n- It receives monthly payments directly.\n\n**Result**\n\nThe account is a Montana Consumer Loan Act candidate. The company needs a Consumer Loan License unless a statutory exemption applies. Its own-name collection ordinarily does not make it an FDCPA debt collector, but the Montana licensing, fee, receipt, advertising, and MCPA rules remain applicable.\n\n**Evidence to retain**\n\n- Loan purpose.\n- Originator identity.\n- NMLS Consumer Loan License status on the origination and collection dates.\n- Contract and fee schedule.\n- Receipts and payment ledger.\n\nClaims: S_MT-P08-C002–C006, C017–C022.\n\n## Example 2 — Original creditor using a collection-company identity\n\n**Facts**\n\n- Original creditor owns the account.\n- Letters use “National Recovery Bureau.”\n- The name is not clearly identified as the creditor’s registered DBA and suggests an unrelated third-party agency.\n\n**Result**\n\nMontana licensing still depends on the underlying account and activity. Federally, the creditor can fall within the FDCPA’s other-name provision even though it owns the debt. MCPA deception analysis is separate.\n\n**Missing facts**\n\n- Legal and registered assumed names.\n- Letterhead, caller ID, websites, scripts.\n- Whether a reasonable consumer would understand that the creditor itself is collecting.\n\nClaims: C010, C025, C031.\n\n## Example 3 — Transferred Montana Consumer Loan Act loan\n\n**Facts**\n\n- Licensed nonbank lender originated a personal loan under the MCLA.\n- Buyer acquires the loan.\n- Buyer or its servicer receives payments and directs them to the buyer.\n\n**Result**\n\nThe contract remains governed by the MCLA. BFID’s current interpretation indicates that the servicing entity needs a Consumer Loan License. Ownership of the loan does not remove the fee and account-handling restrictions.\n\n**Public check**\n\nSearch the collector and any servicing entity separately in NMLS Consumer Access; do not infer one entity’s license covers an affiliate.\n\nClaims: C003–C009, C016.\n\n## Example 4 — Bank-originated credit-card debt purchased after default\n\n**Facts**\n\n- National bank originated the card.\n- Debt was in default when purchased by a nonbank debt buyer.\n- Buyer uses a third-party agency.\n\n**Montana result**\n\nBFID states that its MCLA servicing memorandum does not apply to bank-originated loans. No general Montana debt-buyer license was identified. MCPA, contract, retail-installment, telemarketing, professional, and other activity-specific rules must still be checked.\n\n**Federal result**\n\n- *Henson* prevents reliance only on the “owed another” prong against the owner collecting for itself.\n- *McAdory* leaves the buyer potentially covered under the principal-purpose prong.\n- The outside agency ordinarily remains subject to the “owed another” analysis.\n\nClaims: C001, C007, C028–C033.\n\n## Example 5 — Passive debt buyer with no consumer communications\n\n**Facts**\n\n- Buyer acquires defaulted consumer portfolios.\n- All calls, letters, and lawsuits are outsourced.\n- Most revenue comes from collections.\n\n**Result**\n\nNo Montana license follows solely from the word “buyer”; the debt’s origin and the buyer’s payment-control or retail-installment activity must be determined. Under *McAdory*, the lack of direct communication does not defeat the federal principal-purpose theory at the pleading stage.\n\n**Documents**\n\n- Revenue breakdown.\n- Acquisition agreements.\n- Servicing and agency contracts.\n- Authority to approve settlements and lawsuits.\n- Ownership and affiliate chart.\n\nClaims: C008–C010, C029–C030.\n\n## Example 6 — Remote agency collecting medical debt\n\n**Facts**\n\n- Collector is headquartered outside Montana.\n- It collects a Montana hospital bill.\n- It does not originate loans or receive payments on an MCLA loan.\n\n**Result**\n\nBFID says service-provider obligations such as hospital bills are outside the MCLA. No general Montana collection-agency license was identified. The collector may nevertheless be subject to the FDCPA if the obligation is consumer debt, and to the MCPA for unfair or deceptive conduct.\n\nAn out-of-state headquarters is not an exemption from applicable law.\n\nClaims: C001, C007, C023–C026, C031.\n\n## Example 7 — Represented consumer and workplace contact\n\n**Facts**\n\n- Third-party collector knows the consumer has counsel for the debt.\n- Collector calls the consumer’s workplace.\n- Employer prohibits personal collection calls.\n\n**State result**\n\nNo general Montana statute independently duplicating the federal represented-consumer and workplace rules was located. MCPA unfairness or deception may still apply based on the full facts.\n\n**Federal result**\n\nIf the caller is a federally covered debt collector and the attorney is readily ascertainable, §1692c restricts direct contact. Known employer restrictions create a separate federal problem.\n\nClaims: C025, C034–C036.\n\n## Example 8 — Call frequency and text-message opt-out\n\n**Facts**\n\n- Covered collector places eight connected calls concerning one debt within seven consecutive days.\n- Collector also sends texts with no simple opt-out.\n\n**Federal result**\n\nEight calls exceed Regulation F’s seven-call threshold and trigger the rebuttable frequency presumption unless a stated exclusion applies. The texts raise the federal opt-out requirement.\n\n**Montana result**\n\nThose numbers and opt-out mechanics are not independently enacted Montana thresholds on the reviewed record. The same pattern could still support an MCPA unfairness theory depending on context.\n\nNo exact calendar is calculated because call dates, conversations, excluded calls, direct consent, and debt count are not supplied.\n\nClaims: C025, C037–C039.\n\n## Example 9 — MCLA late-charge arithmetic\n\n**Assumptions**\n\n- Covered MCLA loan.\n- $200 is past due.\n- Contract permits a late charge.\n- No prior late charge has been imposed on that same past-due amount.\n\nCalculation:\n\n5%×$200=$105\\%\\times \\$200=\\$105%×$200=$10Compare $15 against $10:\n\nmax⁡($15,$10)=$15\\max(\\$15,\\$10)=\\$15max($15,$10)=$15Apply the $50 cap:\n\nmin⁡($15,$50)=$15\\min(\\$15,\\$50)=\\$15min($15,$50)=$15Maximum statutory late charge on those assumptions: **$15**.\n\nSuppose the collector instead charges $55. The excess is:\n\n$55−$15=$40\\$55-\\$15=\\$40$55−$15=$40The statutory double-excess forfeiture is:\n\n2×$40=$802\\times \\$40=\\$802×$40=$80This $80 calculation does not establish the consumer’s complete remedy, attorney fees, offset, or litigation result.\n\nClaims: C018–C020.\n\n## Example 10 — Retail installment delinquency alternatives\n\n**Assumptions**\n\n- Montana retail installment contract.\n- $200 installment is at least ten days late.\n- Contract authorizes the applicable delinquency method.\n\n### Flat method\n\nMaximum flat charge=$10\\text{Maximum flat charge}=\\$10Maximum flat charge=$10### Alternative 15% calculation\n\n15%×$200=$3015\\%\\times \\$200=\\$3015%×$200=$30The holder may use the alternative method if validly adopted; it may not simply stack $10 and $30 into a $40 delinquency fee.\n\nClaims: C012–C014, C022.\n\n## Example 11 — Attorney filing a time-barred collection suit\n\n**Facts**\n\n- Law firm regularly collects consumer debts.\n- It files suit after the applicable limitation expired.\n- It requests admissions implying the debt is enforceable.\n- It seeks attorney fees not authorized by contract or law.\n\n**Result**\n\n*Heintz* makes litigation a covered collection activity; *McCollough* confirms potential FDCPA liability for time-barred litigation, false litigation requests, and unauthorized fees. Whether the claim was actually expired requires the later debt-specific limitations and revival pass.\n\nClaims: C032, C040–C041.\n\n## Example 12 — Repossession at a residence\n\n**Facts**\n\n- Secured creditor has a present right to possession after default.\n- Repossession agent encounters active physical resistance.\n\n**Result**\n\nMontana UCC permits nonjudicial repossession only without breach of the peace. Proceeding through resistance is not approved by the statute. If the agent does no more than enforce the security interest, *Obduskey* limits general FDCPA coverage but preserves §1692f(6); conduct beyond pure enforcement can change the analysis.\n\nClaims: C042–C043.\n\n## Example 13 — Commercial debt\n\n**Facts**\n\n- Corporation owes a vendor $40,000 for business inventory.\n- Individual owner personally guaranteed payment.\n- Collection agency contacts the guarantor.\n\n**Result**\n\nThe underlying transaction remains business-purpose on these facts. Neither the MCLA consumer-loan definition nor the federal FDCPA consumer-debt definition is satisfied merely because the guarantor is a natural person. Contract, guaranty, UCC, MCPA public-enforcement, and general law remain separate.\n\nClaims: C002, C024, C031.\n\n# VIII. PASS-08 source register\n\n| Source ID | Instrument, issuer, literal URL, and pinpoint | Version, status, and access limits |\n| --- | --- | --- |\n| **S_MT-P08-S001** | **Montana Consumer Loan Act**, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html, §32-5-102. Restriction/transfer/voidness/exemptions: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html, §32-5-103. License/renewal: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html, §32-5-201. Fitness: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0020/0320-0050-0020-0020.html, §32-5-202. Discipline: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html, §32-5-207. NMLS: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0090/0320-0050-0020-0090.html, §32-5-209. Fees: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html, §32-5-301. Receipts: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html, §32-5-304. | **Fresh direct official HTML read October 26, 2026.** Published MCA 2025; no PDF page/index. Internet-code disclaimer applies. No comprehensive post-2025 legislative audit. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html) |\n| **S_MT-P08-S002** | Additional MCLA operations and enforcement: records https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html, §32-5-307; advertising https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html, §32-5-309; department powers §§32-5-401–403; cease-and-desist https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0080/0320-0050-0040-0080.html, §32-5-408; public list/complaints https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0090/0320-0050-0040-0090.html, §32-5-409. | **Fresh official HTML read October 26, 2026.** Used only for entry, conduct, records, and bounded discipline; full remedies deferred. [Montana Code Annotated+6](https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html) |\n| **S_MT-P08-S003** | **Servicers of Montana Consumer Loans Memorandum**, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf. Printed pp.1–3, zero-based PDF indices 0–2. | **Fresh official three-page PDF read and visually inspected October 26, 2026. Historical agency memorandum dated February 23, 2016.** It interprets receiving or accepting and retaining/directing payments as servicing. Page 2 contains an apparent obsolete-title typographical reference; current §32-5-103 was read separately. Not a court holding. [Montana Department of Administration+5](https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf) |\n| **S_MT-P08-S004** | **Mortgage and Consumer Finance** and FAQ, Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/; https://doa.mt.gov/BFID/mortgage-consumer-finance/faq. Relevant current sections: Consumer Loan Companies, servicing clarification, fees, branches, employees, physical office, bond, reporting, Sales Finance Companies, public forms. | **Fresh direct official pages read October 26, 2026.** Current operational interpretation, not a substitute for statutes or adjudication. [Montana Department of Administration+1](https://doa.mt.gov/BFID/mortgage-consumer-finance/) |\n| **S_MT-P08-S005** | **NMLS public routes**, State Regulatory Registry/CSBS. Checklist compiler: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx. Consumer Access: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Home.aspx. Universal Company Form version 5.0: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/Shared%20Documents/NMLS%20Company%20%28MU1%29%20Form.pdf, printed pp.1–9/PDF indices 0–8. | **Fresh official route checks October 26, 2026.** Checklist compiler and public verification routes located. No Montana company-specific checklist was generated; no named provider was searched. MU1 is a universal instructional form, not Montana authorization. [Nationwide Licensing System+2](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx?utm_source=chatgpt.com) |\n| **S_MT-P08-S006** | **Current Montana consumer-loan administrative-rule index**, Montana Secretary of State. Chapter route: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9; ARM 2.59.301, .302, .305, .306, .310, .319 routes as identified in the official index. | **Fresh official search rendering October 26, 2026; direct rule-body routes returned HTTP 405.** Search rendering established current titles and selected text, but complete current rule bodies and later rule history were not certified. [Montana Administrative Rules+4](https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9) |\n| **S_MT-P08-S007** | **Bounded general-license checks.** Private-investigator exemption: https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html, §37-60-105. Foreign LLC activities: https://mca.legmt.gov/bills/mca/title_0350/chapter_0080/part_0100/section_0010/0350-0080-0100-0010.html, §35-8-1001. BFID Consumer Information: https://doa.mt.gov/BFID/consumer-info. | **Fresh official HTML and official-domain searches October 26, 2026.** These provisions do not create a general collector license. Absence conclusion remains bounded to public official sources searched. [Montana Code Annotated+2](https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html?utm_source=chatgpt.com) |\n| **S_MT-P08-S008** | **Montana Retail Installment Sales Act**, Montana Legislature. Definitions: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html, §31-1-202. Licensing: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html, §31-1-221. Delinquency: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html, §31-1-235. Statements/receipts: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0360/0310-0010-0020-0360.html, §31-1-236. | **Fresh official HTML read October 26, 2026.** Published MCA 2025; no comprehensive later audit. [Montana Legislature+3](https://leg.mt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html) |\n| **S_MT-P08-S009** | **Retail installment discipline and charge consequence**, https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html, §31-1-203. | **Fresh official HTML read October 26, 2026.** Used only for bounded licensing and charge consequence; full remedies later. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html) |\n| **S_MT-P08-S010** | **Specialized state boundaries.** Deferred deposit https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html, §31-1-722. UCC repossession https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html, §30-9A-609. Ambulance reporting https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html, §30-14-2602. Attorney claim purchase §§37-61-408 and 410. | **Fresh official HTML read October 26, 2026.** Used only for conduct/scope boundaries, not full sector dossiers. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html) |\n| **S_MT-P08-S011** | **Montana Consumer Protection Act**, Montana Legislature. Definitions https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §30-14-102. Unlawful practices .../section_0030/..., §103. Federal interpretation/rules .../section_0040/..., §104. Exemptions .../section_0050/..., §105. | **Fresh official HTML read October 26, 2026.** Used for state conduct boundary; full remedies were assigned separately. [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-P08-S012** | **ARM 23.19.101, Unfair or Deceptive Acts or Practices**, Montana Secretary of State. https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d. | **Fresh official search rendering October 26, 2026; direct body returned HTTP 405.** Selected current clauses were visible in search rendering. Complete body not authenticated. [Montana Administrative Rules+2](https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d) |\n| **S_MT-P08-S013** | **FDCPA definitions and state-law preservation**, U.S. House Office of Law Revision Counsel. Definitions: https://uscode.house.gov/us/usc/119-124/t15/s1692a/, 15 U.S.C. §1692a. State law: https://uscode.house.gov/us/usc/119-124/t15/s1692n/, §1692n. | **Fresh direct official HTML read October 26, 2026.** Text through Public Law 119-124, October 15, 2026. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1692a/) |\n| **S_MT-P08-S014** | **FDCPA communications and conduct**, official U.S. Code. Communications https://uscode.house.gov/us/usc/119-124/t15/s1692c/; harassment .../s1692d/; false representations .../s1692e/; unfair practices .../s1692f/. | **Fresh direct official HTML read October 26, 2026.** Federal rules only; coverage remains model-specific. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1692c/) |\n| **S_MT-P08-S015** | **Regulation F**, CFPB/eCFR. Definitions https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2; communications .../subpart-B/section-1006.6; frequency/harassment .../section-1006.14; unfair practices .../section-1006.22. | **Fresh direct official eCFR read October 26, 2026.** Title 12 displayed through October 22, 2026, last amendment information as displayed. Not Montana law. [eCFR+3](https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2) |\n| **S_MT-P08-S016** | ***Henson v. Santander Consumer USA Inc.*, 582 U.S. 79 (2017)**, U.S. Supreme Court. https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf. Opinion pp.1–5, zero-based PDF indices 0–4. | **Fresh full 13-page official opinion PDF read and relevant pages inspected October 26, 2026.** Holding limited to “owed another” prong; principal-purpose issue expressly not decided. [Supreme Court](https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf) |\n| **S_MT-P08-S017** | ***McAdory v. DNF Associates, LLC*, 952 F.3d 1089 (9th Cir. 2020)**. https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf. Opinion pp.8–11, zero-based PDF indices 7–10. | **Fresh full official Ninth Circuit PDF read and relevant pages inspected October 26, 2026.** Rule 12(b)(6) reversal/remand; no final merits finding about every passive buyer. [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf) |\n| **S_MT-P08-S018** | ***Heintz v. Jenkins*, 514 U.S. 291 (1995)**. https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf. U.S. Reports pp.291–294, zero-based PDF indices 0–3. | **Fresh full nine-page official U.S. Reports PDF read October 26, 2026.** Controlling attorney-litigation boundary. [GovInfo](https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf?ref=hoaweekly.com) |\n| **S_MT-P08-S019** | ***Obduskey v. McCarthy & Holthus LLP*, 586 U.S. 466 (2019)**. https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf. Opinion pp.1–16, zero-based PDF indices 0–15. | **Fresh full 20-page official PDF read October 26, 2026.** Holding limited to entity doing no more than nonjudicial foreclosure. [Supreme Court](https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf) |\n| **S_MT-P08-S020** | ***McCollough v. Johnson, Rodenburg & Lauinger, LLC*, 637 F.3d 939 (9th Cir. 2011)**. https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf. Opinion pp.9–18, zero-based PDF indices 8–17. | **Fresh full official Ninth Circuit PDF read October 26, 2026.** Montana litigation; used only for law-firm and litigation-conduct boundary. [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf) |\n| **S_MT-P08-S021** | ***Jacobson v. Bayview Loan Servicing, LLC*, 2016 MT 101**, Montana Supreme Court. https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520. Relevant opinion pp.16–23, zero-based PDF indices 15–22. | **Fresh full 36-page opinion reproduction read and relevant pages inspected October 26, 2026.** Secondary host of primary judicial opinion; mortgage context. [Justia Law](https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520) |\n| **S_MT-P08-S022** | ***Baird v. Norwest Bank*, 255 Mont. 317, 843 P.2d 327 (1992)**. https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html, especially opinion pp.12–15 as reproduced. | **Fresh full opinion HTML read October 26, 2026.** Secondary host of Montana Supreme Court opinion. MCPA lending/collection holding, not licensing. [Justia Law](https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html) |\n| **S_MT-P08-S023** | **Westgate cease-and-desist order**, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf. Printed pp.1–2, zero-based PDF indices 0–1. | **Fresh official two-page PDF read and visually inspected October 26, 2026. Historical June 12, 2014 party-specific order.** No generalized collector-license holding. [Montana Department of Administration+2](https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf) |\n| **S_MT-P08-S024** | **Consumer complaint route**, Montana DOJ Office of Consumer Protection. https://dojmt.gov/office-of-consumer-protection/consumer-complaints/. | **Fresh official search-rendered operational evidence October 26, 2026.** Complaint route, not licensing proof, legal advice, tolling, or adjudication. [Montana Department of Justice](https://dojmt.gov/office-of-consumer-protection/consumer-complaints/) |\n| **S_MT-P08-S025** | **2025 Senate Bill 377 history**, Montana Legislature. Introduced print and official bill-history route located through the 2025 Legislature site. | **Fresh official search/rendering October 26, 2026.** Bill died in process and is not operative law. Used only to avoid treating a proposed agency reorganization as current. [Montana Legislative Archive+1](https://archive.legmt.gov/) |\n| **S_MT-P08-S026** | **Targeted official-source search log** for Montana collection-agency license, debt-buyer license, state call restrictions, and exact provider orders. | **Fresh bounded searches October 26, 2026.** No general license or comprehensive state mini-FDCPA was located. This is provenance, not independent legal authority and not proof of absolute absence. [Montana Code Annotated+4](https://mca.legmt.gov/bills/2017/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html?utm_source=chatgpt.com) |\n\n# IX. PASS-08 claim register\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, consequence, and confidence |\n| --- | --- | --- | --- |\n| **S_MT-P08-C001** | No generally applicable standalone Montana collection-agency or debt-buyer license was identified in current official public sources. | S004–S007, S026 | **High-confidence bounded search result**, not categorical proof against every activity-specific license. |\n| **S_MT-P08-C002** | MCLA “consumer loan” is personal, family, or household credit to an individual, excluding specified deferred-deposit and residential mortgage loans. | S001 §32-5-102 | **High.** Purpose at origination controls. |\n| **S_MT-P08-C003** | The MCLA’s express licensing prohibition is phrased around making consumer loans for compensation. | S001 §32-5-103(1) | **High.** Servicing conclusion also relies on transfer/collection text and agency interpretation. |\n| **S_MT-P08-C004** | Transferred MCLA loan contracts continue to be governed by the chapter. | S001 §32-5-103(2) | **High.** |\n| **S_MT-P08-C005** | A loan made or collected in violation by an unlicensed, nonexempt person is void and the person has no right to collect or retain principal, interest, fees, or charges. | S001 §32-5-103(4) | **High.** Only for covered MCLA loans and established violation. |\n| **S_MT-P08-C006** | Banks, specified depositories, credit unions, and the narrow fewer-than-four-own-fund lender are exempt from MCLA licensing. | S001 §32-5-103(5) | **High; statutory conditions required.** |\n| **S_MT-P08-C007** | BFID interprets receiving or accepting MCLA payments and retaining or directing them as servicing requiring a license. | S003 pp.1–3; S004 | **High for current agency position; not appellate construction.** |\n| **S_MT-P08-C008** | BFID says its servicing interpretation applies only to MCLA-originated loans, not bank- or credit-union-originated loans. | S004 | **High for agency guidance.** Other laws remain applicable. |\n| **S_MT-P08-C009** | BFID says utilities, service providers such as doctors/hospitals, and estates are outside the MCLA. | S004 | **High for agency interpretation.** Not a generic MCPA/FDCPA exemption. |\n| **S_MT-P08-C010** | A debt buyer’s ownership alone does not resolve Montana licensing; origin, contract type, and payment/control activity matter. | S001, S003–S004, S008 | **High analytical boundary.** |\n| **S_MT-P08-C011** | A business purchasing Montana retail installment contracts generally needs a Sales Finance License, subject to statutory exemptions and isolated-purchase boundary. | S008 §§202, 221 | **High.** |\n| **S_MT-P08-C012** | Sales Finance License fee is $100 per principal/branch, expires December 31, and does not require a Montana physical office. | S008 §221; S004 | **High.** |\n| **S_MT-P08-C013** | The Retail Installment Sales Act allows either a $10 delinquency charge or an alternative fixed charge calculated at no more than 15% of the defaulted installment after at least ten days. | S008 §235 | **High.** Methods are alternatives. |\n| **S_MT-P08-C014** | Retail installment holders have statement, cash-receipt, payoff acknowledgment, and security-release duties. | S008 §236 | **High.** |\n| **S_MT-P08-C015** | Each MCLA business location requires a license; licenses are nontransferable and expire December 31. | S001 §201 | **High.** |\n| **S_MT-P08-C016** | Consumer Loan initial and renewal fees are $500 per entity or branch license. | S001 §201; S004 | **High.** |\n| **S_MT-P08-C017** | BFID licenses Consumer Loan entities and branches, not individual employees, and does not require a Montana physical office. | S004 FAQ | **High for operational guidance.** |\n| **S_MT-P08-C018** | BFID states no bond is required for a Consumer Loan License. | S004 FAQ | **High for current operational requirement; current NMLS checklist still should be checked.** |\n| **S_MT-P08-C019** | Consumer Loan licenses and Sales Finance licenses are applied for and publicly verified through NMLS. | S004–S005 | **High.** No named entity was checked. |\n| **S_MT-P08-C020** | Montana does not issue a paper Consumer Loan license and does not require display; proof is electronic through NMLS. | S004 FAQ | **High.** |\n| **S_MT-P08-C021** | Consumer Loan applicants are subject to statutory character/fitness, licensing-history, judgment, and application-accuracy criteria. | S001 §202 | **High.** |\n| **S_MT-P08-C022** | BFID may impose up to $1,000 per established MCLA violation, restitution, costs, and license/right suspension or revocation after the statutory process. | S001 §207 | **High.** Full remedies deferred. |\n| **S_MT-P08-C023** | MCLA late and deferral charges use the greater of $15 or 5%, capped at $50, and the same past-due amount may receive only one late fee. | S001 §301(3)–(4) | **High.** Contract authorization required. |\n| **S_MT-P08-C024** | MCLA prohibits unauthorized additional fees and requires forfeiture of twice the excess amount. | S001 §301(6) | **High.** Complete remedy treatment deferred. |\n| **S_MT-P08-C025** | MCLA requires cash receipts, reliable payment records, and payoff/satisfaction action within ten days after full repayment. | S001 §304 | **High.** |\n| **S_MT-P08-C026** | MCLA prohibits false or misleading advertising about rates, terms, or conditions. | S002 §309 | **High.** |\n| **S_MT-P08-C027** | Montana’s MCPA applies to collection of consumer loans, including original-creditor bank collection. | S011; S022 | **High.** *Baird* is not a licensing case. |\n| **S_MT-P08-C028** | The MCPA regulated-activity exemption is not a blanket exemption for banks, attorneys, nonprofits, collectors, or licensees. | S011 §105 | **High textual boundary.** |\n| **S_MT-P08-C029** | No general Montana statutory 8 a.m.–9 p.m. collection-contact window was located. | S001–S012, S026 | **Qualified negative.** Federal law may apply. |\n| **S_MT-P08-C030** | No general Montana numeric call-frequency rule equivalent to Regulation F’s seven-in-seven presumptions was located. | S001–S012, S026 | **Qualified negative.** |\n| **S_MT-P08-C031** | No general Montana collector electronic-message opt-out rule equivalent to Regulation F was located. | S001–S012, S026 | **Qualified negative.** |\n| **S_MT-P08-C032** | FDCPA debt is limited to personal, family, or household obligations. | S013 §1692a(5) | **High.** Business debt excluded. |\n| **S_MT-P08-C033** | FDCPA debt collector includes principal-purpose collectors and persons regularly collecting debts owed another. | S013 §1692a(6) | **High.** Independent prongs. |\n| **S_MT-P08-C034** | A creditor collecting its own debt under a name suggesting a third party can be a federal debt collector. | S013 §1692a(6) | **High.** Actual name presentation required. |\n| **S_MT-P08-C035** | Creditor employees collecting in the creditor’s name are generally excluded federally; the affiliate exclusion is narrower and conditional. | S013 §1692a(6)(A)–(B) | **High.** |\n| **S_MT-P08-C036** | Government officers, process servers, and specified fiduciary/originator/pre-default acquisition activities have federal exclusions. | S013 §1692a(6) | **High; exact conditions required.** |\n| **S_MT-P08-C037** | *Henson* excludes an owner collecting purchased debt from the “owed another” prong but does not decide principal-purpose coverage. | S016 | **High controlling holding.** |\n| **S_MT-P08-C038** | *McAdory* allows principal-purpose coverage of a passive debt buyer that outsources direct collection. | S017 | **High Ninth Circuit pleading-stage holding.** |\n| **S_MT-P08-C039** | Attorneys regularly collecting consumer debts through litigation are federally covered under *Heintz*. | S018 | **High controlling holding.** |\n| **S_MT-P08-C040** | An entity doing no more than nonjudicial security-interest enforcement is generally covered only for §1692f(6), under *Obduskey*. | S019 | **High, limited to pure enforcement activity.** |\n| **S_MT-P08-C041** | The FDCPA restricts inconvenient, workplace, represented-consumer, third-party, and post-cease communications for covered collectors. | S014 §1692c | **High, conditional on federal coverage.** |\n| **S_MT-P08-C042** | FDCPA prohibits harassment, repeated calls with prohibited intent, false legal/credit threats, false identity or status, and unauthorized amounts. | S014 §§1692d–f | **High, conditional.** |\n| **S_MT-P08-C043** | Regulation F creates rebuttable telephone-frequency presumptions and electronic opt-out requirements; those are not independently Montana rules. | S015 §§1006.6, .14, .22 | **High.** |\n| **S_MT-P08-C044** | FDCPA preserves noninconsistent state law, including more protective state rules. | S013 §1692n | **High.** |\n| **S_MT-P08-C045** | *McCollough* confirms that collection litigation, time-barred suits, false discovery requests, and unauthorized fee claims can fall within the FDCPA. | S020 | **High; debt-specific limitations deferred.** |\n| **S_MT-P08-C046** | *Jacobson* applies federal collection and Montana consumer-protection principles to misleading mortgage servicing/foreclosure communications and represented-party contact. | S021 | **High for that mortgage context.** |\n| **S_MT-P08-C047** | UCC self-help repossession is permitted only without breach of the peace. | S010 §30-9A-609 | **High.** |\n| **S_MT-P08-C048** | Deferred-deposit collectors are limited by the $30 one-time returned-check fee and may not collect the identified bad-check statutory damages. | S010 §31-1-722 | **High; covered account required.** |\n| **S_MT-P08-C049** | Certain transferred ambulance bills carry a Montana no-delinquent-reporting instruction to the collection agency. | S010 §30-14-2602 | **High; full reporting rules deferred.** |\n| **S_MT-P08-C050** | An attorney may not buy a claim with intent and purpose to sue on it, subject to statutory exceptions. | S010 §§37-61-408, 410 | **High.** |\n| **S_MT-P08-C051** | The current official consumer-loan ARM index was located, but direct bodies failed; complete current rule certification remains incomplete. | S006 | **High provenance statement.** |\n| **S_MT-P08-C052** | 2025 SB 377 did not become law; current BFID remains within the Department of Administration on reviewed current sources. | S004, S025 | **High current-status conclusion.** |\n| **S_MT-P08-C053** | A Montana license or absence of one does not by itself establish FDCPA coverage, MCPA liability, debt validity, or a private remedy. | S001–S015 | **High structural boundary.** |\n| **S_MT-P08-C054** | Actual license status must be checked entity-by-entity and license-type-by-license-type through NMLS; no provider was approved here. | S005 | **High methodological conclusion.** |\n\n# X. Component coverage and gap table\n\n| Assigned component | Status | Claim IDs | Exact remaining evidence or next action |\n| --- | --- | --- | --- |\n| General collection-agency license | Bounded answered: none identified | C001 | Monitor later legislation/rules; check specialized activity before relying on absence. |\n| General debt-buyer license | Bounded answered: none identified | C001, C010 | Apply MCLA, Sales Finance, mortgage, telemarketing, and sector regimes to actual model. |\n| MCLA personal-purpose scope | Answered | C002 | Obtain original loan purpose and documents. |\n| Commercial-debt exclusion from MCLA | Answered textually | C002 | Mixed-purpose and guaranty issues remain fact-specific. |\n| MCLA lender license | Answered | C003, C006 | Verify actual exemption and NMLS status. |\n| MCLA servicer license | Answered as agency interpretation | C004–C008 | Controlling appellate interpretation remains absent. |\n| MCLA transferred-loan coverage | Answered | C004 | Trace assignment and original statutory status. |\n| MCLA unlicensed-collection voidness | Answered textually | C005 | Full private remedy, limitations, restitution, and defensive-use analysis later. |\n| Bank/credit-union exemption | Answered | C006, C008 | Confirm actual charter and origination. |\n| Utility/medical/estate MCLA boundary | Answered as BFID guidance | C009 | Other state and federal rules remain. |\n| Original creditor own-name | Answered in core | C003, C027, C035 | Actual creditor identity and account type. |\n| Original creditor other-name FDCPA route | Answered | C034 | Consumer-perception and DBA facts. |\n| Third-party contingency agency | Partial | C001, C032–C036 | Debt purpose, clients, volume, and any activity-specific license. |\n| Debt buyer of MCLA loan | Partial | C004–C010 | Ownership, servicing activity, payment control, and license. |\n| Passive debt buyer | Partial | C010, C037–C038 | Principal-purpose facts and state activity. |\n| Retail installment purchaser | Answered in core | C011–C014 | Contract characterization, acquisition frequency, exemption, and license status. |\n| Mortgage buyer/servicer | Excluded | — | Separate Montana Mortgage Act pass. |\n| Attorney collector | Answered in core | C039, C045, C050 | Actual regularity, debt purpose, claim purchase, and litigation conduct. |\n| Litigation-only attorney | Partial | C039–C040, C045 | Security-enforcement versus money-collection activity. |\n| Affiliate collector | Partial | C035 | Ownership/control, clients, principal business, and names. |\n| Employee collector | Answered in core | C017, C035 | Employer license and own-name status. |\n| Nonprofit collector | Partial | C001, C036 | Actual services and narrow federal nonprofit DMP exclusion. |\n| Out-of-state/remote collector | Answered in part | C007, C015–C017 | Exact location/branch activity and account nexus. |\n| Digital-only collector | Partial | C017, C031, C043 | Location, electronic contacts, branch activity, and federal coverage. |\n| Government collector | Answered federally | C036 | State/public-debt authority outside scope. |\n| Commercial collector | Answered as consumer-law boundary | C002, C032 | General contract, tort, licensing, and commercial collection law later. |\n| Consumer Loan application | Route answered | C015–C021 | Generate and inspect current entity-specific NMLS checklist when needed. |\n| Consumer Loan fee | Answered | C016 | NMLS system charges, if any, remain checklist-specific. |\n| Consumer Loan renewal/expiry | Answered in core | C015–C016 | Current late-renewal/reinstatement mechanics from checklist. |\n| Consumer Loan bond | Answered operationally as none | C018 | Recheck current NMLS checklist before application. |\n| Consumer Loan qualifying persons | Partial | C021 | NMLS control-person forms and current checklist. |\n| Consumer Loan branches | Answered in core | C015–C017 | Remote-worker/location interpretation requires actual facts. |\n| Employee individual license | Answered as none | C017 | Other professional licenses may apply. |\n| Sales Finance application and fee | Answered in core | C011–C012 | Current generated NMLS checklist. |\n| Public license lookup | Answered | C019–C020, C054 | No named provider checked. |\n| Paper/display license | Answered as none | C020 | Advertising/name duties still apply. |\n| BFID complaint route | Partial | C022 | Actual complaint procedure and SES materials entity-specific. |\n| OCP complaint route | Answered operationally | — | Not a license lookup or adjudication. |\n| MCLA interest and late charges | Answered | C023–C024 | Actual contract, balance, prior fee, and voluntary-service facts. |\n| MCLA receipts/payoff | Answered | C025 | Actual payment method and payoff date. |\n| MCLA advertising | Answered | C026 | Complete current rule body inaccessible. |\n| Retail installment late charges | Answered | C013 | Actual contractual method and default date. |\n| Retail installment statements/receipts | Answered | C014 | Actual written request and payment facts. |\n| MCPA application to original creditors | Answered | C027–C028 | Full standing/remedy analysis retained in separate pass. |\n| State call-time rule | No general rule identified | C029 | Monitor later statute/rule; federal coverage separately. |\n| State call-frequency rule | No general rule identified | C030 | Same. |\n| State workplace-contact rule | No general rule identified | C029–C031 | MCPA and federal fact-specific analysis. |\n| State represented-consumer rule | No general rule identified | C029–C031 | *Jacobson* federal/MCPA application does not create universal statute. |\n| State third-party-contact rule | No general rule identified | C029–C031 | Privacy and federal law later. |\n| State cease-contact rule | No general rule identified | C029–C031 | Federal written-notice rule if covered. |\n| State electronic opt-out | No general rule identified | C031 | Regulation F if covered. |\n| Harassment/abuse | Partial state MCPA plus federal | C027–C028, C042–C043 | Actual conduct and private standing. |\n| False creditor/owner identity | Answered in principle | C026–C028, C042, C046 | Assignment proof and materiality. |\n| False legal or credit threat | Answered in principle | C027–C028, C042 | Actual authority, intent, and federal coverage. |\n| Unauthorized fees | Answered for selected account types | C013, C023–C024, C042, C048 | Contract and debt-type classification. |\n| Payment allocation | Unresolved in this pass | — | Later documentation/account pass and any applicable federal rule. |\n| Payment receipts | Answered for MCLA/retail installment | C014, C025 | Other debt types remain. |\n| Repossession | Answered at UCC boundary | C040, C047 | Notice, sale, deficiency, breach-of-peace cases later. |\n| Bankruptcy contact | Excluded | — | Federal stay/discharge pass. |\n| Deceased debtor contact | Partial federal definition only | C041 | Probate, estate, and actual representative later. |\n| Ambulance reporting | Partial boundary | C049 | Full credit-reporting/furnishing pass. |\n| FDCPA definitions/exclusions | Answered at gateway level | C032–C036 | Full federal protocol later. |\n| Debt-buyer federal coverage | Answered at gateway level | C037–C038 | Actual principal-purpose and portfolio facts. |\n| Attorney federal coverage | Answered | C039, C045 | Actual regularity and claim. |\n| Security-interest federal coverage | Answered | C040 | Conduct beyond pure enforcement. |\n| Federal communications | Answered only at gateway level | C041–C043 | Full validation, call logs, consent, and exceptions later. |\n| Regulation F electronic rules | Answered at gateway level | C043 | Full safe-harbor protocol later. |\n| FDCPA preemption/preservation | Answered | C044 | Specific conflict analysis if state rule identified. |\n| Validation notice/documentation | Excluded | — | Dedicated later pass. |\n| Dispute handling | Excluded except general conduct | — | Dedicated validation/documentation pass. |\n| Account-level ownership proof | Excluded | — | Dedicated documentation/litigation pass. |\n| Credit reporting/furnishing | Excluded except ambulance crossover | C049 | Dedicated reporting pass. |\n| Debt-specific limitations/revival | Excluded | C045 only as case boundary | Dedicated limitations pass. |\n| Collection suit/service/default judgment | Excluded except attorney gateway | C039, C045 | Dedicated litigation pass. |\n| Garnishment/execution | Excluded | — | Dedicated remedies/litigation pass. |\n| Full collector remedies/private rights | Excluded | C022–C024, C053 only as boundaries | Dedicated remedies pass. |\n| Local and tribal law | Excluded | — | Separate jurisdictional passes. |\n| Current complete ARM text | Unresolved | C051 | Authenticated current body or certified export. |\n| Post-2025 legislative currentness | Partial | C052 | Comprehensive later session/special-session and future-effective audit. |\n| Actual provider authorization | Unresolved/excluded | C054 | Official entity-specific NMLS check only when provider named. |\n\n# XI. Researcher self-check\n\n## Freshly read or directly inspected on October 26, 2026\n\n- Current published 2025 Montana Consumer Loan Act sections covering definitions, licensing, transfer, voidness, fees, receipts, records, advertising, examinations, complaints, cease-and-desist, and bounded discipline.\n- Current BFID Consumer Loan, Sales Finance, and FAQ pages.\n- The complete three-page BFID 2016 consumer-loan-servicer memorandum.\n- Montana Retail Installment Sales Act definitions, licensing, delinquency charges, statements, receipts, and bounded discipline.\n- Montana Consumer Protection Act definitions, prohibited-practice, interpretation, and exemption sections.\n- Deferred-deposit, UCC repossession, ambulance-reporting, private-investigator, foreign-LLC, and attorney-claim-purchase provisions.\n- Current U.S. Code FDCPA definitions, communications, conduct, and state-law-preservation sections.\n- Current eCFR Regulation F definitions and relevant communication, frequency, and unfair-practice provisions.\n- The complete opinions in *Henson*, *McAdory*, *Heintz*, *Obduskey*, *McCollough*, *Jacobson*, and *Baird*.\n- The two-page historical Westgate cease-and-desist order.\n- Current NMLS public checklist and Consumer Access routes.\n\n## Fresh but access-limited\n\n- Current official Montana consumer-loan administrative-rule index and selected official search renderings were available, but direct rule-body routes returned HTTP 405.\n- The current official ARM 23.19.101 search rendering was available, but its direct body also returned HTTP 405.\n- The NMLS checklist compiler was located, but no company-specific Montana checklist was generated.\n- The OCP complaint route was search-rendered; it was not treated as licensing or adjudicative evidence.\n\n## Bounded negative searches\n\nOfficial-source searches did not identify:\n\n- A current general Montana Collection Agency License.\n- A current general Montana Debt Buyer License.\n- A comprehensive Montana mini-FDCPA.\n- A general Montana collection-call time or frequency statute.\n- A general Montana represented-consumer, third-party, cease-contact, or electronic-opt-out collection rule.\n- A controlling Montana appellate interpretation of BFID’s servicing memorandum.\n- A comprehensive public Montana debt-buyer enforcement-order archive.\n\nThose search results do not prove that no unpublished order, district-court decision, internal interpretation, special sector rule, local rule, tribal rule, or later enactment exists.\n\n## Not read or resolved\n\n- Any actual collector’s or buyer’s NMLS record.\n- Any private servicing, purchase, placement, payment-processing, or collection agreement.\n- Any actual call logs, texts, emails, letters, validation notices, dispute records, credit reports, or furnishing records.\n- Complete current Montana ARM bodies and all rulemaking history.\n- A complete paid citator, every Montana trial docket, or every BFID/DOJ administrative file.\n- Full validation, documentation, reporting, limitations, revival, litigation, judgment, garnishment, bankruptcy, probate, local, tribal, or sector analysis.\n- Full private-remedy and limitation treatment for Consumer Loan Act or Retail Installment Sales Act violations.\n- P4, P6, or P7 as accepted premises; necessary statutes were independently read for this pass.\n\nExact individual source-fetch timestamps were not exposed and are not invented. No provider lookup, application, filing, complaint, regulator contact, purchase, account change, private-data access, Chrome control, other-chat access, local-file write, license approval, operational approval, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.\n\n**REPORT PARTIAL — the focused Montana collection licensing/classification and state-specific conduct component is completed to the source and scope limits stated above. Detailed documentation, validation, reporting, litigation, limitations, remedies, local, tribal, and sector work remains required.**\n\nEND S_MT PASS-08\n\n","tables":[{"headers":["Model","Montana licensing result","Federal FDCPA boundary","Evidence that must be retained or checked"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model","Montana licensing result","Federal FDCPA boundary","Evidence that must be retained or checked"],["Nonbank original lender making and collecting its own Montana Consumer Loan Act loans","Consumer Loan License required unless an express exemption applies","Usually creditor, not FDCPA debt collector, when collecting in own name","Loan purpose, originator identity, original license, NMLS record, loan date, payment history"],["Bank or credit union collecting its own originated loan","Exempt from Montana Consumer Loan Act license","Usually original-creditor exclusion if using own name","Charter/depository status, account origin, collector identity, DBA"],["Nonbank original creditor using a different name suggesting a third party","Montana activity-specific license still depends on debt type","FDCPA can include creditor collecting own debt under another name suggesting third-party collection","Call scripts, letterhead, domains, caller ID, legal names, DBAs"],["Ordinary third-party contingency agency collecting a medical, utility, or trade debt","No general Montana collection-agency license identified; other activity-specific law may apply","Usually FDCPA debt collector if regularly collecting another’s consumer debts","Debt purpose, creditor type, agency agreement, collector role, communication logs"],["Servicer receiving payments on a Montana Consumer Loan Act loan","BFID says Consumer Loan License required","FDCPA depends partly on when debt was acquired and principal purpose","Originating license, transfer history, default date, servicing agreement, payment-routing authority"],["Servicer of a bank-originated consumer loan","BFID says the 2016 MCLA memo does not apply to bank-originated loans","May be excluded federally if obtained before default; otherwise fact-dependent","Bank origin, acquisition/default timing, servicing contract, federal status"],["Buyer of Montana Consumer Loan Act loan that collects or directs payments","Strong license trigger under continuing-governance text and BFID servicing interpretation","Ownership does not preclude principal-purpose FDCPA coverage","Loan-origin proof, assignment chain, money flow, NMLS license"],["Passive buyer of defaulted bank credit-card accounts using outside agencies","No Montana Consumer Loan Act license established solely by ownership; no generic debt-buyer license found","Can qualify under principal-purpose prong under McAdory","Revenue model, portfolio composition, collection contracts, acquisition/default status"],["Business purchasing Montana retail installment contracts","Sales Finance License generally required unless exempt/isolated","FDCPA depends on purpose, default status, and collection model","Contract type, Montana formation, acquisition frequency, NMLS sales-finance record"],["Seller retaining its own retail installment contracts","Sales-finance purchaser license may not apply to the original seller merely as seller; substantive Retail Installment Sales Act still applies","Usually original creditor federally","Seller identity, contract, assignment status"],["Attorney or law firm regularly collecting consumer debts through litigation","No general Montana collection-agency license located solely because it litigates; bar/professional rules remain","FDCPA applies to attorneys regularly collecting through litigation","Engagement, volume, pleadings, debt purpose, claim ownership, bar status"],["Attorney buying claims for the purpose of filing suit","Montana professional statute prohibits buying a claim with intent and purpose of bringing an action, subject to specified exceptions","Federal coverage separately analyzed","Purchase documents, intent, prior services or antecedent debt, litigation plan"],["Affiliate collecting for related creditor","No broad Montana affiliate exemption identified; activity-specific license may apply","Narrow FDCPA affiliate exclusion requires common ownership/control, collection only for affiliates, and no principal collection business","Ownership chart, clients, revenues, shared names, collection scope"],["Employee collecting solely for own creditor-employer","Employees do not receive individual Montana consumer-loan licenses; entity/branch licensing controls","Creditor employee generally excluded federally when collecting in creditor’s name","Employment relationship, employer identity, scripts, location"],["Nonprofit collection operation","No general Montana nonprofit exemption from collection/activity-specific licensing","Federal nonprofit DMP exclusion is narrow and not a generic nonprofit-collector exemption","Legal status, actual services, compensation, clients, collection purpose"],["Out-of-state digital agency with Montana accounts","No Montana physical office required for Consumer Loan license; nexus follows covered Montana activity, not headquarters","FDCPA applies to covered interstate collection","Consumer residence, loan origin, remote location, branch activity, NMLS records"],["Repossession company enforcing security interest only","No generic collector license identified; UCC and professional/business rules apply","Limited-purpose debt collector for §1692f(6) when doing no more than security-interest enforcement","Contract, right to possession, default, instructions, conduct at repossession"],["Government officer collecting in official capacity","No general private collection license","Federal statutory exclusion for government officer performing official duties","Agency authority and employment"],["Commercial-debt collector","MCLA and Retail Installment consumer provisions generally do not apply merely because debtor is in Montana","FDCPA excludes business-purpose debt","Contract purpose, entity borrower, use of proceeds"],["Mortgage owner or servicer","Separate Montana Mortgage Act licensing analysis; not resolved here","Federal mortgage-servicing and FDCPA status are default- and activity-dependent","Mortgage type, servicing rights, default/acquisition timing, mortgage license"]]},{"headers":["Conduct or event","Montana state rule located","Covered actor or debt","Federal overlay, if applicable","Remaining hold"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Conduct or event","Montana state rule located","Covered actor or debt","Federal overlay, if applicable","Remaining hold"],["Calls before 8 a.m. or after 9 p.m.","No general Montana debt-collection time window located","—","FDCPA/Reg F presumption for federally covered collectors","Actual federal coverage and consumer location"],["Known inconvenient time or place","MCPA can reach unfair conduct, but no collection-specific Montana test located","Any covered consumer transaction under MCPA","FDCPA/Reg F explicit restriction","Specific notice and collector knowledge"],["Workplace contact","No general Montana workplace-contact prohibition located","—","FDCPA prohibits known/prohibited employer contact in covered cases","Employer rule and collector knowledge"],["Contact with represented consumer","No general Montana collection statute located","MCPA may reach deceptive or oppressive conduct","FDCPA restriction applies to covered collector with attorney knowledge and accessible attorney information","Exact notice and representation scope"],["Third-party disclosure","No general Montana mini-FDCPA provision located","Other privacy law may apply","FDCPA generally limits communications to third parties","Identity of contact, purpose, consent"],["Repeated calls","No state numeric cap located","MCPA potentially applies to oppressive conduct","Reg F seven-in-seven and post-conversation presumptions; FDCPA intent-to-harass rule","Debt count, connected calls, exceptions"],["Obscene, threatening, or abusive language","MCPA potentially reaches unfair conduct","Consumer trade/commerce","FDCPA expressly prohibits violence, obscenity, harassment","Exact words and actor status"],["Threat of arrest or criminal action","MCPA deceptive-practice route","Consumer transaction","FDCPA false-threat and misrepresentation provisions","Truth, legal authority, intent"],["False threat to sue, garnish, seize, or report","MCPA and loan-advertising rules may apply","Consumer transaction; specific loan laws","FDCPA expressly addresses unlawful or unintended legal/credit consequences","Legal right, intent, applicable procedure"],["False creditor or owner identity","MCPA prohibits deceptive conduct","Original creditor, servicer, buyer, collector","FDCPA false-representation provisions","Assignment evidence and materiality"],["Failure to state collector identity on call","No general Montana call-opening formula located","—","FDCPA prohibits failure to disclose caller identity where applicable","Federal status and communication purpose"],["Business legal name/address in advertising","ARM search rendering and MCPA support identity transparency","Advertising in trade/commerce","Federal law may add collector identification","Complete current official ARM body inaccessible"],["Written cease request","No general Montana cease-contact rule located","—","FDCPA restricts further communication after qualifying written notice, subject to three exceptions","Receipt, address, communication type"],["Electronic-message opt-out","No Montana-specific general opt-out rule located","—","Reg F requires simple electronic opt-out in covered messages","Federal status and message type"],["Social-media contact","No general Montana debt-specific rule located","MCPA/privacy law potentially relevant","Reg F restricts public-viewable messages and requires private-message opt-out","Platform settings and content"],["Unauthorized fee or interest","MCLA, Retail Installment, Deferred Deposit, contract, and MCPA provisions","Depends on account origin/type","FDCPA prohibits amounts not authorized by agreement or law","Contract, originating statute, assignment"],["Payment receipt","MCLA requires receipt for cash and records; retail installment statute has receipt duties","Covered licensee or holder","Federal law may add periodic/validation duties","Payment method and account type"],["Payment allocation","No general Montana debt-collection allocation rule established in this pass","Loan-specific contracts may control","Federal law can impose allocation duties in specified multiple-debt situations, deferred to later pass","Multiple accounts and consumer instruction"],["Payoff/release","MCLA and Retail Installment Sales Act impose account-specific duties","Covered loan/contract holder","Other law may apply to mortgages and security interests","Debt type and full-payment date"],["Repossession","UCC prohibits nonjudicial repossession involving breach of peace","Secured party and agent","FDCPA §1692f(6) may apply to security-interest enforcer","Default, right to possession, conduct"],["Contact after bankruptcy filing","No complete state bankruptcy-contact rule analyzed","—","Federal automatic stay/discharge law controls; later pass","Filing, notice, debt type, stay status"],["Deceased consumer","No general Montana collection-contact rule located","Estate and probate law potentially controls","FDCPA defines “consumer” broadly for §1692c to include executor/administrator","Appointment and communication target"],["Commercial debt","Consumer-specific Montana and federal statutes generally inapplicable","Business-purpose obligation","FDCPA does not cover business debt","Purpose at origination, guarantor status"],["Credit reporting of covered ambulance bill","Specific Montana prohibition route","Specified ambulance account and agency","FCRA/Reg V later","Account qualification and furnishing event"]]},{"headers":["Source ID","Instrument, issuer, literal URL, and pinpoint","Version, status, and access limits"],"index":2,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html","text":"Montana Code Annotated\n+4"},{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html","text":"Montana Code Annotated\n+6"},{"href":"https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf","text":"Montana Department of Administration\n+5"},{"href":"https://doa.mt.gov/BFID/mortgage-consumer-finance/","text":"Montana Department of Administration\n+1"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx?utm_source=chatgpt.com","text":"Nationwide Licensing System\n+2"},{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9","text":"Montana Administrative Rules\n+4"},{"href":"https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html?utm_source=chatgpt.com","text":"Montana Code Annotated\n+2"},{"href":"https://leg.mt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html","text":"Montana Legislature\n+3"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html","text":"Montana Code Annotated\n+4"},{"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://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d","text":"Montana Administrative Rules\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692a/","text":"U.S. Code\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692c/","text":"U.S. Code\n+3"},{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2","text":"eCFR\n+3"},{"href":"https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf","text":"Supreme Court"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf","text":"Ninth Circuit Court of Appeals"},{"href":"https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf?ref=hoaweekly.com","text":"GovInfo"},{"href":"https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf","text":"Supreme Court"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf","text":"Ninth Circuit Court of Appeals"},{"href":"https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html","text":"Justia Law"},{"href":"https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf","text":"Montana Department of Administration\n+2"},{"href":"https://dojmt.gov/office-of-consumer-protection/consumer-complaints/","text":"Montana Department of Justice"},{"href":"https://archive.legmt.gov/","text":"Montana Legislative Archive\n+1"},{"href":"https://mca.legmt.gov/bills/2017/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html?utm_source=chatgpt.com","text":"Montana Code Annotated\n+4"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html","text":"Montana Code Annotated\n+4"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html","text":"Montana Code Annotated\n+6"}],[{"href":"https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf","text":"Montana Department of Administration\n+5"}],[{"href":"https://doa.mt.gov/BFID/mortgage-consumer-finance/","text":"Montana Department of Administration\n+1"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx?utm_source=chatgpt.com","text":"Nationwide Licensing System\n+2"}],[{"href":"https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9","text":"Montana Administrative Rules\n+4"}],[{"href":"https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html?utm_source=chatgpt.com","text":"Montana Code Annotated\n+2"}],[{"href":"https://leg.mt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html","text":"Montana Legislature\n+3"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html","text":"Montana Code Annotated\n+4"}],[{"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://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d","text":"Montana Administrative Rules\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692a/","text":"U.S. Code\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692c/","text":"U.S. Code\n+3"}],[{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2","text":"eCFR\n+3"}],[{"href":"https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf","text":"Supreme Court"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf","text":"Ninth Circuit Court of Appeals"}],[{"href":"https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf?ref=hoaweekly.com","text":"GovInfo"}],[{"href":"https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf","text":"Supreme Court"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf","text":"Ninth Circuit Court of Appeals"}],[{"href":"https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html","text":"Justia Law"}],[{"href":"https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf","text":"Montana Department of Administration\n+2"}],[{"href":"https://dojmt.gov/office-of-consumer-protection/consumer-complaints/","text":"Montana Department of Justice"}],[{"href":"https://archive.legmt.gov/","text":"Montana Legislative Archive\n+1"}],[{"href":"https://mca.legmt.gov/bills/2017/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html?utm_source=chatgpt.com","text":"Montana Code Annotated\n+4"}]],"rows":[["Source ID","Instrument, issuer, literal URL, and pinpoint","Version, status, and access limits"],["S_MT-P08-S001","Montana Consumer Loan Act, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html, §32-5-102. Restriction/transfer/voidness/exemptions: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html, §32-5-103. License/renewal: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html, §32-5-201. Fitness: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0020/0320-0050-0020-0020.html, §32-5-202. Discipline: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html, §32-5-207. NMLS: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0090/0320-0050-0020-0090.html, §32-5-209. Fees: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html, §32-5-301. Receipts: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html, §32-5-304.","Fresh direct official HTML read October 26, 2026. Published MCA 2025; no PDF page/index. Internet-code disclaimer applies. No comprehensive post-2025 legislative audit. \nMontana Code Annotated\n+4"],["S_MT-P08-S002","Additional MCLA operations and enforcement: records https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html, §32-5-307; advertising https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html, §32-5-309; department powers §§32-5-401–403; cease-and-desist https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0080/0320-0050-0040-0080.html, §32-5-408; public list/complaints https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0090/0320-0050-0040-0090.html, §32-5-409.","Fresh official HTML read October 26, 2026. Used only for entry, conduct, records, and bounded discipline; full remedies deferred. \nMontana Code Annotated\n+6"],["S_MT-P08-S003","Servicers of Montana Consumer Loans Memorandum, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf. Printed pp.1–3, zero-based PDF indices 0–2.","Fresh official three-page PDF read and visually inspected October 26, 2026. Historical agency memorandum dated February 23, 2016. It interprets receiving or accepting and retaining/directing payments as servicing. Page 2 contains an apparent obsolete-title typographical reference; current §32-5-103 was read separately. Not a court holding. \nMontana Department of Administration\n+5"],["S_MT-P08-S004","Mortgage and Consumer Finance and FAQ, Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/; https://doa.mt.gov/BFID/mortgage-consumer-finance/faq. Relevant current sections: Consumer Loan Companies, servicing clarification, fees, branches, employees, physical office, bond, reporting, Sales Finance Companies, public forms.","Fresh direct official pages read October 26, 2026. Current operational interpretation, not a substitute for statutes or adjudication. \nMontana Department of Administration\n+1"],["S_MT-P08-S005","NMLS public routes, State Regulatory Registry/CSBS. Checklist compiler: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx. Consumer Access: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Home.aspx. Universal Company Form version 5.0: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/Shared%20Documents/NMLS%20Company%20%28MU1%29%20Form.pdf, printed pp.1–9/PDF indices 0–8.","Fresh official route checks October 26, 2026. Checklist compiler and public verification routes located. No Montana company-specific checklist was generated; no named provider was searched. MU1 is a universal instructional form, not Montana authorization. \nNationwide Licensing System\n+2"],["S_MT-P08-S006","Current Montana consumer-loan administrative-rule index, Montana Secretary of State. Chapter route: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9; ARM 2.59.301, .302, .305, .306, .310, .319 routes as identified in the official index.","Fresh official search rendering October 26, 2026; direct rule-body routes returned HTTP 405. Search rendering established current titles and selected text, but complete current rule bodies and later rule history were not certified. \nMontana Administrative Rules\n+4"],["S_MT-P08-S007","Bounded general-license checks. Private-investigator exemption: https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html, §37-60-105. Foreign LLC activities: https://mca.legmt.gov/bills/mca/title_0350/chapter_0080/part_0100/section_0010/0350-0080-0100-0010.html, §35-8-1001. BFID Consumer Information: https://doa.mt.gov/BFID/consumer-info.","Fresh official HTML and official-domain searches October 26, 2026. These provisions do not create a general collector license. Absence conclusion remains bounded to public official sources searched. \nMontana Code Annotated\n+2"],["S_MT-P08-S008","Montana Retail Installment Sales Act, Montana Legislature. Definitions: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html, §31-1-202. Licensing: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html, §31-1-221. Delinquency: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html, §31-1-235. Statements/receipts: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0360/0310-0010-0020-0360.html, §31-1-236.","Fresh official HTML read October 26, 2026. Published MCA 2025; no comprehensive later audit. \nMontana Legislature\n+3"],["S_MT-P08-S009","Retail installment discipline and charge consequence, https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html, §31-1-203.","Fresh official HTML read October 26, 2026. Used only for bounded licensing and charge consequence; full remedies later. \nMontana Code Annotated"],["S_MT-P08-S010","Specialized state boundaries. Deferred deposit https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html, §31-1-722. UCC repossession https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html, §30-9A-609. Ambulance reporting https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html, §30-14-2602. Attorney claim purchase §§37-61-408 and 410.","Fresh official HTML read October 26, 2026. Used only for conduct/scope boundaries, not full sector dossiers. \nMontana Code Annotated\n+4"],["S_MT-P08-S011","Montana Consumer Protection Act, Montana Legislature. Definitions https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §30-14-102. Unlawful practices .../section_0030/..., §103. Federal interpretation/rules .../section_0040/..., §104. Exemptions .../section_0050/..., §105.","Fresh official HTML read October 26, 2026. Used for state conduct boundary; full remedies were assigned separately. \nMontana Code Annotated\n+3"],["S_MT-P08-S012","ARM 23.19.101, Unfair or Deceptive Acts or Practices, Montana Secretary of State. https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d.","Fresh official search rendering October 26, 2026; direct body returned HTTP 405. Selected current clauses were visible in search rendering. Complete body not authenticated. \nMontana Administrative Rules\n+2"],["S_MT-P08-S013","FDCPA definitions and state-law preservation, U.S. House Office of Law Revision Counsel. Definitions: https://uscode.house.gov/us/usc/119-124/t15/s1692a/, 15 U.S.C. §1692a. State law: https://uscode.house.gov/us/usc/119-124/t15/s1692n/, §1692n.","Fresh direct official HTML read October 26, 2026. Text through Public Law 119-124, October 15, 2026. \nU.S. Code\n+1"],["S_MT-P08-S014","FDCPA communications and conduct, official U.S. Code. Communications https://uscode.house.gov/us/usc/119-124/t15/s1692c/; harassment .../s1692d/; false representations .../s1692e/; unfair practices .../s1692f/.","Fresh direct official HTML read October 26, 2026. Federal rules only; coverage remains model-specific. \nU.S. Code\n+3"],["S_MT-P08-S015","Regulation F, CFPB/eCFR. Definitions https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2; communications .../subpart-B/section-1006.6; frequency/harassment .../section-1006.14; unfair practices .../section-1006.22.","Fresh direct official eCFR read October 26, 2026. Title 12 displayed through October 22, 2026, last amendment information as displayed. Not Montana law. \neCFR\n+3"],["S_MT-P08-S016","Henson v. Santander Consumer USA Inc., 582 U.S. 79 (2017), U.S. Supreme Court. https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf. Opinion pp.1–5, zero-based PDF indices 0–4.","Fresh full 13-page official opinion PDF read and relevant pages inspected October 26, 2026. Holding limited to “owed another” prong; principal-purpose issue expressly not decided. \nSupreme Court"],["S_MT-P08-S017","McAdory v. DNF Associates, LLC, 952 F.3d 1089 (9th Cir. 2020). https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf. Opinion pp.8–11, zero-based PDF indices 7–10.","Fresh full official Ninth Circuit PDF read and relevant pages inspected October 26, 2026. Rule 12(b)(6) reversal/remand; no final merits finding about every passive buyer. \nNinth Circuit Court of Appeals"],["S_MT-P08-S018","Heintz v. Jenkins, 514 U.S. 291 (1995). https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf. U.S. Reports pp.291–294, zero-based PDF indices 0–3.","Fresh full nine-page official U.S. Reports PDF read October 26, 2026. Controlling attorney-litigation boundary. \nGovInfo"],["S_MT-P08-S019","Obduskey v. McCarthy & Holthus LLP, 586 U.S. 466 (2019). https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf. Opinion pp.1–16, zero-based PDF indices 0–15.","Fresh full 20-page official PDF read October 26, 2026. Holding limited to entity doing no more than nonjudicial foreclosure. \nSupreme Court"],["S_MT-P08-S020","McCollough v. Johnson, Rodenburg & Lauinger, LLC, 637 F.3d 939 (9th Cir. 2011). https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf. Opinion pp.9–18, zero-based PDF indices 8–17.","Fresh full official Ninth Circuit PDF read October 26, 2026. Montana litigation; used only for law-firm and litigation-conduct boundary. \nNinth Circuit Court of Appeals"],["S_MT-P08-S021","Jacobson v. Bayview Loan Servicing, LLC, 2016 MT 101, Montana Supreme Court. https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520. Relevant opinion pp.16–23, zero-based PDF indices 15–22.","Fresh full 36-page opinion reproduction read and relevant pages inspected October 26, 2026. Secondary host of primary judicial opinion; mortgage context. \nJustia Law"],["S_MT-P08-S022","Baird v. Norwest Bank, 255 Mont. 317, 843 P.2d 327 (1992). https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html, especially opinion pp.12–15 as reproduced.","Fresh full opinion HTML read October 26, 2026. Secondary host of Montana Supreme Court opinion. MCPA lending/collection holding, not licensing. \nJustia Law"],["S_MT-P08-S023","Westgate cease-and-desist order, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf. Printed pp.1–2, zero-based PDF indices 0–1.","Fresh official two-page PDF read and visually inspected October 26, 2026. Historical June 12, 2014 party-specific order. No generalized collector-license holding. \nMontana Department of Administration\n+2"],["S_MT-P08-S024","Consumer complaint route, Montana DOJ Office of Consumer Protection. https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.","Fresh official search-rendered operational evidence October 26, 2026. Complaint route, not licensing proof, legal advice, tolling, or adjudication. \nMontana Department of Justice"],["S_MT-P08-S025","2025 Senate Bill 377 history, Montana Legislature. Introduced print and official bill-history route located through the 2025 Legislature site.","Fresh official search/rendering October 26, 2026. Bill died in process and is not operative law. Used only to avoid treating a proposed agency reorganization as current. \nMontana Legislative Archive\n+1"],["S_MT-P08-S026","Targeted official-source search log for Montana collection-agency license, debt-buyer license, state call restrictions, and exact provider orders.","Fresh bounded searches October 26, 2026. No general license or comprehensive state mini-FDCPA was located. This is provenance, not independent legal authority and not proof of absolute absence. \nMontana Code Annotated\n+4"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, consequence, and confidence"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, consequence, and confidence"],["S_MT-P08-C001","No generally applicable standalone Montana collection-agency or debt-buyer license was identified in current official public sources.","S004–S007, S026","High-confidence bounded search result, not categorical proof against every activity-specific license."],["S_MT-P08-C002","MCLA “consumer loan” is personal, family, or household credit to an individual, excluding specified deferred-deposit and residential mortgage loans.","S001 §32-5-102","High. Purpose at origination controls."],["S_MT-P08-C003","The MCLA’s express licensing prohibition is phrased around making consumer loans for compensation.","S001 §32-5-103(1)","High. Servicing conclusion also relies on transfer/collection text and agency interpretation."],["S_MT-P08-C004","Transferred MCLA loan contracts continue to be governed by the chapter.","S001 §32-5-103(2)","High."],["S_MT-P08-C005","A loan made or collected in violation by an unlicensed, nonexempt person is void and the person has no right to collect or retain principal, interest, fees, or charges.","S001 §32-5-103(4)","High. Only for covered MCLA loans and established violation."],["S_MT-P08-C006","Banks, specified depositories, credit unions, and the narrow fewer-than-four-own-fund lender are exempt from MCLA licensing.","S001 §32-5-103(5)","High; statutory conditions required."],["S_MT-P08-C007","BFID interprets receiving or accepting MCLA payments and retaining or directing them as servicing requiring a license.","S003 pp.1–3; S004","High for current agency position; not appellate construction."],["S_MT-P08-C008","BFID says its servicing interpretation applies only to MCLA-originated loans, not bank- or credit-union-originated loans.","S004","High for agency guidance. Other laws remain applicable."],["S_MT-P08-C009","BFID says utilities, service providers such as doctors/hospitals, and estates are outside the MCLA.","S004","High for agency interpretation. Not a generic MCPA/FDCPA exemption."],["S_MT-P08-C010","A debt buyer’s ownership alone does not resolve Montana licensing; origin, contract type, and payment/control activity matter.","S001, S003–S004, S008","High analytical boundary."],["S_MT-P08-C011","A business purchasing Montana retail installment contracts generally needs a Sales Finance License, subject to statutory exemptions and isolated-purchase boundary.","S008 §§202, 221","High."],["S_MT-P08-C012","Sales Finance License fee is $100 per principal/branch, expires December 31, and does not require a Montana physical office.","S008 §221; S004","High."],["S_MT-P08-C013","The Retail Installment Sales Act allows either a $10 delinquency charge or an alternative fixed charge calculated at no more than 15% of the defaulted installment after at least ten days.","S008 §235","High. Methods are alternatives."],["S_MT-P08-C014","Retail installment holders have statement, cash-receipt, payoff acknowledgment, and security-release duties.","S008 §236","High."],["S_MT-P08-C015","Each MCLA business location requires a license; licenses are nontransferable and expire December 31.","S001 §201","High."],["S_MT-P08-C016","Consumer Loan initial and renewal fees are $500 per entity or branch license.","S001 §201; S004","High."],["S_MT-P08-C017","BFID licenses Consumer Loan entities and branches, not individual employees, and does not require a Montana physical office.","S004 FAQ","High for operational guidance."],["S_MT-P08-C018","BFID states no bond is required for a Consumer Loan License.","S004 FAQ","High for current operational requirement; current NMLS checklist still should be checked."],["S_MT-P08-C019","Consumer Loan licenses and Sales Finance licenses are applied for and publicly verified through NMLS.","S004–S005","High. No named entity was checked."],["S_MT-P08-C020","Montana does not issue a paper Consumer Loan license and does not require display; proof is electronic through NMLS.","S004 FAQ","High."],["S_MT-P08-C021","Consumer Loan applicants are subject to statutory character/fitness, licensing-history, judgment, and application-accuracy criteria.","S001 §202","High."],["S_MT-P08-C022","BFID may impose up to $1,000 per established MCLA violation, restitution, costs, and license/right suspension or revocation after the statutory process.","S001 §207","High. Full remedies deferred."],["S_MT-P08-C023","MCLA late and deferral charges use the greater of $15 or 5%, capped at $50, and the same past-due amount may receive only one late fee.","S001 §301(3)–(4)","High. Contract authorization required."],["S_MT-P08-C024","MCLA prohibits unauthorized additional fees and requires forfeiture of twice the excess amount.","S001 §301(6)","High. Complete remedy treatment deferred."],["S_MT-P08-C025","MCLA requires cash receipts, reliable payment records, and payoff/satisfaction action within ten days after full repayment.","S001 §304","High."],["S_MT-P08-C026","MCLA prohibits false or misleading advertising about rates, terms, or conditions.","S002 §309","High."],["S_MT-P08-C027","Montana’s MCPA applies to collection of consumer loans, including original-creditor bank collection.","S011; S022","High. Baird is not a licensing case."],["S_MT-P08-C028","The MCPA regulated-activity exemption is not a blanket exemption for banks, attorneys, nonprofits, collectors, or licensees.","S011 §105","High textual boundary."],["S_MT-P08-C029","No general Montana statutory 8 a.m.–9 p.m. collection-contact window was located.","S001–S012, S026","Qualified negative. Federal law may apply."],["S_MT-P08-C030","No general Montana numeric call-frequency rule equivalent to Regulation F’s seven-in-seven presumptions was located.","S001–S012, S026","Qualified negative."],["S_MT-P08-C031","No general Montana collector electronic-message opt-out rule equivalent to Regulation F was located.","S001–S012, S026","Qualified negative."],["S_MT-P08-C032","FDCPA debt is limited to personal, family, or household obligations.","S013 §1692a(5)","High. Business debt excluded."],["S_MT-P08-C033","FDCPA debt collector includes principal-purpose collectors and persons regularly collecting debts owed another.","S013 §1692a(6)","High. Independent prongs."],["S_MT-P08-C034","A creditor collecting its own debt under a name suggesting a third party can be a federal debt collector.","S013 §1692a(6)","High. Actual name presentation required."],["S_MT-P08-C035","Creditor employees collecting in the creditor’s name are generally excluded federally; the affiliate exclusion is narrower and conditional.","S013 §1692a(6)(A)–(B)","High."],["S_MT-P08-C036","Government officers, process servers, and specified fiduciary/originator/pre-default acquisition activities have federal exclusions.","S013 §1692a(6)","High; exact conditions required."],["S_MT-P08-C037","Henson excludes an owner collecting purchased debt from the “owed another” prong but does not decide principal-purpose coverage.","S016","High controlling holding."],["S_MT-P08-C038","McAdory allows principal-purpose coverage of a passive debt buyer that outsources direct collection.","S017","High Ninth Circuit pleading-stage holding."],["S_MT-P08-C039","Attorneys regularly collecting consumer debts through litigation are federally covered under Heintz.","S018","High controlling holding."],["S_MT-P08-C040","An entity doing no more than nonjudicial security-interest enforcement is generally covered only for §1692f(6), under Obduskey.","S019","High, limited to pure enforcement activity."],["S_MT-P08-C041","The FDCPA restricts inconvenient, workplace, represented-consumer, third-party, and post-cease communications for covered collectors.","S014 §1692c","High, conditional on federal coverage."],["S_MT-P08-C042","FDCPA prohibits harassment, repeated calls with prohibited intent, false legal/credit threats, false identity or status, and unauthorized amounts.","S014 §§1692d–f","High, conditional."],["S_MT-P08-C043","Regulation F creates rebuttable telephone-frequency presumptions and electronic opt-out requirements; those are not independently Montana rules.","S015 §§1006.6, .14, .22","High."],["S_MT-P08-C044","FDCPA preserves noninconsistent state law, including more protective state rules.","S013 §1692n","High."],["S_MT-P08-C045","McCollough confirms that collection litigation, time-barred suits, false discovery requests, and unauthorized fee claims can fall within the FDCPA.","S020","High; debt-specific limitations deferred."],["S_MT-P08-C046","Jacobson applies federal collection and Montana consumer-protection principles to misleading mortgage servicing/foreclosure communications and represented-party contact.","S021","High for that mortgage context."],["S_MT-P08-C047","UCC self-help repossession is permitted only without breach of the peace.","S010 §30-9A-609","High."],["S_MT-P08-C048","Deferred-deposit collectors are limited by the $30 one-time returned-check fee and may not collect the identified bad-check statutory damages.","S010 §31-1-722","High; covered account required."],["S_MT-P08-C049","Certain transferred ambulance bills carry a Montana no-delinquent-reporting instruction to the collection agency.","S010 §30-14-2602","High; full reporting rules deferred."],["S_MT-P08-C050","An attorney may not buy a claim with intent and purpose to sue on it, subject to statutory exceptions.","S010 §§37-61-408, 410","High."],["S_MT-P08-C051","The current official consumer-loan ARM index was located, but direct bodies failed; complete current rule certification remains incomplete.","S006","High provenance statement."],["S_MT-P08-C052","2025 SB 377 did not become law; current BFID remains within the Department of Administration on reviewed current sources.","S004, S025","High current-status conclusion."],["S_MT-P08-C053","A Montana license or absence of one does not by itself establish FDCPA coverage, MCPA liability, debt validity, or a private remedy.","S001–S015","High structural boundary."],["S_MT-P08-C054","Actual license status must be checked entity-by-entity and license-type-by-license-type through NMLS; no provider was approved here.","S005","High methodological conclusion."]]},{"headers":["Assigned component","Status","Claim IDs","Exact remaining evidence or next action"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned component","Status","Claim IDs","Exact remaining evidence or next action"],["General collection-agency license","Bounded answered: none identified","C001","Monitor later legislation/rules; check specialized activity before relying on absence."],["General debt-buyer license","Bounded answered: none identified","C001, C010","Apply MCLA, Sales Finance, mortgage, telemarketing, and sector regimes to actual model."],["MCLA personal-purpose scope","Answered","C002","Obtain original loan purpose and documents."],["Commercial-debt exclusion from MCLA","Answered textually","C002","Mixed-purpose and guaranty issues remain fact-specific."],["MCLA lender license","Answered","C003, C006","Verify actual exemption and NMLS status."],["MCLA servicer license","Answered as agency interpretation","C004–C008","Controlling appellate interpretation remains absent."],["MCLA transferred-loan coverage","Answered","C004","Trace assignment and original statutory status."],["MCLA unlicensed-collection voidness","Answered textually","C005","Full private remedy, limitations, restitution, and defensive-use analysis later."],["Bank/credit-union exemption","Answered","C006, C008","Confirm actual charter and origination."],["Utility/medical/estate MCLA boundary","Answered as BFID guidance","C009","Other state and federal rules remain."],["Original creditor own-name","Answered in core","C003, C027, C035","Actual creditor identity and account type."],["Original creditor other-name FDCPA route","Answered","C034","Consumer-perception and DBA facts."],["Third-party contingency agency","Partial","C001, C032–C036","Debt purpose, clients, volume, and any activity-specific license."],["Debt buyer of MCLA loan","Partial","C004–C010","Ownership, servicing activity, payment control, and license."],["Passive debt buyer","Partial","C010, C037–C038","Principal-purpose facts and state activity."],["Retail installment purchaser","Answered in core","C011–C014","Contract characterization, acquisition frequency, exemption, and license status."],["Mortgage buyer/servicer","Excluded","—","Separate Montana Mortgage Act pass."],["Attorney collector","Answered in core","C039, C045, C050","Actual regularity, debt purpose, claim purchase, and litigation conduct."],["Litigation-only attorney","Partial","C039–C040, C045","Security-enforcement versus money-collection activity."],["Affiliate collector","Partial","C035","Ownership/control, clients, principal business, and names."],["Employee collector","Answered in core","C017, C035","Employer license and own-name status."],["Nonprofit collector","Partial","C001, C036","Actual services and narrow federal nonprofit DMP exclusion."],["Out-of-state/remote collector","Answered in part","C007, C015–C017","Exact location/branch activity and account nexus."],["Digital-only collector","Partial","C017, C031, C043","Location, electronic contacts, branch activity, and federal coverage."],["Government collector","Answered federally","C036","State/public-debt authority outside scope."],["Commercial collector","Answered as consumer-law boundary","C002, C032","General contract, tort, licensing, and commercial collection law later."],["Consumer Loan application","Route answered","C015–C021","Generate and inspect current entity-specific NMLS checklist when needed."],["Consumer Loan fee","Answered","C016","NMLS system charges, if any, remain checklist-specific."],["Consumer Loan renewal/expiry","Answered in core","C015–C016","Current late-renewal/reinstatement mechanics from checklist."],["Consumer Loan bond","Answered operationally as none","C018","Recheck current NMLS checklist before application."],["Consumer Loan qualifying persons","Partial","C021","NMLS control-person forms and current checklist."],["Consumer Loan branches","Answered in core","C015–C017","Remote-worker/location interpretation requires actual facts."],["Employee individual license","Answered as none","C017","Other professional licenses may apply."],["Sales Finance application and fee","Answered in core","C011–C012","Current generated NMLS checklist."],["Public license lookup","Answered","C019–C020, C054","No named provider checked."],["Paper/display license","Answered as none","C020","Advertising/name duties still apply."],["BFID complaint route","Partial","C022","Actual complaint procedure and SES materials entity-specific."],["OCP complaint route","Answered operationally","—","Not a license lookup or adjudication."],["MCLA interest and late charges","Answered","C023–C024","Actual contract, balance, prior fee, and voluntary-service facts."],["MCLA receipts/payoff","Answered","C025","Actual payment method and payoff date."],["MCLA advertising","Answered","C026","Complete current rule body inaccessible."],["Retail installment late charges","Answered","C013","Actual contractual method and default date."],["Retail installment statements/receipts","Answered","C014","Actual written request and payment facts."],["MCPA application to original creditors","Answered","C027–C028","Full standing/remedy analysis retained in separate pass."],["State call-time rule","No general rule identified","C029","Monitor later statute/rule; federal coverage separately."],["State call-frequency rule","No general rule identified","C030","Same."],["State workplace-contact rule","No general rule identified","C029–C031","MCPA and federal fact-specific analysis."],["State represented-consumer rule","No general rule identified","C029–C031","Jacobson federal/MCPA application does not create universal statute."],["State third-party-contact rule","No general rule identified","C029–C031","Privacy and federal law later."],["State cease-contact rule","No general rule identified","C029–C031","Federal written-notice rule if covered."],["State electronic opt-out","No general rule identified","C031","Regulation F if covered."],["Harassment/abuse","Partial state MCPA plus federal","C027–C028, C042–C043","Actual conduct and private standing."],["False creditor/owner identity","Answered in principle","C026–C028, C042, C046","Assignment proof and materiality."],["False legal or credit threat","Answered in principle","C027–C028, C042","Actual authority, intent, and federal coverage."],["Unauthorized fees","Answered for selected account types","C013, C023–C024, C042, C048","Contract and debt-type classification."],["Payment allocation","Unresolved in this pass","—","Later documentation/account pass and any applicable federal rule."],["Payment receipts","Answered for MCLA/retail installment","C014, C025","Other debt types remain."],["Repossession","Answered at UCC boundary","C040, C047","Notice, sale, deficiency, breach-of-peace cases later."],["Bankruptcy contact","Excluded","—","Federal stay/discharge pass."],["Deceased debtor contact","Partial federal definition only","C041","Probate, estate, and actual representative later."],["Ambulance reporting","Partial boundary","C049","Full credit-reporting/furnishing pass."],["FDCPA definitions/exclusions","Answered at gateway level","C032–C036","Full federal protocol later."],["Debt-buyer federal coverage","Answered at gateway level","C037–C038","Actual principal-purpose and portfolio facts."],["Attorney federal coverage","Answered","C039, C045","Actual regularity and claim."],["Security-interest federal coverage","Answered","C040","Conduct beyond pure enforcement."],["Federal communications","Answered only at gateway level","C041–C043","Full validation, call logs, consent, and exceptions later."],["Regulation F electronic rules","Answered at gateway level","C043","Full safe-harbor protocol later."],["FDCPA preemption/preservation","Answered","C044","Specific conflict analysis if state rule identified."],["Validation notice/documentation","Excluded","—","Dedicated later pass."],["Dispute handling","Excluded except general conduct","—","Dedicated validation/documentation pass."],["Account-level ownership proof","Excluded","—","Dedicated documentation/litigation pass."],["Credit reporting/furnishing","Excluded except ambulance crossover","C049","Dedicated reporting pass."],["Debt-specific limitations/revival","Excluded","C045 only as case boundary","Dedicated limitations pass."],["Collection suit/service/default judgment","Excluded except attorney gateway","C039, C045","Dedicated litigation pass."],["Garnishment/execution","Excluded","—","Dedicated remedies/litigation pass."],["Full collector remedies/private rights","Excluded","C022–C024, C053 only as boundaries","Dedicated remedies pass."],["Local and tribal law","Excluded","—","Separate jurisdictional passes."],["Current complete ARM text","Unresolved","C051","Authenticated current body or certified export."],["Post-2025 legislative currentness","Partial","C052","Comprehensive later session/special-session and future-effective audit."],["Actual provider authorization","Unresolved/excluded","C054","Official entity-specific NMLS check only when provider named."]]}],"claims":[{"claim_id":"S_MT-P08-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C001","Precise assertion":"No generally applicable standalone Montana collection-agency or debt-buyer license was identified in current official public sources.","Sources and pinpoints":"S004–S007, S026","Conditions, consequence, and confidence":"High-confidence bounded search result, not categorical proof against every activity-specific license."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C002","Precise assertion":"MCLA “consumer loan” is personal, family, or household credit to an individual, excluding specified deferred-deposit and residential mortgage loans.","Sources and pinpoints":"S001 §32-5-102","Conditions, consequence, and confidence":"High. Purpose at origination controls."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C003","Precise assertion":"The MCLA’s express licensing prohibition is phrased around making consumer loans for compensation.","Sources and pinpoints":"S001 §32-5-103(1)","Conditions, consequence, and confidence":"High. Servicing conclusion also relies on transfer/collection text and agency interpretation."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C004","Precise assertion":"Transferred MCLA loan contracts continue to be governed by the chapter.","Sources and pinpoints":"S001 §32-5-103(2)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C005","Precise assertion":"A loan made or collected in violation by an unlicensed, nonexempt person is void and the person has no right to collect or retain principal, interest, fees, or charges.","Sources and pinpoints":"S001 §32-5-103(4)","Conditions, consequence, and confidence":"High. Only for covered MCLA loans and established violation."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C006","Precise assertion":"Banks, specified depositories, credit unions, and the narrow fewer-than-four-own-fund lender are exempt from MCLA licensing.","Sources and pinpoints":"S001 §32-5-103(5)","Conditions, consequence, and confidence":"High; statutory conditions required."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C007","Precise assertion":"BFID interprets receiving or accepting MCLA payments and retaining or directing them as servicing requiring a license.","Sources and pinpoints":"S003 pp.1–3; S004","Conditions, consequence, and confidence":"High for current agency position; not appellate construction."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C008","Precise assertion":"BFID says its servicing interpretation applies only to MCLA-originated loans, not bank- or credit-union-originated loans.","Sources and pinpoints":"S004","Conditions, consequence, and confidence":"High for agency guidance. Other laws remain applicable."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C009","Precise assertion":"BFID says utilities, service providers such as doctors/hospitals, and estates are outside the MCLA.","Sources and pinpoints":"S004","Conditions, consequence, and confidence":"High for agency interpretation. Not a generic MCPA/FDCPA exemption."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C010","Precise assertion":"A debt buyer’s ownership alone does not resolve Montana licensing; origin, contract type, and payment/control activity matter.","Sources and pinpoints":"S001, S003–S004, S008","Conditions, consequence, and confidence":"High analytical boundary."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C011","Precise assertion":"A business purchasing Montana retail installment contracts generally needs a Sales Finance License, subject to statutory exemptions and isolated-purchase boundary.","Sources and pinpoints":"S008 §§202, 221","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C012","Precise assertion":"Sales Finance License fee is $100 per principal/branch, expires December 31, and does not require a Montana physical office.","Sources and pinpoints":"S008 §221; S004","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C013","Precise assertion":"The Retail Installment Sales Act allows either a $10 delinquency charge or an alternative fixed charge calculated at no more than 15% of the defaulted installment after at least ten days.","Sources and pinpoints":"S008 §235","Conditions, consequence, and confidence":"High. Methods are alternatives."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C014","Precise assertion":"Retail installment holders have statement, cash-receipt, payoff acknowledgment, and security-release duties.","Sources and pinpoints":"S008 §236","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C015","Precise assertion":"Each MCLA business location requires a license; licenses are nontransferable and expire December 31.","Sources and pinpoints":"S001 §201","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C016","Precise assertion":"Consumer Loan initial and renewal fees are $500 per entity or branch license.","Sources and pinpoints":"S001 §201; S004","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C017","Precise assertion":"BFID licenses Consumer Loan entities and branches, not individual employees, and does not require a Montana physical office.","Sources and pinpoints":"S004 FAQ","Conditions, consequence, and confidence":"High for operational guidance."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C018","Precise assertion":"BFID states no bond is required for a Consumer Loan License.","Sources and pinpoints":"S004 FAQ","Conditions, consequence, and confidence":"High for current operational requirement; current NMLS checklist still should be checked."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C019","Precise assertion":"Consumer Loan licenses and Sales Finance licenses are applied for and publicly verified through NMLS.","Sources and pinpoints":"S004–S005","Conditions, consequence, and confidence":"High. No named entity was checked."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C020","Precise assertion":"Montana does not issue a paper Consumer Loan license and does not require display; proof is electronic through NMLS.","Sources and pinpoints":"S004 FAQ","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C021","Precise assertion":"Consumer Loan applicants are subject to statutory character/fitness, licensing-history, judgment, and application-accuracy criteria.","Sources and pinpoints":"S001 §202","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C022","Precise assertion":"BFID may impose up to $1,000 per established MCLA violation, restitution, costs, and license/right suspension or revocation after the statutory process.","Sources and pinpoints":"S001 §207","Conditions, consequence, and confidence":"High. Full remedies deferred."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C023","Precise assertion":"MCLA late and deferral charges use the greater of $15 or 5%, capped at $50, and the same past-due amount may receive only one late fee.","Sources and pinpoints":"S001 §301(3)–(4)","Conditions, consequence, and confidence":"High. Contract authorization required."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C024","Precise assertion":"MCLA prohibits unauthorized additional fees and requires forfeiture of twice the excess amount.","Sources and pinpoints":"S001 §301(6)","Conditions, consequence, and confidence":"High. Complete remedy treatment deferred."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C025","Precise assertion":"MCLA requires cash receipts, reliable payment records, and payoff/satisfaction action within ten days after full repayment.","Sources and pinpoints":"S001 §304","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C026","Precise assertion":"MCLA prohibits false or misleading advertising about rates, terms, or conditions.","Sources and pinpoints":"S002 §309","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C027","Precise assertion":"Montana’s MCPA applies to collection of consumer loans, including original-creditor bank collection.","Sources and pinpoints":"S011; S022","Conditions, consequence, and confidence":"High. Baird is not a licensing case."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C028","Precise assertion":"The MCPA regulated-activity exemption is not a blanket exemption for banks, attorneys, nonprofits, collectors, or licensees.","Sources and pinpoints":"S011 §105","Conditions, consequence, and confidence":"High textual boundary."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C029","Precise assertion":"No general Montana statutory 8 a.m.–9 p.m. collection-contact window was located.","Sources and pinpoints":"S001–S012, S026","Conditions, consequence, and confidence":"Qualified negative. Federal law may apply."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C030","Precise assertion":"No general Montana numeric call-frequency rule equivalent to Regulation F’s seven-in-seven presumptions was located.","Sources and pinpoints":"S001–S012, S026","Conditions, consequence, and confidence":"Qualified negative."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C031","Precise assertion":"No general Montana collector electronic-message opt-out rule equivalent to Regulation F was located.","Sources and pinpoints":"S001–S012, S026","Conditions, consequence, and confidence":"Qualified negative."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C032","Precise assertion":"FDCPA debt is limited to personal, family, or household obligations.","Sources and pinpoints":"S013 §1692a(5)","Conditions, consequence, and confidence":"High. Business debt excluded."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C033","Precise assertion":"FDCPA debt collector includes principal-purpose collectors and persons regularly collecting debts owed another.","Sources and pinpoints":"S013 §1692a(6)","Conditions, consequence, and confidence":"High. Independent prongs."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C034","Precise assertion":"A creditor collecting its own debt under a name suggesting a third party can be a federal debt collector.","Sources and pinpoints":"S013 §1692a(6)","Conditions, consequence, and confidence":"High. Actual name presentation required."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C035","Precise assertion":"Creditor employees collecting in the creditor’s name are generally excluded federally; the affiliate exclusion is narrower and conditional.","Sources and pinpoints":"S013 §1692a(6)(A)–(B)","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C036","Precise assertion":"Government officers, process servers, and specified fiduciary/originator/pre-default acquisition activities have federal exclusions.","Sources and pinpoints":"S013 §1692a(6)","Conditions, consequence, and confidence":"High; exact conditions required."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C037","Precise assertion":"Henson excludes an owner collecting purchased debt from the “owed another” prong but does not decide principal-purpose coverage.","Sources and pinpoints":"S016","Conditions, consequence, and confidence":"High controlling holding."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C038","Precise assertion":"McAdory allows principal-purpose coverage of a passive debt buyer that outsources direct collection.","Sources and pinpoints":"S017","Conditions, consequence, and confidence":"High Ninth Circuit pleading-stage holding."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C039","Precise assertion":"Attorneys regularly collecting consumer debts through litigation are federally covered under Heintz.","Sources and pinpoints":"S018","Conditions, consequence, and confidence":"High controlling holding."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C040","Precise assertion":"An entity doing no more than nonjudicial security-interest enforcement is generally covered only for §1692f(6), under Obduskey.","Sources and pinpoints":"S019","Conditions, consequence, and confidence":"High, limited to pure enforcement activity."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C041","Precise assertion":"The FDCPA restricts inconvenient, workplace, represented-consumer, third-party, and post-cease communications for covered collectors.","Sources and pinpoints":"S014 §1692c","Conditions, consequence, and confidence":"High, conditional on federal coverage."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C042","Precise assertion":"FDCPA prohibits harassment, repeated calls with prohibited intent, false legal/credit threats, false identity or status, and unauthorized amounts.","Sources and pinpoints":"S014 §§1692d–f","Conditions, consequence, and confidence":"High, conditional."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C043","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C043","Precise assertion":"Regulation F creates rebuttable telephone-frequency presumptions and electronic opt-out requirements; those are not independently Montana rules.","Sources and pinpoints":"S015 §§1006.6, .14, .22","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned","coordinator_finding_id":"S_MT-P08-Q002","coordinator_example_frequency_qualification":"Narrative/E8mustspecify sameparticularperson andparticulardebt; preserveall1006.14(b)conditions."},{"claim_id":"S_MT-P08-C044","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C044","Precise assertion":"FDCPA preserves noninconsistent state law, including more protective state rules.","Sources and pinpoints":"S013 §1692n","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C045","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C045","Precise assertion":"McCollough confirms that collection litigation, time-barred suits, false discovery requests, and unauthorized fee claims can fall within the FDCPA.","Sources and pinpoints":"S020","Conditions, consequence, and confidence":"High; debt-specific limitations deferred."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C046","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C046","Precise assertion":"Jacobson applies federal collection and Montana consumer-protection principles to misleading mortgage servicing/foreclosure communications and represented-party contact.","Sources and pinpoints":"S021","Conditions, consequence, and confidence":"High for that mortgage context."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C047","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C047","Precise assertion":"UCC self-help repossession is permitted only without breach of the peace.","Sources and pinpoints":"S010 §30-9A-609","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C048","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C048","Precise assertion":"Deferred-deposit collectors are limited by the $30 one-time returned-check fee and may not collect the identified bad-check statutory damages.","Sources and pinpoints":"S010 §31-1-722","Conditions, consequence, and confidence":"High; covered account required."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C049","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C049","Precise assertion":"Certain transferred ambulance bills carry a Montana no-delinquent-reporting instruction to the collection agency.","Sources and pinpoints":"S010 §30-14-2602","Conditions, consequence, and confidence":"High; full reporting rules deferred."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C050","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C050","Precise assertion":"An attorney may not buy a claim with intent and purpose to sue on it, subject to statutory exceptions.","Sources and pinpoints":"S010 §§37-61-408, 410","Conditions, consequence, and confidence":"High."},"coordinator_verification_status":"case_or_unreopened_statutory_component_held_not_fresh_full_primary_acceptance","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C051","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C051","Precise assertion":"The current official consumer-loan ARM index was located, but direct bodies failed; complete current rule certification remains incomplete.","Sources and pinpoints":"S006","Conditions, consequence, and confidence":"High provenance statement."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C052","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C052","Precise assertion":"2025 SB 377 did not become law; current BFID remains within the Department of Administration on reviewed current sources.","Sources and pinpoints":"S004, S025","Conditions, consequence, and confidence":"High current-status conclusion."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C053","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C053","Precise assertion":"A Montana license or absence of one does not by itself establish FDCPA coverage, MCPA liability, debt validity, or a private remedy.","Sources and pinpoints":"S001–S015","Conditions, consequence, and confidence":"High structural boundary."},"coordinator_verification_status":"scoped_comparison_version_scope_and_actual_application_holds_remain","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"},{"claim_id":"S_MT-P08-C054","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P08-C054","Precise assertion":"Actual license status must be checked entity-by-entity and license-type-by-license-type through NMLS; no provider was approved here.","Sources and pinpoints":"S005","Conditions, consequence, and confidence":"High methodological conclusion."},"coordinator_verification_status":"researcher_negative_or_procedural_currentness_claim_not_reperformed_or_actual_authorization","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_example_reference_status":"Q001example_links_repair_pending_UNSENT; actualclaimtextnotreassigned"}],"sources":[{"source_id":"S_MT-P08-S001","urls":["https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0020/0320-0050-0020-0020.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0090/0320-0050-0020-0090.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html"],"researcher_record":{"Source ID":"S_MT-P08-S001","Instrument, issuer, literal URL, and pinpoint":"Montana Consumer Loan Act, Montana Legislature. Definition: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html, §32-5-102. Restriction/transfer/voidness/exemptions: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html, §32-5-103. License/renewal: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html, §32-5-201. Fitness: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0020/0320-0050-0020-0020.html, §32-5-202. Discipline: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html, §32-5-207. NMLS: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0090/0320-0050-0020-0090.html, §32-5-209. Fees: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html, §32-5-301. Receipts: https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html, §32-5-304.","Version, status, and access limits":"Fresh direct official HTML read October 26, 2026. Published MCA 2025; no PDF page/index. Internet-code disclaimer applies. No comprehensive post-2025 legislative audit. \nMontana Code Annotated\n+4"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0020/0320-0050-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0010/section_0030/0320-0050-0010-0030.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0010/0320-0050-0020-0010.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0020/0320-0050-0020-0020.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0020/section_0070/0320-0050-0020-0070.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0010/0320-0050-0030-0010.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0040/0320-0050-0030-0040.html"]},{"source_id":"S_MT-P08-S002","urls":["https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0080/0320-0050-0040-0080.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0090/0320-0050-0040-0090.html"],"researcher_record":{"Source ID":"S_MT-P08-S002","Instrument, issuer, literal URL, and pinpoint":"Additional MCLA operations and enforcement: records https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html, §32-5-307; advertising https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html, §32-5-309; department powers §§32-5-401–403; cease-and-desist https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0080/0320-0050-0040-0080.html, §32-5-408; public list/complaints https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0040/section_0090/0320-0050-0040-0090.html, §32-5-409.","Version, status, and access limits":"Fresh official HTML read October 26, 2026. Used only for entry, conduct, records, and bounded discipline; full remedies deferred. \nMontana Code Annotated\n+6"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0070/0320-0050-0030-0070.html","https://mca.legmt.gov/bills/mca/title_0320/chapter_0050/part_0030/section_0090/0320-0050-0030-0090.html"]},{"source_id":"S_MT-P08-S003","urls":["https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S003","Instrument, issuer, literal URL, and pinpoint":"Servicers of Montana Consumer Loans Memorandum, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf. Printed pp.1–3, zero-based PDF indices 0–2.","Version, status, and access limits":"Fresh official three-page PDF read and visually inspected October 26, 2026. Historical agency memorandum dated February 23, 2016. It interprets receiving or accepting and retaining/directing payments as servicing. Page 2 contains an apparent obsolete-title typographical reference; current §32-5-103 was read separately. Not a court holding. \nMontana Department of Administration\n+5"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://doa.mt.gov/_docs/bfid/Consumer-Loan/Consumer-Loan-Servicer-Memorandum-02-23-16.pdf"]},{"source_id":"S_MT-P08-S004","urls":["https://doa.mt.gov/BFID/mortgage-consumer-finance/","https://doa.mt.gov/BFID/mortgage-consumer-finance/faq"],"researcher_record":{"Source ID":"S_MT-P08-S004","Instrument, issuer, literal URL, and pinpoint":"Mortgage and Consumer Finance and FAQ, Montana Department of Administration, BFID. https://doa.mt.gov/BFID/mortgage-consumer-finance/; https://doa.mt.gov/BFID/mortgage-consumer-finance/faq. Relevant current sections: Consumer Loan Companies, servicing clarification, fees, branches, employees, physical office, bond, reporting, Sales Finance Companies, public forms.","Version, status, and access limits":"Fresh direct official pages read October 26, 2026. Current operational interpretation, not a substitute for statutes or adjudication. \nMontana Department of Administration\n+1"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://doa.mt.gov/BFID/mortgage-consumer-finance/","https://doa.mt.gov/BFID/mortgage-consumer-finance/faq","https://doa.mt.gov/BFID/mortgage-consumer-finance/faq"]},{"source_id":"S_MT-P08-S005","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Home.aspx","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/Shared%20Documents/NMLS%20Company%20%28MU1%29%20Form.pdf","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P08-S005","Instrument, issuer, literal URL, and pinpoint":"NMLS public routes, State Regulatory Registry/CSBS. Checklist compiler: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx. Consumer Access: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Home.aspx. Universal Company Form version 5.0: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/Shared%20Documents/NMLS%20Company%20%28MU1%29%20Form.pdf, printed pp.1–9/PDF indices 0–8.","Version, status, and access limits":"Fresh official route checks October 26, 2026. Checklist compiler and public verification routes located. No Montana company-specific checklist was generated; no named provider was searched. MU1 is a universal instructional form, not Montana authorization. \nNationwide Licensing System\n+2"},"coordinator_verification_status":"not_freshly_reopened_researcher_limits_retained","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S006","urls":["https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9"],"researcher_record":{"Source ID":"S_MT-P08-S006","Instrument, issuer, literal URL, and pinpoint":"Current Montana consumer-loan administrative-rule index, Montana Secretary of State. Chapter route: https://rules.mt.gov/browse/collections/aec52c46-128e-4279-9068-8af5d5432d74/sections/faa0f5ae-bb0f-4a0f-bbb3-f050aa0ca1f9; ARM 2.59.301, .302, .305, .306, .310, .319 routes as identified in the official index.","Version, status, and access limits":"Fresh official search rendering October 26, 2026; direct rule-body routes returned HTTP 405. Search rendering established current titles and selected text, but complete current rule bodies and later rule history were not certified. \nMontana Administrative Rules\n+4"},"coordinator_verification_status":"prior_ARMaccess_failure_complete_current_body_held_not_retried","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S007","urls":["https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html","https://mca.legmt.gov/bills/mca/title_0350/chapter_0080/part_0100/section_0010/0350-0080-0100-0010.html","https://doa.mt.gov/BFID/consumer-info","https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P08-S007","Instrument, issuer, literal URL, and pinpoint":"Bounded general-license checks. Private-investigator exemption: https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html, §37-60-105. Foreign LLC activities: https://mca.legmt.gov/bills/mca/title_0350/chapter_0080/part_0100/section_0010/0350-0080-0100-0010.html, §35-8-1001. BFID Consumer Information: https://doa.mt.gov/BFID/consumer-info.","Version, status, and access limits":"Fresh official HTML and official-domain searches October 26, 2026. These provisions do not create a general collector license. Absence conclusion remains bounded to public official sources searched. \nMontana Code Annotated\n+2"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://mca.legmt.gov/bills/MCA/title_0370/chapter_0600/part_0010/section_0050/0370-0600-0010-0050.html","https://mca.legmt.gov/bills/mca/title_0350/chapter_0080/part_0100/section_0010/0350-0080-0100-0010.html"]},{"source_id":"S_MT-P08-S008","urls":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0360/0310-0010-0020-0360.html","https://leg.mt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html"],"researcher_record":{"Source ID":"S_MT-P08-S008","Instrument, issuer, literal URL, and pinpoint":"Montana Retail Installment Sales Act, Montana Legislature. Definitions: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html, §31-1-202. Licensing: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html, §31-1-221. Delinquency: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html, §31-1-235. Statements/receipts: https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0360/0310-0010-0020-0360.html, §31-1-236.","Version, status, and access limits":"Fresh official HTML read October 26, 2026. Published MCA 2025; no comprehensive later audit. \nMontana Legislature\n+3"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0020/0310-0010-0020-0020.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0210/0310-0010-0020-0210.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0350/0310-0010-0020-0350.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0360/0310-0010-0020-0360.html"]},{"source_id":"S_MT-P08-S009","urls":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html"],"researcher_record":{"Source ID":"S_MT-P08-S009","Instrument, issuer, literal URL, and pinpoint":"Retail installment discipline and charge consequence, https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0020/section_0030/0310-0010-0020-0030.html, §31-1-203.","Version, status, and access limits":"Fresh official HTML read October 26, 2026. Used only for bounded licensing and charge consequence; full remedies later. \nMontana Code Annotated"},"coordinator_verification_status":"not_freshly_reopened_researcher_limits_retained","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S010","urls":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html","https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html"],"researcher_record":{"Source ID":"S_MT-P08-S010","Instrument, issuer, literal URL, and pinpoint":"Specialized state boundaries. Deferred deposit https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html, §31-1-722. UCC repossession https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html, §30-9A-609. Ambulance reporting https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html, §30-14-2602. Attorney claim purchase §§37-61-408 and 410.","Version, status, and access limits":"Fresh official HTML read October 26, 2026. Used only for conduct/scope boundaries, not full sector dossiers. \nMontana Code Annotated\n+4"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0010/part_0070/section_0220/0310-0010-0070-0220.html","https://mca.legmt.gov/bills/mca/title_0300/chapter_009A/part_0060/section_0090/0300-009A-0060-0090.html","https://mca.legmt.gov/bills/MCA/title_0300/chapter_0140/part_0260/section_0020/0300-0140-0260-0020.html"]},{"source_id":"S_MT-P08-S011","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html"],"researcher_record":{"Source ID":"S_MT-P08-S011","Instrument, issuer, literal URL, and pinpoint":"Montana Consumer Protection Act, Montana Legislature. Definitions https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0010/section_0020/0300-0140-0010-0020.html, §30-14-102. Unlawful practices .../section_0030/..., §103. Federal interpretation/rules .../section_0040/..., §104. Exemptions .../section_0050/..., §105.","Version, status, and access limits":"Fresh official HTML read October 26, 2026. Used for state conduct boundary; full remedies were assigned separately. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"fresh_selected_primary_or_agency_text_with_version_and_application_holds","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_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_0050/0300-0140-0010-0050.html"]},{"source_id":"S_MT-P08-S012","urls":["https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d"],"researcher_record":{"Source ID":"S_MT-P08-S012","Instrument, issuer, literal URL, and pinpoint":"ARM 23.19.101, Unfair or Deceptive Acts or Practices, Montana Secretary of State. https://rules.mt.gov/policy-library-documents/text/html/7d357f6bdcfe7f48c8a005a3cece9b59d956570904773cf2027a9e1835fbe49d.","Version, status, and access limits":"Fresh official search rendering October 26, 2026; direct body returned HTTP 405. Selected current clauses were visible in search rendering. Complete body not authenticated. \nMontana Administrative Rules\n+2"},"coordinator_verification_status":"prior_ARMaccess_failure_complete_current_body_held_not_retried","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S013","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1692a/","https://uscode.house.gov/us/usc/119-124/t15/s1692n/"],"researcher_record":{"Source ID":"S_MT-P08-S013","Instrument, issuer, literal URL, and pinpoint":"FDCPA definitions and state-law preservation, U.S. House Office of Law Revision Counsel. Definitions: https://uscode.house.gov/us/usc/119-124/t15/s1692a/, 15 U.S.C. §1692a. State law: https://uscode.house.gov/us/usc/119-124/t15/s1692n/, §1692n.","Version, status, and access limits":"Fresh direct official HTML read October 26, 2026. Text through Public Law 119-124, October 15, 2026. \nU.S. Code\n+1"},"coordinator_verification_status":"GPOalternate_print_compared_OLRCcutoff_not_freshly_confirmed","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://www.govinfo.gov/link/uscode/15/1692a","https://www.govinfo.gov/link/uscode/15/1692n"]},{"source_id":"S_MT-P08-S014","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1692c/"],"researcher_record":{"Source ID":"S_MT-P08-S014","Instrument, issuer, literal URL, and pinpoint":"FDCPA communications and conduct, official U.S. Code. Communications https://uscode.house.gov/us/usc/119-124/t15/s1692c/; harassment .../s1692d/; false representations .../s1692e/; unfair practices .../s1692f/.","Version, status, and access limits":"Fresh direct official HTML read October 26, 2026. Federal rules only; coverage remains model-specific. \nU.S. Code\n+3"},"coordinator_verification_status":"not_freshly_reopened_researcher_limits_retained","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S015","urls":["https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2"],"researcher_record":{"Source ID":"S_MT-P08-S015","Instrument, issuer, literal URL, and pinpoint":"Regulation F, CFPB/eCFR. Definitions https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2; communications .../subpart-B/section-1006.6; frequency/harassment .../section-1006.14; unfair practices .../section-1006.22.","Version, status, and access limits":"Fresh direct official eCFR read October 26, 2026. Title 12 displayed through October 22, 2026, last amendment information as displayed. Not Montana law. \neCFR\n+3"},"coordinator_verification_status":"fresh_complete_selected_eCFR2_6_14_not_complete_federal_protocol","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":["https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-A/section-1006.2","https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-B/section-1006.14","https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-B/section-1006.6"]},{"source_id":"S_MT-P08-S016","urls":["https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S016","Instrument, issuer, literal URL, and pinpoint":"Henson v. Santander Consumer USA Inc., 582 U.S. 79 (2017), U.S. Supreme Court. https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf. Opinion pp.1–5, zero-based PDF indices 0–4.","Version, status, and access limits":"Fresh full 13-page official opinion PDF read and relevant pages inspected October 26, 2026. Holding limited to “owed another” prong; principal-purpose issue expressly not decided. \nSupreme Court"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S017","urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S017","Instrument, issuer, literal URL, and pinpoint":"McAdory v. DNF Associates, LLC, 952 F.3d 1089 (9th Cir. 2020). https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf. Opinion pp.8–11, zero-based PDF indices 7–10.","Version, status, and access limits":"Fresh full official Ninth Circuit PDF read and relevant pages inspected October 26, 2026. Rule 12(b)(6) reversal/remand; no final merits finding about every passive buyer. \nNinth Circuit Court of Appeals"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S018","urls":["https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf","https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf?ref=hoaweekly.com"],"researcher_record":{"Source ID":"S_MT-P08-S018","Instrument, issuer, literal URL, and pinpoint":"Heintz v. Jenkins, 514 U.S. 291 (1995). https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf. U.S. Reports pp.291–294, zero-based PDF indices 0–3.","Version, status, and access limits":"Fresh full nine-page official U.S. Reports PDF read October 26, 2026. Controlling attorney-litigation boundary. \nGovInfo"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S019","urls":["https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S019","Instrument, issuer, literal URL, and pinpoint":"Obduskey v. McCarthy & Holthus LLP, 586 U.S. 466 (2019). https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf. Opinion pp.1–16, zero-based PDF indices 0–15.","Version, status, and access limits":"Fresh full 20-page official PDF read October 26, 2026. Holding limited to entity doing no more than nonjudicial foreclosure. \nSupreme Court"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S020","urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S020","Instrument, issuer, literal URL, and pinpoint":"McCollough v. Johnson, Rodenburg & Lauinger, LLC, 637 F.3d 939 (9th Cir. 2011). https://cdn.ca9.uscourts.gov/datastore/opinions/2011/03/04/09-35767.pdf. Opinion pp.9–18, zero-based PDF indices 8–17.","Version, status, and access limits":"Fresh full official Ninth Circuit PDF read October 26, 2026. Montana litigation; used only for law-firm and litigation-conduct boundary. \nNinth Circuit Court of Appeals"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S021","urls":["https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520"],"researcher_record":{"Source ID":"S_MT-P08-S021","Instrument, issuer, literal URL, and pinpoint":"Jacobson v. Bayview Loan Servicing, LLC, 2016 MT 101, Montana Supreme Court. https://cases.justia.com/montana/supreme-court/2016-da-15-0108.pdf?ts=1462379520. Relevant opinion pp.16–23, zero-based PDF indices 15–22.","Version, status, and access limits":"Fresh full 36-page opinion reproduction read and relevant pages inspected October 26, 2026. Secondary host of primary judicial opinion; mortgage context. \nJustia Law"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S022","urls":["https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html"],"researcher_record":{"Source ID":"S_MT-P08-S022","Instrument, issuer, literal URL, and pinpoint":"Baird v. Norwest Bank, 255 Mont. 317, 843 P.2d 327 (1992). https://law.justia.com/cases/montana/supreme-court/1992/373eed51-a4d3-47a5-a850-607030c84844.html, especially opinion pp.12–15 as reproduced.","Version, status, and access limits":"Fresh full opinion HTML read October 26, 2026. Secondary host of Montana Supreme Court opinion. MCPA lending/collection holding, not licensing. \nJustia Law"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S023","urls":["https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf"],"researcher_record":{"Source ID":"S_MT-P08-S023","Instrument, issuer, literal URL, and pinpoint":"Westgate cease-and-desist order, Montana Department of Administration, BFID. https://doa.mt.gov/_docs/bfid/Enforcement_Actions/M2014-133/Cease_and_Desist_06-12-14_Redacted.pdf. Printed pp.1–2, zero-based PDF indices 0–1.","Version, status, and access limits":"Fresh official two-page PDF read and visually inspected October 26, 2026. Historical June 12, 2014 party-specific order. No generalized collector-license holding. \nMontana Department of Administration\n+2"},"coordinator_verification_status":"case_or_party_specific_order_not_freshly_reopened","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S024","urls":["https://dojmt.gov/office-of-consumer-protection/consumer-complaints/"],"researcher_record":{"Source ID":"S_MT-P08-S024","Instrument, issuer, literal URL, and pinpoint":"Consumer complaint route, Montana DOJ Office of Consumer Protection. https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.","Version, status, and access limits":"Fresh official search-rendered operational evidence October 26, 2026. Complaint route, not licensing proof, legal advice, tolling, or adjudication. \nMontana Department of Justice"},"coordinator_verification_status":"not_freshly_reopened_researcher_limits_retained","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S025","urls":["https://archive.legmt.gov/"],"researcher_record":{"Source ID":"S_MT-P08-S025","Instrument, issuer, literal URL, and pinpoint":"2025 Senate Bill 377 history, Montana Legislature. Introduced print and official bill-history route located through the 2025 Legislature site.","Version, status, and access limits":"Fresh official search/rendering October 26, 2026. Bill died in process and is not operative law. Used only to avoid treating a proposed agency reorganization as current. \nMontana Legislative Archive\n+1"},"coordinator_verification_status":"not_freshly_reopened_researcher_limits_retained","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]},{"source_id":"S_MT-P08-S026","urls":["https://mca.legmt.gov/bills/2017/mca/title_0300/chapter_0140/part_0200/section_0130/0300-0140-0200-0130.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P08-S026","Instrument, issuer, literal URL, and pinpoint":"Targeted official-source search log for Montana collection-agency license, debt-buyer license, state call restrictions, and exact provider orders.","Version, status, and access limits":"Fresh bounded searches October 26, 2026. No general license or comprehensive state mini-FDCPA was located. This is provenance, not independent legal authority and not proof of absolute absence. \nMontana Code Annotated\n+4"},"coordinator_verification_status":"researcher_bounded_search_provenance_not_independent_authority_not_reperformed","coordinator_review":"[internal evidence reference]","coordinator_check_evidence":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_selected_access_URLs":[]}],"coverage":[{"topic":"General collection-agency license","researcher_record":{"Assigned component":"General collection-agency license","Status":"Bounded answered: none identified","Claim IDs":"C001","Exact remaining evidence or next action":"Monitor later legislation/rules; check specialized activity before relying on absence."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"General debt-buyer license","researcher_record":{"Assigned component":"General debt-buyer license","Status":"Bounded answered: none identified","Claim IDs":"C001, C010","Exact remaining evidence or next action":"Apply MCLA, Sales Finance, mortgage, telemarketing, and sector regimes to actual model."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA personal-purpose scope","researcher_record":{"Assigned component":"MCLA personal-purpose scope","Status":"Answered","Claim IDs":"C002","Exact remaining evidence or next action":"Obtain original loan purpose and documents."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Commercial-debt exclusion from MCLA","researcher_record":{"Assigned component":"Commercial-debt exclusion from MCLA","Status":"Answered textually","Claim IDs":"C002","Exact remaining evidence or next action":"Mixed-purpose and guaranty issues remain fact-specific."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA lender license","researcher_record":{"Assigned component":"MCLA lender license","Status":"Answered","Claim IDs":"C003, C006","Exact remaining evidence or next action":"Verify actual exemption and NMLS status."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA servicer license","researcher_record":{"Assigned component":"MCLA servicer license","Status":"Answered as agency interpretation","Claim IDs":"C004–C008","Exact remaining evidence or next action":"Controlling appellate interpretation remains absent."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA transferred-loan coverage","researcher_record":{"Assigned component":"MCLA transferred-loan coverage","Status":"Answered","Claim IDs":"C004","Exact remaining evidence or next action":"Trace assignment and original statutory status."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA unlicensed-collection voidness","researcher_record":{"Assigned component":"MCLA unlicensed-collection voidness","Status":"Answered textually","Claim IDs":"C005","Exact remaining evidence or next action":"Full private remedy, limitations, restitution, and defensive-use analysis later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Bank/credit-union exemption","researcher_record":{"Assigned component":"Bank/credit-union exemption","Status":"Answered","Claim IDs":"C006, C008","Exact remaining evidence or next action":"Confirm actual charter and origination."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Utility/medical/estate MCLA boundary","researcher_record":{"Assigned component":"Utility/medical/estate MCLA boundary","Status":"Answered as BFID guidance","Claim IDs":"C009","Exact remaining evidence or next action":"Other state and federal rules remain."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Original creditor own-name","researcher_record":{"Assigned component":"Original creditor own-name","Status":"Answered in core","Claim IDs":"C003, C027, C035","Exact remaining evidence or next action":"Actual creditor identity and account type."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Original creditor other-name FDCPA route","researcher_record":{"Assigned component":"Original creditor other-name FDCPA route","Status":"Answered","Claim IDs":"C034","Exact remaining evidence or next action":"Consumer-perception and DBA facts."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Third-party contingency agency","researcher_record":{"Assigned component":"Third-party contingency agency","Status":"Partial","Claim IDs":"C001, C032–C036","Exact remaining evidence or next action":"Debt purpose, clients, volume, and any activity-specific license."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Debt buyer of MCLA loan","researcher_record":{"Assigned component":"Debt buyer of MCLA loan","Status":"Partial","Claim IDs":"C004–C010","Exact remaining evidence or next action":"Ownership, servicing activity, payment control, and license."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Passive debt buyer","researcher_record":{"Assigned component":"Passive debt buyer","Status":"Partial","Claim IDs":"C010, C037–C038","Exact remaining evidence or next action":"Principal-purpose facts and state activity."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Retail installment purchaser","researcher_record":{"Assigned component":"Retail installment purchaser","Status":"Answered in core","Claim IDs":"C011–C014","Exact remaining evidence or next action":"Contract characterization, acquisition frequency, exemption, and license status."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Mortgage buyer/servicer","researcher_record":{"Assigned component":"Mortgage buyer/servicer","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Separate Montana Mortgage Act pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Attorney collector","researcher_record":{"Assigned component":"Attorney collector","Status":"Answered in core","Claim IDs":"C039, C045, C050","Exact remaining evidence or next action":"Actual regularity, debt purpose, claim purchase, and litigation conduct."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Litigation-only attorney","researcher_record":{"Assigned component":"Litigation-only attorney","Status":"Partial","Claim IDs":"C039–C040, C045","Exact remaining evidence or next action":"Security-enforcement versus money-collection activity."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Affiliate collector","researcher_record":{"Assigned component":"Affiliate collector","Status":"Partial","Claim IDs":"C035","Exact remaining evidence or next action":"Ownership/control, clients, principal business, and names."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Employee collector","researcher_record":{"Assigned component":"Employee collector","Status":"Answered in core","Claim IDs":"C017, C035","Exact remaining evidence or next action":"Employer license and own-name status."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Nonprofit collector","researcher_record":{"Assigned component":"Nonprofit collector","Status":"Partial","Claim IDs":"C001, C036","Exact remaining evidence or next action":"Actual services and narrow federal nonprofit DMP exclusion."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Out-of-state/remote collector","researcher_record":{"Assigned component":"Out-of-state/remote collector","Status":"Answered in part","Claim IDs":"C007, C015–C017","Exact remaining evidence or next action":"Exact location/branch activity and account nexus."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Digital-only collector","researcher_record":{"Assigned component":"Digital-only collector","Status":"Partial","Claim IDs":"C017, C031, C043","Exact remaining evidence or next action":"Location, electronic contacts, branch activity, and federal coverage."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Government collector","researcher_record":{"Assigned component":"Government collector","Status":"Answered federally","Claim IDs":"C036","Exact remaining evidence or next action":"State/public-debt authority outside scope."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Commercial collector","researcher_record":{"Assigned component":"Commercial collector","Status":"Answered as consumer-law boundary","Claim IDs":"C002, C032","Exact remaining evidence or next action":"General contract, tort, licensing, and commercial collection law later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan application","researcher_record":{"Assigned component":"Consumer Loan application","Status":"Route answered","Claim IDs":"C015–C021","Exact remaining evidence or next action":"Generate and inspect current entity-specific NMLS checklist when needed."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan fee","researcher_record":{"Assigned component":"Consumer Loan fee","Status":"Answered","Claim IDs":"C016","Exact remaining evidence or next action":"NMLS system charges, if any, remain checklist-specific."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan renewal/expiry","researcher_record":{"Assigned component":"Consumer Loan renewal/expiry","Status":"Answered in core","Claim IDs":"C015–C016","Exact remaining evidence or next action":"Current late-renewal/reinstatement mechanics from checklist."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan bond","researcher_record":{"Assigned component":"Consumer Loan bond","Status":"Answered operationally as none","Claim IDs":"C018","Exact remaining evidence or next action":"Recheck current NMLS checklist before application."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan qualifying persons","researcher_record":{"Assigned component":"Consumer Loan qualifying persons","Status":"Partial","Claim IDs":"C021","Exact remaining evidence or next action":"NMLS control-person forms and current checklist."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Consumer Loan branches","researcher_record":{"Assigned component":"Consumer Loan branches","Status":"Answered in core","Claim IDs":"C015–C017","Exact remaining evidence or next action":"Remote-worker/location interpretation requires actual facts."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Employee individual license","researcher_record":{"Assigned component":"Employee individual license","Status":"Answered as none","Claim IDs":"C017","Exact remaining evidence or next action":"Other professional licenses may apply."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Sales Finance application and fee","researcher_record":{"Assigned component":"Sales Finance application and fee","Status":"Answered in core","Claim IDs":"C011–C012","Exact remaining evidence or next action":"Current generated NMLS checklist."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Public license lookup","researcher_record":{"Assigned component":"Public license lookup","Status":"Answered","Claim IDs":"C019–C020, C054","Exact remaining evidence or next action":"No named provider checked."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Paper/display license","researcher_record":{"Assigned component":"Paper/display license","Status":"Answered as none","Claim IDs":"C020","Exact remaining evidence or next action":"Advertising/name duties still apply."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"BFID complaint route","researcher_record":{"Assigned component":"BFID complaint route","Status":"Partial","Claim IDs":"C022","Exact remaining evidence or next action":"Actual complaint procedure and SES materials entity-specific."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"OCP complaint route","researcher_record":{"Assigned component":"OCP complaint route","Status":"Answered operationally","Claim IDs":"—","Exact remaining evidence or next action":"Not a license lookup or adjudication."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA interest and late charges","researcher_record":{"Assigned component":"MCLA interest and late charges","Status":"Answered","Claim IDs":"C023–C024","Exact remaining evidence or next action":"Actual contract, balance, prior fee, and voluntary-service facts."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA receipts/payoff","researcher_record":{"Assigned component":"MCLA receipts/payoff","Status":"Answered","Claim IDs":"C025","Exact remaining evidence or next action":"Actual payment method and payoff date."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCLA advertising","researcher_record":{"Assigned component":"MCLA advertising","Status":"Answered","Claim IDs":"C026","Exact remaining evidence or next action":"Complete current rule body inaccessible."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Retail installment late charges","researcher_record":{"Assigned component":"Retail installment late charges","Status":"Answered","Claim IDs":"C013","Exact remaining evidence or next action":"Actual contractual method and default date."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Retail installment statements/receipts","researcher_record":{"Assigned component":"Retail installment statements/receipts","Status":"Answered","Claim IDs":"C014","Exact remaining evidence or next action":"Actual written request and payment facts."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"MCPA application to original creditors","researcher_record":{"Assigned component":"MCPA application to original creditors","Status":"Answered","Claim IDs":"C027–C028","Exact remaining evidence or next action":"Full standing/remedy analysis retained in separate pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State call-time rule","researcher_record":{"Assigned component":"State call-time rule","Status":"No general rule identified","Claim IDs":"C029","Exact remaining evidence or next action":"Monitor later statute/rule; federal coverage separately."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State call-frequency rule","researcher_record":{"Assigned component":"State call-frequency rule","Status":"No general rule identified","Claim IDs":"C030","Exact remaining evidence or next action":"Same."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_frequency_hold":"Q002person-and-debtpremise clarification pending_UNSENT"},{"topic":"State workplace-contact rule","researcher_record":{"Assigned component":"State workplace-contact rule","Status":"No general rule identified","Claim IDs":"C029–C031","Exact remaining evidence or next action":"MCPA and federal fact-specific analysis."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State represented-consumer rule","researcher_record":{"Assigned component":"State represented-consumer rule","Status":"No general rule identified","Claim IDs":"C029–C031","Exact remaining evidence or next action":"Jacobson federal/MCPA application does not create universal statute."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State third-party-contact rule","researcher_record":{"Assigned component":"State third-party-contact rule","Status":"No general rule identified","Claim IDs":"C029–C031","Exact remaining evidence or next action":"Privacy and federal law later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State cease-contact rule","researcher_record":{"Assigned component":"State cease-contact rule","Status":"No general rule identified","Claim IDs":"C029–C031","Exact remaining evidence or next action":"Federal written-notice rule if covered."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"State electronic opt-out","researcher_record":{"Assigned component":"State electronic opt-out","Status":"No general rule identified","Claim IDs":"C031","Exact remaining evidence or next action":"Regulation F if covered."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Harassment/abuse","researcher_record":{"Assigned component":"Harassment/abuse","Status":"Partial state MCPA plus federal","Claim IDs":"C027–C028, C042–C043","Exact remaining evidence or next action":"Actual conduct and private standing."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"False creditor/owner identity","researcher_record":{"Assigned component":"False creditor/owner identity","Status":"Answered in principle","Claim IDs":"C026–C028, C042, C046","Exact remaining evidence or next action":"Assignment proof and materiality."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"False legal or credit threat","researcher_record":{"Assigned component":"False legal or credit threat","Status":"Answered in principle","Claim IDs":"C027–C028, C042","Exact remaining evidence or next action":"Actual authority, intent, and federal coverage."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Unauthorized fees","researcher_record":{"Assigned component":"Unauthorized fees","Status":"Answered for selected account types","Claim IDs":"C013, C023–C024, C042, C048","Exact remaining evidence or next action":"Contract and debt-type classification."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Payment allocation","researcher_record":{"Assigned component":"Payment allocation","Status":"Unresolved in this pass","Claim IDs":"—","Exact remaining evidence or next action":"Later documentation/account pass and any applicable federal rule."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Payment receipts","researcher_record":{"Assigned component":"Payment receipts","Status":"Answered for MCLA/retail installment","Claim IDs":"C014, C025","Exact remaining evidence or next action":"Other debt types remain."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Repossession","researcher_record":{"Assigned component":"Repossession","Status":"Answered at UCC boundary","Claim IDs":"C040, C047","Exact remaining evidence or next action":"Notice, sale, deficiency, breach-of-peace cases later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Bankruptcy contact","researcher_record":{"Assigned component":"Bankruptcy contact","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Federal stay/discharge pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Deceased debtor contact","researcher_record":{"Assigned component":"Deceased debtor contact","Status":"Partial federal definition only","Claim IDs":"C041","Exact remaining evidence or next action":"Probate, estate, and actual representative later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Ambulance reporting","researcher_record":{"Assigned component":"Ambulance reporting","Status":"Partial boundary","Claim IDs":"C049","Exact remaining evidence or next action":"Full credit-reporting/furnishing pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"FDCPA definitions/exclusions","researcher_record":{"Assigned component":"FDCPA definitions/exclusions","Status":"Answered at gateway level","Claim IDs":"C032–C036","Exact remaining evidence or next action":"Full federal protocol later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Debt-buyer federal coverage","researcher_record":{"Assigned component":"Debt-buyer federal coverage","Status":"Answered at gateway level","Claim IDs":"C037–C038","Exact remaining evidence or next action":"Actual principal-purpose and portfolio facts."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Attorney federal coverage","researcher_record":{"Assigned component":"Attorney federal coverage","Status":"Answered","Claim IDs":"C039, C045","Exact remaining evidence or next action":"Actual regularity and claim."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Security-interest federal coverage","researcher_record":{"Assigned component":"Security-interest federal coverage","Status":"Answered","Claim IDs":"C040","Exact remaining evidence or next action":"Conduct beyond pure enforcement."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Federal communications","researcher_record":{"Assigned component":"Federal communications","Status":"Answered only at gateway level","Claim IDs":"C041–C043","Exact remaining evidence or next action":"Full validation, call logs, consent, and exceptions later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_frequency_hold":"Q002person-and-debtpremise clarification pending_UNSENT"},{"topic":"Regulation F electronic rules","researcher_record":{"Assigned component":"Regulation F electronic rules","Status":"Answered at gateway level","Claim IDs":"C043","Exact remaining evidence or next action":"Full safe-harbor protocol later."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00","coordinator_frequency_hold":"Q002person-and-debtpremise clarification pending_UNSENT"},{"topic":"FDCPA preemption/preservation","researcher_record":{"Assigned component":"FDCPA preemption/preservation","Status":"Answered","Claim IDs":"C044","Exact remaining evidence or next action":"Specific conflict analysis if state rule identified."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Validation notice/documentation","researcher_record":{"Assigned component":"Validation notice/documentation","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Dedicated later pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Dispute handling","researcher_record":{"Assigned component":"Dispute handling","Status":"Excluded except general conduct","Claim IDs":"—","Exact remaining evidence or next action":"Dedicated validation/documentation pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Account-level ownership proof","researcher_record":{"Assigned component":"Account-level ownership proof","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Dedicated documentation/litigation pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Credit reporting/furnishing","researcher_record":{"Assigned component":"Credit reporting/furnishing","Status":"Excluded except ambulance crossover","Claim IDs":"C049","Exact remaining evidence or next action":"Dedicated reporting pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Debt-specific limitations/revival","researcher_record":{"Assigned component":"Debt-specific limitations/revival","Status":"Excluded","Claim IDs":"C045 only as case boundary","Exact remaining evidence or next action":"Dedicated limitations pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Collection suit/service/default judgment","researcher_record":{"Assigned component":"Collection suit/service/default judgment","Status":"Excluded except attorney gateway","Claim IDs":"C039, C045","Exact remaining evidence or next action":"Dedicated litigation pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Garnishment/execution","researcher_record":{"Assigned component":"Garnishment/execution","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Dedicated remedies/litigation pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Full collector remedies/private rights","researcher_record":{"Assigned component":"Full collector remedies/private rights","Status":"Excluded","Claim IDs":"C022–C024, C053 only as boundaries","Exact remaining evidence or next action":"Dedicated remedies pass."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Local and tribal law","researcher_record":{"Assigned component":"Local and tribal law","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Separate jurisdictional passes."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Current complete ARM text","researcher_record":{"Assigned component":"Current complete ARM text","Status":"Unresolved","Claim IDs":"C051","Exact remaining evidence or next action":"Authenticated current body or certified export."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Post-2025 legislative currentness","researcher_record":{"Assigned component":"Post-2025 legislative currentness","Status":"Partial","Claim IDs":"C052","Exact remaining evidence or next action":"Comprehensive later session/special-session and future-effective audit."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"},{"topic":"Actual provider authorization","researcher_record":{"Assigned component":"Actual provider authorization","Status":"Unresolved/excluded","Claim IDs":"C054","Exact remaining evidence or next action":"Official entity-specific NMLS check only when provider named."},"coordinator_acceptance":"scoped_review_with_version_application_and_Q001traceability_holds_not_parent_acceptance","coordinator_review":"[internal evidence reference]","coordinator_reviewed_at":"2026-10-29T02:43:58.845478+00:00"}],"annotations":{},"corrections":[{"issue_id":"S_MT-P08-Q001","finding":"Multiple example references point to different propositions. E09fee arithmetic citesC018-C020(bond/NMLS/paperlicense),notC023-C024(fee formula/forfeiture). E08frequency/optout citesC025/C037-C039(receipt/debtbuyer/attorney),notC043. Existing supported narrative is retained, but these references cannot serve as precise evidence links.","affected_claim_ids":[],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":[],"localization":"report_level_pending_localization_required","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."},{"issue_id":"S_MT-P08-Q002","finding":"The report states eight connected calls about one debt but does not expressly constrain all calls to the same particular person. The operative frequency presumption is person-and-debt specific, not a debt-wide aggregate across different persons.","affected_claim_ids":[],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":["https://www.ecfr.gov/current/title-12/chapter-X/part-1006/subpart-B/section-1006.14"],"localization":"report_level_pending_localization_required","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."}],"resolved_corrections":[],"review_history":[{"id":"S_MT-P08-scoped-review-20261029","status":"reviewed_Q001_Q002_pending_UNSENT_with_source_application_holds","at":null}]}