{"meta":{"key":"s_ne--pass-01","task":"S_NE","title":"SNE Nebraska provider market access and consumer fees","parent_title":"Nebraska debt and debt relief law","edition":"pass-01","path":"/research/s_ne--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":5,"claims":34,"sources":17,"review_status":"revise","review_complete":true,"sha256":"abd8a1df2dadf00a73bb3d0276d24159e421ae209f3305ce405a83f8de4ec658","headings":["Executive determination","Model disposition matrix","1. Definitions and classification","1.1 Nebraska “debt management”","1.2 DMP and concession services","1.3 Principal-reduction settlement","1.4 Noncustodial negotiation-only service","1.5 Conditional Credit Services Organization Act overlap","1.6 Consumer versus business purpose","1.7 Nebraska resident and remote-provider nexus","2. Prohibited, licensed, registered, or exempt models","2.1 Covered debt management is licensed—not merely registered","2.2 Chapter 69 exemptions","2.3 Credit-services registration and bond","2.4 CSO exemptions","2.5 Money-transmission crossover","3. Applicable consumer fees and present limits","3.1 Licensed Chapter 69 debt-management fees","3.2 Statutory base—not “enrolled debt”","3.3 No verified indexing or adjusted amounts","3.4 Nebraska CSO fees","3.5 Nebraska CSO cancellation refund","4. When fees may be requested or received","4.1 Nebraska Chapter 69 timing","4.2 Federal TSR debt-relief timing—separate common context","4.3 Federal dedicated accounts","4.4 Separate TSR credit-repair timing","4.5 Federal CROA overlap","5. Actual regulator access, application, and lookup","5.1 Debt-management regulator and procedure","5.2 Debt-management public roster","5.3 CSO regulator and lookup","5.4 Rules and guidance status","6. Worked fee and boundary examples","Example 1 — Standard 12-month licensed custodial DMP","Example 2 — Lower balance where $25 exceeds nominal monthly amortization","Example 3 — Cancellation after four lawfully applied monthly fees","Example 4 — Individually settled debt under the TSR proportional method, with Nebraska monthly cap","Example 5 — Noncustodial 25%-of-enrolled-debt proposal","Example 6 — Nebraska CSO plus federal CROA","Example 7 — CSO obtaining a Nebraska Installment Loan and Sales Act loan","Exact next investigations","Actually opened and read","Discovery/search-rendered or limited-access material","Not read or not performed"],"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_NE/pass-01","facets":{"geography":["us","us-ne"],"debt_type":[],"stage":["repossession"],"subject":["fees-outcomes","provider-licensing"]},"scope":"FreshNebraskaprovider-access/feescomponentonly; allbroaderstatecategoriesrequired","pending_corrections":0},"markdown":"# S_NE PASS-01 — Nebraska provider market access and consumer fees\n\n**Actual research/access date:** October 24, 2026, Pacific time\n**Execution:** Regular Chat with public-web browsing; actual available model was GPT-5.6 Sol Pro under the authorized quality-first fallback. No Deep Research, Work, Chrome control, APIs, purchases, account changes, contacts, other chats, private borrower data, applications, or publication actions were used.\n\n**Component status:** Substantive provider-access and consumer-fee research completed with explicit holds. This is **not** Nebraska-wide approval, a provider authorization opinion, A066 acceptance, or completion of the remaining Nebraska dossier.\n\n## Executive determination\n\nNebraska’s specific Debt Management Act is best read as a **custodial debt-management statute**, not as an all-purpose license for every business calling itself a debt-settlement company. Its definition requires both:\n\n1. fee-based planning and management of a qualifying debtor’s financial affairs; **and**\n2. receipt from that debtor of money or “evidences thereof” for distribution to creditors.\n\nA business satisfying those elements must obtain a Nebraska Secretary of State debt-management license before operating. A licensed model may include creditor concessions and principal-reduction compromises; principal reduction does not move an otherwise covered custodial program outside the Act. [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201)\n\nThe Act’s principal consumer-fee limit is:\n\nTotal contracted fee ≤ 15% × the amount of money agreed to be paid through the licensee.\n\nThat is **not** a verified 15%-of-enrolled-debt rule, a savings-based fee, or an across-the-board authorization for negotiation-only debt settlement. The fee must be amortized over the contract, a credited initial payment may not exceed $25, and cancellation compensation may not exceed 25% of the remaining unamortized contracted fee. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212)\n\nA provider that negotiates but never receives or controls debtor funds appears, under the text’s conjunctive wording, to fall outside the specific Chapter 69 definition. But this investigation did **not** establish that such a model is affirmatively authorized in Nebraska. “Evidences thereof,” third-party dedicated-account control, payment authority, remote-provider nexus, and possible application of the Nebraska Credit Services Organization Act remain material classification questions. Federal TSR compliance does not create Nebraska permission.\n\n## Model disposition matrix\n\n| Business model | Nebraska disposition established in this pass | Required authority or principal hold |\n| --- | --- | --- |\n| Custodial DMP—provider plans finances, receives debtor funds, distributes to creditors | **Licensed pathway established** | Nebraska Secretary of State debt-management license under §§69-1201–69-1217; bond, contract, account, and other conditions apply. C001–C006 |\n| Custodial principal-reduction settlement—same custody/distribution features, but provider negotiates compromises | **Licensed pathway established** | Compromises are expressly contemplated by §69-1213(5); same Chapter 69 license and fee regime. C003–C006 |\n| Noncustodial settlement negotiation—consumer retains funds in an independent account and provider cannot receive/control them | **No affirmative Nebraska pathway established; HOLD** | Plain §69-1201 text may place it outside Chapter 69, but no court/agency interpretation was located for “evidences thereof,” account control, payment instructions, or remote operation. It may conditionally fall under the CSO Act. C007, C018 |\n| Provider-controlled or provider-affiliated dedicated account | **Likely classification risk; not approved** | Federal dedicated-account conditions do not decide Nebraska “receiving” or “evidences thereof.” Exact Nebraska treatment remains held. C007, C025 |\n| Fee-based counseling/advice without receiving creditor-distribution funds | **Apparently outside Chapter 69 on the text; other-law hold** | May be a Nebraska credit-services organization when credit-improvement or credit-obtaining representations are made. C007, C018 |\n| Free education or self-help tools, with no provider fee and no receipt of funds | **Outside the literal Chapter 69 definition on those facts** | No fee and no custody; deceptive-practice, legal-services, referral, and other later-pass issues remain open. C001 |\n| Credit-improvement/credit-repair service | **Conditional registration pathway** | Nebraska CSO registration and $100,000 bond/account unless exempt; federal CROA and possibly TSR impose stricter fee timing. C018–C027 |\n| Service to obtain an extension of credit | **Conditional CSO pathway** | No provider payment before the credit is obtained; zero-fee rule for a loan governed by the Nebraska Installment Loan and Sales Act. C021 |\n| Attorney actually acting in regular course of legal profession | **Conditionally exempt from Chapter 69** | A marketing affiliation, attorney ownership, or nominal attorney relationship is not enough. C005–C006 |\n| 501(c)(3) nonprofit | **No Chapter 69 nonprofit exemption** | Nebraska CSO Act and federal CROA have distinct 501(c)(3) exemptions, but those do not exempt a covered custodial model from Chapter 69. C006, C019, C027 |\n| Bank or other listed institution | **Conditionally exempt** | Only as stated in §69-1202 and while performing the activity in the regular course of the entity’s principal authorized business. C005 |\n| Covered Chapter 69 activity without license | **Unlawful; potentially criminal** | Knowing or willful unlicensed debt management is a Class II misdemeanor. C004 |\n\n# A. Substantive answers to the numbered scope\n\n## 1. Definitions and classification\n\n### 1.1 Nebraska “debt management”\n\nNeb. Rev. Stat. §69-1201(1) defines debt management through a conjunctive set of activities:\n\n- planning and managing the financial affairs of a debtor;\n- for a fee from the debtor; **and**\n- receiving from the debtor money or “evidences thereof” for distribution to creditors in payment or partial payment of obligations.\n\nThe qualifying “debtor” is a wage earner whose principal income comes from wages, salary, or commission. “Creditor” is framed in terms of a person for whose benefit money is collected and disbursed by the licensee. C001–C002. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201)\n\nThis produces four important boundaries:\n\n1. **Custody/distribution is part of the definition.** Financial advice or negotiation alone does not plainly satisfy the entire definition.\n2. **A marketing label is not decisive.** A business calling itself “credit counseling,” “debt resolution,” “debt settlement,” “financial wellness,” or “legal support” is covered if its actual conduct satisfies the statutory elements.\n3. **The statute does not separately define DMP and debt settlement.** Those labels must be classified by actual conduct.\n4. **“Evidences thereof” creates an unresolved perimeter.** No Nebraska court or official interpretation was located explaining whether it includes ACH authority, withdrawal authority, a payment instruction, control of a consumer-owned account, or another noncash instrument.\n\n### 1.2 DMP and concession services\n\nA conventional DMP in which the provider:\n\n- performs a budget analysis,\n- arranges creditor concessions,\n- receives the consumer’s monthly payment, and\n- remits funds to creditors\n\nfalls squarely within the Chapter 69 model. The Act requires a separate debtor-benefit account and generally requires remittance to creditors within 15 days—seven days for cash—with a maximum 35-day holding period where reasonable accumulation is needed. C001, C010. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\n### 1.3 Principal-reduction settlement\n\nPrincipal reduction is not excluded. Section 69-1213(5) expressly states that when a licensee arranges a compromise with one or more creditors, the debtor must receive the full benefit of the compromise. Thus, a custodial program does not cease being licensed debt management merely because it negotiates less-than-full-balance settlements rather than only interest or payment concessions. C003. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213)\n\nThat does **not** mean every negotiation-only settlement service is licensed under Chapter 69. The receipt/distribution element still has to be addressed.\n\n### 1.4 Noncustodial negotiation-only service\n\nThe strongest textual reading of §69-1201 is that a provider that only negotiates and never receives debtor money or an “evidence thereof” for creditor distribution does not satisfy the whole Chapter 69 definition. This is an interpretation from the conjunctive text—not a located Nebraska judicial holding.\n\nAccordingly:\n\n- The Chapter 69 license and 15% fee formula cannot safely be treated as an affirmative license or fee authorization for that model.\n- An independently administered, consumer-owned dedicated account may reduce custody risk, but the federal dedicated-account rule does not resolve Nebraska’s broader “evidences thereof” language.\n- A provider’s contractual power to direct payments, approve disbursements, debit fees, replace the account administrator, or condition settlements on account balances could materially change the classification.\n- No Nebraska court decision or Secretary of State interpretation resolving those facts was located.\n\n**Disposition:** Chapter 69 coverage is uncertain to unlikely on a truly noncustodial fact pattern, but **public market access remains held rather than approved**. C007, C025, C031.\n\n### 1.5 Conditional Credit Services Organization Act overlap\n\nNebraska separately defines a “credit services organization” as a person who, for payment and with respect to credit extended by others, provides or represents that it will provide:\n\n- improvement of a buyer’s credit record, history, or rating;\n- obtaining an extension of credit; or\n- advice or assistance concerning either activity.\n\n“Buyer” means an individual, and “extension of credit” is limited to credit primarily for personal, family, or household purposes. C018. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-802)\n\nTherefore, a noncustodial settlement provider does **not automatically** become a CSO merely because settlement may eventually affect a credit score. The trigger is the service actually provided or represented. Statements such as these would materially increase CSO/CROA risk:\n\n- “We improve your credit.”\n- “Our program repairs your credit history.”\n- “We remove negative debt entries.”\n- “We help you qualify for new credit.”\n- “Enroll now so your score recovers.”\n\nA debt-management licensee is expressly exempt from Nebraska’s CSO Act. Thus, a properly licensed Chapter 69 provider ordinarily does not need duplicate CSO registration for conduct within the debt-management license. C019. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-803)\n\n### 1.6 Consumer versus business purpose\n\nThe two Nebraska regimes use different boundaries:\n\n- **Debt Management Act:** “debtor” is a wage earner whose principal income derives from wages, salary, or commission. The Act does not expressly say the obligations must be personal, family, or household debts. A business entity is not naturally a “wage earner,” but application to an individual’s business-purpose obligations was not resolved by a located decision. C002.\n- **CSO Act:** the credit must be offered or granted primarily for personal, family, or household purposes, and the buyer must be an individual. C018.\n- **Federal TSR:** telemarketing calls between a telemarketer and a business to induce a business purchase are generally exempt, subject to the rule’s stated exceptions. That federal provision does not determine Nebraska Chapter 69 coverage. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6)\n\n**Hold:** Do not categorically treat sole-proprietor or personally guaranteed business debt as included or excluded from Chapter 69 without fact-specific Nebraska analysis.\n\n### 1.7 Nebraska resident and remote-provider nexus\n\nThe Act requires a license to engage in debt-management business “in this state,” but the reviewed statute does not provide an express resident-customer, internet solicitation, remote-office, or choice-of-law test. Section 69-1201 defines an “office” as each physical location where debt management occurs, while the application statute requests the exact office location. C008. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201)\n\nThe July 9, 2026 active roster contains many licensees with addresses outside Nebraska. That proves that out-of-state entities can and do use the Nebraska license. It does **not** independently prove the exact threshold at which an out-of-state company serving a Nebraska resident is deemed to conduct business “in this state.” [Nebraska Secretary of State+2](https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf)\n\n**Remote nexus remains unresolved.** The conservative provider-access assumption is that delivering a covered custodial program to Nebraska wage earners creates licensing risk even without a Nebraska office, but this pass did not locate a controlling nexus interpretation.\n\n## 2. Prohibited, licensed, registered, or exempt models\n\n### 2.1 Covered debt management is licensed—not merely registered\n\nSection 69-1203 makes it unlawful to engage in debt-management business without first obtaining the required license. Section 69-1205 directs the Secretary of State to investigate responsibility, experience, character, fitness, felony history, and prior defaults in accounting for money before issuing the license. Knowing or willful unlicensed operation is a Class II misdemeanor. C004. [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203)\n\nThe principal licensing conditions relevant to this component include:\n\n- written application to the Secretary of State;\n- $200 main-office license fee within each county;\n- $100 for each additional office;\n- $200 initial investigation fee;\n- $10,000 bond;\n- filing a blank copy of the intended debtor contract;\n- notice of contract changes within 30 days;\n- expiration on December 31;\n- renewal application by December 1 with a $100 renewal fee and bond;\n- separate application for each office.\n\nThese are government/provider charges, not consumer-fee permissions. C016. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204)\n\n### 2.2 Chapter 69 exemptions\n\nThe Act excludes the following only when they act in the regular course of their respective businesses or professions:\n\n- attorneys at law;\n- duly authorized/admitted banks, fiduciaries, financing institutions, and lending institutions performing credit and financial adjusting in the regular course of their principal business;\n- title insurers and abstract companies while doing escrow business;\n- employees of licensed debt managers; and\n- judicial officers or others acting under court orders. C005. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202)\n\nImportant failures of exemption:\n\n- There is **no express nonprofit exemption** in §69-1202.\n- Forming a 501(c)(3) does not by itself exempt a custodial debt-management program.\n- Having an attorney as owner, advisor, vendor, or nominal program participant does not establish that the business itself is an attorney acting in the regular course of the legal profession.\n- A financial institution is not exempt for every affiliate or outsourced service merely because it has a regulated institution somewhere in the structure.\n- The person asserting a CSO exemption bears the burden under that separate statute; Chapter 69 does not contain an equivalent burden clause, but its exemptions remain activity-limited. C005–C006.\n\n### 2.3 Credit-services registration and bond\n\nA covered Nebraska CSO must, before conducting business in the state:\n\n- file a registration statement with the Secretary of State;\n- disclose specified ownership and Nebraska governmental litigation/complaint information;\n- update material registration information within 90 days;\n- permit a buyer to inspect the registration;\n- obtain a $100,000 surety bond or establish a qualifying $100,000 surety account; and\n- provide the statutory precontract disclosure and written contract.\n\nThe Secretary may charge a filing fee up to $100. That is a government filing charge, not a consumer-fee cap. C020. [Nebraska Legislature+3](https://nebraskalegislature.gov/laws/statutes.php?statute=45-805)\n\n### 2.4 CSO exemptions\n\nThe CSO Act exempts, among others:\n\n- regulated lenders;\n- insured banks and qualifying subsidiaries;\n- credit unions;\n- §501(c)(3) nonprofits;\n- Nebraska real estate licensees within their licensed scope;\n- attorneys licensed in Nebraska acting within their legal practice;\n- specified securities professionals within scope;\n- consumer reporting agencies;\n- certain real-estate-secured lenders;\n- Nebraska collection agencies and solicitors acting within their licensed scope; and\n- Nebraska debt-management licensees.\n\nThe claimant bears the burden of proving the exemption. C019. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-803)\n\n### 2.5 Money-transmission crossover\n\nEffective July 18, 2026, Nebraska’s Money Transmitters Act expressly exempts a person licensed in Nebraska and acting within the state within the scope of a:\n\n- collection-agency license;\n- CSO license/registration; or\n- debt-management license.\n\nThat exemption does not establish that an unlicensed or out-of-scope settlement model is exempt from money-transmission regulation. It also does not answer whether a particular dedicated-account structure constitutes money transmission in the first place. C029. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\n## 3. Applicable consumer fees and present limits\n\n### 3.1 Licensed Chapter 69 debt-management fees\n\n| Fee element | Current verified Nebraska rule | Important boundary |\n| --- | --- | --- |\n| Total contracted fee | No more than **15% of the amount of money agreed to be paid through the licensee** | Do not substitute enrolled balance, original debt balance, amount saved, or amount forgiven for the statutory base. |\n| Contract period | Maximum 36 months | Actual contracted fee—not automatically the statutory maximum—must be amortized across the contract. |\n| Periodic/monthly application | No more than the monthly amortized amount may be applied while contract is active | No verified retroactive “catch-up” rule was located. |\n| Initial payment | Up to **$25**, credited to total fee | Not an extra fee above the total cap. Its relationship to a smaller monthly amortized amount is unresolved. |\n| Cancellation | Not more than **25% of the remaining unamortized contracted fee** | Text does not clearly resolve whether this is an additional exit charge on top of lawfully applied fees or the entire remaining settlement. |\n| Prepayment | Contract must clearly state the settlement provision | No separate statutory prepayment formula was located. |\n| Per-debt settlement fee | No separate state authorization | Any label remains subject to total cap and amortization if the model is Chapter 69 debt management. |\n| Savings fee | No separate state authorization | Federal TSR may permit a uniform percentage-of-savings allocation when applicable, but Nebraska’s own cap remains based on money agreed through the licensee. |\n| Setup/enrollment fee | Only the credited initial payment is specifically identified | Renaming a charge does not avoid total cap or timing restrictions. |\n| Additional “costs” | **HOLD** | §69-1213(2) uses “less fees and costs” in describing remittances, but no open-ended consumer-cost authority, definition, or cap was located. Do not infer unlimited pass-through costs. |\n| Referral compensation | Prohibited for licensee referral of debtors or acceptance/payment of referral bonuses | Cannot be turned into a separate consumer charge. |\n| Promissory-note or secured fee | Prohibited | A licensee cannot take a note, mortgage, or other security for its fee. |\n\nThe operative fee language appears in §69-1212; the 36-month limit appears in §69-1209; the separate-account and remittance provisions appear in §§69-1210 and 69-1213; and prohibited fee forms and referrals appear in §69-1214. C009–C014, C034. [Nebraska Legislature+4](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209)\n\n### 3.2 Statutory base—not “enrolled debt”\n\nThe exact current statutory base is:\n\nthe amount of money agreed to be paid through the licensee.\n\nNo authority reviewed converts this into:\n\n- gross enrolled balance;\n- starting account balance;\n- amount forgiven;\n- amount saved;\n- settlement amount when the settlement funds do not pass through the licensee; or\n- a generic 15% fee for every Nebraska debt-settlement customer.\n\nThe statute does not expressly resolve whether “money agreed to be paid through the licensee” excludes the licensee’s own fee or means only creditor-bound funds. Sections 69-1201, 69-1210, and 69-1213 strongly associate the pass-through money with creditor distributions, but no controlling interpretation was located. The exact denominator should therefore be stated in the contract and treated conservatively. C011, C031.\n\n### 3.3 No verified indexing or adjusted amounts\n\nSection 69-1212 still states:\n\n- 15%;\n- $25 initial payment; and\n- 25% of the remaining unamortized fee on cancellation.\n\nThe statute contains no CPI or periodic adjustment formula. No debt-management fee adjustment bulletin, order, or verified regulation changing those figures was located. The official dynamic rules catalog could not be fully retrieved through the permitted non-JavaScript route, so the narrower finding is:\n\n- **No statutory indexing exists.**\n- **No current adjustment notice was verified.**\n- A categorical statement that no relevant regulation has ever existed remains held pending a fully accessible Title 433 and rulemaking-docket review. C015, C030.\n\nThe Nebraska Department of Banking and Finance consumer article saying settlement companies “often charge 15–25% of enrolled debt” is general educational content, not the Chapter 69 fee formula or a Nebraska fee authorization. C032. [Nebraska Banking and Finance](https://ndbf.nebraska.gov/are-debt-settlement-plans-you)\n\n### 3.4 Nebraska CSO fees\n\nThe Nebraska CSO Act does not provide a general consumer percentage or dollar cap.\n\nIts state-law timing rules are:\n\n1. For services other than obtaining credit, no money may be charged or received before all agreed services are completed **unless** the CSO has the required bond or surety account.\n2. For obtaining or attempting to obtain credit, no money may be charged or received before the credit is obtained.\n3. No fee may be charged solely for referring a buyer to a retail seller offering substantially the same credit generally available to the public.\n4. No brokerage or other fee whatsoever may be charged in connection with a loan governed by the Nebraska Installment Loan and Sales Act.\n5. The total cost and payment terms must be disclosed in the precontract statement and contract. C021. [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=45-804)\n\nThe state bond exception is not an answer to federal CROA or TSR advance-fee rules.\n\n### 3.5 Nebraska CSO cancellation refund\n\nA buyer may cancel a Nebraska CSO contract before midnight of the third day after signing. The Nebraska text says “third day,” not “third business day.” If the buyer cancels, the CSO must return any payment within ten days after receiving the cancellation notice. C022. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-808)\n\nFederal CROA separately provides a three-**business-day** period and bars the provision of services during that period. The stricter applicable requirement governs.\n\n## 4. When fees may be requested or received\n\n## 4.1 Nebraska Chapter 69 timing\n\nA licensed debt manager is not entitled to a fee or charge until the debt-management program has been:\n\n1. arranged; and\n2. approved by the debtor.\n\nThe contract is not effective until the debtor makes a payment to the licensee for distribution to creditors. Fees must then be applied no faster than the contractual monthly amortization, subject to the credited initial-payment language. C014. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212)\n\nThe statute does not cleanly resolve the sequence between:\n\n- the credited $25 initial payment;\n- program arrangement and approval;\n- the first creditor-distribution payment; and\n- contract effectiveness.\n\nA conservative implementation would not treat the $25 as earned before the program is arranged and approved, and would not treat the Chapter 69 contract as effective before a separate creditor-distribution payment occurs. Federal law may delay any fee still further.\n\n## 4.2 Federal TSR debt-relief timing—separate common context\n\nWhen the Telemarketing Sales Rule applies to the transaction, a seller or telemarketer may not request or receive a debt-relief fee until:\n\n1. at least one debt has actually been renegotiated, settled, reduced, or otherwise altered under a settlement agreement, DMP, or other valid agreement executed by the customer;\n2. the customer has made at least one payment under that agreement; and\n3. for individually resolved debts, the fee is allocated using one consistent permitted method:the same proportional relationship as the debt’s enrolled amount bears to total enrolled debt; orthe same percentage of savings for every debt.\n\nThe two methods cannot be switched opportunistically from debt to debt. C023–C024. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe TSR’s definition reaches services represented to alter terms of unsecured debt, including balance, interest, or fees. Its telemarketing definition requires a plan, program, or campaign involving more than one interstate telephone call. Calls responding to general advertisements and direct mail do not receive the ordinary inbound-call exemption when the advertisement concerns debt-relief services. Business-to-business calls are separately treated. C023. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nAccordingly:\n\n- Nebraska’s $25 initial-payment provision is **not** federal advance-fee authorization.\n- Nebraska’s monthly amortization does not permit a fee before the TSR trigger.\n- After a TSR trigger, Nebraska’s monthly cap can remain the tighter limit.\n- No authority was located allowing retroactive collection of several missed Nebraska monthly installments immediately after the first TSR trigger.\n\n## 4.3 Federal dedicated accounts\n\nThe TSR permits a provider to require deposits into a dedicated account only when:\n\n- funds are held at an insured institution;\n- the customer owns the funds and receives any interest;\n- the administrator is independent of the debt-relief service;\n- no referral compensation is exchanged; and\n- the customer can withdraw without penalty and receive all unearned funds within seven business days.\n\nThis federal safe structure does not establish that Nebraska will regard every such account as noncustodial. Nebraska’s “money or evidences thereof” language and the provider’s actual contractual authority remain decisive unresolved facts. C025. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## 4.4 Separate TSR credit-repair timing\n\nWhere the seller or telemarketer represents that it will remove derogatory information or improve a person’s credit history, record, or rating, 16 C.F.R. §310.4(a)(2) separately bars payment until:\n\n- the represented service period has expired; and\n- the seller has provided a consumer report demonstrating the promised result, issued more than six months after the result was achieved.\n\nThat is distinct from the debt-relief trigger in §310.4(a)(5). A business making both settlement and credit-improvement representations may need to satisfy both applicable branches rather than selecting the easier one. C026. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## 4.5 Federal CROA overlap\n\nFederal CROA conditionally applies where a person uses interstate commerce or the mails, for payment, for an express or implied purpose of improving a consumer’s credit record, history, or rating—or provides advice concerning such improvement.\n\nCROA:\n\n- bars charging or receiving payment for an agreed service before that service is fully performed;\n- requires a written contract;\n- prohibits service during the first three business days;\n- grants cancellation without penalty before midnight of the third business day; and\n- contains specific exemptions, including qualifying §501(c)(3) nonprofits, a creditor restructuring its own debt, and depository institutions or credit unions and qualifying affiliates.\n\nA Nebraska CSO bond does not create a federal CROA advance-fee exception. C027. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1679a/)\n\n## 5. Actual regulator access, application, and lookup\n\n### 5.1 Debt-management regulator and procedure\n\nThe issuing regulator is the **Nebraska Secretary of State**.\n\nIts public Debt Management Agencies page links:\n\n- the licensed-agency roster;\n- license application;\n- personal/corporate financial statement;\n- officer interrogatory;\n- bond form;\n- branch-office application; and\n- governing statutes. C017. [Nebraska Secretary of State](https://sos.nebraska.gov/licensing/debt-management-agencies)\n\nThe application form operationally requests entity and office information and supporting organizational documents, and reflects the statutory initial fee and investigation fee. The statute—not the form—is the controlling source of legal permission. [Nebraska Secretary of State+1](https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf)\n\n### 5.2 Debt-management public roster\n\nThe opened roster is titled **“Active Debt Management Agency Licensees,”** dated July 9, 2026, and states that all listed licenses expire December 31, 2026. It contains both Nebraska and out-of-state addresses. C017. [Nebraska Secretary of State+2](https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf)\n\nLimitations:\n\n- It is a dated snapshot, not proven real-time status on October 24.\n- It does not display license numbers or disciplinary history in the extracted fields.\n- No named provider was submitted or tested.\n- Presence on the roster establishes listed status as of the roster’s date—not permission for conduct outside the license’s scope.\n- Absence from the roster should be rechecked against the agency’s current public record before making a provider-specific conclusion.\n\n### 5.3 CSO regulator and lookup\n\nThe Secretary of State’s Credit Services Organizations page links the active registration roster, registration form, bond form, and statutes. The opened active roster is dated July 9, 2026. The registration form reflects the $100 filing fee and $100,000 bond/account structure. C020. [Nebraska Secretary of State+4](https://sos.nebraska.gov/licensing/credit-services-organizations)\n\nAgain, registration procedure is distinct from a conclusion that a particular company is currently registered or that its particular debt-settlement model is within the registration.\n\n### 5.4 Rules and guidance status\n\nThe Secretary of State’s official index lists Title 433 as “Licensing Regulations.” Its current public licensing-guidance list names guidance for athlete agents, civil-litigation funding, collection-agency work-from-home operations, and private detectives; it does not list debt-management guidance. The February 19, 2026 annual index shows the same general structure. C030. [Nebraska Secretary of State+2](https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents)\n\nHowever:\n\n- the official Title 433 catalog and proposed-rule docket returned only a JavaScript shell through the permitted route;\n- no API, Chrome-control workaround, or account action was used;\n- several directly indexed Title 433 chapter documents were opened and identified as other licensing subjects, but a fully consolidated current Title 433 package was not available;\n- therefore, this report does **not** make the categorical claim that no debt-management regulation, adoption order, pending amendment, or historical interpretation exists.\n\nThe current statute and publicly available operational materials are sufficient to identify the statutory license and fee structure, but not to close the regulation-history gap.\n\n## 6. Worked fee and boundary examples\n\nAll monetary figures are dollars. Percentages are converted to decimals for multiplication. No rounding is needed except where stated. These examples show legal ceilings and boundaries; they do not establish a particular provider’s authorization.\n\n### Example 1 — Standard 12-month licensed custodial DMP\n\n**Inputs**\n\n- Money contractually agreed to be paid through licensee: B = $6,000\n- Contract term: n = 12 months\n- Contracted fee: F = statutory maximum\n- Nebraska percentage: r = 15%\n\n**Operator**\n\n- Aggregate ceiling = B × r\n- Monthly amortized amount = F ÷ n\n\n**Intermediate**\n\n- $6,000 × 0.15 = $900\n- $900 ÷ 12 = $75 per month\n\n**Result**\n\n- Maximum total contracted fee: **$900**\n- Maximum monthly amount applied while contract remains active: **$75**\n- Initial payment: up to **$25**, credited against the $900—not added on top of it.\n\n**Timing conditions**\n\n- Program must first be arranged and approved.\n- Contract is not effective until a payment is made for creditor distribution.\n- If TSR applies, no fee—including the $25—may be requested or received before the federal performance trigger.\n\n**Initial-payment ambiguity**\n\nThe statute does not expressly say whether the $25 is:\n\n- part of the first $75 installment; or\n- a separate initial application followed by later installments reduced so total fees remain $900.\n\nThe conservative first-month treatment is $25 initial plus no more than $50 additional fee that month. A provider using $25 plus the full $75 in month one should obtain authoritative support and ensure later amortization prevents total fees exceeding $900.\n\n### Example 2 — Lower balance where $25 exceeds nominal monthly amortization\n\n**Inputs**\n\n- B = $1,200 through the licensee\n- n = 12 months\n- r = 15%\n\n**Operator and intermediate**\n\n- Total ceiling = $1,200 × 0.15 = $180\n- Nominal monthly amount = $180 ÷ 12 = $15\n\n**Result**\n\n- Total fee cannot exceed **$180**.\n- Nominal monthly amortization is **$15**.\n- The statute separately allows a credited initial payment up to **$25**.\n\n**Boundary**\n\nBecause the text introduces the $25 with an exception to the monthly rule, a $25 initial payment is textually plausible even though it exceeds $15. But the exact later-month adjustment is not specified.\n\nTwo possible accountings are:\n\n1. count only $15 as a first-month charge and treat the remaining $10 as unearned debtor money until later; or\n2. apply $25 initially, then reduce later installments so cumulative fees never exceed $180.\n\nNo controlling interpretation was located. It would be unsafe to charge $25 plus twelve additional $15 installments because that equals $205 and exceeds the lawful total by $25.\n\n### Example 3 — Cancellation after four lawfully applied monthly fees\n\n**Inputs**\n\n- B = $6,000\n- Total contracted fee F = $900\n- n = 12 months\n- Monthly amount = $75\n- Four monthly amounts were lawfully applied after all applicable state and federal triggers.\n\nTo keep the scenario internally consistent, assume either:\n\n- the TSR does not apply; or\n- an executed DMP altered all covered debts together, the debtor made the required payment, and the four fees were collected only afterward.\n\n**Intermediate**\n\n- Fees already applied = 4 × $75 = $300\n- Remaining unamortized fee = $900 − $300 = $600\n- Cancellation ceiling = $600 × 0.25 = $150\n\n**Result**\n\n- Previously applied fees: **$300**\n- Maximum cancellation amount under the apparent additional-charge reading: **$150**\n- Maximum cumulative total under that reading: **$450**\n\n**Interpretive hold**\n\nSection 69-1212 does not expressly state whether the 25% amount:\n\n- is an additional cancellation charge on top of already earned fees; or\n- is the complete remaining settlement on cancellation.\n\nThe $150 ceiling is mathematically correct, but the legal characterization remains unresolved.\n\n### Example 4 — Individually settled debt under the TSR proportional method, with Nebraska monthly cap\n\n**Inputs**\n\n- Total debt enrolled for TSR allocation: E = $10,000\n- Debt A enrolled amount: A = $4,000\n- Debt B enrolled amount: $6,000\n- Amount agreed to pass through Nebraska licensee: B_NE = $10,000\n- Total contracted fee: F = $1,500\n- Contract term: 20 months\n- TSR method selected: proportional enrolled-debt method for every debt\n- Prior fees before any settlement trigger: $0\n\n**Nebraska calculations**\n\n- Nebraska ceiling = $10,000 × 0.15 = $1,500\n- Monthly cap = $1,500 ÷ 20 = $75\n\n**TSR Debt A allocation**\n\n- Debt A proportion = $4,000 ÷ $10,000 = 0.40\n- Maximum fee attributable to Debt A = 0.40 × $1,500 = $600\n\n**Performance facts**\n\n- Debt A is settled under an executed agreement.\n- Customer makes the first required payment under that agreement.\n- Debt B has not yet been settled.\n\n**Result at the first trigger**\n\n- TSR permits earning against Debt A up to the allocated $600, subject to all applicable conditions.\n- Nebraska allows no more than the current monthly amount of **$75**.\n- Therefore, the presently collectible fee is **no more than $75**, not $600.\n- Cumulative fees attributable to Debt A cannot exceed $600.\n- Fees attributable to Debt B remain unearned under the individual-debt TSR rule until Debt B satisfies its own trigger.\n- The provider cannot switch Debt B to a percentage-of-savings method.\n\n**No catch-up assumption**\n\nBecause prior fees were $0, the example does not invent earlier “earned” installments. No Nebraska authority was located allowing an immediate catch-up of all pre-trigger monthly amounts.\n\n**Changed state-base failure case**\n\nIf the actual amount agreed to pass through the licensee were only $6,000, the Nebraska aggregate ceiling would be:\n\n- $6,000 × 0.15 = **$900**\n\nA $1,500 fee contract would then exceed Nebraska’s cap even though the federal proportional arithmetic was otherwise correct.\n\n### Example 5 — Noncustodial 25%-of-enrolled-debt proposal\n\n**Inputs**\n\n- Enrolled debt = $10,000\n- Proposed fee = 25% of enrolled debt\n- Provider never receives debtor funds and claims no control of the independent account.\n\n**Arithmetic**\n\n- $10,000 × 0.25 = $2,500\n\n**Legal result**\n\n- The Chapter 69 15% formula cannot be used to validate or invalidate the $2,500 fee automatically because the provider may not fit Chapter 69’s custodial definition.\n- No affirmative Nebraska statute or license authorizing a 25%-of-enrolled-debt negotiation-only model was established.\n- If the transaction is telemarketed debt relief, the TSR may control when the fee can be earned—but federal timing compliance does not create Nebraska market access.\n- If credit-improvement representations are made, the Nebraska CSO Act, CROA, and possibly the TSR credit-repair rule may apply.\n\n**Disposition:** **HOLD—no lawful Nebraska fee pathway established on these facts.**\n\n### Example 6 — Nebraska CSO plus federal CROA\n\n**Inputs**\n\n- Total advertised credit-improvement fee = $500\n- Provider is registered and has the Nebraska $100,000 bond.\n- Service expressly promises to improve the buyer’s credit history.\n- Interstate communications are used.\n- Buyer signs Monday.\n\n**Nebraska state result**\n\n- Nebraska does not supply a general percentage cap.\n- The bonded CSO may appear eligible for the state-law precompletion exception for non-credit-obtaining services.\n- Buyer may cancel within three days as stated in Nebraska law.\n- Any payment must be returned within ten days after cancellation notice.\n\n**Federal CROA result**\n\n- No service may be provided during the first three business days.\n- Consumer may cancel through the federal three-business-day period.\n- No portion of the $500 may be charged or received for an agreed service until that service is fully performed.\n\n**Result**\n\nThe Nebraska bond does not authorize an advance fee prohibited by federal CROA. The currently lawful advance fee is **$0** on the stated facts.\n\n### Example 7 — CSO obtaining a Nebraska Installment Loan and Sales Act loan\n\n**Inputs**\n\n- Provider offers to obtain a loan governed by that Act.\n- Proposed “application/brokerage fee” = $300.\n\n**Operator**\n\nNeb. Rev. Stat. §45-804(8): no brokerage fee or other fee or charge whatsoever in connection with that loan.\n\n**Result**\n\n- Lawful provider fee on this branch: **$0**\n- The bond exception does not change the result.\n\n# B. Source table\n\n| Source ID | Authority, literal URL, and exact pinpoint | Version/effective status and actual access | Jurisdiction and limitations |\n| --- | --- | --- | --- |\n| **S_NE-P1-S001** | **Nebraska Debt Management Act, Neb. Rev. Stat. §§69-1201–69-1217.** Material sections actually read: §69-1201 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201; §69-1202 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202; §69-1203 license: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203; §69-1204 application/bond: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204; §69-1205 issuance: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1205; §69-1206 renewal: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1206; §69-1207 discipline: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207; §69-1208 rules: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1208; §69-1209 contract: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209; §69-1210 account: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210; §69-1211 examination: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211; §69-1212 fees/timing: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212; §69-1213 duties/compromise: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213; §69-1214 prohibitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214; §69-1215 penalty: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1215. [Nebraska Legislature+14](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | Official current codification pages as displayed and checked October 24, 2026. Section histories vary; §69-1204 and §69-1206 were amended in 2020; §69-1212’s current fee text traces to 1967. No future-effective language displayed. | Controlling Nebraska statute. No located decision resolves key noncustodial or remote-nexus language. |\n| **S_NE-P1-S002** | Nebraska Secretary of State, Debt Management Agencies: https://sos.nebraska.gov/licensing/debt-management-agencies, links at page lines 98–107. [Nebraska Secretary of State](https://sos.nebraska.gov/licensing/debt-management-agencies) | Page checked October 24, 2026; footer ©2026. | Operational licensing page; not a substitute for statutory permission. |\n| **S_NE-P1-S003** | SOS Debt Management Statutes index: https://sos.nebraska.gov/licensing/debt-management-statutes, lines 94–115. [Nebraska Secretary of State](https://sos.nebraska.gov/licensing/debt-management-statutes) | Checked October 24, 2026. | Navigation/index only; linked Legislature text controls. |\n| **S_NE-P1-S004** | Active Debt Management Agency Licensees PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf, pp. 1–2. [Nebraska Secretary of State+2](https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf) | PDF dated July 9, 2026; says licenses expire December 31, 2026; opened, parsed, and visually inspected October 24. | Dated roster, not real-time verification or scope opinion. |\n| **S_NE-P1-S005** | Debt Management License Application PDF: https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf, p. 1. [Nebraska Secretary of State+1](https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf) | Undated form as publicly displayed; opened and visually inspected October 24, 2026. | Procedure/supporting-document evidence only. Statute controls fees and eligibility. |\n| **S_NE-P1-S006** | SOS Index of Rules and Regulations and Guidance Documents: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents, Title 433 at lines 97–107 and licensing guidance at lines 144–149. [Nebraska Secretary of State](https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents) | Checked October 24, 2026. | Shows official index structure and listed guidance; absence from list is not conclusive proof no rule exists. |\n| **S_NE-P1-S007** | Secretary of State annual rules/guidance index PDF: https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf, pp. 1–2. [Nebraska Legislature+1](https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf) | Dated February 19, 2026; opened and visually inspected October 24. | Annual snapshot, not proof against later rulemaking. |\n| **S_NE-P1-S008** | Official dynamic rules routes: https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket. [Nebraska Rules+1](https://rules.nebraska.gov/rules?agencyId=61&titleId=201) | Access attempted October 24, 2026; both returned JavaScript application shells through available public-web route. | Full current Title 433 and docket not retrieved. No API/Chrome workaround used. |\n| **S_NE-P1-S009** | **Nebraska Credit Services Organization Act.** §45-802 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-802; §45-803 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-803; §45-804 prohibited acts/fees: https://nebraskalegislature.gov/laws/statutes.php?statute=45-804; §45-805 bond/account: https://nebraskalegislature.gov/laws/statutes.php?statute=45-805; §45-806 registration: https://nebraskalegislature.gov/laws/statutes.php?statute=45-806; §45-807 disclosures: https://nebraskalegislature.gov/laws/statutes.php?statute=45-807; §45-808 contract/cancellation: https://nebraskalegislature.gov/laws/statutes.php?statute=45-808. [Nebraska Legislature+6](https://nebraskalegislature.gov/laws/statutes.php?statute=45-802) | Official current codification pages checked October 24, 2026. §45-804 reflects 2025 LB474 amendment. | Conditional overlap only; debt settlement does not automatically equal credit services. |\n| **S_NE-P1-S010** | SOS Credit Services Organizations page: https://sos.nebraska.gov/licensing/credit-services-organizations, lines 94–113. [Nebraska Secretary of State](https://sos.nebraska.gov/licensing/credit-services-organizations) | Checked October 24, 2026. | Procedure and public links; not substantive classification guidance. |\n| **S_NE-P1-S011** | Active CSO roster PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf, p. 1. [Nebraska Secretary of State+1](https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf) | Dated July 9, 2026; opened and visually inspected October 24. | Snapshot only; no named-provider conclusion. |\n| **S_NE-P1-S012** | CSO Registration Form: https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf, p. 1. [Nebraska Secretary of State+1](https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf) | Public form opened and visually inspected October 24, 2026. | Procedure only. |\n| **S_NE-P1-S013** | Neb. Rev. Stat. §8-2703(14), Money Transmitters Act exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703) | Current codification checked October 24, 2026; 2026 LB717; operative July 18, 2026. | Exemption only for licensed persons acting within license scope; not full money-transmission analysis. |\n| **S_NE-P1-S014** | Federal TSR: 16 C.F.R. §310.2: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2; §310.4: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; §310.6: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6. [eCFR+3](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) | eCFR displayed Title 16 current through October 22, 2026; last amended October 19, 2026; accessed October 24. | Federal common context only; applicability requires telemarketing facts and exemptions analysis. |\n| **S_NE-P1-S015** | Federal CROA: 15 U.S.C. §1679a: https://uscode.house.gov/us/usc/119-124/t15/s1679a/; §1679b: https://uscode.house.gov/us/usc/119-124/t15/s1679b/; §1679d: https://uscode.house.gov/us/usc/119-124/t15/s1679d/; §1679e: https://uscode.house.gov/us/usc/119-124/t15/s1679e/. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1679a/) | U.S. Code source states laws in effect through Public Law 119-124, October 15, 2026; accessed October 24. | Conditional on credit-improvement purpose and statutory jurisdiction/exemptions. |\n| **S_NE-P1-S016** | Nebraska Department of Banking and Finance consumer education: https://ndbf.nebraska.gov/are-debt-settlement-plans-you; https://ndbf.nebraska.gov/how-can-i-negotiate-better-terms-my-creditors. [Nebraska Banking and Finance+1](https://ndbf.nebraska.gov/are-debt-settlement-plans-you) | First article posted February 17, 2026; accessed October 24. | Consumer education, not licensing authority, fee ceiling, or formal interpretation. |\n| **S_NE-P1-S017** | Nebraska appellate-opinion public repository searched: https://www.nebraska.gov/apps-courts-epub/; exact-citation searches also run against official Nebraska Judicial Branch and public case indexes. | Searched October 24, 2026 for §§69-1201, 69-1212, “Debt Management Act,” and “Credit Services Organization Act.” | No on-point controlling Nebraska appellate decision located. Search was not a paid docket search or exhaustive citator review. |\n\n# C. Claim register\n\n| Claim ID | Precise assertion | Source and pinpoint | Conditions, exceptions, and confidence |\n| --- | --- | --- | --- |\n| **S_NE-P1-C001** | Chapter 69 debt management requires fee-based financial planning/management **and** receipt of debtor money or evidences for creditor distribution. | S001, §69-1201(1). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | **High** for text; judicial meaning of “evidences thereof” unresolved. |\n| **S_NE-P1-C002** | A Chapter 69 debtor is a wage earner whose principal income is wages, salary, or commission; no express personal-purpose debt limitation appears. | S001, §69-1201(4). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | **High** for text; business-purpose and sole-proprietor application held. |\n| **S_NE-P1-C003** | A licensed custodial model may arrange debt compromises, and the debtor must receive the full benefit. | S001, §69-1213(5). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213) | **High**; does not independently cover noncustodial settlement. |\n| **S_NE-P1-C004** | Covered debt management requires a prior SOS license; knowing/willful unlicensed operation is a Class II misdemeanor. | S001, §§69-1203, 69-1215. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203) | **High**. |\n| **S_NE-P1-C005** | Chapter 69 exemptions are limited to the listed professions/entities acting in their regular course. | S001, §69-1202. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202) | **High**; exact “regular course” applications are fact-dependent. |\n| **S_NE-P1-C006** | Chapter 69 has no express nonprofit exemption, and an attorney connection alone does not establish the attorney exemption. | S001, §69-1202. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202) | **High** for absence/text; corporate-practice facts require analysis. |\n| **S_NE-P1-C007** | A genuinely noncustodial negotiation-only model appears outside the conjunctive definition, but no affirmative Nebraska permission was established. | S001, §69-1201(1); S017 search. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | **Medium/HOLD**; account authority and “evidences thereof” unresolved. |\n| **S_NE-P1-C008** | Statute uses “in this state” but provides no explicit remote-customer nexus test; roster shows out-of-state licensees. | S001, §§69-1201(5), 69-1204; S004. [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | **Partial**; exact remote trigger held. |\n| **S_NE-P1-C009** | Written contract must identify obligations, creditors, total charges, dates, and may not exceed 36 months. | S001, §69-1209. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209) | **High**. |\n| **S_NE-P1-C010** | Licensee must use a separate debtor-benefit account and generally remit within 15 days, seven for cash, never holding over 35 days. | S001, §§69-1210, 69-1213(2). [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210) | **High**; reasonable accumulation exception applies. |\n| **S_NE-P1-C011** | Total fee ceiling is 15% of money agreed to be paid through the licensee. | S001, §69-1212 sentence 2. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212) | **High** for formula; denominator treatment of provider fees unresolved. |\n| **S_NE-P1-C012** | Fee must be amortized; no more than monthly amortized amount may be applied; up to $25 may be required initially and credited. | S001, §69-1212 sentence 3. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212) | **High** for text; interaction when $25 exceeds monthly amount unresolved. |\n| **S_NE-P1-C013** | Cancellation compensation is capped at 25% of remaining unamortized fee; cancellation/prepayment settlement must be in contract. | S001, §69-1212. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212) | **High** for arithmetic; whether additional or substitution held. |\n| **S_NE-P1-C014** | No state fee until program arranged and debtor-approved; contract not effective until payment for creditor distribution. | S001, §69-1212 final sentences. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212) | **High**; precise $25 sequence held. |\n| **S_NE-P1-C015** | No statutory indexing formula exists; no adjusted fee notice was verified. | S001, §69-1212; S006–S008. | **High** for no statutory indexing; **partial** for regulation/bulletin universe. |\n| **S_NE-P1-C016** | Application entails $200 main-office fee, $100 additional office, $200 investigation, $10,000 bond; renewal fee $100. | S001, §§69-1204, 69-1206. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204) | **High**; provider/government charges, not consumer fees. |\n| **S_NE-P1-C017** | SOS provides application and public roster; July 9 roster says licenses expire December 31, 2026. | S002, S004, S005. [Nebraska Secretary of State+1](https://sos.nebraska.gov/licensing/debt-management-agencies) | **High** for dated documents; no named-provider or real-time conclusion. |\n| **S_NE-P1-C018** | CSO status is triggered by paid services/representations concerning credit improvement, obtaining credit, or related advice. | S009, §45-802. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-802) | **High**; settlement alone is not automatic CSO coverage. |\n| **S_NE-P1-C019** | CSO Act has listed exemptions, including 501(c)(3), in-scope Nebraska attorneys, and debt-management licensees; claimant bears burden. | S009, §45-803. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-803) | **High**. |\n| **S_NE-P1-C020** | Covered CSO must register before business and maintain $100,000 bond/account. | S009, §§45-805–45-806; S010–S012. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=45-805) | **High**. |\n| **S_NE-P1-C021** | Nebraska CSO Act has no general consumer cap; bonded exception may allow precompletion payment for non-credit-obtaining services, but obtaining-credit fees wait until credit obtained; NILS Act loan fees are prohibited. | S009, §45-804(1), (2), (8). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-804) | **High** for state law; federal restrictions separate. |\n| **S_NE-P1-C022** | Nebraska CSO buyer has three-day cancellation and payment return within ten days after notice. | S009, §45-808. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=45-808) | **High**; text says days, not business days. |\n| **S_NE-P1-C023** | TSR debt-relief definition covers represented alterations of unsecured debt; applicability requires telemarketing facts, and debt-relief ad/direct-mail calls are carved out of ordinary inbound exemptions. | S014, §§310.2(o), 310.6(b)(5)–(7). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) | **High** federal text; transaction-specific applicability required. |\n| **S_NE-P1-C024** | Applicable TSR prohibits debt-relief fees until one debt is altered, one payment is made, and individual-debt fees use a consistent proportion or savings method. | S014, §310.4(a)(5)(i). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High**. |\n| **S_NE-P1-C025** | TSR dedicated-account conditions do not settle Nebraska custody classification. | S014, §310.4(a)(5)(ii); S001, §69-1201(1). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High** as separation-of-law conclusion; Nebraska application held. |\n| **S_NE-P1-C026** | TSR credit-repair branch has distinct result-documentation and six-month timing. | S014, §310.4(a)(2). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High** when representations and TSR coverage exist. |\n| **S_NE-P1-C027** | CROA conditionally covers paid credit-improvement services and bars payment before agreed service is fully performed; three-business-day protections apply. | S015, §§1679a, 1679b, 1679d, 1679e. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1679a/) | **High**; federal exemptions and jurisdiction must be tested. |\n| **S_NE-P1-C028** | State fee permission and federal fee timing are independent; compliance with one does not satisfy the other. | S001 §69-1212; S014 §310.4; S015 §1679b. | **High** legal-layering conclusion. |\n| **S_NE-P1-C029** | Money-transmitter exemption protects only a Nebraska-licensed person acting within license scope. | S013, §8-2703(14). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703) | **High**; full money-transmission classification excluded. |\n| **S_NE-P1-C030** | No debt-management-specific regulation/guidance was verified, but official dynamic rules catalog was inaccessible without JavaScript. | S006–S008. [Nebraska Secretary of State+2](https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents) | **Partial/HOLD**; cannot prove complete absence. |\n| **S_NE-P1-C031** | No controlling Nebraska appellate interpretation was located for the principal classification and fee ambiguities. | S017. | **Limited negative search result**, not an exhaustive citator/docket conclusion. |\n| **S_NE-P1-C032** | NDBF’s “15–25% of enrolled debt” statement is consumer education, not Nebraska’s statutory fee ceiling. | S016; compare S001 §69-1212. [Nebraska Banking and Finance+1](https://ndbf.nebraska.gov/are-debt-settlement-plans-you) | **High**. |\n| **S_NE-P1-C033** | Labels such as nonprofit, law firm, DMP, settlement, or credit counseling do not replace activity-based classification. | S001 §§69-1201–1202; S009 §§45-802–803. | **High**. |\n| **S_NE-P1-C034** | §69-1213 mentions remittance “less fees and costs,” but no separate open-ended consumer-cost authority or cap was verified. | S001 §§69-1209, 69-1212, 69-1213(2). [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209) | **HOLD** for any consumer cost outside disclosed lawful fee. |\n\n# D. Component coverage and gap table\n\n| Component issue | Status | Findings/claim IDs | Exact missing evidence or next investigation |\n| --- | --- | --- | --- |\n| Debt-management definition | **Answered** | Conjunctive planning/fee/custody/distribution test. C001 | Court/agency interpretation only if a disputed fact pattern arises. |\n| “Debtor” definition | **Answered/partial** | Wage earner income test. C002 | Decision or interpretation addressing sole proprietor, business-purpose obligations, retirees, gig income, and mixed income. |\n| DMP versus settlement | **Answered** | No separate statutory labels; actual conduct governs. C001, C003, C033 | None for basic distinction. |\n| Principal reduction | **Answered** | Compromise expressly contemplated in licensed model. C003 | Later pass should test creditor-consent and settlement-contract issues. |\n| Custodial model | **Answered** | Licensed Chapter 69 pathway. C004, C009–C014 | Full operational compliance audit later. |\n| Noncustodial negotiation | **Unresolved/held** | Likely outside plain Chapter 69 definition; no affirmative permission. C007 | Official interpretation or controlling case on “and,” “evidences thereof,” account/payment authority, and third-party account structures. |\n| Dedicated-account classification | **Unresolved/held** | Federal rule verified; Nebraska effect not resolved. C025 | Nebraska SOS/AG/court authority applying §69-1201 to consumer-owned accounts. |\n| Consumer/business-purpose boundary | **Partial** | Chapter 69 wage-earner test; CSO personal-purpose test. C002, C018 | Nebraska authority on individual business debt and mixed-purpose portfolios. |\n| Nebraska resident/remote-provider nexus | **Partial** | Out-of-state licensing operationally shown; exact nexus absent. C008 | Statute, rule, order, or case defining “in this state” for remote service. |\n| License/prohibition | **Answered** | License required; unlicensed knowing/willful activity criminal. C004 | Later enforcement-history review. |\n| Debt-management issuing regulator | **Answered** | Secretary of State. C004, C017 | None. |\n| Debt-management application | **Answered for public procedure** | Application, fees, bond, contract filing. C016–C017 | Current internal processing standards, processing time, and unpublished requirements not investigated. |\n| Debt-management roster | **Answered with date limitation** | July 9, 2026 active roster; expiry statement. C017 | Same-day provider-specific confirmation if later requested. |\n| Attorney exemption | **Answered textually** | Only attorneys acting in regular professional course. C005–C006 | Entity/practice-specific facts and unauthorized-practice analysis later. |\n| Nonprofit exemption | **Answered** | None in Chapter 69; distinct CSO/CROA exemptions. C006, C019, C027 | Federal nonprofit/FTC-jurisdiction analysis if relied upon. |\n| Institutional exclusions | **Answered textually** | Banks, fiduciaries, lenders, title/escrow, employees, court actors. C005 | Entity-specific charter and activity review later. |\n| Debt-management total fee base | **Answered with denominator hold** | 15% of money agreed through licensee. C011 | Authority on whether denominator excludes provider fee and treatment of failed/modified payments. |\n| Setup/initial fee | **Answered/partial** | Up to $25, credited. C012 | Interpretation of timing and interaction with monthly amount. |\n| Monthly fee | **Answered** | Contracted fee amortized; no more than monthly amount. C012 | Rounding/final-installment rule not found. |\n| Settlement/per-debt/savings fee | **Answered as no separate state pathway** | Must remain within Chapter 69 formula; TSR allocation separate. C011, C024 | State interpretation if provider proposes hybrid fee. |\n| Cancellation fee | **Answered arithmetically/partial legally** | 25% of remaining unamortized fee. C013 | Whether additional to earned fees or replacement/settlement. |\n| Prepayment | **Partial** | Contract must state provision. C013 | No formula located; need rules/cases/contracts review. |\n| Refund/credit | **Partial** | $25 credited; CSO cancellation refund verified. C012, C022 | Chapter 69 termination/refund treatment beyond cancellation charge. |\n| Additional consumer “costs” | **Unresolved/held** | “Fees and costs” phrase found; no separate authority. C034 | Rules, approved contracts, or interpretation defining permissible costs. |\n| Indexing/current adjusted amounts | **Answered for statute; rules gap remains** | No statutory index; no adjustment verified. C015, C030 | Accessible complete Title 433 and docket/adoption-order review. |\n| State fee timing | **Answered with initial-payment sequence hold** | Program arranged/approved; creditor-distribution payment activates contract. C014 | Official interpretation of $25 sequence. |\n| Federal TSR debt-relief timing | **Answered as conditional overlay** | First altered debt + first payment + allocation. C023–C024 | Transaction-specific telemarketing and exemption facts. |\n| TSR credit-repair timing | **Answered as conditional overlay** | Separate result and six-month documentation rule. C026 | Representation-specific facts. |\n| Federal CROA overlap | **Answered as conditional overlay** | Credit-improvement trigger, advance-fee ban, cancellation. C027 | Entity exemption and exact services/representations. |\n| Nebraska CSO definition | **Answered** | Credit improvement/obtaining credit/advice. C018 | Application to a particular settlement message or funnel. |\n| Nebraska CSO authorization | **Answered** | Registration and $100,000 bond/account. C020 | Named-provider lookup if requested. |\n| Nebraska CSO fee cap | **Answered** | No general cap verified; timing/zero-fee branches apply. C021 | Other sector-specific laws beyond the NILS branch remain later work. |\n| CSO cancellation | **Answered** | Three days; refund within ten. C022 | Calendar computation/holiday case law not reviewed. |\n| Rules and adoption orders | **Partial/held** | Static index checked; dynamic catalog inaccessible. C030 | Obtain an accessible official consolidated Title 433 and docket record; inspect all debt-management amendments/orders. |\n| Controlling cases | **Partial/held** | No on-point appellate authority found. C031 | Full citator, paid docket, trial orders, administrative decisions, and historical AG opinions. |\n| Money-transmitter interaction | **Partial** | In-scope license exemption verified. C029 | Full unlicensed/dedicated-account money-transmission analysis later. |\n| Named-provider authorization | **Not performed by design** | No provider supplied; no status inference. C017 | Exact legal name, aliases, and requested status date. |\n| Agreement content beyond fee fields | **Excluded/later pass** | Only fee-relevant contract terms reviewed. | Full agreement-form, disclosure, electronic-signature, assignment, arbitration, and modification review. |\n| Funds/trust/bond operational audit | **Excluded/later pass** | Basic account and bonds identified. | Reconciliation, permissible withdrawals, surety claims, insolvency, administrator relationships. |\n| Remedies/enforcement | **Excluded/later pass** | License discipline and criminal penalty noted only as needed. | Private actions, UDAP, AG authority, restitution, administrative practice, limitation periods. |\n| Collections/litigation | **Excluded/later pass** | Not necessary to current permission/fee result. | Collection Agency Act, FDCPA, state procedure, creditor litigation, garnishment. |\n| Secured debt and sector laws | **Excluded/later pass** | NILS fee prohibition included only because directly in CSO fee section. | Mortgage, auto, student, tax, medical, utilities, tribal, agricultural, and regulated-professional debt. |\n| Local/tribal law | **Excluded/later pass** | No conclusion. | Municipal, tribal, choice-of-law, sovereign, and reservation nexus research. |\n| Full exemption universe | **Excluded/later pass** | Principal Chapter 69 and CSO exemptions covered. | Sector, federal-preemption, government-contractor, creditor, and special-entity exemptions. |\n| Model acts/comments | **Not relied upon** | No model act used as Nebraska law. | Historical-legislative pass may compare source act only with enacted version and adoption history. |\n\n## Exact next investigations\n\nThe following should be separate Nebraska passes rather than silently folded into this component:\n\n1. **Title 433 completion:** obtain and inspect every currently effective Title 433 chapter, amendment certificate, effective date, and pending/adopted order through October 24, 2026.\n2. **Noncustodial classification:** locate administrative correspondence, enforcement pleadings, AG opinions, trial orders, or appellate decisions addressing “evidences thereof,” payment authority, independent accounts, and remote settlement providers.\n3. **Approved-contract evidence:** examine publicly obtainable approved or filed Chapter 69 contracts for treatment of the $25 payment, monthly amortization, cancellation charge, prepayment, costs, and rounding—without treating private forms as law.\n4. **Remote nexus:** determine what Nebraska conduct, consumer location, solicitation, account location, or creditor nexus constitutes business “in this state.”\n5. **Money-transmission pass:** analyze unlicensed, dedicated-account, payment-processor, agent-of-payee, and settlement-disbursement structures under the current July 18, 2026 Money Transmitters Act.\n6. **Enforcement/case pass:** paid and nonpaid docket/citator research for administrative actions, trial-level orders, consent judgments, and historical AG opinions; no purchase was made in this pass.\n7. **Remaining dossier categories:** full agreements, bonds/trust, remedies, limitations, collections, litigation, secured debt, creditor types, local/tribal issues, choice of law, electronic contracting, unauthorized practice, UDAP, advertising, referral arrangements, and federal/state enforcement overlap.\n\n# E. Researcher self-check\n\n## Actually opened and read\n\n- Official Nebraska Legislature pages for the material portions of §§69-1201 through 69-1215.\n- Official Nebraska Legislature pages for §§45-802 through 45-808.\n- Current §8-2703, including the 2026 source history and July 18, 2026 operative date.\n- Nebraska Secretary of State debt-management and CSO licensing pages.\n- SOS debt-management statute index.\n- Debt-management active roster PDF, both pages, including visual inspection.\n- Debt-management application PDF, including visual inspection.\n- CSO active roster and registration-form PDFs, including visual inspection.\n- SOS HTML rules/guidance index.\n- February 19, 2026 annual rules/guidance index PDF, including visual inspection.\n- Current eCFR text of 16 C.F.R. §§310.2, 310.4, and 310.6.\n- Current U.S. Code text of 15 U.S.C. §§1679a, 1679b, 1679d, and 1679e.\n- Nebraska Department of Banking and Finance consumer-education pages, used only for contrast and not as licensing authority.\n\n## Discovery/search-rendered or limited-access material\n\n- The official dynamic Nebraska rules catalog and rulemaking docket returned JavaScript shells through the permitted public-web route. They were not treated as substantive proof.\n- Directly indexed Title 433 chapters located in official search were inspected sufficiently to identify several other licensing subjects, but no claim is made that every chapter or amendment was retrieved.\n- Exact-citation and act-name searches were run across public Nebraska appellate and official sources. No on-point decision was located, but this was not an exhaustive paid citator or docket investigation.\n- A state court route involving a charge was not purchased or used.\n\n## Not read or not performed\n\n- No private provider contracts, internal regulator files, nonpublic applications, examination reports, or private borrower data.\n- No application, registration, complaint, contact, or records request.\n- No named-provider license determination.\n- No comprehensive trial-court docket or commercial citator search.\n- No complete historical legislative-intent review.\n- No full Nebraska Collection Agency Act, consumer-protection, money-transmission, remedies, limitations, secured-debt, local, tribal, tax, bankruptcy, or litigation analysis.\n- No representation that the work was independently reviewed, locally written, regulator-approved, legal advice, or publication-ready.\n\n**Bottom-line provider-access hold:** A properly licensed custodial DMP or custodial compromise program has a verified Nebraska pathway and a specific pass-through-based fee regime. A noncustodial negotiation-only debt-settlement company does **not** obtain Nebraska permission merely by following the federal TSR or charging a familiar percentage of enrolled debt. That model remains held pending a defensible Nebraska classification and any conditionally applicable CSO, money-transmission, credit-repair, and remote-nexus analysis.\n\nEND S_NE PASS-01.\n\n","tables":[{"headers":["Business model","Nebraska disposition established in this pass","Required authority or principal hold"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Nebraska disposition established in this pass","Required authority or principal hold"],["Custodial DMP—provider plans finances, receives debtor funds, distributes to creditors","Licensed pathway established","Nebraska Secretary of State debt-management license under §§69-1201–69-1217; bond, contract, account, and other conditions apply. C001–C006"],["Custodial principal-reduction settlement—same custody/distribution features, but provider negotiates compromises","Licensed pathway established","Compromises are expressly contemplated by §69-1213(5); same Chapter 69 license and fee regime. C003–C006"],["Noncustodial settlement negotiation—consumer retains funds in an independent account and provider cannot receive/control them","No affirmative Nebraska pathway established; HOLD","Plain §69-1201 text may place it outside Chapter 69, but no court/agency interpretation was located for “evidences thereof,” account control, payment instructions, or remote operation. It may conditionally fall under the CSO Act. C007, C018"],["Provider-controlled or provider-affiliated dedicated account","Likely classification risk; not approved","Federal dedicated-account conditions do not decide Nebraska “receiving” or “evidences thereof.” Exact Nebraska treatment remains held. C007, C025"],["Fee-based counseling/advice without receiving creditor-distribution funds","Apparently outside Chapter 69 on the text; other-law hold","May be a Nebraska credit-services organization when credit-improvement or credit-obtaining representations are made. C007, C018"],["Free education or self-help tools, with no provider fee and no receipt of funds","Outside the literal Chapter 69 definition on those facts","No fee and no custody; deceptive-practice, legal-services, referral, and other later-pass issues remain open. C001"],["Credit-improvement/credit-repair service","Conditional registration pathway","Nebraska CSO registration and $100,000 bond/account unless exempt; federal CROA and possibly TSR impose stricter fee timing. C018–C027"],["Service to obtain an extension of credit","Conditional CSO pathway","No provider payment before the credit is obtained; zero-fee rule for a loan governed by the Nebraska Installment Loan and Sales Act. C021"],["Attorney actually acting in regular course of legal profession","Conditionally exempt from Chapter 69","A marketing affiliation, attorney ownership, or nominal attorney relationship is not enough. C005–C006"],["501(c)(3) nonprofit","No Chapter 69 nonprofit exemption","Nebraska CSO Act and federal CROA have distinct 501(c)(3) exemptions, but those do not exempt a covered custodial model from Chapter 69. C006, C019, C027"],["Bank or other listed institution","Conditionally exempt","Only as stated in §69-1202 and while performing the activity in the regular course of the entity’s principal authorized business. C005"],["Covered Chapter 69 activity without license","Unlawful; potentially criminal","Knowing or willful unlicensed debt management is a Class II misdemeanor. C004"]]},{"headers":["Fee element","Current verified Nebraska rule","Important boundary"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Fee element","Current verified Nebraska rule","Important boundary"],["Total contracted fee","No more than 15% of the amount of money agreed to be paid through the licensee","Do not substitute enrolled balance, original debt balance, amount saved, or amount forgiven for the statutory base."],["Contract period","Maximum 36 months","Actual contracted fee—not automatically the statutory maximum—must be amortized across the contract."],["Periodic/monthly application","No more than the monthly amortized amount may be applied while contract is active","No verified retroactive “catch-up” rule was located."],["Initial payment","Up to $25, credited to total fee","Not an extra fee above the total cap. Its relationship to a smaller monthly amortized amount is unresolved."],["Cancellation","Not more than 25% of the remaining unamortized contracted fee","Text does not clearly resolve whether this is an additional exit charge on top of lawfully applied fees or the entire remaining settlement."],["Prepayment","Contract must clearly state the settlement provision","No separate statutory prepayment formula was located."],["Per-debt settlement fee","No separate state authorization","Any label remains subject to total cap and amortization if the model is Chapter 69 debt management."],["Savings fee","No separate state authorization","Federal TSR may permit a uniform percentage-of-savings allocation when applicable, but Nebraska’s own cap remains based on money agreed through the licensee."],["Setup/enrollment fee","Only the credited initial payment is specifically identified","Renaming a charge does not avoid total cap or timing restrictions."],["Additional “costs”","HOLD","§69-1213(2) uses “less fees and costs” in describing remittances, but no open-ended consumer-cost authority, definition, or cap was located. Do not infer unlimited pass-through costs."],["Referral compensation","Prohibited for licensee referral of debtors or acceptance/payment of referral bonuses","Cannot be turned into a separate consumer charge."],["Promissory-note or secured fee","Prohibited","A licensee cannot take a note, mortgage, or other security for its fee."]]},{"headers":["Source ID","Authority, literal URL, and exact pinpoint","Version/effective status and actual access","Jurisdiction and limitations"],"index":2,"links":[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+14"},{"href":"https://sos.nebraska.gov/licensing/debt-management-agencies","text":"Nebraska Secretary of State"},{"href":"https://sos.nebraska.gov/licensing/debt-management-statutes","text":"Nebraska Secretary of State"},{"href":"https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf","text":"Nebraska Secretary of State\n+2"},{"href":"https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf","text":"Nebraska Secretary of State\n+1"},{"href":"https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents","text":"Nebraska Secretary of State"},{"href":"https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf","text":"Nebraska Legislature\n+1"},{"href":"https://rules.nebraska.gov/rules?agencyId=61&titleId=201","text":"Nebraska Rules\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-802","text":"Nebraska Legislature\n+6"},{"href":"https://sos.nebraska.gov/licensing/credit-services-organizations","text":"Nebraska Secretary of State"},{"href":"https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf","text":"Nebraska Secretary of State\n+1"},{"href":"https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf","text":"Nebraska Secretary of State\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703","text":"Nebraska Legislature\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+3"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"},{"href":"https://ndbf.nebraska.gov/are-debt-settlement-plans-you","text":"Nebraska Banking and Finance\n+1"}],"row_links":[[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+14"}],[{"href":"https://sos.nebraska.gov/licensing/debt-management-agencies","text":"Nebraska Secretary of State"}],[{"href":"https://sos.nebraska.gov/licensing/debt-management-statutes","text":"Nebraska Secretary of State"}],[{"href":"https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf","text":"Nebraska Secretary of State\n+2"}],[{"href":"https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf","text":"Nebraska Secretary of State\n+1"}],[{"href":"https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents","text":"Nebraska Secretary of State"}],[{"href":"https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf","text":"Nebraska Legislature\n+1"}],[{"href":"https://rules.nebraska.gov/rules?agencyId=61&titleId=201","text":"Nebraska Rules\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-802","text":"Nebraska Legislature\n+6"}],[{"href":"https://sos.nebraska.gov/licensing/credit-services-organizations","text":"Nebraska Secretary of State"}],[{"href":"https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf","text":"Nebraska Secretary of State\n+1"}],[{"href":"https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf","text":"Nebraska Secretary of State\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703","text":"Nebraska Legislature\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+3"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"}],[{"href":"https://ndbf.nebraska.gov/are-debt-settlement-plans-you","text":"Nebraska Banking and Finance\n+1"}],[]],"rows":[["Source ID","Authority, literal URL, and exact pinpoint","Version/effective status and actual access","Jurisdiction and limitations"],["S_NE-P1-S001","Nebraska Debt Management Act, Neb. Rev. Stat. §§69-1201–69-1217. Material sections actually read: §69-1201 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201; §69-1202 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202; §69-1203 license: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203; §69-1204 application/bond: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204; §69-1205 issuance: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1205; §69-1206 renewal: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1206; §69-1207 discipline: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207; §69-1208 rules: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1208; §69-1209 contract: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209; §69-1210 account: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210; §69-1211 examination: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211; §69-1212 fees/timing: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212; §69-1213 duties/compromise: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213; §69-1214 prohibitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214; §69-1215 penalty: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1215. \nNebraska Legislature\n+14","Official current codification pages as displayed and checked October 24, 2026. Section histories vary; §69-1204 and §69-1206 were amended in 2020; §69-1212’s current fee text traces to 1967. No future-effective language displayed.","Controlling Nebraska statute. No located decision resolves key noncustodial or remote-nexus language."],["S_NE-P1-S002","Nebraska Secretary of State, Debt Management Agencies: https://sos.nebraska.gov/licensing/debt-management-agencies, links at page lines 98–107. \nNebraska Secretary of State","Page checked October 24, 2026; footer ©2026.","Operational licensing page; not a substitute for statutory permission."],["S_NE-P1-S003","SOS Debt Management Statutes index: https://sos.nebraska.gov/licensing/debt-management-statutes, lines 94–115. \nNebraska Secretary of State","Checked October 24, 2026.","Navigation/index only; linked Legislature text controls."],["S_NE-P1-S004","Active Debt Management Agency Licensees PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf, pp. 1–2. \nNebraska Secretary of State\n+2","PDF dated July 9, 2026; says licenses expire December 31, 2026; opened, parsed, and visually inspected October 24.","Dated roster, not real-time verification or scope opinion."],["S_NE-P1-S005","Debt Management License Application PDF: https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf, p. 1. \nNebraska Secretary of State\n+1","Undated form as publicly displayed; opened and visually inspected October 24, 2026.","Procedure/supporting-document evidence only. Statute controls fees and eligibility."],["S_NE-P1-S006","SOS Index of Rules and Regulations and Guidance Documents: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents, Title 433 at lines 97–107 and licensing guidance at lines 144–149. \nNebraska Secretary of State","Checked October 24, 2026.","Shows official index structure and listed guidance; absence from list is not conclusive proof no rule exists."],["S_NE-P1-S007","Secretary of State annual rules/guidance index PDF: https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf, pp. 1–2. \nNebraska Legislature\n+1","Dated February 19, 2026; opened and visually inspected October 24.","Annual snapshot, not proof against later rulemaking."],["S_NE-P1-S008","Official dynamic rules routes: https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket. \nNebraska Rules\n+1","Access attempted October 24, 2026; both returned JavaScript application shells through available public-web route.","Full current Title 433 and docket not retrieved. No API/Chrome workaround used."],["S_NE-P1-S009","Nebraska Credit Services Organization Act. §45-802 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-802; §45-803 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-803; §45-804 prohibited acts/fees: https://nebraskalegislature.gov/laws/statutes.php?statute=45-804; §45-805 bond/account: https://nebraskalegislature.gov/laws/statutes.php?statute=45-805; §45-806 registration: https://nebraskalegislature.gov/laws/statutes.php?statute=45-806; §45-807 disclosures: https://nebraskalegislature.gov/laws/statutes.php?statute=45-807; §45-808 contract/cancellation: https://nebraskalegislature.gov/laws/statutes.php?statute=45-808. \nNebraska Legislature\n+6","Official current codification pages checked October 24, 2026. §45-804 reflects 2025 LB474 amendment.","Conditional overlap only; debt settlement does not automatically equal credit services."],["S_NE-P1-S010","SOS Credit Services Organizations page: https://sos.nebraska.gov/licensing/credit-services-organizations, lines 94–113. \nNebraska Secretary of State","Checked October 24, 2026.","Procedure and public links; not substantive classification guidance."],["S_NE-P1-S011","Active CSO roster PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf, p. 1. \nNebraska Secretary of State\n+1","Dated July 9, 2026; opened and visually inspected October 24.","Snapshot only; no named-provider conclusion."],["S_NE-P1-S012","CSO Registration Form: https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf, p. 1. \nNebraska Secretary of State\n+1","Public form opened and visually inspected October 24, 2026.","Procedure only."],["S_NE-P1-S013","Neb. Rev. Stat. §8-2703(14), Money Transmitters Act exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703. \nNebraska Legislature\n+1","Current codification checked October 24, 2026; 2026 LB717; operative July 18, 2026.","Exemption only for licensed persons acting within license scope; not full money-transmission analysis."],["S_NE-P1-S014","Federal TSR: 16 C.F.R. §310.2: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2; §310.4: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; §310.6: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6. \neCFR\n+3","eCFR displayed Title 16 current through October 22, 2026; last amended October 19, 2026; accessed October 24.","Federal common context only; applicability requires telemarketing facts and exemptions analysis."],["S_NE-P1-S015","Federal CROA: 15 U.S.C. §1679a: https://uscode.house.gov/us/usc/119-124/t15/s1679a/; §1679b: https://uscode.house.gov/us/usc/119-124/t15/s1679b/; §1679d: https://uscode.house.gov/us/usc/119-124/t15/s1679d/; §1679e: https://uscode.house.gov/us/usc/119-124/t15/s1679e/. \nU.S. Code\n+3","U.S. Code source states laws in effect through Public Law 119-124, October 15, 2026; accessed October 24.","Conditional on credit-improvement purpose and statutory jurisdiction/exemptions."],["S_NE-P1-S016","Nebraska Department of Banking and Finance consumer education: https://ndbf.nebraska.gov/are-debt-settlement-plans-you; https://ndbf.nebraska.gov/how-can-i-negotiate-better-terms-my-creditors. \nNebraska Banking and Finance\n+1","First article posted February 17, 2026; accessed October 24.","Consumer education, not licensing authority, fee ceiling, or formal interpretation."],["S_NE-P1-S017","Nebraska appellate-opinion public repository searched: https://www.nebraska.gov/apps-courts-epub/; exact-citation searches also run against official Nebraska Judicial Branch and public case indexes.","Searched October 24, 2026 for §§69-1201, 69-1212, “Debt Management Act,” and “Credit Services Organization Act.”","No on-point controlling Nebraska appellate decision located. Search was not a paid docket search or exhaustive citator review."]]},{"headers":["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, and confidence"],"index":3,"links":[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203","text":"Nebraska Legislature\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+2"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210","text":"Nebraska Legislature\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204","text":"Nebraska Legislature\n+1"},{"href":"https://sos.nebraska.gov/licensing/debt-management-agencies","text":"Nebraska Secretary of State\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-802","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-803","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-805","text":"Nebraska Legislature\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-804","text":"Nebraska Legislature"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-808","text":"Nebraska Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703","text":"Nebraska Legislature"},{"href":"https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents","text":"Nebraska Secretary of State\n+2"},{"href":"https://ndbf.nebraska.gov/are-debt-settlement-plans-you","text":"Nebraska Banking and Finance\n+1"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209","text":"Nebraska Legislature\n+2"}],"row_links":[[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203","text":"Nebraska Legislature\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+2"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210","text":"Nebraska Legislature\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","text":"Nebraska Legislature"}],[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204","text":"Nebraska Legislature\n+1"}],[{"href":"https://sos.nebraska.gov/licensing/debt-management-agencies","text":"Nebraska Secretary of State\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-802","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-803","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-805","text":"Nebraska Legislature\n+1"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-804","text":"Nebraska Legislature"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=45-808","text":"Nebraska Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"}],[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703","text":"Nebraska Legislature"}],[{"href":"https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents","text":"Nebraska Secretary of State\n+2"}],[],[{"href":"https://ndbf.nebraska.gov/are-debt-settlement-plans-you","text":"Nebraska Banking and Finance\n+1"}],[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209","text":"Nebraska Legislature\n+2"}]],"rows":[["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, and confidence"],["S_NE-P1-C001","Chapter 69 debt management requires fee-based financial planning/management and receipt of debtor money or evidences for creditor distribution.","S001, §69-1201(1). \nNebraska Legislature","High for text; judicial meaning of “evidences thereof” unresolved."],["S_NE-P1-C002","A Chapter 69 debtor is a wage earner whose principal income is wages, salary, or commission; no express personal-purpose debt limitation appears.","S001, §69-1201(4). \nNebraska Legislature","High for text; business-purpose and sole-proprietor application held."],["S_NE-P1-C003","A licensed custodial model may arrange debt compromises, and the debtor must receive the full benefit.","S001, §69-1213(5). \nNebraska Legislature","High; does not independently cover noncustodial settlement."],["S_NE-P1-C004","Covered debt management requires a prior SOS license; knowing/willful unlicensed operation is a Class II misdemeanor.","S001, §§69-1203, 69-1215. \nNebraska Legislature\n+1","High."],["S_NE-P1-C005","Chapter 69 exemptions are limited to the listed professions/entities acting in their regular course.","S001, §69-1202. \nNebraska Legislature","High; exact “regular course” applications are fact-dependent."],["S_NE-P1-C006","Chapter 69 has no express nonprofit exemption, and an attorney connection alone does not establish the attorney exemption.","S001, §69-1202. \nNebraska Legislature","High for absence/text; corporate-practice facts require analysis."],["S_NE-P1-C007","A genuinely noncustodial negotiation-only model appears outside the conjunctive definition, but no affirmative Nebraska permission was established.","S001, §69-1201(1); S017 search. \nNebraska Legislature","Medium/HOLD; account authority and “evidences thereof” unresolved."],["S_NE-P1-C008","Statute uses “in this state” but provides no explicit remote-customer nexus test; roster shows out-of-state licensees.","S001, §§69-1201(5), 69-1204; S004. \nNebraska Legislature\n+2","Partial; exact remote trigger held."],["S_NE-P1-C009","Written contract must identify obligations, creditors, total charges, dates, and may not exceed 36 months.","S001, §69-1209. \nNebraska Legislature","High."],["S_NE-P1-C010","Licensee must use a separate debtor-benefit account and generally remit within 15 days, seven for cash, never holding over 35 days.","S001, §§69-1210, 69-1213(2). \nNebraska Legislature\n+1","High; reasonable accumulation exception applies."],["S_NE-P1-C011","Total fee ceiling is 15% of money agreed to be paid through the licensee.","S001, §69-1212 sentence 2. \nNebraska Legislature","High for formula; denominator treatment of provider fees unresolved."],["S_NE-P1-C012","Fee must be amortized; no more than monthly amortized amount may be applied; up to $25 may be required initially and credited.","S001, §69-1212 sentence 3. \nNebraska Legislature","High for text; interaction when $25 exceeds monthly amount unresolved."],["S_NE-P1-C013","Cancellation compensation is capped at 25% of remaining unamortized fee; cancellation/prepayment settlement must be in contract.","S001, §69-1212. \nNebraska Legislature","High for arithmetic; whether additional or substitution held."],["S_NE-P1-C014","No state fee until program arranged and debtor-approved; contract not effective until payment for creditor distribution.","S001, §69-1212 final sentences. \nNebraska Legislature","High; precise $25 sequence held."],["S_NE-P1-C015","No statutory indexing formula exists; no adjusted fee notice was verified.","S001, §69-1212; S006–S008.","High for no statutory indexing; partial for regulation/bulletin universe."],["S_NE-P1-C016","Application entails $200 main-office fee, $100 additional office, $200 investigation, $10,000 bond; renewal fee $100.","S001, §§69-1204, 69-1206. \nNebraska Legislature\n+1","High; provider/government charges, not consumer fees."],["S_NE-P1-C017","SOS provides application and public roster; July 9 roster says licenses expire December 31, 2026.","S002, S004, S005. \nNebraska Secretary of State\n+1","High for dated documents; no named-provider or real-time conclusion."],["S_NE-P1-C018","CSO status is triggered by paid services/representations concerning credit improvement, obtaining credit, or related advice.","S009, §45-802. \nNebraska Legislature","High; settlement alone is not automatic CSO coverage."],["S_NE-P1-C019","CSO Act has listed exemptions, including 501(c)(3), in-scope Nebraska attorneys, and debt-management licensees; claimant bears burden.","S009, §45-803. \nNebraska Legislature","High."],["S_NE-P1-C020","Covered CSO must register before business and maintain $100,000 bond/account.","S009, §§45-805–45-806; S010–S012. \nNebraska Legislature\n+1","High."],["S_NE-P1-C021","Nebraska CSO Act has no general consumer cap; bonded exception may allow precompletion payment for non-credit-obtaining services, but obtaining-credit fees wait until credit obtained; NILS Act loan fees are prohibited.","S009, §45-804(1), (2), (8). \nNebraska Legislature","High for state law; federal restrictions separate."],["S_NE-P1-C022","Nebraska CSO buyer has three-day cancellation and payment return within ten days after notice.","S009, §45-808. \nNebraska Legislature","High; text says days, not business days."],["S_NE-P1-C023","TSR debt-relief definition covers represented alterations of unsecured debt; applicability requires telemarketing facts, and debt-relief ad/direct-mail calls are carved out of ordinary inbound exemptions.","S014, §§310.2(o), 310.6(b)(5)–(7). \neCFR\n+1","High federal text; transaction-specific applicability required."],["S_NE-P1-C024","Applicable TSR prohibits debt-relief fees until one debt is altered, one payment is made, and individual-debt fees use a consistent proportion or savings method.","S014, §310.4(a)(5)(i). \neCFR","High."],["S_NE-P1-C025","TSR dedicated-account conditions do not settle Nebraska custody classification.","S014, §310.4(a)(5)(ii); S001, §69-1201(1). \neCFR\n+1","High as separation-of-law conclusion; Nebraska application held."],["S_NE-P1-C026","TSR credit-repair branch has distinct result-documentation and six-month timing.","S014, §310.4(a)(2). \neCFR","High when representations and TSR coverage exist."],["S_NE-P1-C027","CROA conditionally covers paid credit-improvement services and bars payment before agreed service is fully performed; three-business-day protections apply.","S015, §§1679a, 1679b, 1679d, 1679e. \nU.S. Code\n+3","High; federal exemptions and jurisdiction must be tested."],["S_NE-P1-C028","State fee permission and federal fee timing are independent; compliance with one does not satisfy the other.","S001 §69-1212; S014 §310.4; S015 §1679b.","High legal-layering conclusion."],["S_NE-P1-C029","Money-transmitter exemption protects only a Nebraska-licensed person acting within license scope.","S013, §8-2703(14). \nNebraska Legislature","High; full money-transmission classification excluded."],["S_NE-P1-C030","No debt-management-specific regulation/guidance was verified, but official dynamic rules catalog was inaccessible without JavaScript.","S006–S008. \nNebraska Secretary of State\n+2","Partial/HOLD; cannot prove complete absence."],["S_NE-P1-C031","No controlling Nebraska appellate interpretation was located for the principal classification and fee ambiguities.","S017.","Limited negative search result, not an exhaustive citator/docket conclusion."],["S_NE-P1-C032","NDBF’s “15–25% of enrolled debt” statement is consumer education, not Nebraska’s statutory fee ceiling.","S016; compare S001 §69-1212. \nNebraska Banking and Finance\n+1","High."],["S_NE-P1-C033","Labels such as nonprofit, law firm, DMP, settlement, or credit counseling do not replace activity-based classification.","S001 §§69-1201–1202; S009 §§45-802–803.","High."],["S_NE-P1-C034","§69-1213 mentions remittance “less fees and costs,” but no separate open-ended consumer-cost authority or cap was verified.","S001 §§69-1209, 69-1212, 69-1213(2). \nNebraska Legislature\n+2","HOLD for any consumer cost outside disclosed lawful fee."]]},{"headers":["Component issue","Status","Findings/claim IDs","Exact missing evidence or next investigation"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component issue","Status","Findings/claim IDs","Exact missing evidence or next investigation"],["Debt-management definition","Answered","Conjunctive planning/fee/custody/distribution test. C001","Court/agency interpretation only if a disputed fact pattern arises."],["“Debtor” definition","Answered/partial","Wage earner income test. C002","Decision or interpretation addressing sole proprietor, business-purpose obligations, retirees, gig income, and mixed income."],["DMP versus settlement","Answered","No separate statutory labels; actual conduct governs. C001, C003, C033","None for basic distinction."],["Principal reduction","Answered","Compromise expressly contemplated in licensed model. C003","Later pass should test creditor-consent and settlement-contract issues."],["Custodial model","Answered","Licensed Chapter 69 pathway. C004, C009–C014","Full operational compliance audit later."],["Noncustodial negotiation","Unresolved/held","Likely outside plain Chapter 69 definition; no affirmative permission. C007","Official interpretation or controlling case on “and,” “evidences thereof,” account/payment authority, and third-party account structures."],["Dedicated-account classification","Unresolved/held","Federal rule verified; Nebraska effect not resolved. C025","Nebraska SOS/AG/court authority applying §69-1201 to consumer-owned accounts."],["Consumer/business-purpose boundary","Partial","Chapter 69 wage-earner test; CSO personal-purpose test. C002, C018","Nebraska authority on individual business debt and mixed-purpose portfolios."],["Nebraska resident/remote-provider nexus","Partial","Out-of-state licensing operationally shown; exact nexus absent. C008","Statute, rule, order, or case defining “in this state” for remote service."],["License/prohibition","Answered","License required; unlicensed knowing/willful activity criminal. C004","Later enforcement-history review."],["Debt-management issuing regulator","Answered","Secretary of State. C004, C017","None."],["Debt-management application","Answered for public procedure","Application, fees, bond, contract filing. C016–C017","Current internal processing standards, processing time, and unpublished requirements not investigated."],["Debt-management roster","Answered with date limitation","July 9, 2026 active roster; expiry statement. C017","Same-day provider-specific confirmation if later requested."],["Attorney exemption","Answered textually","Only attorneys acting in regular professional course. C005–C006","Entity/practice-specific facts and unauthorized-practice analysis later."],["Nonprofit exemption","Answered","None in Chapter 69; distinct CSO/CROA exemptions. C006, C019, C027","Federal nonprofit/FTC-jurisdiction analysis if relied upon."],["Institutional exclusions","Answered textually","Banks, fiduciaries, lenders, title/escrow, employees, court actors. C005","Entity-specific charter and activity review later."],["Debt-management total fee base","Answered with denominator hold","15% of money agreed through licensee. C011","Authority on whether denominator excludes provider fee and treatment of failed/modified payments."],["Setup/initial fee","Answered/partial","Up to $25, credited. C012","Interpretation of timing and interaction with monthly amount."],["Monthly fee","Answered","Contracted fee amortized; no more than monthly amount. C012","Rounding/final-installment rule not found."],["Settlement/per-debt/savings fee","Answered as no separate state pathway","Must remain within Chapter 69 formula; TSR allocation separate. C011, C024","State interpretation if provider proposes hybrid fee."],["Cancellation fee","Answered arithmetically/partial legally","25% of remaining unamortized fee. C013","Whether additional to earned fees or replacement/settlement."],["Prepayment","Partial","Contract must state provision. C013","No formula located; need rules/cases/contracts review."],["Refund/credit","Partial","$25 credited; CSO cancellation refund verified. C012, C022","Chapter 69 termination/refund treatment beyond cancellation charge."],["Additional consumer “costs”","Unresolved/held","“Fees and costs” phrase found; no separate authority. C034","Rules, approved contracts, or interpretation defining permissible costs."],["Indexing/current adjusted amounts","Answered for statute; rules gap remains","No statutory index; no adjustment verified. C015, C030","Accessible complete Title 433 and docket/adoption-order review."],["State fee timing","Answered with initial-payment sequence hold","Program arranged/approved; creditor-distribution payment activates contract. C014","Official interpretation of $25 sequence."],["Federal TSR debt-relief timing","Answered as conditional overlay","First altered debt + first payment + allocation. C023–C024","Transaction-specific telemarketing and exemption facts."],["TSR credit-repair timing","Answered as conditional overlay","Separate result and six-month documentation rule. C026","Representation-specific facts."],["Federal CROA overlap","Answered as conditional overlay","Credit-improvement trigger, advance-fee ban, cancellation. C027","Entity exemption and exact services/representations."],["Nebraska CSO definition","Answered","Credit improvement/obtaining credit/advice. C018","Application to a particular settlement message or funnel."],["Nebraska CSO authorization","Answered","Registration and $100,000 bond/account. C020","Named-provider lookup if requested."],["Nebraska CSO fee cap","Answered","No general cap verified; timing/zero-fee branches apply. C021","Other sector-specific laws beyond the NILS branch remain later work."],["CSO cancellation","Answered","Three days; refund within ten. C022","Calendar computation/holiday case law not reviewed."],["Rules and adoption orders","Partial/held","Static index checked; dynamic catalog inaccessible. C030","Obtain an accessible official consolidated Title 433 and docket record; inspect all debt-management amendments/orders."],["Controlling cases","Partial/held","No on-point appellate authority found. C031","Full citator, paid docket, trial orders, administrative decisions, and historical AG opinions."],["Money-transmitter interaction","Partial","In-scope license exemption verified. C029","Full unlicensed/dedicated-account money-transmission analysis later."],["Named-provider authorization","Not performed by design","No provider supplied; no status inference. C017","Exact legal name, aliases, and requested status date."],["Agreement content beyond fee fields","Excluded/later pass","Only fee-relevant contract terms reviewed.","Full agreement-form, disclosure, electronic-signature, assignment, arbitration, and modification review."],["Funds/trust/bond operational audit","Excluded/later pass","Basic account and bonds identified.","Reconciliation, permissible withdrawals, surety claims, insolvency, administrator relationships."],["Remedies/enforcement","Excluded/later pass","License discipline and criminal penalty noted only as needed.","Private actions, UDAP, AG authority, restitution, administrative practice, limitation periods."],["Collections/litigation","Excluded/later pass","Not necessary to current permission/fee result.","Collection Agency Act, FDCPA, state procedure, creditor litigation, garnishment."],["Secured debt and sector laws","Excluded/later pass","NILS fee prohibition included only because directly in CSO fee section.","Mortgage, auto, student, tax, medical, utilities, tribal, agricultural, and regulated-professional debt."],["Local/tribal law","Excluded/later pass","No conclusion.","Municipal, tribal, choice-of-law, sovereign, and reservation nexus research."],["Full exemption universe","Excluded/later pass","Principal Chapter 69 and CSO exemptions covered.","Sector, federal-preemption, government-contractor, creditor, and special-entity exemptions."],["Model acts/comments","Not relied upon","No model act used as Nebraska law.","Historical-legislative pass may compare source act only with enacted version and adoption history."]]}],"claims":[{"claim_id":"S_NE-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C001","Precise assertion":"Chapter 69 debt management requires fee-based financial planning/management and receipt of debtor money or evidences for creditor distribution.","Source and pinpoint":"S001, §69-1201(1). \nNebraska Legislature","Conditions, exceptions, and confidence":"High for text; judicial meaning of “evidences thereof” unresolved."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C002","Precise assertion":"A Chapter 69 debtor is a wage earner whose principal income is wages, salary, or commission; no express personal-purpose debt limitation appears.","Source and pinpoint":"S001, §69-1201(4). \nNebraska Legislature","Conditions, exceptions, and confidence":"High for text; business-purpose and sole-proprietor application held."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C003","Precise assertion":"A licensed custodial model may arrange debt compromises, and the debtor must receive the full benefit.","Source and pinpoint":"S001, §69-1213(5). \nNebraska Legislature","Conditions, exceptions, and confidence":"High; does not independently cover noncustodial settlement."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C004","Precise assertion":"Covered debt management requires a prior SOS license; knowing/willful unlicensed operation is a Class II misdemeanor.","Source and pinpoint":"S001, §§69-1203, 69-1215. \nNebraska Legislature\n+1","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C005","Precise assertion":"Chapter 69 exemptions are limited to the listed professions/entities acting in their regular course.","Source and pinpoint":"S001, §69-1202. \nNebraska Legislature","Conditions, exceptions, and confidence":"High; exact “regular course” applications are fact-dependent."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C006","Precise assertion":"Chapter 69 has no express nonprofit exemption, and an attorney connection alone does not establish the attorney exemption.","Source and pinpoint":"S001, §69-1202. \nNebraska Legislature","Conditions, exceptions, and confidence":"High for absence/text; corporate-practice facts require analysis."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C007","Precise assertion":"A genuinely noncustodial negotiation-only model appears outside the conjunctive definition, but no affirmative Nebraska permission was established.","Source and pinpoint":"S001, §69-1201(1); S017 search. \nNebraska Legislature","Conditions, exceptions, and confidence":"Medium/HOLD; account authority and “evidences thereof” unresolved."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C008","Precise assertion":"Statute uses “in this state” but provides no explicit remote-customer nexus test; roster shows out-of-state licensees.","Source and pinpoint":"S001, §§69-1201(5), 69-1204; S004. \nNebraska Legislature\n+2","Conditions, exceptions, and confidence":"Partial; exact remote trigger held."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C009","Precise assertion":"Written contract must identify obligations, creditors, total charges, dates, and may not exceed 36 months.","Source and pinpoint":"S001, §69-1209. \nNebraska Legislature","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C010","Precise assertion":"Licensee must use a separate debtor-benefit account and generally remit within 15 days, seven for cash, never holding over 35 days.","Source and pinpoint":"S001, §§69-1210, 69-1213(2). \nNebraska Legislature\n+1","Conditions, exceptions, and confidence":"High; reasonable accumulation exception applies."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C011","Precise assertion":"Total fee ceiling is 15% of money agreed to be paid through the licensee.","Source and pinpoint":"S001, §69-1212 sentence 2. \nNebraska Legislature","Conditions, exceptions, and confidence":"High for formula; denominator treatment of provider fees unresolved."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C012","Precise assertion":"Fee must be amortized; no more than monthly amortized amount may be applied; up to $25 may be required initially and credited.","Source and pinpoint":"S001, §69-1212 sentence 3. \nNebraska Legislature","Conditions, exceptions, and confidence":"High for text; interaction when $25 exceeds monthly amount unresolved."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C013","Precise assertion":"Cancellation compensation is capped at 25% of remaining unamortized fee; cancellation/prepayment settlement must be in contract.","Source and pinpoint":"S001, §69-1212. \nNebraska Legislature","Conditions, exceptions, and confidence":"High for arithmetic; whether additional or substitution held."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C014","Precise assertion":"No state fee until program arranged and debtor-approved; contract not effective until payment for creditor distribution.","Source and pinpoint":"S001, §69-1212 final sentences. \nNebraska Legislature","Conditions, exceptions, and confidence":"High; precise $25 sequence held."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C015","Precise assertion":"No statutory indexing formula exists; no adjusted fee notice was verified.","Source and pinpoint":"S001, §69-1212; S006–S008.","Conditions, exceptions, and confidence":"High for no statutory indexing; partial for regulation/bulletin universe."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C016","Precise assertion":"Application entails $200 main-office fee, $100 additional office, $200 investigation, $10,000 bond; renewal fee $100.","Source and pinpoint":"S001, §§69-1204, 69-1206. \nNebraska Legislature\n+1","Conditions, exceptions, and confidence":"High; provider/government charges, not consumer fees."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C017","Precise assertion":"SOS provides application and public roster; July 9 roster says licenses expire December 31, 2026.","Source and pinpoint":"S002, S004, S005. \nNebraska Secretary of State\n+1","Conditions, exceptions, and confidence":"High for dated documents; no named-provider or real-time conclusion."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C018","Precise assertion":"CSO status is triggered by paid services/representations concerning credit improvement, obtaining credit, or related advice.","Source and pinpoint":"S009, §45-802. \nNebraska Legislature","Conditions, exceptions, and confidence":"High; settlement alone is not automatic CSO coverage."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C019","Precise assertion":"CSO Act has listed exemptions, including 501(c)(3), in-scope Nebraska attorneys, and debt-management licensees; claimant bears burden.","Source and pinpoint":"S009, §45-803. \nNebraska Legislature","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C020","Precise assertion":"Covered CSO must register before business and maintain $100,000 bond/account.","Source and pinpoint":"S009, §§45-805–45-806; S010–S012. \nNebraska Legislature\n+1","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C021","Precise assertion":"Nebraska CSO Act has no general consumer cap; bonded exception may allow precompletion payment for non-credit-obtaining services, but obtaining-credit fees wait until credit obtained; NILS Act loan fees are prohibited.","Source and pinpoint":"S009, §45-804(1), (2), (8). \nNebraska Legislature","Conditions, exceptions, and confidence":"High for state law; federal restrictions separate."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C022","Precise assertion":"Nebraska CSO buyer has three-day cancellation and payment return within ten days after notice.","Source and pinpoint":"S009, §45-808. \nNebraska Legislature","Conditions, exceptions, and confidence":"High; text says days, not business days."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C023","Precise assertion":"TSR debt-relief definition covers represented alterations of unsecured debt; applicability requires telemarketing facts, and debt-relief ad/direct-mail calls are carved out of ordinary inbound exemptions.","Source and pinpoint":"S014, §§310.2(o), 310.6(b)(5)–(7). \neCFR\n+1","Conditions, exceptions, and confidence":"High federal text; transaction-specific applicability required."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C024","Precise assertion":"Applicable TSR prohibits debt-relief fees until one debt is altered, one payment is made, and individual-debt fees use a consistent proportion or savings method.","Source and pinpoint":"S014, §310.4(a)(5)(i). \neCFR","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C025","Precise assertion":"TSR dedicated-account conditions do not settle Nebraska custody classification.","Source and pinpoint":"S014, §310.4(a)(5)(ii); S001, §69-1201(1). \neCFR\n+1","Conditions, exceptions, and confidence":"High as separation-of-law conclusion; Nebraska application held."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C026","Precise assertion":"TSR credit-repair branch has distinct result-documentation and six-month timing.","Source and pinpoint":"S014, §310.4(a)(2). \neCFR","Conditions, exceptions, and confidence":"High when representations and TSR coverage exist."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C027","Precise assertion":"CROA conditionally covers paid credit-improvement services and bars payment before agreed service is fully performed; three-business-day protections apply.","Source and pinpoint":"S015, §§1679a, 1679b, 1679d, 1679e. \nU.S. Code\n+3","Conditions, exceptions, and confidence":"High; federal exemptions and jurisdiction must be tested."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C028","Precise assertion":"State fee permission and federal fee timing are independent; compliance with one does not satisfy the other.","Source and pinpoint":"S001 §69-1212; S014 §310.4; S015 §1679b.","Conditions, exceptions, and confidence":"High legal-layering conclusion."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C029","Precise assertion":"Money-transmitter exemption protects only a Nebraska-licensed person acting within license scope.","Source and pinpoint":"S013, §8-2703(14). \nNebraska Legislature","Conditions, exceptions, and confidence":"High; full money-transmission classification excluded."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C030","Precise assertion":"No debt-management-specific regulation/guidance was verified, but official dynamic rules catalog was inaccessible without JavaScript.","Source and pinpoint":"S006–S008. \nNebraska Secretary of State\n+2","Conditions, exceptions, and confidence":"Partial/HOLD; cannot prove complete absence."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C031","Precise assertion":"No controlling Nebraska appellate interpretation was located for the principal classification and fee ambiguities.","Source and pinpoint":"S017.","Conditions, exceptions, and confidence":"Limited negative search result, not an exhaustive citator/docket conclusion."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C032","Precise assertion":"NDBF’s “15–25% of enrolled debt” statement is consumer education, not Nebraska’s statutory fee ceiling.","Source and pinpoint":"S016; compare S001 §69-1212. \nNebraska Banking and Finance\n+1","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C033","Precise assertion":"Labels such as nonprofit, law firm, DMP, settlement, or credit counseling do not replace activity-based classification.","Source and pinpoint":"S001 §§69-1201–1202; S009 §§45-802–803.","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NE-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P1-C034","Precise assertion":"§69-1213 mentions remittance “less fees and costs,” but no separate open-ended consumer-cost authority or cap was verified.","Source and pinpoint":"S001 §§69-1209, 69-1212, 69-1213(2). \nNebraska Legislature\n+2","Conditions, exceptions, and confidence":"HOLD for any consumer cost outside disclosed lawful fee."},"coordinator_verification_status":"reviewed_with_initial_exception_cancellation_federal_precision_and_current_rules_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_NE-P1-S001","urls":["https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1205","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1206","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1208","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1215"],"researcher_record":{"Source ID":"S_NE-P1-S001","Authority, literal URL, and exact pinpoint":"Nebraska Debt Management Act, Neb. Rev. Stat. §§69-1201–69-1217. Material sections actually read: §69-1201 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201; §69-1202 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1202; §69-1203 license: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1203; §69-1204 application/bond: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1204; §69-1205 issuance: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1205; §69-1206 renewal: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1206; §69-1207 discipline: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207; §69-1208 rules: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1208; §69-1209 contract: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209; §69-1210 account: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210; §69-1211 examination: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211; §69-1212 fees/timing: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212; §69-1213 duties/compromise: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213; §69-1214 prohibitions: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214; §69-1215 penalty: https://nebraskalegislature.gov/laws/statutes.php?statute=69-1215. \nNebraska Legislature\n+14","Version/effective status and actual access":"Official current codification pages as displayed and checked October 24, 2026. Section histories vary; §69-1204 and §69-1206 were amended in 2020; §69-1212’s current fee text traces to 1967. No future-effective language displayed.","Jurisdiction and limitations":"Controlling Nebraska statute. No located decision resolves key noncustodial or remote-nexus language."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S002","urls":["https://sos.nebraska.gov/licensing/debt-management-agencies"],"researcher_record":{"Source ID":"S_NE-P1-S002","Authority, literal URL, and exact pinpoint":"Nebraska Secretary of State, Debt Management Agencies: https://sos.nebraska.gov/licensing/debt-management-agencies, links at page lines 98–107. \nNebraska Secretary of State","Version/effective status and actual access":"Page checked October 24, 2026; footer ©2026.","Jurisdiction and limitations":"Operational licensing page; not a substitute for statutory permission."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S003","urls":["https://sos.nebraska.gov/licensing/debt-management-statutes"],"researcher_record":{"Source ID":"S_NE-P1-S003","Authority, literal URL, and exact pinpoint":"SOS Debt Management Statutes index: https://sos.nebraska.gov/licensing/debt-management-statutes, lines 94–115. \nNebraska Secretary of State","Version/effective status and actual access":"Checked October 24, 2026.","Jurisdiction and limitations":"Navigation/index only; linked Legislature text controls."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S004","urls":["https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf"],"researcher_record":{"Source ID":"S_NE-P1-S004","Authority, literal URL, and exact pinpoint":"Active Debt Management Agency Licensees PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Debt%20Management%20Roster.pdf, pp. 1–2. \nNebraska Secretary of State\n+2","Version/effective status and actual access":"PDF dated July 9, 2026; says licenses expire December 31, 2026; opened, parsed, and visually inspected October 24.","Jurisdiction and limitations":"Dated roster, not real-time verification or scope opinion."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S005","urls":["https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf"],"researcher_record":{"Source ID":"S_NE-P1-S005","Authority, literal URL, and exact pinpoint":"Debt Management License Application PDF: https://sos.nebraska.gov/sites/default/files/doc/Debt%20Management%20License%20Application.pdf, p. 1. \nNebraska Secretary of State\n+1","Version/effective status and actual access":"Undated form as publicly displayed; opened and visually inspected October 24, 2026.","Jurisdiction and limitations":"Procedure/supporting-document evidence only. Statute controls fees and eligibility."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S006","urls":["https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents"],"researcher_record":{"Source ID":"S_NE-P1-S006","Authority, literal URL, and exact pinpoint":"SOS Index of Rules and Regulations and Guidance Documents: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents, Title 433 at lines 97–107 and licensing guidance at lines 144–149. \nNebraska Secretary of State","Version/effective status and actual access":"Checked October 24, 2026.","Jurisdiction and limitations":"Shows official index structure and listed guidance; absence from list is not conclusive proof no rule exists."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S007","urls":["https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf"],"researcher_record":{"Source ID":"S_NE-P1-S007","Authority, literal URL, and exact pinpoint":"Secretary of State annual rules/guidance index PDF: https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf, pp. 1–2. \nNebraska Legislature\n+1","Version/effective status and actual access":"Dated February 19, 2026; opened and visually inspected October 24.","Jurisdiction and limitations":"Annual snapshot, not proof against later rulemaking."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S008","urls":["https://rules.nebraska.gov/rules?agencyId=61&titleId=201","https://rules.nebraska.gov/docket"],"researcher_record":{"Source ID":"S_NE-P1-S008","Authority, literal URL, and exact pinpoint":"Official dynamic rules routes: https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket. \nNebraska Rules\n+1","Version/effective status and actual access":"Access attempted October 24, 2026; both returned JavaScript application shells through available public-web route.","Jurisdiction and limitations":"Full current Title 433 and docket not retrieved. No API/Chrome workaround used."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S009","urls":["https://nebraskalegislature.gov/laws/statutes.php?statute=45-802","https://nebraskalegislature.gov/laws/statutes.php?statute=45-803","https://nebraskalegislature.gov/laws/statutes.php?statute=45-804","https://nebraskalegislature.gov/laws/statutes.php?statute=45-805","https://nebraskalegislature.gov/laws/statutes.php?statute=45-806","https://nebraskalegislature.gov/laws/statutes.php?statute=45-807","https://nebraskalegislature.gov/laws/statutes.php?statute=45-808"],"researcher_record":{"Source ID":"S_NE-P1-S009","Authority, literal URL, and exact pinpoint":"Nebraska Credit Services Organization Act. §45-802 definitions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-802; §45-803 exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=45-803; §45-804 prohibited acts/fees: https://nebraskalegislature.gov/laws/statutes.php?statute=45-804; §45-805 bond/account: https://nebraskalegislature.gov/laws/statutes.php?statute=45-805; §45-806 registration: https://nebraskalegislature.gov/laws/statutes.php?statute=45-806; §45-807 disclosures: https://nebraskalegislature.gov/laws/statutes.php?statute=45-807; §45-808 contract/cancellation: https://nebraskalegislature.gov/laws/statutes.php?statute=45-808. \nNebraska Legislature\n+6","Version/effective status and actual access":"Official current codification pages checked October 24, 2026. §45-804 reflects 2025 LB474 amendment.","Jurisdiction and limitations":"Conditional overlap only; debt settlement does not automatically equal credit services."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S010","urls":["https://sos.nebraska.gov/licensing/credit-services-organizations"],"researcher_record":{"Source ID":"S_NE-P1-S010","Authority, literal URL, and exact pinpoint":"SOS Credit Services Organizations page: https://sos.nebraska.gov/licensing/credit-services-organizations, lines 94–113. \nNebraska Secretary of State","Version/effective status and actual access":"Checked October 24, 2026.","Jurisdiction and limitations":"Procedure and public links; not substantive classification guidance."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S011","urls":["https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf"],"researcher_record":{"Source ID":"S_NE-P1-S011","Authority, literal URL, and exact pinpoint":"Active CSO roster PDF: https://sos.nebraska.gov/sites/default/files/doc/regulations/licensing/20260709_Credit%20Service%20Roster.pdf, p. 1. \nNebraska Secretary of State\n+1","Version/effective status and actual access":"Dated July 9, 2026; opened and visually inspected October 24.","Jurisdiction and limitations":"Snapshot only; no named-provider conclusion."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S012","urls":["https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf"],"researcher_record":{"Source ID":"S_NE-P1-S012","Authority, literal URL, and exact pinpoint":"CSO Registration Form: https://sos.nebraska.gov/sites/default/files/doc/Registration%20Form.pdf, p. 1. \nNebraska Secretary of State\n+1","Version/effective status and actual access":"Public form opened and visually inspected October 24, 2026.","Jurisdiction and limitations":"Procedure only."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S013","urls":["https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703"],"researcher_record":{"Source ID":"S_NE-P1-S013","Authority, literal URL, and exact pinpoint":"Neb. Rev. Stat. §8-2703(14), Money Transmitters Act exemptions: https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703. \nNebraska Legislature\n+1","Version/effective status and actual access":"Current codification checked October 24, 2026; 2026 LB717; operative July 18, 2026.","Jurisdiction and limitations":"Exemption only for licensed persons acting within license scope; not full money-transmission analysis."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S014","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"],"researcher_record":{"Source ID":"S_NE-P1-S014","Authority, literal URL, and exact pinpoint":"Federal TSR: 16 C.F.R. §310.2: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2; §310.4: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4; §310.6: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6. \neCFR\n+3","Version/effective status and actual access":"eCFR displayed Title 16 current through October 22, 2026; last amended October 19, 2026; accessed October 24.","Jurisdiction and limitations":"Federal common context only; applicability requires telemarketing facts and exemptions analysis."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S015","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679a/","https://uscode.house.gov/us/usc/119-124/t15/s1679b/","https://uscode.house.gov/us/usc/119-124/t15/s1679d/","https://uscode.house.gov/us/usc/119-124/t15/s1679e/"],"researcher_record":{"Source ID":"S_NE-P1-S015","Authority, literal URL, and exact pinpoint":"Federal CROA: 15 U.S.C. §1679a: https://uscode.house.gov/us/usc/119-124/t15/s1679a/; §1679b: https://uscode.house.gov/us/usc/119-124/t15/s1679b/; §1679d: https://uscode.house.gov/us/usc/119-124/t15/s1679d/; §1679e: https://uscode.house.gov/us/usc/119-124/t15/s1679e/. \nU.S. Code\n+3","Version/effective status and actual access":"U.S. Code source states laws in effect through Public Law 119-124, October 15, 2026; accessed October 24.","Jurisdiction and limitations":"Conditional on credit-improvement purpose and statutory jurisdiction/exemptions."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S016","urls":["https://ndbf.nebraska.gov/are-debt-settlement-plans-you","https://ndbf.nebraska.gov/how-can-i-negotiate-better-terms-my-creditors"],"researcher_record":{"Source ID":"S_NE-P1-S016","Authority, literal URL, and exact pinpoint":"Nebraska Department of Banking and Finance consumer education: https://ndbf.nebraska.gov/are-debt-settlement-plans-you; https://ndbf.nebraska.gov/how-can-i-negotiate-better-terms-my-creditors. \nNebraska Banking and Finance\n+1","Version/effective status and actual access":"First article posted February 17, 2026; accessed October 24.","Jurisdiction and limitations":"Consumer education, not licensing authority, fee ceiling, or formal interpretation."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NE-P1-S017","urls":["https://www.nebraska.gov/apps-courts-epub/"],"researcher_record":{"Source ID":"S_NE-P1-S017","Authority, literal URL, and exact pinpoint":"Nebraska appellate-opinion public repository searched: https://www.nebraska.gov/apps-courts-epub/; exact-citation searches also run against official Nebraska Judicial Branch and public case indexes.","Version/effective status and actual access":"Searched October 24, 2026 for §§69-1201, 69-1212, “Debt Management Act,” and “Credit Services Organization Act.”","Jurisdiction and limitations":"No on-point controlling Nebraska appellate decision located. Search was not a paid docket search or exhaustive citator review."},"coordinator_verification_status":"see_exact_selected_primary_failed_rules_annual_unread_version_and_explicit_reuse_in_reviews/S_NE-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Debt-management definition","researcher_record":{"Component issue":"Debt-management definition","Status":"Answered","Findings/claim IDs":"Conjunctive planning/fee/custody/distribution test. C001","Exact missing evidence or next investigation":"Court/agency interpretation only if a disputed fact pattern arises."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"“Debtor” definition","researcher_record":{"Component issue":"“Debtor” definition","Status":"Answered/partial","Findings/claim IDs":"Wage earner income test. C002","Exact missing evidence or next investigation":"Decision or interpretation addressing sole proprietor, business-purpose obligations, retirees, gig income, and mixed income."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP versus settlement","researcher_record":{"Component issue":"DMP versus settlement","Status":"Answered","Findings/claim IDs":"No separate statutory labels; actual conduct governs. C001, C003, C033","Exact missing evidence or next investigation":"None for basic distinction."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Principal reduction","researcher_record":{"Component issue":"Principal reduction","Status":"Answered","Findings/claim IDs":"Compromise expressly contemplated in licensed model. C003","Exact missing evidence or next investigation":"Later pass should test creditor-consent and settlement-contract issues."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial model","researcher_record":{"Component issue":"Custodial model","Status":"Answered","Findings/claim IDs":"Licensed Chapter 69 pathway. C004, C009–C014","Exact missing evidence or next investigation":"Full operational compliance audit later."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial negotiation","researcher_record":{"Component issue":"Noncustodial negotiation","Status":"Unresolved/held","Findings/claim IDs":"Likely outside plain Chapter 69 definition; no affirmative permission. C007","Exact missing evidence or next investigation":"Official interpretation or controlling case on “and,” “evidences thereof,” account/payment authority, and third-party account structures."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Dedicated-account classification","researcher_record":{"Component issue":"Dedicated-account classification","Status":"Unresolved/held","Findings/claim IDs":"Federal rule verified; Nebraska effect not resolved. C025","Exact missing evidence or next investigation":"Nebraska SOS/AG/court authority applying §69-1201 to consumer-owned accounts."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business-purpose boundary","researcher_record":{"Component issue":"Consumer/business-purpose boundary","Status":"Partial","Findings/claim IDs":"Chapter 69 wage-earner test; CSO personal-purpose test. C002, C018","Exact missing evidence or next investigation":"Nebraska authority on individual business debt and mixed-purpose portfolios."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nebraska resident/remote-provider nexus","researcher_record":{"Component issue":"Nebraska resident/remote-provider nexus","Status":"Partial","Findings/claim IDs":"Out-of-state licensing operationally shown; exact nexus absent. C008","Exact missing evidence or next investigation":"Statute, rule, order, or case defining “in this state” for remote service."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"License/prohibition","researcher_record":{"Component issue":"License/prohibition","Status":"Answered","Findings/claim IDs":"License required; unlicensed knowing/willful activity criminal. C004","Exact missing evidence or next investigation":"Later enforcement-history review."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-management issuing regulator","researcher_record":{"Component issue":"Debt-management issuing regulator","Status":"Answered","Findings/claim IDs":"Secretary of State. C004, C017","Exact missing evidence or next investigation":"None."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-management application","researcher_record":{"Component issue":"Debt-management application","Status":"Answered for public procedure","Findings/claim IDs":"Application, fees, bond, contract filing. C016–C017","Exact missing evidence or next investigation":"Current internal processing standards, processing time, and unpublished requirements not investigated."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-management roster","researcher_record":{"Component issue":"Debt-management roster","Status":"Answered with date limitation","Findings/claim IDs":"July 9, 2026 active roster; expiry statement. C017","Exact missing evidence or next investigation":"Same-day provider-specific confirmation if later requested."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exemption","researcher_record":{"Component issue":"Attorney exemption","Status":"Answered textually","Findings/claim IDs":"Only attorneys acting in regular professional course. C005–C006","Exact missing evidence or next investigation":"Entity/practice-specific facts and unauthorized-practice analysis later."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit exemption","researcher_record":{"Component issue":"Nonprofit exemption","Status":"Answered","Findings/claim IDs":"None in Chapter 69; distinct CSO/CROA exemptions. C006, C019, C027","Exact missing evidence or next investigation":"Federal nonprofit/FTC-jurisdiction analysis if relied upon."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Institutional exclusions","researcher_record":{"Component issue":"Institutional exclusions","Status":"Answered textually","Findings/claim IDs":"Banks, fiduciaries, lenders, title/escrow, employees, court actors. C005","Exact missing evidence or next investigation":"Entity-specific charter and activity review later."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Debt-management total fee base","researcher_record":{"Component issue":"Debt-management total fee base","Status":"Answered with denominator hold","Findings/claim IDs":"15% of money agreed through licensee. C011","Exact missing evidence or next investigation":"Authority on whether denominator excludes provider fee and treatment of failed/modified payments."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Setup/initial fee","researcher_record":{"Component issue":"Setup/initial fee","Status":"Answered/partial","Findings/claim IDs":"Up to $25, credited. C012","Exact missing evidence or next investigation":"Interpretation of timing and interaction with monthly amount."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Monthly fee","researcher_record":{"Component issue":"Monthly fee","Status":"Answered","Findings/claim IDs":"Contracted fee amortized; no more than monthly amount. C012","Exact missing evidence or next investigation":"Rounding/final-installment rule not found."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement/per-debt/savings fee","researcher_record":{"Component issue":"Settlement/per-debt/savings fee","Status":"Answered as no separate state pathway","Findings/claim IDs":"Must remain within Chapter 69 formula; TSR allocation separate. C011, C024","Exact missing evidence or next investigation":"State interpretation if provider proposes hybrid fee."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation fee","researcher_record":{"Component issue":"Cancellation fee","Status":"Answered arithmetically/partial legally","Findings/claim IDs":"25% of remaining unamortized fee. C013","Exact missing evidence or next investigation":"Whether additional to earned fees or replacement/settlement."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Prepayment","researcher_record":{"Component issue":"Prepayment","Status":"Partial","Findings/claim IDs":"Contract must state provision. C013","Exact missing evidence or next investigation":"No formula located; need rules/cases/contracts review."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Refund/credit","researcher_record":{"Component issue":"Refund/credit","Status":"Partial","Findings/claim IDs":"$25 credited; CSO cancellation refund verified. C012, C022","Exact missing evidence or next investigation":"Chapter 69 termination/refund treatment beyond cancellation charge."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Additional consumer “costs”","researcher_record":{"Component issue":"Additional consumer “costs”","Status":"Unresolved/held","Findings/claim IDs":"“Fees and costs” phrase found; no separate authority. C034","Exact missing evidence or next investigation":"Rules, approved contracts, or interpretation defining permissible costs."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Indexing/current adjusted amounts","researcher_record":{"Component issue":"Indexing/current adjusted amounts","Status":"Answered for statute; rules gap remains","Findings/claim IDs":"No statutory index; no adjustment verified. C015, C030","Exact missing evidence or next investigation":"Accessible complete Title 433 and docket/adoption-order review."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State fee timing","researcher_record":{"Component issue":"State fee timing","Status":"Answered with initial-payment sequence hold","Findings/claim IDs":"Program arranged/approved; creditor-distribution payment activates contract. C014","Exact missing evidence or next investigation":"Official interpretation of $25 sequence."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR debt-relief timing","researcher_record":{"Component issue":"Federal TSR debt-relief timing","Status":"Answered as conditional overlay","Findings/claim IDs":"First altered debt + first payment + allocation. C023–C024","Exact missing evidence or next investigation":"Transaction-specific telemarketing and exemption facts."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"TSR credit-repair timing","researcher_record":{"Component issue":"TSR credit-repair timing","Status":"Answered as conditional overlay","Findings/claim IDs":"Separate result and six-month documentation rule. C026","Exact missing evidence or next investigation":"Representation-specific facts."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Federal CROA overlap","researcher_record":{"Component issue":"Federal CROA overlap","Status":"Answered as conditional overlay","Findings/claim IDs":"Credit-improvement trigger, advance-fee ban, cancellation. C027","Exact missing evidence or next investigation":"Entity exemption and exact services/representations."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nebraska CSO definition","researcher_record":{"Component issue":"Nebraska CSO definition","Status":"Answered","Findings/claim IDs":"Credit improvement/obtaining credit/advice. C018","Exact missing evidence or next investigation":"Application to a particular settlement message or funnel."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nebraska CSO authorization","researcher_record":{"Component issue":"Nebraska CSO authorization","Status":"Answered","Findings/claim IDs":"Registration and $100,000 bond/account. C020","Exact missing evidence or next investigation":"Named-provider lookup if requested."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nebraska CSO fee cap","researcher_record":{"Component issue":"Nebraska CSO fee cap","Status":"Answered","Findings/claim IDs":"No general cap verified; timing/zero-fee branches apply. C021","Exact missing evidence or next investigation":"Other sector-specific laws beyond the NILS branch remain later work."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"CSO cancellation","researcher_record":{"Component issue":"CSO cancellation","Status":"Answered","Findings/claim IDs":"Three days; refund within ten. C022","Exact missing evidence or next investigation":"Calendar computation/holiday case law not reviewed."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Rules and adoption orders","researcher_record":{"Component issue":"Rules and adoption orders","Status":"Partial/held","Findings/claim IDs":"Static index checked; dynamic catalog inaccessible. C030","Exact missing evidence or next investigation":"Obtain an accessible official consolidated Title 433 and docket record; inspect all debt-management amendments/orders."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling cases","researcher_record":{"Component issue":"Controlling cases","Status":"Partial/held","Findings/claim IDs":"No on-point appellate authority found. C031","Exact missing evidence or next investigation":"Full citator, paid docket, trial orders, administrative decisions, and historical AG opinions."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Money-transmitter interaction","researcher_record":{"Component issue":"Money-transmitter interaction","Status":"Partial","Findings/claim IDs":"In-scope license exemption verified. C029","Exact missing evidence or next investigation":"Full unlicensed/dedicated-account money-transmission analysis later."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider authorization","researcher_record":{"Component issue":"Named-provider authorization","Status":"Not performed by design","Findings/claim IDs":"No provider supplied; no status inference. C017","Exact missing evidence or next investigation":"Exact legal name, aliases, and requested status date."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement content beyond fee fields","researcher_record":{"Component issue":"Agreement content beyond fee fields","Status":"Excluded/later pass","Findings/claim IDs":"Only fee-relevant contract terms reviewed.","Exact missing evidence or next investigation":"Full agreement-form, disclosure, electronic-signature, assignment, arbitration, and modification review."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Funds/trust/bond operational audit","researcher_record":{"Component issue":"Funds/trust/bond operational audit","Status":"Excluded/later pass","Findings/claim IDs":"Basic account and bonds identified.","Exact missing evidence or next investigation":"Reconciliation, permissible withdrawals, surety claims, insolvency, administrator relationships."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Remedies/enforcement","researcher_record":{"Component issue":"Remedies/enforcement","Status":"Excluded/later pass","Findings/claim IDs":"License discipline and criminal penalty noted only as needed.","Exact missing evidence or next investigation":"Private actions, UDAP, AG authority, restitution, administrative practice, limitation periods."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collections/litigation","researcher_record":{"Component issue":"Collections/litigation","Status":"Excluded/later pass","Findings/claim IDs":"Not necessary to current permission/fee result.","Exact missing evidence or next investigation":"Collection Agency Act, FDCPA, state procedure, creditor litigation, garnishment."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt and sector laws","researcher_record":{"Component issue":"Secured debt and sector laws","Status":"Excluded/later pass","Findings/claim IDs":"NILS fee prohibition included only because directly in CSO fee section.","Exact missing evidence or next investigation":"Mortgage, auto, student, tax, medical, utilities, tribal, agricultural, and regulated-professional debt."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Local/tribal law","researcher_record":{"Component issue":"Local/tribal law","Status":"Excluded/later pass","Findings/claim IDs":"No conclusion.","Exact missing evidence or next investigation":"Municipal, tribal, choice-of-law, sovereign, and reservation nexus research."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full exemption universe","researcher_record":{"Component issue":"Full exemption universe","Status":"Excluded/later pass","Findings/claim IDs":"Principal Chapter 69 and CSO exemptions covered.","Exact missing evidence or next investigation":"Sector, federal-preemption, government-contractor, creditor, and special-entity exemptions."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Model acts/comments","researcher_record":{"Component issue":"Model acts/comments","Status":"Not relied upon","Findings/claim IDs":"No model act used as Nebraska law.","Exact missing evidence or next investigation":"Historical-legislative pass may compare source act only with enacted version and adoption history."},"coordinator_acceptance":"reviewed_partial_with_holds_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}