{"meta":{"key":"s_ne--pass-04","task":"S_NE","title":"SNE Nebraska consumer-money custody, account, and return architecture","parent_title":"Nebraska debt and debt relief law","edition":"pass-04","path":"/research/s_ne--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":5,"claims":34,"sources":10,"review_status":"accepted_with_limits_checked_core_partial_component","review_complete":true,"sha256":"65a023d5bd8701a41e19fde4b5bbd7c0b5ede767ac1cea1567437814a3cbd445","headings":["Executive determination","1. Chapter 69 custody entry point and model classification","1.1 Operative entry point","1.2 Indirect receipt and control","1.3 Consumer-owned designated accounts","1.4 Scheduled creditor distributions","1.5 Genuinely noncustodial negotiation","2. Account institution, segregation, deposit, remittance, fees, interest, and shortages","2.1 What Nebraska affirmatively requires","2.2 Institution and location","2.3 Account title, ownership, and beneficial interest","2.4 Deposit deadline","2.5 Creditor-remittance deadlines","2.6 Provider-fee withdrawals","2.7 Interest","2.8 Reserves, shortages, bank charges, and reversals","2.9 FDIC recognition is a separate federal inquiry","2.10 Bankruptcy priority remains held","3. Ledgers, reconciliation, statements, examinations, and cessation records","3.1 General books and records","3.2 Debtor-level records","3.3 Consumer statements and access","3.4 Regulator examination","3.5 Cessation and insolvency","4. Cancellation, failed plans, rejected proposals, and returns","4.1 Separate the four amounts","4.2 Nebraska return architecture","4.3 Cancellation compensation versus principal","4.4 Failed enrollment or ineffective contract","4.5 Rejected creditor proposal","4.6 Provider termination or closure","4.7 Federal seven-business-day return is not a Nebraska rule","5. Nebraska money-transmission gateway for administrators and processors","5.1 Basic definition and Nebraska nexus","5.2 In-scope Chapter 69 exemption","5.3 Potential independent administrator pathways","5.4 Authorized-delegate funds","5.5 Money-transmitter records and reconciliation","5.6 Forwarding and refunds","5.7 Receipts","5.8 Insolvency protections in the money-transmitter branch","6. Reconciliation with the conditional federal dedicated-account overlay","Common assumptions","Ledger 1 — Licensed custodial DMP, no established fee","Ledger 2 — Fee withdrawal only after explicit predicates","Ledger 3 — Reasonable accumulation to a sum certain","Ledger 4 — ACH reversal after a completed creditor payment","Ledger 5 — Consumer-owned account with unresolved Nebraska classification","Nebraska result","Conditional federal result","Ledger 6 — Independent licensed money transmitter refund","Ledger 7 — Authorized delegate commingling rule","Freshly read in PASS-04","Explicitly reused rather than independently reread as a separate review","Not authenticated or not read","Actions 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-04","facets":{"geography":["us","us-ne"],"debt_type":[],"stage":[],"subject":["client-money"]},"scope":"Exactreviewed remaining Nebraska funds/account/custody/administrator/return component; P3servicewithdrawalprecision andcurrentTitle433/fee/provider/broaderholds retained.","pending_corrections":0},"markdown":"# S_NE PASS-04 — Nebraska consumer-money custody, account, and return architecture\n\n**Actual fresh research date:** October 25, 2026, Pacific time\n**Mode/model:** Regular Chat; GPT-5.6 Sol Pro\n**Review status:** Same-coordinator continuation, **not independent review**.\n\nThis pass addresses only custody, account operation, necessary return mechanics, administrators/processors, and the limited money-transmission gateway. PASS-01 through PASS-03 findings and corrections remain unchanged unless expressly supplemented here. The unresolved Title 433 evidence gap was not converted into a no-rule finding, and the inaccessible endpoints were not repeatedly queried.\n\n## Executive determination\n\nA licensed Nebraska debt-management model has a definite statutory custody architecture:\n\n1. Chapter 69 is entered when the provider both plans/manages a debtor’s financial affairs for a fee **and receives money or “evidences thereof” from the debtor for creditor distribution**.\n2. The licensee must place all debtor payments received for creditors into a **separate bank account for the benefit of debtors**.\n3. Those payments remain there until remitted to a debtor, creditor, or the licensee for a fee that is otherwise lawfully payable.\n4. Creditor remittances ordinarily must occur within 15 days after receipt—or seven days for cash—with a reasonable-accumulation exception that never permits retention beyond 35 days after receipt.\n5. The licensee must keep transaction and debtor-level records, provide requested accountings, and submit to Secretary of State examination. [Nebraska Legislature+3](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201)\n\nThe verified statute does **not** specify:\n\n- a Nebraska-located bank;\n- a federally insured bank;\n- exact account-title wording;\n- individual bank accounts for each consumer;\n- express legal or beneficial ownership;\n- an express Chapter 69 statutory trust;\n- entitlement to account interest;\n- a numerical deposit deadline;\n- a reconciliation frequency;\n- chargeback, shortage, reserve, ACH-return, or bank-fee allocation;\n- a cancellation-specific principal-return deadline;\n- a provider wind-down or account-transfer procedure; or\n- bankruptcy priority.\n\nThose omissions remain legal and operational gaps. They cannot be filled by calling an account “trust,” “consumer-owned,” “independent,” “FBO,” or “noncustodial.”\n\nNebraska’s current Money Transmitters Act creates a second, entity-specific gateway. A Chapter 69 licensee acting within the scope of that license has a statutory money-transmitter exemption, but that exemption does **not automatically pass to an affiliate, bank-account administrator, payment processor, technology vendor, or independent settlement-account company**. Such an entity must independently be licensed, be an authorized delegate, or satisfy every element of a statutory exemption. [Nebraska Legislature+2](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\n# A. Account and model matrix\n\n| Model or flow | Chapter 69 custody result | Account and money-transmission consequence | PASS-04 disposition |\n| --- | --- | --- | --- |\n| Licensed debt manager directly receives a debtor’s payment and schedules creditor distributions | Directly within the statutory custody architecture when the remaining definition elements are satisfied | Deposit creditor-benefit payments into the separate debtor-benefit bank account; follow remittance and record duties. The licensee’s in-scope activity may use §8-2703(14)’s money-transmitter exemption. | **Answered** |\n| Licensed debt manager receives money through its own employee or a processor acting solely as the licensee’s receiving arm | Substance points toward receipt by the licensee, but Chapter 69 does not define attributed or constructive receipt | Processor authority, agency, account ownership, loss allocation, and control must be examined. A processor’s separate legal entity status matters under the Money Transmitters Act. | **Partial; entity facts required** |\n| Provider affiliate owns the receiving account or can debit, release, redirect, approve, or veto creditor payments | Account title alone does not establish noncustody; these powers are material to “receiving” money or “evidences thereof” | The provider’s Chapter 69 and §8-2703(14) exemptions do not automatically cover the affiliate. | **Unresolved classification** |\n| Consumer-owned designated account; provider or affiliate has payment authority or fee-debit authority | Consumer ownership alone does not establish that the model is outside Chapter 69 | “Evidences thereof,” indirect receipt, and control remain unresolved under Nebraska law; independent money-transmitter analysis may be required. | **Held** |\n| Consumer-owned account administered by an unaffiliated entity; provider cannot receive, direct, block, debit, or approve transfers | Strongest factual case for noncustodial treatment, but no controlling Nebraska interpretation was located | Administrator still needs its own Nebraska status if it receives money for transmission. Federal TSR account compliance does not establish Nebraska permission. | **Held; not affirmatively authorized** |\n| Consumer pays creditors directly and provider only negotiates, with no provider or affiliate receipt or payment authority | Does not plainly satisfy Chapter 69’s receipt/distribution element | No Chapter 69 account duties on the stated facts, but the broader legality of the negotiation service remains outside this funds pass. | **Textual boundary only** |\n| Independent Nebraska money-transmitter licensee receives consumer money and sends it to creditors | Processing alone does not make it the Chapter 69 debt manager | Money-transmitter records, refund, permissible-investment, receipt, and solvency rules may apply to the administrator. | **Conditional lawful gateway** |\n| Authorized delegate of a Nebraska money-transmitter licensee | Operates on behalf of the money-transmitter licensee, not automatically on behalf of the Chapter 69 licensee | Written delegate contract, trust for the licensee, records, examination, no subdelegation, and immediate cessation when principal authority ends. | **Conditional lawful gateway** |\n| Claimed agent-of-payee, intermediary-processor, payment-system-operator, or bank-service-provider model | Labels do not establish an exemption | Every statutory condition must be met, including written agreements, allocation of loss, identification of the principal provider, and scope restrictions. | **Fact-dependent hold** |\n| Federal TSR-compliant dedicated account | Does not itself determine Nebraska custody or licensing | Conditional federal ownership, insured-institution, independence, interest, service-withdrawal, and return requirements apply when the TSR account provision is actually applicable. | **Conditional federal overlay only** |\n\n# B. Substantive answers\n\n## 1. Chapter 69 custody entry point and model classification\n\n### 1.1 Operative entry point\n\nNeb. Rev. Stat. §69-1201(1) uses a conjunctive definition. “Debt management” requires:\n\n- planning and managing the financial affairs of a debtor;\n- for a fee from that debtor; **and**\n- receiving from the debtor money or “evidences thereof” for distribution to creditors in payment or partial payment of obligations.\n\nA “creditor” is correspondingly defined as a person for whose benefit money is collected and disbursed by licensees. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201)\n\nThis makes direct custody straightforward: when a licensed debt manager takes the debtor’s payment and later pays creditors, Chapter 69’s account architecture applies.\n\n### 1.2 Indirect receipt and control\n\nChapter 69 does not define:\n\n- “receiving”;\n- “evidences thereof”;\n- constructive receipt;\n- payment-control authority;\n- an account administrator;\n- a payment processor;\n- a consumer-owned settlement account; or\n- when an affiliate’s receipt is attributed to the debt manager.\n\nNo controlling Nebraska decision or official interpretation was located that resolves those terms for modern ACH, debit authorization, application-programming-interface, or independent-account structures. The following facts are therefore material but not individually dispositive:\n\n- who is the bank’s customer;\n- who has legal and beneficial ownership;\n- who may initiate or cancel an ACH debit;\n- who may approve, veto, delay, or redirect creditor payments;\n- who may debit provider fees;\n- whether payment to the processor discharges any consumer obligation;\n- whether the processor acts for the provider, consumer, creditor, or money-transmitter licensee;\n- who bears loss if the processor fails;\n- who receives account statements and data;\n- whether the provider can replace or direct the administrator; and\n- whether the provider possesses a check, payment instrument, debit mandate, or other “evidence” of the consumer’s funds.\n\nA provider cannot establish noncustody merely by placing legal title to the bank account in the consumer, an affiliate, or a processor while retaining practical payment authority.\n\n### 1.3 Consumer-owned designated accounts\n\nA genuinely consumer-owned account administered independently, where the debt-relief provider and its affiliates cannot receive funds, direct or block transfers, debit fees, or control the administrator, presents the strongest textual case for falling outside Chapter 69’s receipt element.\n\nThat conclusion remains a **classification hold**, not an affirmative Nebraska authorization, because:\n\n- “evidences thereof” is undefined;\n- no Nebraska authority addressing these account mechanics was located;\n- the administrator’s own money-transmission status remains separate; and\n- actual agreements and control rights were not provided.\n\nConversely, a nominally consumer-owned account does not eliminate custody risk when the provider or affiliate has effective disbursement or fee-debit authority.\n\n### 1.4 Scheduled creditor distributions\n\nA model in which the provider receives regular consumer payments and schedules or executes creditor payments is the paradigm Chapter 69 custodial model. The statute expressly requires a written contract listing the obligations and creditors, and treats a contract as ineffective until the debtor makes a payment to the licensee for creditor distribution. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209)\n\n### 1.5 Genuinely noncustodial negotiation\n\nA model in which:\n\n- the consumer retains sole control of the money;\n- the consumer independently pays the creditor;\n- the provider never receives money or a payment instrument;\n- the provider cannot debit, direct, approve, or block payments; and\n- no affiliate or agent receives money for the provider\n\ndoes not plainly satisfy the entire §69-1201(1) definition.\n\nThat does not resolve market access for the negotiation service under other Nebraska or federal laws. It only addresses the Chapter 69 funds element.\n\n## 2. Account institution, segregation, deposit, remittance, fees, interest, and shortages\n\n### 2.1 What Nebraska affirmatively requires\n\nSection 69-1210 requires a licensed debt manager to maintain:\n\na separate bank account for the benefit of debtors.\n\nAll payments received from debtors for creditors must be deposited there, and the payments must remain there until remitted to:\n\n- the debtor;\n- a creditor; or\n- the licensee for fees. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\nThis establishes a restricted-purpose account and requires separation from the licensee’s ordinary operating funds. It does not require one bank account for every debtor. The statutory text is compatible with one pooled debtor-benefit account, provided the licensee’s debtor-level records accurately identify each debtor’s receipts, disbursements, and charges.\n\nThe Act does not expressly authorize using one debtor’s balance to cover another debtor’s creditor payment, shortage, chargeback, or fee. No such cross-consumer netting permission was verified.\n\n### 2.2 Institution and location\n\nThe verified Chapter 69 text says “bank account.” It does not specify:\n\n- Nebraska location;\n- federally insured status;\n- FDIC or NCUA coverage;\n- state or national charter;\n- minimum capitalization;\n- whether a credit-union account qualifies;\n- one or multiple banks;\n- concentration limits; or\n- an approved-bank list.\n\nAccordingly, no insurer qualification or geographic location may be invented from Chapter 69’s silence.\n\nWhen the federal TSR dedicated-account provision independently applies, it requires an **insured financial institution**. That is a separate federal condition, not a Nebraska Chapter 69 requirement. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 2.3 Account title, ownership, and beneficial interest\n\nChapter 69 does not prescribe exact account-title language. It says the account is maintained “for the benefit of debtors,” but does not expressly say:\n\n- the debtors hold legal title;\n- each debtor holds a fractional beneficial interest;\n- the licensee is a trustee;\n- the account is a statutory trust;\n- funds are outside the licensee’s bankruptcy estate; or\n- the account has federal pass-through deposit insurance.\n\nThus, an “FBO,” “trust,” “escrow,” or “custodial” title is relevant evidence but is not conclusive by itself.\n\n### 2.4 Deposit deadline\n\nSection 69-1210 commands deposit of all qualifying payments but supplies no numerical “same day,” “next business day,” or other deposit deadline. Section 69-1213’s 7-, 15-, and 35-day rules govern creditor remittance and retention after receipt; they should not be rewritten as a statutory deposit deadline. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\n### 2.5 Creditor-remittance deadlines\n\nThe verified rules are:\n\n- Noncash funds: remit to creditors within **15 days after receipt**.\n- Cash: remit within **seven days after receipt**.\n- Exception: funds may be held longer when reasonable payment of one or more obligations requires accumulation of a sum certain.\n- Absolute ceiling: the licensee may never retain funds longer than **35 days after receipt from the debtor**. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213)\n\nThe 35-day limit is measured from receipt, not from cancellation, settlement approval, or a later accounting event. For multiple deposits, each receipt has its own statutory age.\n\nThe accumulation exception is not a general liquidity reserve. It must be tied to reasonable payment of identified debtor obligations and cannot extend beyond 35 days.\n\n### 2.6 Provider-fee withdrawals\n\nSection 69-1210 identifies the licensee as a possible remittance recipient “for fees,” and §69-1213 describes creditor remittances “less fees and costs.” Those clauses do not independently establish that a fee has been earned or is currently payable. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\nA withdrawal for the licensee requires, at minimum:\n\n- a fee permitted by the contract;\n- satisfaction of §69-1212’s arrangement, approval, effectiveness, amortization, and other conditions;\n- satisfaction of any independently applicable federal earning conditions;\n- correct allocation to the relevant consumer or debt; and\n- an account balance not already committed or remitted elsewhere.\n\nA numerical amount below a statutory cap is not automatically earned. The earlier PASS-01 through PASS-03 holds concerning the initial $25 payment, cancellation compensation, catch-up charges, “costs,” prepayment, and federal allocation remain unchanged.\n\n### 2.7 Interest\n\nChapter 69 does not state:\n\n- whether the account must be interest-bearing;\n- whether the debtor, provider, bank, or another person owns interest;\n- how pooled-account interest is allocated; or\n- whether interest may offset bank or administrator fees.\n\nNo state-law interest allocation should be inferred.\n\nFor a covered federal TSR account, the consumer must own the funds and be paid accrued interest, if any. That federal condition does not establish the treatment of interest in every Nebraska Chapter 69 account. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 2.8 Reserves, shortages, bank charges, and reversals\n\nNo Chapter 69 provision reviewed establishes:\n\n- a required operating or liquidity reserve;\n- overdraft permission;\n- shortage-allocation rules;\n- ACH-return allocation;\n- chargeback rights;\n- returned-check fees;\n- bank-fee pass-through;\n- administrator-fee pass-through;\n- priority among consumers in a pooled account; or\n- a mechanism for replenishing a shortage.\n\nThe phrase “less fees and costs” is not sufficient to invent any of those charges. The actual bank agreement, ACH authorization, processor agreement, consumer contract, cleared-funds status, and any governing rule are necessary.\n\n### 2.9 FDIC recognition is a separate federal inquiry\n\nFederal deposit-insurance rules generally presume ownership from the insured bank’s deposit-account records. For fiduciary coverage, the fiduciary relationship must be disclosed in the bank’s records, and the beneficial interests must be ascertainable from the bank’s records or good-faith records maintained in the ordinary course. Multi-tier structures have additional disclosure requirements. Funds genuinely owned by principals and deposited in an agent, custodian, or nominee account may be insured as if deposited in the principals’ names, subject to the governing rules and aggregation. [eCFR+1](https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5)\n\nTherefore:\n\n- Chapter 69’s “for the benefit of debtors” phrase does not itself prove FDIC pass-through treatment.\n- A bank-account title alone does not prove pass-through treatment.\n- Provider records alone may be insufficient if the bank’s records do not disclose the fiduciary relationship.\n- FDIC treatment addresses the depository institution’s failure; it does not resolve provider bankruptcy, fraud, ACH disputes, or account-contract ownership.\n\n### 2.10 Bankruptcy priority remains held\n\nFederal bankruptcy law brings into the estate the debtor’s legal or equitable interests. If a debtor holds only legal title and not an equitable interest, §541(d) limits the estate to that legal title and excludes an equitable interest the debtor does not hold. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t11/s541/)\n\nApplying that principle to a Chapter 69 debt manager requires facts and state-law conclusions not established here:\n\n- actual account title;\n- legal and beneficial ownership;\n- whether a valid trust exists;\n- tracing;\n- commingling;\n- account and consumer-contract terms;\n- bank setoff rights;\n- perfected interests;\n- insolvency orders; and\n- the particular debtor entity in bankruptcy.\n\nChapter 69 does not expressly create the kind of insolvency statutory trust that Nebraska’s Money Transmitters Act expressly creates for a money-transmitter licensee’s permissible investments. No conclusion that Chapter 69 funds are automatically outside a provider’s bankruptcy estate is warranted.\n\n## 3. Ledgers, reconciliation, statements, examinations, and cessation records\n\n### 3.1 General books and records\n\nSection 69-1210 requires books, accounts, and records sufficient for the Secretary of State to determine compliance. They must be preserved for at least five years after the final entry on the recorded transaction. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\n### 3.2 Debtor-level records\n\nSection 69-1213 separately requires complete and adequate records for each debtor during the contract and for five years after cancellation or completion. Those records must contain complete information concerning:\n\n- the contract;\n- extensions;\n- payments;\n- disbursements; and\n- charges. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213)\n\nThese two retention clauses have different trigger language. An implementation must satisfy both. Retaining records through the later potentially applicable date is a conservative operational approach, not an express statutory “later-of” formula.\n\nThe statute does not prescribe:\n\n- a chart of accounts;\n- a particular ledger layout;\n- double-entry accounting;\n- transaction identifiers;\n- daily balance reports;\n- immutable audit logs;\n- bank-to-ledger reconciliation frequency;\n- segregation by consumer at the bank level; or\n- electronic-record standards.\n\nA debtor-level subledger is nevertheless practically necessary to produce the required complete debtor information and prevent one debtor’s funds or charges from being attributed to another.\n\n### 3.3 Consumer statements and access\n\nUpon request, the licensee must:\n\n- furnish a written account statement each 90 days; or\n- provide a verbal accounting whenever requested during normal business hours. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213)\n\nThe reviewed text does not require:\n\n- automatic statements when the consumer makes no request;\n- monthly statements;\n- real-time online access;\n- direct access to the bank account;\n- downloadable transaction history;\n- notice of every pending ACH item; or\n- an account-closing statement.\n\nA requested statement should be reconcilable to the required records of payments, disbursements, and charges, but the statute does not specify its exact fields.\n\n### 3.4 Regulator examination\n\nThe Secretary of State may examine a licensee without notice, question under oath the licensee and specified associated persons—including customers and creditors—and compel production of books, accounts, records, and files in an alleged-violation investigation. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211)\n\nNo Chapter 69 clause reviewed requires routine consumer-account reports to be filed with the Secretary, or immediate notice to the Secretary when:\n\n- a bank account is changed;\n- an account is frozen or closed;\n- an ACH processor is replaced;\n- a shortage occurs;\n- a chargeback happens;\n- a payment is rejected; or\n- the provider loses access to the account.\n\nThose matters may be addressed by an unverified rule, order, examination instruction, approved contract, or bank agreement; no such current authority was authenticated in this pass.\n\n### 3.5 Cessation and insolvency\n\nInsolvency, bankruptcy, receivership, or a general assignment for creditors is grounds for denial, suspension, or revocation of a Chapter 69 license. The license is nontransferable. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207)\n\nChapter 69 does not provide a verified detailed wind-down procedure for:\n\n- notifying every debtor;\n- transferring the account;\n- replacing the licensee;\n- freezing provider fees;\n- reconciling pending creditor payments;\n- returning all balances;\n- dealing with unpresented checks;\n- assigning contracts; or\n- providing final statements.\n\nThe separate-account, record, and maximum-retention duties do not disappear merely because the provider becomes insolvent or stops operating, but the exact turnover procedure requires an actual regulator or court order, valid contract provisions, and bank records.\n\n## 4. Cancellation, failed plans, rejected proposals, and returns\n\n### 4.1 Separate the four amounts\n\nA cancellation analysis must keep four categories separate:\n\n1. **Already completed creditor remittances**\nThese are no longer part of the held account balance and must not be subtracted a second time.\n2. **Unremitted consumer principal**\nThese are funds still held for the debtor’s creditor program.\n3. **Fees already lawfully earned and paid**\nThese require all state and applicable federal predicates; their prior payment must be traceable.\n4. **Proposed cancellation compensation or other unpaid charges**\nThese are not automatically earned merely because they are within a numerical state ceiling.\n\n### 4.2 Nebraska return architecture\n\nChapter 69 requires the contract to state the cancellation and prepayment settlement. It also expressly permits an account remittance to the debtor. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212)\n\nThat establishes a legal route for returning unremitted money to the debtor. It does not supply an immediate cancellation-specific return deadline.\n\nThe independently applicable 35-day maximum remains an outer retention ceiling measured from the date each payment was received. It is not a rule allowing the licensee to keep canceled-plan funds for 35 days when they can and should be returned sooner; nor does it identify the correct recipient in every failed-plan scenario.\n\n### 4.3 Cancellation compensation versus principal\n\nThe possible cancellation compensation under §69-1212 is analytically different from unremitted principal:\n\n- The principal is the consumer’s money received for the creditor program.\n- Cancellation compensation is a provider charge subject to unresolved state characterization and any federal earning limits.\n- A state numerical ceiling does not make the charge federally earned.\n- A provider may not deduct it from held money without an actual lawful entitlement and correct account authority.\n\nThe PASS-02 and PASS-03 qualifications remain unchanged.\n\n### 4.4 Failed enrollment or ineffective contract\n\nA Chapter 69 licensee is not entitled to any fee or charge before the program is arranged and approved by the debtor. The contract is not effective until the debtor makes a payment to the licensee for creditor distribution. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212)\n\nIf money reaches the licensee but the program is never arranged or approved:\n\n- no provider fee is established;\n- if the money was received for creditor benefit, the strongest textual reading is that the separate-account and retention protections attach to that money;\n- if no creditor payment can lawfully or practically be made, return to the debtor is a permitted account disposition; and\n- the exact state return deadline, beyond the maximum-retention rule, is not specified.\n\nThe actual payment authorization and contract formation facts would be essential.\n\n### 4.5 Rejected creditor proposal\n\nA creditor’s rejection of a proposal does not itself:\n\n- earn a provider fee;\n- authorize a cancellation charge;\n- restart the 15-, 7-, or 35-day clocks;\n- permit indefinite accumulation; or\n- make the funds the provider’s property.\n\nIf the provider can still reasonably apply the money to another identified obligation, the accumulation exception may be relevant. Otherwise, the funds must be remitted under the authorized plan or returned. The statute does not establish a universal ordering rule between partial creditor remittance and debtor return after rejection.\n\n### 4.6 Provider termination or closure\n\nA license termination does not transfer the Chapter 69 license or establish ownership of the account. Chapter 69 contains no verified automatic successor-provider mechanism.\n\nFor money-transmitter licensees, a different statute expressly preserves preexisting lawful contract obligations after suspension, revocation, cancellation, surrender, or expiration, while an authorized delegate must immediately stop providing money transmission when the principal license terminates. Those provisions apply only to the money-transmitter branch. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724)\n\n### 4.7 Federal seven-business-day return is not a Nebraska rule\n\nWhen §310.4(a)(5)(ii) actually applies:\n\n- the customer may withdraw from the **debt-relief service** at any time without penalty;\n- upon request, the customer must receive all covered-account funds except fees earned in compliance with §310.4(a)(5)(i)(A)–(C);\n- return must occur within seven business days.\n\nThat is not:\n\n- an unconditional right under the TSR to close a bank account;\n- a Nebraska Chapter 69 return deadline;\n- proof that every Nebraska customer has such an account; or\n- permission to deduct a fee merely because a state cap exists. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## 5. Nebraska money-transmission gateway for administrators and processors\n\n## 5.1 Basic definition and Nebraska nexus\n\nCurrent Nebraska law defines money transmission to include receiving money for transmission from a person located in Nebraska. “Receiving money for transmission” means receiving money or monetary value in the United States for transmission by electronic or other means.\n\nFor electronic or telephone transactions, the provider may determine Nebraska location from information such as the consumer’s residential address, an entity’s principal place of business, another physical address, or account-associated records. An “authorized delegate” is a person designated by a money-transmitter licensee to conduct money transmission on its behalf. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702)\n\nA person generally may not engage in, advertise, solicit, or hold itself out as providing money transmission unless:\n\n- licensed;\n- acting as an authorized delegate within a written contract; or\n- within a statutory exemption and not conducting transmission outside that exemption. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2709)\n\n### 5.2 In-scope Chapter 69 exemption\n\nSection 8-2703(14) exempts a person licensed in Nebraska and acting within Nebraska within the scope of its:\n\n- collection-agency license;\n- credit-services-organization authority; or\n- debt-management license. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\nThe operative limitations are important:\n\n- It is the status of the actual receiving legal entity that matters.\n- The activity must be within that entity’s license scope.\n- A parent, subsidiary, affiliate, account administrator, processor, vendor, or referral partner does not inherit the exemption merely from association with the licensed debt manager.\n- A provider cannot use the exemption to conduct independent money transmission outside the debt-management license.\n- The Department of Banking and Finance may require documentation demonstrating an exemption. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2704)\n\n### 5.3 Potential independent administrator pathways\n\nAn administrator receiving Nebraska consumer money may need to fit one of these paths:\n\n#### Licensed money transmitter\n\nThe administrator itself holds a current Nebraska money-transmitter license and performs the transaction within that license.\n\n#### Authorized delegate\n\nThe administrator is designated by a licensed money transmitter and acts within a written delegate contract. The principal must conduct a risk-based background review and maintain compliance policies. The contract must define authority, rights, duties, handling and remittance terms, records, examination consent, and regulatory control. No subdelegate is permitted. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724)\n\n#### Payment-system operator\n\nThe exception is limited to processing, clearing, or settlement **between or among licensed or exempt persons** in specified payment systems. Merely transmitting ACH files does not establish the exception when the counterparties or activity do not satisfy it.\n\n#### Agent of payee\n\nEvery condition must be met:\n\n- a written agreement with the payee;\n- public holding-out by the payee that the agent accepts payments on its behalf;\n- payment deemed received by the payee when received by the agent;\n- extinguishment of the payor’s obligation; and\n- no payor loss risk if the agent fails to remit.\n\nThe payment must be for goods or services, other than money transmission, provided by the payee. A creditor-payment or debt-settlement structure cannot be assumed to satisfy that language without examining the underlying obligation and agreements. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\n#### Intermediary processor\n\nThe entity with the direct outstanding money-transmission obligation must:\n\n- be licensed or exempt;\n- be identified to the sender as the transmission provider; and\n- bear sole responsibility, including making the sender whole if transmission fails.\n\nA white-label platform does not establish this exception merely by calling itself a processor. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\n#### Bank service provider or agent\n\nThe exception applies only when the service provider acts for a qualifying exempt depository institution under a written agreement and the exempt institution assumes all risk of loss and legal responsibility upon receipt by the provider. A bank account or banking relationship alone is insufficient. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703)\n\n### 5.4 Authorized-delegate funds\n\nAn authorized delegate must hold money received for transmission, net of fees, in trust **for the benefit of the money-transmitter licensee**. If commingled with the delegate’s own property, the statute deems the commingled property held in trust for the licensee up to the applicable amount. This is not an express consumer trust and should not be confused with Chapter 69’s debtor-benefit bank account. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724)\n\n### 5.5 Money-transmitter records and reconciliation\n\nA money-transmitter licensee must retain for at least five years:\n\n- outstanding-obligation records;\n- a general ledger posted at least monthly;\n- bank statements and bank-reconciliation records;\n- records of outstanding and paid obligations; and\n- its delegate list.\n\nRecords may be outside Nebraska if accessible to the director within seven business days after notice. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2723)\n\nThese duties do not automatically apply to an in-scope Chapter 69 licensee using §8-2703(14)’s exemption. They may apply to a separately licensed administrator.\n\n### 5.6 Forwarding and refunds\n\nA money-transmitter licensee must forward funds according to the sender agreement unless it reasonably believes fraud or another legal violation may be involved. If it does not forward, it must normally explain why in response to the sender. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2726)\n\nSubject to exclusions and exceptions, a money-transmitter licensee must refund money within ten days after receiving the sender’s written request. Relevant exceptions include:\n\n- timely forwarding;\n- instructions committing an equivalent amount to the designated person;\n- an agreed later forwarding date;\n- a legal or crime concern; or\n- an insufficiently identifiable request.\n\nThe refund provision does not apply to funds governed by the federal remittance rule or received under the specified written payee-processing agreement. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727)\n\nThis ten-day rule must not be applied automatically to a Chapter 69 debt manager whose conduct is exempt from the Money Transmitters Act.\n\n### 5.7 Receipts\n\nUnless an exception applies, a money-transmitter licensee or delegate must give the sender a retainable receipt containing transaction, recipient, licensee, amount, fee, and regulator information. The receipt provision has exclusions for federal remittances, nonconsumer-purpose transfers, specified payee-processing arrangements, and payroll services. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2728)\n\nChapter 69 itself does not contain this same transaction-receipt form.\n\n### 5.8 Insolvency protections in the money-transmitter branch\n\nA money-transmitter licensee must maintain permissible investments at least equal to its aggregate outstanding transmission obligations. Upon insolvency, bankruptcy, receivership, dissolution, reorganization, or specified creditor action, those investments are held in a statutory trust for purchasers and holders of outstanding obligations, protected from attachment by nonbeneficiaries, and allocated pro rata and equitably across applicable states. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2732)\n\nThis express statutory trust applies to the money-transmitter licensee’s permissible investments. It should not be imported into Chapter 69 merely because both regimes involve consumer funds.\n\nA money-transmitter licensee also must report bankruptcy, receivership, dissolution, reorganization, or a general assignment to the director within one business day after it has reason to know of the event. That reporting duty is likewise specific to the money-transmitter branch. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2721)\n\n## 6. Reconciliation with the conditional federal dedicated-account overlay\n\nWhen the TSR account provision applies, the verified federal conditions are:\n\n- the account is at an insured financial institution;\n- the customer owns the account funds;\n- the customer receives accrued interest, if any;\n- the administrator is not owned, controlled by, or affiliated with the debt-relief service;\n- the administrator and debt-relief service exchange no referral compensation;\n- the customer may withdraw from the debt-relief service without penalty; and\n- upon request, all account funds except fees earned under the complete §310.4(a)(5)(i)(A)–(C) conditions must be received within seven business days. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThose requirements do not answer the Nebraska questions:\n\n| Federal fact | What it does **not** prove under Nebraska law |\n| --- | --- |\n| Customer owns account funds | That the provider never receives “evidences thereof” or lacks payment control |\n| Independent administrator | That the administrator is exempt from Nebraska money-transmitter licensing |\n| Insured financial institution | That FDIC pass-through record requirements are satisfied |\n| Provider cannot be affiliated with administrator | That no agency, payment-instruction, or contract relationship exists |\n| Withdrawal from debt-relief service | A right under this TSR clause to close the bank account or independently cancel every ACH authorization |\n| Seven-business-day return | A universal Nebraska return deadline |\n| Earned-fee exception | That any particular fee is earned, correctly allocated, or deductible under state law |\n| Consumer ownership | Automatic bankruptcy exclusion without actual ownership, tracing, and record evidence |\n\nService withdrawal, bank-account closure, revocation of an ACH authorization, cancellation of a Chapter 69 contract, and return of the current account balance are separate events. One document may address several, but the legal rules must not be collapsed.\n\n# C. Bounded ledger examples\n\n## Common assumptions\n\nUnless an example says otherwise:\n\n- All figures are United States dollars.\n- No rounding is necessary.\n- Receipts are cleared funds.\n- No interest, pending ACH items, unpresented checks, reversals, chargebacks, bank fees, or administrator fees exist.\n- No fee is deducted unless the example expressly stipulates that the fee is contractually payable, permitted by Nebraska law, and—if applicable—earned under federal law.\n- Completed creditor remittances are final and are not subtracted twice.\n- The examples are not evidence of any provider’s actual account.\n\n## Ledger 1 — Licensed custodial DMP, no established fee\n\n**Facts**\n\n- Day 0: licensee receives noncash consumer funds: **$1,000**\n- Day 10: remittance to Creditor A: **$600**\n- Day 10: remittance to Creditor B: **$250**\n- Lawfully earned and payable provider fee established: **$0**\n\n**Ledger**\n\nPlain text\n```\nStarting cleared receipt                         $1,000\nLess completed Creditor A remittance              -600\nLess completed Creditor B remittance              -250\nLess established payable fee                         0\n                                                -------\nCurrent held balance                              $150\n```\n\nThe two creditor remittances occurred within the 15-day state deadline. The current held balance is $150; the $850 already remitted is not deducted again.\n\nIf the consumer cancels on Day 10 and no further creditor payment is authorized:\n\n- conditional unremitted principal return: **$150**\n- presumptive recipient for a return: **the debtor**, because §69-1210 expressly permits remittance to the debtor;\n- state cancellation-specific return deadline: **not established**;\n- absolute state retention ceiling: no later than 35 days after the Day 0 receipt, absent an earlier required disposition.\n\nNo cancellation compensation is deducted because no legal entitlement to it is assumed. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\n## Ledger 2 — Fee withdrawal only after explicit predicates\n\n**Facts**\n\n- Starting cleared receipt: **$800**\n- Creditor payment made on Day 12: **$650**\n- A **$40 fee** is expressly stipulated to have satisfied:the actual contract;all Nebraska arrangement, approval, effectiveness, and amortization conditions;any applicable federal debt-level earning and allocation conditions; andthe account’s valid payment authority.\n- No cancellation compensation or additional charge is assumed.\n\n**Ledger**\n\nPlain text\n```\nStarting cleared receipt                           $800\nLess completed creditor remittance                 -650\nLess expressly established earned/payable fee       -40\n                                                   ----\nCurrent held balance                               $110\n```\n\nOn cancellation, with no pending item or further creditor instruction, the conditional principal return is **$110**.\n\nThe example does not prove the $40 predicates for any real transaction. It illustrates that §69-1210’s fee-remittance endpoint may be used only after lawful entitlement has independently been established. [Nebraska Legislature+1](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210)\n\n## Ledger 3 — Reasonable accumulation to a sum certain\n\n**Facts**\n\n- Creditor requires a single **$500** payment.\n- Day 0 noncash receipt: **$300**\n- Day 20 additional noncash receipt: **$200**\n- Day 22 creditor remittance: **$500**\n- Fee: **$0**\n\n**Per-receipt timing**\n\nPlain text\n```\nFirst receipt held:   Day 0 through Day 22 = 22 days\nSecond receipt held:  Day 20 through Day 22 = 2 days\n```\n\n**Ledger**\n\nPlain text\n```\nDay 0 receipt                                      $300\nDay 20 receipt                                     +200\n                                                  -----\nAvailable accumulated sum                          $500\nDay 22 creditor remittance                         -500\n                                                  -----\nCurrent held balance                                  $0\n```\n\nThe accumulation is tied to a specific reasonable creditor payment, and neither receipt exceeds 35 days.\n\nIf the second $200 never arrives, the first $300 cannot remain with the licensee after Day 35. Whether it must be sent as an acceptable partial creditor payment or returned to the debtor depends on creditor acceptance, the contract, and actual instructions; the statute does not supply a universal ordering rule. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213)\n\n## Ledger 4 — ACH reversal after a completed creditor payment\n\n**Facts**\n\n- Day 0 cleared receipt: **$1,200**\n- Day 10 completed creditor payment: **$700**\n- Provisional held balance: **$500**\n- Day 14 ACH reversal allocated to this same consumer: **$150**\n- Fee and bank charge: **$0**\n\n**Ledger**\n\nPlain text\n```\nStarting cleared receipt                         $1,200\nLess completed creditor remittance                -700\n                                                -------\nBalance before reversal                            $500\nLess consumer-specific ACH reversal                -150\n                                                -------\nCurrent held balance                               $350\n```\n\nThe completed $700 creditor payment is subtracted once. The current balance is $350.\n\nNebraska Chapter 69 does not specify who ultimately bears the reversal loss or permit the licensee to charge another consumer’s balance. This result assumes the reversal is validly allocated to this consumer under the actual bank and ACH agreements. A bank-imposed charge is not deducted because no contractual or legal pass-through authority is established.\n\nConditional cancellation return before any proven fee: **$350**.\n\n## Ledger 5 — Consumer-owned account with unresolved Nebraska classification\n\n**Facts**\n\n- Consumer deposits into an account titled in the consumer’s name: **$1,000**\n- Account administrator sends creditor payment: **$600**\n- Remaining bank balance: **$400**\n- Provider fee earned under federal and state law: **$0**\n- No interest, pending transfer, reversal, or bank hold.\n\n**Arithmetic**\n\nPlain text\n```\nConsumer account deposit                         $1,000\nLess completed creditor payment                    -600\n                                                -------\nCurrent account balance                            $400\n```\n\n### Nebraska result\n\nThe $400 arithmetic does not establish whether:\n\n- the provider received money or “evidences thereof”;\n- the provider is noncustodial;\n- the administrator is a money transmitter;\n- the provider has fee-debit or payment authority; or\n- Chapter 69’s separate-account duty applies.\n\nThose outcomes require the account, ACH, administrator, provider, and creditor-payment agreements.\n\n### Conditional federal result\n\nAssume additionally that §310.4(a)(5)(ii) applies, the customer requests withdrawal from the debt-relief service, and no fee has been earned under §310.4(a)(5)(i)(A)–(C). The amount to be received within seven business days is:\n\nPlain text\n```\nCurrent covered-account funds                      $400\nLess federally earned fee                              0\n                                                   ----\nConditional federal return                         $400\n```\n\nThis is a request-based withdrawal from the debt-relief service and return of covered-account funds. It is not an automatic order to close the bank account. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n## Ledger 6 — Independent licensed money transmitter refund\n\n**Facts**\n\n- Independent Nebraska money-transmitter licensee receives: **$700**\n- No money has been forwarded or committed to a recipient.\n- Sender provides an identifiable written refund request on Day 2.\n- No crime/law hold, federal-remittance exclusion, payee-processing exclusion, or agreed later transfer date applies.\n- Fee: **$0**\n\n**Ledger**\n\nPlain text\n```\nMoney received for transmission                    $700\nMoney forwarded or committed                          0\n                                                   ----\nOutstanding amount                                 $700\nWritten refund request amount                      $700\n```\n\nConditional result: the money-transmitter licensee must refund **$700 within ten days after receipt of the written request**.\n\nThis example does not apply the ten-day rule to an in-scope Chapter 69 licensee that is exempt under §8-2703(14). [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727)\n\n## Ledger 7 — Authorized delegate commingling rule\n\n**Facts**\n\n- Authorized delegate receives for transmission: **$900**\n- Established delegate fees: **$0**\n- Delegate has its own funds in the same account: **$2,000**\n\n**Ledger**\n\nPlain text\n```\nDelegate's own funds                              $2,000\nTransmission funds received                         +900\n                                                 -------\nTotal commingled property                         $2,900\n\nTransmission money net of fees                      $900\nStatutory trust amount for licensee                  $900\n```\n\nUnder §8-2724, the $900 is treated as held in trust **for the money-transmitter licensee**, despite commingling. The provision does not itself establish a consumer trust, determine the consumer’s Chapter 69 balance, or authorize a provider fee.\n\nThe delegate may not appoint a subdelegate. If the principal license terminates, the delegate must immediately cease money-transmission activity. [Nebraska Legislature](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724)\n\n# D. Source register\n\n| Source ID | Title, issuer, literal URL, and exact pinpoint | Version/effective status and actual access | Use and limitations; prior relationship |\n| --- | --- | --- | --- |\n| **S_NE-P4-S001** | **Nebraska Debt Management Act—selected operative funds provisions**, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201 §69-1201(1), (6); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207 §69-1207(1)(e), (3); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212 complete operative paragraph; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213 subsections (1)–(5); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214 subsections (1)–(6). [Nebraska Legislature+7](https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201) | Current official codification pages as displayed and freshly read October 25, 2026 Pacific. Principal funds clauses show 1967 source history; §69-1201 also shows 1993 amendment. No complete session-law or rule-history audit. | Controlling state statutory source. Reuses document family previously identified as S_NE-P1-S001 and S_NE-P2-S002, with fresh P4 funds readings. Sections are not counted as independent authorities. |\n| **S_NE-P4-S002** | **Nebraska Money Transmitters Act—current gateway and operational provisions**, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702 §§8-2702(3), (11), (13), (22), (25), (30)–(31); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703 §§8-2703(1)–(3), (7), (12)–(14), (17); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2704; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2709; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2720; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2721; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2723; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2725; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2726; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2728; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2732; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2734. [Nebraska Legislature+13](https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702) | Current official codification freshly read October 25, 2026 Pacific. §§8-2702 and 8-2703 display an operative date of July 18, 2026. Source histories differ by section; no claim is made that the 2026 amendments first created every relevant concept. | Controlling state source for the limited processor/administrator gateway. Not a full money-transmission licensing, application, enforcement, or rule audit. |\n| **S_NE-P4-S003** | **16 C.F.R. §310.4**, Federal Trade Commission rule in eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4, paragraphs (a)(5)(i)(A)–(C) and (a)(5)(ii)(A)–(E). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | eCFR displayed Title 16 current through October 22, 2026 and last amended October 19, 2026; freshly opened October 25. | Conditional federal overlay only. Reuses S_NE-P2-S001 and the PASS-03 wording correction. No full TSR coverage or exemptions rerun. |\n| **S_NE-P4-S004** | **12 C.F.R. §§330.5 and 330.7**, Federal Deposit Insurance Corporation. https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5, paragraphs (a)(1)–(2), (b)(1)–(3); https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.7, paragraphs (a)–(c). [eCFR+1](https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5) | eCFR displayed Title 12 current through October 22, 2026 and last amended October 2, 2026; freshly read October 25. | Governs FDIC recognition of deposit ownership/fiduciary interests. Does not establish Nebraska account ownership, actual insurance, provider solvency protection, or coverage at a specific institution. |\n| **S_NE-P4-S005** | **11 U.S.C. §541**, Office of the Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t11/s541/, subsections (a)(1), (b)(1), and (d). [U.S. Code](https://uscode.house.gov/us/usc/119-124/t11/s541/) | Text states laws in effect through Public Law 119-124, October 15, 2026; freshly read October 25. | Governs bankruptcy-estate interests generally. No Nebraska Chapter 69 bankruptcy case, tracing decision, or provider insolvency record was reviewed. |\n| **S_NE-P4-S006** | **Debt Management Statutes**, Nebraska Secretary of State. https://sos.nebraska.gov/licensing/debt-management-statutes, entries for §§69-1201–69-1217. [Nebraska Secretary of State](https://sos.nebraska.gov/licensing/debt-management-statutes?utm_source=chatgpt.com) | Current agency navigation page accessed October 25; page metadata contains an older submission date that is not a legal effective date. | Navigation only; not an independent interpretation or substitute for the Legislature text. Prior alias S_NE-P1-S003. |\n| **S_NE-P4-S007** | **Current Title 433 routes and annual index**: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents; https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket; https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf. | PASS-02 access history preserved: HTML index identified Title 433; dynamic catalog produced a JavaScript shell; docket produced distinct shell/403 observations; annual document was a dated snapshot with limited extraction/view history. P4 did not repeat the same inaccessible loop. | **Failed/not-complete current-rule route.** No complete current Title 433 DMP account rule, docket, or adoption-order universe authenticated. Prior aliases S_NE-P2-S004–S007. |\n| **S_NE-P4-S008** | **2023 Occupational Regulation Review—Secretary of State programs**, Nebraska Legislative Council. https://nebraskalegislature.gov/FloorDocs/108/PDF/Agencies/Legislative_Council/707_20231218-113223.pdf, printed/report pp. 3–4. | Dated December 2023; freshly read and visually inspected October 25, 2026. | Secondary official historical/context source only. It identifies rulemaking authority and Title assignments but describes an incomplete review; it is not current rule text or proof of no later rule. |\n| **S_NE-P4-S009** | **Bounded public interpretation search routes**, including Nebraska appellate publication repository https://www.nebraska.gov/apps-courts-epub/ and exact-term searches across official Nebraska Legislature, SOS, Judicial Branch, Attorney General, and NDBF domains for “evidences thereof,” §§69-1201, 69-1210, 69-1213, third-party account, administrator, and processor terms. | Search-only work on October 25, 2026. No on-point controlling interpretation was located. | Negative search result only; not an exhaustive commercial citator, administrative-file, trial-docket, or records-request search and not proof that no interpretation exists. |\n| **S_NE-P4-S010** | **Nebraska Money Transmitters Act index**, Nebraska Department of Banking and Finance. https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act. [Nebraska Banking and Finance](https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act?utm_source=chatgpt.com) | Current agency navigation page accessed October 25, 2026. | Used only to confirm the agency’s current statutory navigation. Operative Legislature text controls. Older NDBF PDFs surfaced by search were not relied upon because they predate the 2025–2026 recodification. |\n\n# E. Claim register\n\n| Claim ID | Precise assertion | Source and pinpoint | Conditions, exceptions, currentness, and confidence |\n| --- | --- | --- | --- |\n| **S_NE-P4-C001** | Chapter 69 custody requires fee-based financial planning/management and receipt of debtor money or evidences for creditor distribution. | S001, §69-1201(1). | **High** for text; “evidences thereof” and attributed receipt remain unresolved. |\n| **S_NE-P4-C002** | Direct receipt by a licensed debt manager for scheduled creditor distribution is within the statutory custody architecture. | S001, §§69-1201(1), 69-1209, 69-1210, 69-1212. | **High** when all definition and debtor conditions are met. |\n| **S_NE-P4-C003** | Provider/affiliate/processor indirect control and consumer-owned accounts cannot be classified solely by account title or marketing label. | S001, §§69-1201(1), 69-1210; S009 limited search. | **Medium/HOLD**; no controlling interpretation found. |\n| **S_NE-P4-C004** | A genuinely negotiation-only model with no receipt, evidence, debit authority, payment direction, or affiliate receipt does not plainly satisfy the receipt element. | S001, §69-1201(1). | **Textual inference only**; not affirmative market authorization. |\n| **S_NE-P4-C005** | Licensee must maintain a separate bank account for debtors’ benefit and deposit all qualifying creditor-benefit payments there. | S001, §69-1210 sentence 1. | **High**. |\n| **S_NE-P4-C006** | Account money remains until remitted to debtor, creditor, or licensee for fees. | S001, §69-1210 sentence 1. | **High**; a fee destination does not establish earning or amount. |\n| **S_NE-P4-C007** | Chapter 69 does not expressly require one bank account per consumer; debtor-level records are nevertheless mandatory. | S001, §§69-1210, 69-1213(1). | **High** for absence and records; pooled-account implementation remains subject to accurate allocation. |\n| **S_NE-P4-C008** | Chapter 69 provides no numerical deposit deadline. | S001, §§69-1210, 69-1213. | **High** for reviewed statutory text; unverified current-rule gap remains. |\n| **S_NE-P4-C009** | Creditor remittance is due in 15 days, seven days for cash, subject to reasonable sum-certain accumulation and an absolute 35-day retention ceiling. | S001, §69-1213(2). | **High**. Each receipt retains its own clock. |\n| **S_NE-P4-C010** | “Less fees and costs” and the fee-remittance endpoint do not independently establish that a particular fee or cost is earned or deductible. | S001, §§69-1210, 69-1212, 69-1213(2). | **High** as statutory reconciliation; exact “costs” authority remains held. |\n| **S_NE-P4-C011** | Chapter 69 does not specify bank location, federal insurance, exact title, legal ownership, interest ownership, reserves, shortage rules, or chargeback allocation. | S001, §§69-1210–1213; S007 gap. | **High** for the reviewed text; cannot exclude an unread rule or order. |\n| **S_NE-P4-C012** | “For the benefit of debtors” establishes restricted purpose but is not an express Chapter 69 statutory-trust or bankruptcy-priority clause. | S001, §69-1210; compare S002, §§8-2724(5), 8-2732(3)–(5). | **High** for wording comparison; ultimate trust status remains a legal/factual hold. |\n| **S_NE-P4-C013** | FDIC fiduciary recognition depends on insured-bank records and ascertainable beneficial interests; a Nebraska statutory label alone is insufficient. | S004, §§330.5(a)–(b), 330.7(a). | **High** federal rule; actual account/institution facts unknown. |\n| **S_NE-P4-C014** | Under 11 U.S.C. §541(d), property where the debtor has only legal title enters the estate only to that extent, but applying this to Chapter 69 funds requires actual ownership and trust analysis. | S005, §541(a)(1), (d). | **High** for federal text; **held** for a Chapter 69 provider. |\n| **S_NE-P4-C015** | General transaction records must be retained at least five years after the final entry. | S001, §69-1210 sentence 2. | **High**. |\n| **S_NE-P4-C016** | Complete per-debtor contract, extension, payment, disbursement, and charge records must be retained during the contract and five years after cancellation or completion. | S001, §69-1213(1). | **High**. |\n| **S_NE-P4-C017** | Upon request, a debtor is entitled to a written statement each 90 days or a verbal accounting during normal business hours. | S001, §69-1213(3). | **High**; no automatic online or monthly access established. |\n| **S_NE-P4-C018** | The Secretary may conduct unannounced examinations and compel records and testimony in violation investigations. | S001, §69-1211. | **High**. |\n| **S_NE-P4-C019** | No Chapter 69 account-change, closure, shortage, or cessation notice procedure was verified. | S001; S007 current-rule gap. | **Partial/HOLD**; actual rule/order/manual universe incomplete. |\n| **S_NE-P4-C020** | Nebraska permits remittance to the debtor, providing a return route for unremitted principal, but no cancellation-specific immediate return deadline was verified. | S001, §§69-1210, 69-1212–1213. | **High** for permitted destination; **partial** for timing and trigger. |\n| **S_NE-P4-C021** | Already completed creditor remittances are not part of the current held balance and may not be subtracted twice. | S001, §§69-1210, 69-1213; ledger arithmetic. | **High** accounting conclusion, assuming remittance was final. |\n| **S_NE-P4-C022** | A failed enrollment or rejected proposal does not itself earn a provider fee or restart statutory receipt clocks. | S001, §§69-1212–1213. | **High** for fee/clock principles; exact return recipient may depend on valid instructions. |\n| **S_NE-P4-C023** | Insolvency, bankruptcy, receivership, or general assignment is a Chapter 69 license-discipline ground, but no detailed wind-down mechanism was verified. | S001, §69-1207(1)(e); S007 gap. | **High/partial**. |\n| **S_NE-P4-C024** | Nebraska money transmission includes receiving money for transmission from a Nebraska-located person, including electronic or telephone-location rules. | S002, §8-2702(13), (22), (30). | **High**, current operative text. |\n| **S_NE-P4-C025** | A Chapter 69 licensee has a money-transmitter exemption only as the licensed entity acts within the scope of its license. | S002, §8-2703(14). | **High**; actual entity, transaction, and “within this state” facts remain required. |\n| **S_NE-P4-C026** | The Chapter 69 exemption does not automatically transfer to an affiliate, processor, administrator, or independent contractor. | S002, §§8-2703, 8-2704, 8-2709. | **High** as entity/scope conclusion. |\n| **S_NE-P4-C027** | Agent-of-payee, intermediary, payment-system, and bank-service-provider exceptions have complete written-agreement, responsibility, loss, and scope conditions. | S002, §8-2703(1)–(3), (13). | **High** for text; application held. |\n| **S_NE-P4-C028** | An authorized delegate requires a written contract, may not subdelegate, and holds net transmission funds in trust for the money-transmitter licensee. | S002, §8-2724. | **High**; trust beneficiary is the licensee, not expressly the consumer. |\n| **S_NE-P4-C029** | A money-transmitter licensee must keep five-year records including a monthly-posted general ledger and bank reconciliation records. | S002, §8-2723. | **High**; does not automatically govern an exempt Chapter 69 licensee. |\n| **S_NE-P4-C030** | The money-transmitter ten-day written-request refund rule has specified exclusions and exceptions and is not a universal Chapter 69 rule. | S002, §8-2727. | **High**. |\n| **S_NE-P4-C031** | Money-transmitter permissible investments are subject to an express insolvency statutory trust for outstanding-obligation beneficiaries. | S002, §8-2732(1), (3)–(5). | **High**; not transferable to Chapter 69 by analogy. |\n| **S_NE-P4-C032** | Conditional TSR dedicated-account rules require insured institution, customer ownership and interest, independent administrator, no referral exchange, service withdrawal without penalty, and request-based seven-business-day return less properly earned fees. | S003, §310.4(a)(5)(ii)(A)–(E). | **High** federal text; actual TSR and account coverage held. |\n| **S_NE-P4-C033** | The TSR right is withdrawal from the debt-relief service, not an unconditional right under that clause to withdraw directly from or close the bank account. | S003, §310.4(a)(5)(ii)(E). | **High**; preserves PASS-03 correction. |\n| **S_NE-P4-C034** | No current substantive Title 433 DMP account rule or formal interpretation was authenticated; that remains a verification gap, not a no-rule conclusion. | S007–S009. | **Partial/HOLD**. |\n\n# F. Component coverage and gap table\n\n| Funds/account issue | Status | Claim IDs | Exact missing evidence or next action |\n| --- | --- | --- | --- |\n| Chapter 69 custody entry point | **Answered** | C001–C002 | Apply to actual service and flow facts. |\n| Direct licensee custody | **Answered** | C002, C005–C006 | Actual bank and ledger evidence for a provider-specific conclusion. |\n| “Evidences thereof” | **Unresolved** | C003 | Controlling decision, official interpretation, enforcement order, or modern account-control facts. |\n| Affiliate or processor attributed receipt | **Unresolved** | C003, C026 | Entity chart, agency agreement, bank customer, ACH rights, payment authority, and Nebraska interpretation. |\n| Consumer-owned designated account | **Partial/held** | C003–C004, C032 | Account agreement, administrator contract, provider authority, federal coverage, and state interpretation. |\n| Truly negotiation-only flow | **Answered only as textual boundary** | C004 | Full legality and market-access pass remains required. |\n| Separate debtor-benefit bank account | **Answered** | C005–C006 | No further action for literal statutory requirement. |\n| Separation from operating funds | **Answered textually** | C005 | Actual bank statements and accounting evidence for implementation. |\n| One account per consumer | **Not required by verified text** | C007 | Current rule/order or approved-form evidence could add requirements. |\n| Cross-consumer pooling and shortage netting | **Unresolved** | C007, C011 | Formal authority and actual accounting controls. |\n| Numerical deposit deadline | **Unresolved** | C008 | Current Title 433 rule, order, guidance, or approved contract. |\n| Fifteen-day remittance | **Answered** | C009 | Actual receipt and payment dates. |\n| Seven-day cash remittance | **Answered** | C009 | Actual payment form and receipt date. |\n| Reasonable accumulation | **Answered textually; application fact-dependent** | C009 | Creditor amount, reasonableness, and per-receipt dates. |\n| Thirty-five-day maximum | **Answered** | C009 | Actual receipt chronology. |\n| Fee withdrawal endpoint | **Answered conditionally** | C006, C010 | Contract, state earning, federal earning, allocation, and authorization. |\n| Initial $25 treatment | **Excluded/preserved hold** | Prior P2/P3 | Current rule or controlling interpretation; not reopened. |\n| Cancellation compensation | **Excluded except principal separation** | C020; prior P2/P3 | Contract, federal earning, account terms, and state interpretation. |\n| “Fees and costs” | **Unresolved** | C010 | Rule, approved contract, decision, or formal interpretation defining permissible costs. |\n| Bank location and charter | **Unresolved** | C011 | Current rule/order and actual account agreement. |\n| FDIC/NCUA requirement under Chapter 69 | **Not established** | C011, C013 | State authority; actual institution and insurance status. |\n| Account-title wording | **Unresolved** | C011–C012 | Rule/order and bank documents. |\n| Legal and beneficial ownership | **Unresolved** | C012–C014 | Bank/account contracts, state property/trust law, tracing, and case authority. |\n| Chapter 69 statutory trust | **Not established** | C012 | Controlling Nebraska authority. |\n| FDIC pass-through treatment | **Partial federal framework** | C013 | Bank records, fiduciary disclosure, beneficial-interest records, aggregation, and institution status. |\n| Bankruptcy exclusion/priority | **Partial/held** | C012, C014 | Provider bankruptcy facts, trust creation, tracing, setoff, and controlling court decision. |\n| Interest ownership | **Unresolved under state law** | C011, C032 | Account contract/rule; TSR result only when federally covered. |\n| Reserves and shortages | **Unresolved** | C011 | Rule, bank contract, processor agreement, bond/insolvency pass. |\n| Chargebacks and ACH reversals | **Unresolved** | C011 | ACH authorization, NACHA/bank terms, account agreement, actual posting records. |\n| Bank and administrator fees | **Unresolved** | C010–C011 | Contract and legal pass-through authority. |\n| General transaction records | **Answered** | C015 | Actual records for compliance test. |\n| Per-debtor ledger contents | **Answered** | C016 | Exact format remains operational choice unless a rule exists. |\n| Reconciliation frequency | **Unresolved for Chapter 69** | C016, C019 | Current rule/manual; money-transmitter requirements do not automatically apply. |\n| Requested written statements | **Answered** | C017 | Actual request and statement content. |\n| Verbal accounting | **Answered** | C017 | Actual request and normal-business-hours facts. |\n| Automatic/monthly/online access | **Not established** | C017 | Contract or current rule. |\n| Secretary examinations | **Answered** | C018 | Provider-specific examination records excluded. |\n| Account change/closure notice | **Unresolved** | C019 | Current rule, order, regulator manual, or provider order. |\n| Cancellation return route | **Answered in part** | C020 | Contract, actual authorization, current balance, and recipient. |\n| Cancellation-specific state deadline | **Unresolved** | C020 | Rule, order, case, or contract; 35-day ceiling remains separate. |\n| Failed enrollment | **Partial** | C022 | Payment purpose, approval, contract formation, and actual receipt facts. |\n| Rejected creditor proposal | **Partial** | C022 | Creditor acceptance, accumulation need, consumer instructions, contract. |\n| Already remitted funds | **Answered accounting boundary** | C021 | Evidence that remittance was completed/final. |\n| Provider cessation/insolvency | **Partial** | C023 | Regulator/court order, bank freeze, account records, successor arrangement. |\n| Money-transmission basic gateway | **Answered** | C024 | Actual entity and transaction facts. |\n| In-scope DMP exemption | **Answered textually** | C025 | Actual license, entity, scope, and Nebraska transaction nexus. |\n| Independent administrator status | **Unresolved until facts supplied** | C026–C028 | License, delegate contract, exemption agreement, loss allocation. |\n| Agent-of-payee exception | **Partial/conditional** | C027 | Payee agreement, public holding-out, discharge, loss risk, underlying goods/services. |\n| Intermediary-processor exception | **Partial/conditional** | C027 | Principal entity’s license/exemption, sender receipt, sole responsibility. |\n| Bank-service-provider exception | **Partial/conditional** | C027 | Written bank agreement and full assumption of risk/legal responsibility. |\n| Authorized delegate structure | **Answered textually** | C028 | Actual licensee, filed delegate status, contract, and scope. |\n| Money-transmitter records | **Answered conditionally** | C029 | Applies only to licensed MT branch. |\n| Money-transmitter refunds | **Answered conditionally** | C030 | Written request and every statutory exception. |\n| Money-transmitter insolvency trust | **Answered conditionally** | C031 | Actual licensed MT, permissible investments, outstanding obligations. |\n| Conditional TSR dedicated account | **Answered as overlay** | C032–C033 | TSR coverage, account, administrator, request, earned fees, pending items. |\n| Withdrawal from service versus bank closure | **Answered** | C033 | Actual bank/ACH rights remain contractual and otherwise legal. |\n| Current Title 433 account rules | **Unresolved** | C034 | Accessible official complete current Title 433, docket, and adoption orders. |\n| Bond claims | **Excluded/later pass** | — | Bond form, claimant rights, conditions, surety process, insolvency interaction. |\n| Full contract enforceability | **Excluded except necessary return terms** | — | Complete provider, consumer, bank, ACH, processor, creditor, and administrator agreements. |\n| Remedies, litigation, limitations, collections, secured sectors, local and tribal law | **Excluded/later passes** | — | Separate authorized research. |\n| Named-provider/account verification | **Not performed** | — | Exact entity, license, administrator, bank, and dated account evidence. |\n\n# G. Researcher self-check\n\n## Freshly read in PASS-04\n\n- Complete operative text of the selected Chapter 69 funds provisions:§§69-1201;69-1207;69-1209;69-1210;69-1211;69-1212;69-1213; and69-1214.\n- Current Nebraska Money Transmitters Act provisions necessary for this gateway:§§8-2702;8-2703;8-2704;8-2709;8-2720;8-2721;8-2723 through 8-2728;8-2732; and8-2734.\n- Current 16 C.F.R. §310.4(a)(5)(i)–(ii), preserving the PASS-03 correction.\n- Current 12 C.F.R. §§330.5 and 330.7.\n- Current 11 U.S.C. §541 through the stated statutory currency date.\n- Current SOS and NDBF statutory navigation pages.\n- Targeted official-domain searches for Chapter 69 account, administrator, processor, “evidences thereof,” and third-party-account interpretations.\n- The official 2023 occupational-review report as historical/secondary context.\n- One official static Title 433 Chapter 8 PDF was visually inspected only to confirm that it concerns online notaries, not debt management; it was not used as debt-management authority.\n\n## Explicitly reused rather than independently reread as a separate review\n\n- PASS-01 provider and fee findings.\n- PASS-02 federal precision and Title 433 access history.\n- PASS-03 correction that §310.4(a)(5)(ii)(E) concerns withdrawal from the **debt-relief service**, not an unconditional bank-account withdrawal or closure right.\n- Prior CSO classification findings, except where the current Money Transmitters Act’s in-scope-license exemption was necessary.\n- Prior fee calculations, initial-payment holds, cancellation-compensation holds, and no-catch-up qualification.\n\nThis is not an independent review.\n\n## Not authenticated or not read\n\n- A complete current substantive Title 433 compilation.\n- All rulemaking docket entries, adoption orders, withdrawal notices, and historical Title 433 versions.\n- Any nonpublic SOS manual, examination workpaper, licensing correspondence, or approved contract.\n- Any provider’s actual bank account, bank statement, reconciliation, ACH file, processor agreement, administrator agreement, consumer contract, creditor agreement, or ledger.\n- Any current named-provider or administrator license status.\n- A complete Nebraska appellate, trial-court, bankruptcy, administrative-enforcement, Attorney General, or commercial-citator universe.\n- Actual FDIC insurance status or pass-through treatment for a specific account.\n- A Chapter 69 provider insolvency or bankruptcy case.\n- Bond claims, surety remedies, priority, or recovery procedure.\n- Complete trust-law, bank-setoff, UCC, ACH, electronic-funds-transfer, abandoned-property, or receivership analysis.\n- Full money-transmitter application, net-worth, bond, enforcement, or rule requirements beyond the narrow flow issues addressed.\n- Full contract, remedy, collection, litigation, limitations, secured-debt, sector, local, or tribal analysis.\n\n## Actions not performed\n\nNo Deep Research, Work, Codex research generation, API use, purchase, application, filing, account change, regulator or company contact, records request, private borrower-data access, website action, publication, Chrome control, other chat, or CAPTCHA/security workaround was used.\n\n**Focused disposition:** Nebraska supplies a clear licensed-custody core—separate debtor-benefit bank account, restricted destinations, creditor-remittance clocks, debtor-level records, requested accountings, and regulator examination. It does not publicly resolve the modern perimeter involving consumer-owned accounts, indirect control, administrator attribution, account ownership, FDIC treatment, chargebacks, wind-downs, or bankruptcy priority. The money-transmitter exemption protects only the actual in-scope licensed entity; every separate administrator or processor requires its own entity-specific pathway.\n\nEND S_NE PASS-04.\n\n","tables":[{"headers":["Model or flow","Chapter 69 custody result","Account and money-transmission consequence","PASS-04 disposition"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Model or flow","Chapter 69 custody result","Account and money-transmission consequence","PASS-04 disposition"],["Licensed debt manager directly receives a debtor’s payment and schedules creditor distributions","Directly within the statutory custody architecture when the remaining definition elements are satisfied","Deposit creditor-benefit payments into the separate debtor-benefit bank account; follow remittance and record duties. The licensee’s in-scope activity may use §8-2703(14)’s money-transmitter exemption.","Answered"],["Licensed debt manager receives money through its own employee or a processor acting solely as the licensee’s receiving arm","Substance points toward receipt by the licensee, but Chapter 69 does not define attributed or constructive receipt","Processor authority, agency, account ownership, loss allocation, and control must be examined. A processor’s separate legal entity status matters under the Money Transmitters Act.","Partial; entity facts required"],["Provider affiliate owns the receiving account or can debit, release, redirect, approve, or veto creditor payments","Account title alone does not establish noncustody; these powers are material to “receiving” money or “evidences thereof”","The provider’s Chapter 69 and §8-2703(14) exemptions do not automatically cover the affiliate.","Unresolved classification"],["Consumer-owned designated account; provider or affiliate has payment authority or fee-debit authority","Consumer ownership alone does not establish that the model is outside Chapter 69","“Evidences thereof,” indirect receipt, and control remain unresolved under Nebraska law; independent money-transmitter analysis may be required.","Held"],["Consumer-owned account administered by an unaffiliated entity; provider cannot receive, direct, block, debit, or approve transfers","Strongest factual case for noncustodial treatment, but no controlling Nebraska interpretation was located","Administrator still needs its own Nebraska status if it receives money for transmission. Federal TSR account compliance does not establish Nebraska permission.","Held; not affirmatively authorized"],["Consumer pays creditors directly and provider only negotiates, with no provider or affiliate receipt or payment authority","Does not plainly satisfy Chapter 69’s receipt/distribution element","No Chapter 69 account duties on the stated facts, but the broader legality of the negotiation service remains outside this funds pass.","Textual boundary only"],["Independent Nebraska money-transmitter licensee receives consumer money and sends it to creditors","Processing alone does not make it the Chapter 69 debt manager","Money-transmitter records, refund, permissible-investment, receipt, and solvency rules may apply to the administrator.","Conditional lawful gateway"],["Authorized delegate of a Nebraska money-transmitter licensee","Operates on behalf of the money-transmitter licensee, not automatically on behalf of the Chapter 69 licensee","Written delegate contract, trust for the licensee, records, examination, no subdelegation, and immediate cessation when principal authority ends.","Conditional lawful gateway"],["Claimed agent-of-payee, intermediary-processor, payment-system-operator, or bank-service-provider model","Labels do not establish an exemption","Every statutory condition must be met, including written agreements, allocation of loss, identification of the principal provider, and scope restrictions.","Fact-dependent hold"],["Federal TSR-compliant dedicated account","Does not itself determine Nebraska custody or licensing","Conditional federal ownership, insured-institution, independence, interest, service-withdrawal, and return requirements apply when the TSR account provision is actually applicable.","Conditional federal overlay only"]]},{"headers":["Federal fact","What it does not prove under Nebraska law"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Federal fact","What it does not prove under Nebraska law"],["Customer owns account funds","That the provider never receives “evidences thereof” or lacks payment control"],["Independent administrator","That the administrator is exempt from Nebraska money-transmitter licensing"],["Insured financial institution","That FDIC pass-through record requirements are satisfied"],["Provider cannot be affiliated with administrator","That no agency, payment-instruction, or contract relationship exists"],["Withdrawal from debt-relief service","A right under this TSR clause to close the bank account or independently cancel every ACH authorization"],["Seven-business-day return","A universal Nebraska return deadline"],["Earned-fee exception","That any particular fee is earned, correctly allocated, or deductible under state law"],["Consumer ownership","Automatic bankruptcy exclusion without actual ownership, tracing, and record evidence"]]},{"headers":["Source ID","Title, issuer, literal URL, and exact pinpoint","Version/effective status and actual access","Use and limitations; prior relationship"],"index":2,"links":[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+7"},{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702","text":"Nebraska Legislature\n+13"},{"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-12/chapter-III/subchapter-B/part-330/section-330.5","text":"eCFR\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t11/s541/","text":"U.S. Code"},{"href":"https://sos.nebraska.gov/licensing/debt-management-statutes?utm_source=chatgpt.com","text":"Nebraska Secretary of State"},{"href":"https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act?utm_source=chatgpt.com","text":"Nebraska Banking and Finance"}],"row_links":[[],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","text":"Nebraska Legislature\n+7"}],[{"href":"https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702","text":"Nebraska Legislature\n+13"}],[{"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-12/chapter-III/subchapter-B/part-330/section-330.5","text":"eCFR\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t11/s541/","text":"U.S. Code"}],[{"href":"https://sos.nebraska.gov/licensing/debt-management-statutes?utm_source=chatgpt.com","text":"Nebraska Secretary of State"}],[],[],[],[{"href":"https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act?utm_source=chatgpt.com","text":"Nebraska Banking and Finance"}]],"rows":[["Source ID","Title, issuer, literal URL, and exact pinpoint","Version/effective status and actual access","Use and limitations; prior relationship"],["S_NE-P4-S001","Nebraska Debt Management Act—selected operative funds provisions, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201 §69-1201(1), (6); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207 §69-1207(1)(e), (3); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212 complete operative paragraph; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213 subsections (1)–(5); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214 subsections (1)–(6). \nNebraska Legislature\n+7","Current official codification pages as displayed and freshly read October 25, 2026 Pacific. Principal funds clauses show 1967 source history; §69-1201 also shows 1993 amendment. No complete session-law or rule-history audit.","Controlling state statutory source. Reuses document family previously identified as S_NE-P1-S001 and S_NE-P2-S002, with fresh P4 funds readings. Sections are not counted as independent authorities."],["S_NE-P4-S002","Nebraska Money Transmitters Act—current gateway and operational provisions, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702 §§8-2702(3), (11), (13), (22), (25), (30)–(31); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703 §§8-2703(1)–(3), (7), (12)–(14), (17); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2704; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2709; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2720; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2721; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2723; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2725; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2726; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2728; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2732; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2734. \nNebraska Legislature\n+13","Current official codification freshly read October 25, 2026 Pacific. §§8-2702 and 8-2703 display an operative date of July 18, 2026. Source histories differ by section; no claim is made that the 2026 amendments first created every relevant concept.","Controlling state source for the limited processor/administrator gateway. Not a full money-transmission licensing, application, enforcement, or rule audit."],["S_NE-P4-S003","16 C.F.R. §310.4, Federal Trade Commission rule in eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4, paragraphs (a)(5)(i)(A)–(C) and (a)(5)(ii)(A)–(E). \neCFR","eCFR displayed Title 16 current through October 22, 2026 and last amended October 19, 2026; freshly opened October 25.","Conditional federal overlay only. Reuses S_NE-P2-S001 and the PASS-03 wording correction. No full TSR coverage or exemptions rerun."],["S_NE-P4-S004","12 C.F.R. §§330.5 and 330.7, Federal Deposit Insurance Corporation. https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5, paragraphs (a)(1)–(2), (b)(1)–(3); https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.7, paragraphs (a)–(c). \neCFR\n+1","eCFR displayed Title 12 current through October 22, 2026 and last amended October 2, 2026; freshly read October 25.","Governs FDIC recognition of deposit ownership/fiduciary interests. Does not establish Nebraska account ownership, actual insurance, provider solvency protection, or coverage at a specific institution."],["S_NE-P4-S005","11 U.S.C. §541, Office of the Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t11/s541/, subsections (a)(1), (b)(1), and (d). \nU.S. Code","Text states laws in effect through Public Law 119-124, October 15, 2026; freshly read October 25.","Governs bankruptcy-estate interests generally. No Nebraska Chapter 69 bankruptcy case, tracing decision, or provider insolvency record was reviewed."],["S_NE-P4-S006","Debt Management Statutes, Nebraska Secretary of State. https://sos.nebraska.gov/licensing/debt-management-statutes, entries for §§69-1201–69-1217. \nNebraska Secretary of State","Current agency navigation page accessed October 25; page metadata contains an older submission date that is not a legal effective date.","Navigation only; not an independent interpretation or substitute for the Legislature text. Prior alias S_NE-P1-S003."],["S_NE-P4-S007","Current Title 433 routes and annual index: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents; https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket; https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf.","PASS-02 access history preserved: HTML index identified Title 433; dynamic catalog produced a JavaScript shell; docket produced distinct shell/403 observations; annual document was a dated snapshot with limited extraction/view history. P4 did not repeat the same inaccessible loop.","Failed/not-complete current-rule route. No complete current Title 433 DMP account rule, docket, or adoption-order universe authenticated. Prior aliases S_NE-P2-S004–S007."],["S_NE-P4-S008","2023 Occupational Regulation Review—Secretary of State programs, Nebraska Legislative Council. https://nebraskalegislature.gov/FloorDocs/108/PDF/Agencies/Legislative_Council/707_20231218-113223.pdf, printed/report pp. 3–4.","Dated December 2023; freshly read and visually inspected October 25, 2026.","Secondary official historical/context source only. It identifies rulemaking authority and Title assignments but describes an incomplete review; it is not current rule text or proof of no later rule."],["S_NE-P4-S009","Bounded public interpretation search routes, including Nebraska appellate publication repository https://www.nebraska.gov/apps-courts-epub/ and exact-term searches across official Nebraska Legislature, SOS, Judicial Branch, Attorney General, and NDBF domains for “evidences thereof,” §§69-1201, 69-1210, 69-1213, third-party account, administrator, and processor terms.","Search-only work on October 25, 2026. No on-point controlling interpretation was located.","Negative search result only; not an exhaustive commercial citator, administrative-file, trial-docket, or records-request search and not proof that no interpretation exists."],["S_NE-P4-S010","Nebraska Money Transmitters Act index, Nebraska Department of Banking and Finance. https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act. \nNebraska Banking and Finance","Current agency navigation page accessed October 25, 2026.","Used only to confirm the agency’s current statutory navigation. Operative Legislature text controls. Older NDBF PDFs surfaced by search were not relied upon because they predate the 2025–2026 recodification."]]},{"headers":["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, currentness, and confidence"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source and pinpoint","Conditions, exceptions, currentness, and confidence"],["S_NE-P4-C001","Chapter 69 custody requires fee-based financial planning/management and receipt of debtor money or evidences for creditor distribution.","S001, §69-1201(1).","High for text; “evidences thereof” and attributed receipt remain unresolved."],["S_NE-P4-C002","Direct receipt by a licensed debt manager for scheduled creditor distribution is within the statutory custody architecture.","S001, §§69-1201(1), 69-1209, 69-1210, 69-1212.","High when all definition and debtor conditions are met."],["S_NE-P4-C003","Provider/affiliate/processor indirect control and consumer-owned accounts cannot be classified solely by account title or marketing label.","S001, §§69-1201(1), 69-1210; S009 limited search.","Medium/HOLD; no controlling interpretation found."],["S_NE-P4-C004","A genuinely negotiation-only model with no receipt, evidence, debit authority, payment direction, or affiliate receipt does not plainly satisfy the receipt element.","S001, §69-1201(1).","Textual inference only; not affirmative market authorization."],["S_NE-P4-C005","Licensee must maintain a separate bank account for debtors’ benefit and deposit all qualifying creditor-benefit payments there.","S001, §69-1210 sentence 1.","High."],["S_NE-P4-C006","Account money remains until remitted to debtor, creditor, or licensee for fees.","S001, §69-1210 sentence 1.","High; a fee destination does not establish earning or amount."],["S_NE-P4-C007","Chapter 69 does not expressly require one bank account per consumer; debtor-level records are nevertheless mandatory.","S001, §§69-1210, 69-1213(1).","High for absence and records; pooled-account implementation remains subject to accurate allocation."],["S_NE-P4-C008","Chapter 69 provides no numerical deposit deadline.","S001, §§69-1210, 69-1213.","High for reviewed statutory text; unverified current-rule gap remains."],["S_NE-P4-C009","Creditor remittance is due in 15 days, seven days for cash, subject to reasonable sum-certain accumulation and an absolute 35-day retention ceiling.","S001, §69-1213(2).","High. Each receipt retains its own clock."],["S_NE-P4-C010","“Less fees and costs” and the fee-remittance endpoint do not independently establish that a particular fee or cost is earned or deductible.","S001, §§69-1210, 69-1212, 69-1213(2).","High as statutory reconciliation; exact “costs” authority remains held."],["S_NE-P4-C011","Chapter 69 does not specify bank location, federal insurance, exact title, legal ownership, interest ownership, reserves, shortage rules, or chargeback allocation.","S001, §§69-1210–1213; S007 gap.","High for the reviewed text; cannot exclude an unread rule or order."],["S_NE-P4-C012","“For the benefit of debtors” establishes restricted purpose but is not an express Chapter 69 statutory-trust or bankruptcy-priority clause.","S001, §69-1210; compare S002, §§8-2724(5), 8-2732(3)–(5).","High for wording comparison; ultimate trust status remains a legal/factual hold."],["S_NE-P4-C013","FDIC fiduciary recognition depends on insured-bank records and ascertainable beneficial interests; a Nebraska statutory label alone is insufficient.","S004, §§330.5(a)–(b), 330.7(a).","High federal rule; actual account/institution facts unknown."],["S_NE-P4-C014","Under 11 U.S.C. §541(d), property where the debtor has only legal title enters the estate only to that extent, but applying this to Chapter 69 funds requires actual ownership and trust analysis.","S005, §541(a)(1), (d).","High for federal text; held for a Chapter 69 provider."],["S_NE-P4-C015","General transaction records must be retained at least five years after the final entry.","S001, §69-1210 sentence 2.","High."],["S_NE-P4-C016","Complete per-debtor contract, extension, payment, disbursement, and charge records must be retained during the contract and five years after cancellation or completion.","S001, §69-1213(1).","High."],["S_NE-P4-C017","Upon request, a debtor is entitled to a written statement each 90 days or a verbal accounting during normal business hours.","S001, §69-1213(3).","High; no automatic online or monthly access established."],["S_NE-P4-C018","The Secretary may conduct unannounced examinations and compel records and testimony in violation investigations.","S001, §69-1211.","High."],["S_NE-P4-C019","No Chapter 69 account-change, closure, shortage, or cessation notice procedure was verified.","S001; S007 current-rule gap.","Partial/HOLD; actual rule/order/manual universe incomplete."],["S_NE-P4-C020","Nebraska permits remittance to the debtor, providing a return route for unremitted principal, but no cancellation-specific immediate return deadline was verified.","S001, §§69-1210, 69-1212–1213.","High for permitted destination; partial for timing and trigger."],["S_NE-P4-C021","Already completed creditor remittances are not part of the current held balance and may not be subtracted twice.","S001, §§69-1210, 69-1213; ledger arithmetic.","High accounting conclusion, assuming remittance was final."],["S_NE-P4-C022","A failed enrollment or rejected proposal does not itself earn a provider fee or restart statutory receipt clocks.","S001, §§69-1212–1213.","High for fee/clock principles; exact return recipient may depend on valid instructions."],["S_NE-P4-C023","Insolvency, bankruptcy, receivership, or general assignment is a Chapter 69 license-discipline ground, but no detailed wind-down mechanism was verified.","S001, §69-1207(1)(e); S007 gap.","High/partial."],["S_NE-P4-C024","Nebraska money transmission includes receiving money for transmission from a Nebraska-located person, including electronic or telephone-location rules.","S002, §8-2702(13), (22), (30).","High, current operative text."],["S_NE-P4-C025","A Chapter 69 licensee has a money-transmitter exemption only as the licensed entity acts within the scope of its license.","S002, §8-2703(14).","High; actual entity, transaction, and “within this state” facts remain required."],["S_NE-P4-C026","The Chapter 69 exemption does not automatically transfer to an affiliate, processor, administrator, or independent contractor.","S002, §§8-2703, 8-2704, 8-2709.","High as entity/scope conclusion."],["S_NE-P4-C027","Agent-of-payee, intermediary, payment-system, and bank-service-provider exceptions have complete written-agreement, responsibility, loss, and scope conditions.","S002, §8-2703(1)–(3), (13).","High for text; application held."],["S_NE-P4-C028","An authorized delegate requires a written contract, may not subdelegate, and holds net transmission funds in trust for the money-transmitter licensee.","S002, §8-2724.","High; trust beneficiary is the licensee, not expressly the consumer."],["S_NE-P4-C029","A money-transmitter licensee must keep five-year records including a monthly-posted general ledger and bank reconciliation records.","S002, §8-2723.","High; does not automatically govern an exempt Chapter 69 licensee."],["S_NE-P4-C030","The money-transmitter ten-day written-request refund rule has specified exclusions and exceptions and is not a universal Chapter 69 rule.","S002, §8-2727.","High."],["S_NE-P4-C031","Money-transmitter permissible investments are subject to an express insolvency statutory trust for outstanding-obligation beneficiaries.","S002, §8-2732(1), (3)–(5).","High; not transferable to Chapter 69 by analogy."],["S_NE-P4-C032","Conditional TSR dedicated-account rules require insured institution, customer ownership and interest, independent administrator, no referral exchange, service withdrawal without penalty, and request-based seven-business-day return less properly earned fees.","S003, §310.4(a)(5)(ii)(A)–(E).","High federal text; actual TSR and account coverage held."],["S_NE-P4-C033","The TSR right is withdrawal from the debt-relief service, not an unconditional right under that clause to withdraw directly from or close the bank account.","S003, §310.4(a)(5)(ii)(E).","High; preserves PASS-03 correction."],["S_NE-P4-C034","No current substantive Title 433 DMP account rule or formal interpretation was authenticated; that remains a verification gap, not a no-rule conclusion.","S007–S009.","Partial/HOLD."]]},{"headers":["Funds/account issue","Status","Claim IDs","Exact missing evidence or next action"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Funds/account issue","Status","Claim IDs","Exact missing evidence or next action"],["Chapter 69 custody entry point","Answered","C001–C002","Apply to actual service and flow facts."],["Direct licensee custody","Answered","C002, C005–C006","Actual bank and ledger evidence for a provider-specific conclusion."],["“Evidences thereof”","Unresolved","C003","Controlling decision, official interpretation, enforcement order, or modern account-control facts."],["Affiliate or processor attributed receipt","Unresolved","C003, C026","Entity chart, agency agreement, bank customer, ACH rights, payment authority, and Nebraska interpretation."],["Consumer-owned designated account","Partial/held","C003–C004, C032","Account agreement, administrator contract, provider authority, federal coverage, and state interpretation."],["Truly negotiation-only flow","Answered only as textual boundary","C004","Full legality and market-access pass remains required."],["Separate debtor-benefit bank account","Answered","C005–C006","No further action for literal statutory requirement."],["Separation from operating funds","Answered textually","C005","Actual bank statements and accounting evidence for implementation."],["One account per consumer","Not required by verified text","C007","Current rule/order or approved-form evidence could add requirements."],["Cross-consumer pooling and shortage netting","Unresolved","C007, C011","Formal authority and actual accounting controls."],["Numerical deposit deadline","Unresolved","C008","Current Title 433 rule, order, guidance, or approved contract."],["Fifteen-day remittance","Answered","C009","Actual receipt and payment dates."],["Seven-day cash remittance","Answered","C009","Actual payment form and receipt date."],["Reasonable accumulation","Answered textually; application fact-dependent","C009","Creditor amount, reasonableness, and per-receipt dates."],["Thirty-five-day maximum","Answered","C009","Actual receipt chronology."],["Fee withdrawal endpoint","Answered conditionally","C006, C010","Contract, state earning, federal earning, allocation, and authorization."],["Initial $25 treatment","Excluded/preserved hold","Prior P2/P3","Current rule or controlling interpretation; not reopened."],["Cancellation compensation","Excluded except principal separation","C020; prior P2/P3","Contract, federal earning, account terms, and state interpretation."],["“Fees and costs”","Unresolved","C010","Rule, approved contract, decision, or formal interpretation defining permissible costs."],["Bank location and charter","Unresolved","C011","Current rule/order and actual account agreement."],["FDIC/NCUA requirement under Chapter 69","Not established","C011, C013","State authority; actual institution and insurance status."],["Account-title wording","Unresolved","C011–C012","Rule/order and bank documents."],["Legal and beneficial ownership","Unresolved","C012–C014","Bank/account contracts, state property/trust law, tracing, and case authority."],["Chapter 69 statutory trust","Not established","C012","Controlling Nebraska authority."],["FDIC pass-through treatment","Partial federal framework","C013","Bank records, fiduciary disclosure, beneficial-interest records, aggregation, and institution status."],["Bankruptcy exclusion/priority","Partial/held","C012, C014","Provider bankruptcy facts, trust creation, tracing, setoff, and controlling court decision."],["Interest ownership","Unresolved under state law","C011, C032","Account contract/rule; TSR result only when federally covered."],["Reserves and shortages","Unresolved","C011","Rule, bank contract, processor agreement, bond/insolvency pass."],["Chargebacks and ACH reversals","Unresolved","C011","ACH authorization, NACHA/bank terms, account agreement, actual posting records."],["Bank and administrator fees","Unresolved","C010–C011","Contract and legal pass-through authority."],["General transaction records","Answered","C015","Actual records for compliance test."],["Per-debtor ledger contents","Answered","C016","Exact format remains operational choice unless a rule exists."],["Reconciliation frequency","Unresolved for Chapter 69","C016, C019","Current rule/manual; money-transmitter requirements do not automatically apply."],["Requested written statements","Answered","C017","Actual request and statement content."],["Verbal accounting","Answered","C017","Actual request and normal-business-hours facts."],["Automatic/monthly/online access","Not established","C017","Contract or current rule."],["Secretary examinations","Answered","C018","Provider-specific examination records excluded."],["Account change/closure notice","Unresolved","C019","Current rule, order, regulator manual, or provider order."],["Cancellation return route","Answered in part","C020","Contract, actual authorization, current balance, and recipient."],["Cancellation-specific state deadline","Unresolved","C020","Rule, order, case, or contract; 35-day ceiling remains separate."],["Failed enrollment","Partial","C022","Payment purpose, approval, contract formation, and actual receipt facts."],["Rejected creditor proposal","Partial","C022","Creditor acceptance, accumulation need, consumer instructions, contract."],["Already remitted funds","Answered accounting boundary","C021","Evidence that remittance was completed/final."],["Provider cessation/insolvency","Partial","C023","Regulator/court order, bank freeze, account records, successor arrangement."],["Money-transmission basic gateway","Answered","C024","Actual entity and transaction facts."],["In-scope DMP exemption","Answered textually","C025","Actual license, entity, scope, and Nebraska transaction nexus."],["Independent administrator status","Unresolved until facts supplied","C026–C028","License, delegate contract, exemption agreement, loss allocation."],["Agent-of-payee exception","Partial/conditional","C027","Payee agreement, public holding-out, discharge, loss risk, underlying goods/services."],["Intermediary-processor exception","Partial/conditional","C027","Principal entity’s license/exemption, sender receipt, sole responsibility."],["Bank-service-provider exception","Partial/conditional","C027","Written bank agreement and full assumption of risk/legal responsibility."],["Authorized delegate structure","Answered textually","C028","Actual licensee, filed delegate status, contract, and scope."],["Money-transmitter records","Answered conditionally","C029","Applies only to licensed MT branch."],["Money-transmitter refunds","Answered conditionally","C030","Written request and every statutory exception."],["Money-transmitter insolvency trust","Answered conditionally","C031","Actual licensed MT, permissible investments, outstanding obligations."],["Conditional TSR dedicated account","Answered as overlay","C032–C033","TSR coverage, account, administrator, request, earned fees, pending items."],["Withdrawal from service versus bank closure","Answered","C033","Actual bank/ACH rights remain contractual and otherwise legal."],["Current Title 433 account rules","Unresolved","C034","Accessible official complete current Title 433, docket, and adoption orders."],["Bond claims","Excluded/later pass","—","Bond form, claimant rights, conditions, surety process, insolvency interaction."],["Full contract enforceability","Excluded except necessary return terms","—","Complete provider, consumer, bank, ACH, processor, creditor, and administrator agreements."],["Remedies, litigation, limitations, collections, secured sectors, local and tribal law","Excluded/later passes","—","Separate authorized research."],["Named-provider/account verification","Not performed","—","Exact entity, license, administrator, bank, and dated account evidence."]]}],"claims":[{"claim_id":"S_NE-P4-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C001","Precise assertion":"Chapter 69 custody requires fee-based financial planning/management and receipt of debtor money or evidences for creditor distribution.","Source and pinpoint":"S001, §69-1201(1).","Conditions, exceptions, currentness, and confidence":"High for text; “evidences thereof” and attributed receipt remain unresolved."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C002","Precise assertion":"Direct receipt by a licensed debt manager for scheduled creditor distribution is within the statutory custody architecture.","Source and pinpoint":"S001, §§69-1201(1), 69-1209, 69-1210, 69-1212.","Conditions, exceptions, currentness, and confidence":"High when all definition and debtor conditions are met."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C003","Precise assertion":"Provider/affiliate/processor indirect control and consumer-owned accounts cannot be classified solely by account title or marketing label.","Source and pinpoint":"S001, §§69-1201(1), 69-1210; S009 limited search.","Conditions, exceptions, currentness, and confidence":"Medium/HOLD; no controlling interpretation found."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C004","Precise assertion":"A genuinely negotiation-only model with no receipt, evidence, debit authority, payment direction, or affiliate receipt does not plainly satisfy the receipt element.","Source and pinpoint":"S001, §69-1201(1).","Conditions, exceptions, currentness, and confidence":"Textual inference only; not affirmative market authorization."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C005","Precise assertion":"Licensee must maintain a separate bank account for debtors’ benefit and deposit all qualifying creditor-benefit payments there.","Source and pinpoint":"S001, §69-1210 sentence 1.","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C006","Precise assertion":"Account money remains until remitted to debtor, creditor, or licensee for fees.","Source and pinpoint":"S001, §69-1210 sentence 1.","Conditions, exceptions, currentness, and confidence":"High; a fee destination does not establish earning or amount."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C007","Precise assertion":"Chapter 69 does not expressly require one bank account per consumer; debtor-level records are nevertheless mandatory.","Source and pinpoint":"S001, §§69-1210, 69-1213(1).","Conditions, exceptions, currentness, and confidence":"High for absence and records; pooled-account implementation remains subject to accurate allocation."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C008","Precise assertion":"Chapter 69 provides no numerical deposit deadline.","Source and pinpoint":"S001, §§69-1210, 69-1213.","Conditions, exceptions, currentness, and confidence":"High for reviewed statutory text; unverified current-rule gap remains."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C009","Precise assertion":"Creditor remittance is due in 15 days, seven days for cash, subject to reasonable sum-certain accumulation and an absolute 35-day retention ceiling.","Source and pinpoint":"S001, §69-1213(2).","Conditions, exceptions, currentness, and confidence":"High. Each receipt retains its own clock."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C010","Precise assertion":"“Less fees and costs” and the fee-remittance endpoint do not independently establish that a particular fee or cost is earned or deductible.","Source and pinpoint":"S001, §§69-1210, 69-1212, 69-1213(2).","Conditions, exceptions, currentness, and confidence":"High as statutory reconciliation; exact “costs” authority remains held."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C011","Precise assertion":"Chapter 69 does not specify bank location, federal insurance, exact title, legal ownership, interest ownership, reserves, shortage rules, or chargeback allocation.","Source and pinpoint":"S001, §§69-1210–1213; S007 gap.","Conditions, exceptions, currentness, and confidence":"High for the reviewed text; cannot exclude an unread rule or order."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C012","Precise assertion":"“For the benefit of debtors” establishes restricted purpose but is not an express Chapter 69 statutory-trust or bankruptcy-priority clause.","Source and pinpoint":"S001, §69-1210; compare S002, §§8-2724(5), 8-2732(3)–(5).","Conditions, exceptions, currentness, and confidence":"High for wording comparison; ultimate trust status remains a legal/factual hold."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C013","Precise assertion":"FDIC fiduciary recognition depends on insured-bank records and ascertainable beneficial interests; a Nebraska statutory label alone is insufficient.","Source and pinpoint":"S004, §§330.5(a)–(b), 330.7(a).","Conditions, exceptions, currentness, and confidence":"High federal rule; actual account/institution facts unknown."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C014","Precise assertion":"Under 11 U.S.C. §541(d), property where the debtor has only legal title enters the estate only to that extent, but applying this to Chapter 69 funds requires actual ownership and trust analysis.","Source and pinpoint":"S005, §541(a)(1), (d).","Conditions, exceptions, currentness, and confidence":"High for federal text; held for a Chapter 69 provider."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C015","Precise assertion":"General transaction records must be retained at least five years after the final entry.","Source and pinpoint":"S001, §69-1210 sentence 2.","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C016","Precise assertion":"Complete per-debtor contract, extension, payment, disbursement, and charge records must be retained during the contract and five years after cancellation or completion.","Source and pinpoint":"S001, §69-1213(1).","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C017","Precise assertion":"Upon request, a debtor is entitled to a written statement each 90 days or a verbal accounting during normal business hours.","Source and pinpoint":"S001, §69-1213(3).","Conditions, exceptions, currentness, and confidence":"High; no automatic online or monthly access established."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C018","Precise assertion":"The Secretary may conduct unannounced examinations and compel records and testimony in violation investigations.","Source and pinpoint":"S001, §69-1211.","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C019","Precise assertion":"No Chapter 69 account-change, closure, shortage, or cessation notice procedure was verified.","Source and pinpoint":"S001; S007 current-rule gap.","Conditions, exceptions, currentness, and confidence":"Partial/HOLD; actual rule/order/manual universe incomplete."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C020","Precise assertion":"Nebraska permits remittance to the debtor, providing a return route for unremitted principal, but no cancellation-specific immediate return deadline was verified.","Source and pinpoint":"S001, §§69-1210, 69-1212–1213.","Conditions, exceptions, currentness, and confidence":"High for permitted destination; partial for timing and trigger."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C021","Precise assertion":"Already completed creditor remittances are not part of the current held balance and may not be subtracted twice.","Source and pinpoint":"S001, §§69-1210, 69-1213; ledger arithmetic.","Conditions, exceptions, currentness, and confidence":"High accounting conclusion, assuming remittance was final."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C022","Precise assertion":"A failed enrollment or rejected proposal does not itself earn a provider fee or restart statutory receipt clocks.","Source and pinpoint":"S001, §§69-1212–1213.","Conditions, exceptions, currentness, and confidence":"High for fee/clock principles; exact return recipient may depend on valid instructions."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C023","Precise assertion":"Insolvency, bankruptcy, receivership, or general assignment is a Chapter 69 license-discipline ground, but no detailed wind-down mechanism was verified.","Source and pinpoint":"S001, §69-1207(1)(e); S007 gap.","Conditions, exceptions, currentness, and confidence":"High/partial."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C024","Precise assertion":"Nebraska money transmission includes receiving money for transmission from a Nebraska-located person, including electronic or telephone-location rules.","Source and pinpoint":"S002, §8-2702(13), (22), (30).","Conditions, exceptions, currentness, and confidence":"High, current operative text."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C025","Precise assertion":"A Chapter 69 licensee has a money-transmitter exemption only as the licensed entity acts within the scope of its license.","Source and pinpoint":"S002, §8-2703(14).","Conditions, exceptions, currentness, and confidence":"High; actual entity, transaction, and “within this state” facts remain required."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C026","Precise assertion":"The Chapter 69 exemption does not automatically transfer to an affiliate, processor, administrator, or independent contractor.","Source and pinpoint":"S002, §§8-2703, 8-2704, 8-2709.","Conditions, exceptions, currentness, and confidence":"High as entity/scope conclusion."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C027","Precise assertion":"Agent-of-payee, intermediary, payment-system, and bank-service-provider exceptions have complete written-agreement, responsibility, loss, and scope conditions.","Source and pinpoint":"S002, §8-2703(1)–(3), (13).","Conditions, exceptions, currentness, and confidence":"High for text; application held."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C028","Precise assertion":"An authorized delegate requires a written contract, may not subdelegate, and holds net transmission funds in trust for the money-transmitter licensee.","Source and pinpoint":"S002, §8-2724.","Conditions, exceptions, currentness, and confidence":"High; trust beneficiary is the licensee, not expressly the consumer."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C029","Precise assertion":"A money-transmitter licensee must keep five-year records including a monthly-posted general ledger and bank reconciliation records.","Source and pinpoint":"S002, §8-2723.","Conditions, exceptions, currentness, and confidence":"High; does not automatically govern an exempt Chapter 69 licensee."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C030","Precise assertion":"The money-transmitter ten-day written-request refund rule has specified exclusions and exceptions and is not a universal Chapter 69 rule.","Source and pinpoint":"S002, §8-2727.","Conditions, exceptions, currentness, and confidence":"High."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C031","Precise assertion":"Money-transmitter permissible investments are subject to an express insolvency statutory trust for outstanding-obligation beneficiaries.","Source and pinpoint":"S002, §8-2732(1), (3)–(5).","Conditions, exceptions, currentness, and confidence":"High; not transferable to Chapter 69 by analogy."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C032","Precise assertion":"Conditional TSR dedicated-account rules require insured institution, customer ownership and interest, independent administrator, no referral exchange, service withdrawal without penalty, and request-based seven-business-day return less properly earned fees.","Source and pinpoint":"S003, §310.4(a)(5)(ii)(A)–(E).","Conditions, exceptions, currentness, and confidence":"High federal text; actual TSR and account coverage held."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C033","Precise assertion":"The TSR right is withdrawal from the debt-relief service, not an unconditional right under that clause to withdraw directly from or close the bank account.","Source and pinpoint":"S003, §310.4(a)(5)(ii)(E).","Conditions, exceptions, currentness, and confidence":"High; preserves PASS-03 correction."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_NE-P4-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NE-P4-C034","Precise assertion":"No current substantive Title 433 DMP account rule or formal interpretation was authenticated; that remains a verification gap, not a no-rule conclusion.","Source and pinpoint":"S007–S009.","Conditions, exceptions, currentness, and confidence":"Partial/HOLD."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"sources":[{"source_id":"S_NE-P4-S001","urls":["https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201","https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207","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"],"researcher_record":{"Source ID":"S_NE-P4-S001","Title, issuer, literal URL, and exact pinpoint":"Nebraska Debt Management Act—selected operative funds provisions, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=69-1201 §69-1201(1), (6); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1207 §69-1207(1)(e), (3); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1209 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1210 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1211 complete section; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1212 complete operative paragraph; https://nebraskalegislature.gov/laws/statutes.php?statute=69-1213 subsections (1)–(5); https://nebraskalegislature.gov/laws/statutes.php?statute=69-1214 subsections (1)–(6). \nNebraska Legislature\n+7","Version/effective status and actual access":"Current official codification pages as displayed and freshly read October 25, 2026 Pacific. Principal funds clauses show 1967 source history; §69-1201 also shows 1993 amendment. No complete session-law or rule-history audit.","Use and limitations; prior relationship":"Controlling state statutory source. Reuses document family previously identified as S_NE-P1-S001 and S_NE-P2-S002, with fresh P4 funds readings. Sections are not counted as independent authorities."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S002","urls":["https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2704","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2709","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2720","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2721","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2723","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2725","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2726","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2728","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2732","https://nebraskalegislature.gov/laws/statutes.php?statute=8-2734"],"researcher_record":{"Source ID":"S_NE-P4-S002","Title, issuer, literal URL, and exact pinpoint":"Nebraska Money Transmitters Act—current gateway and operational provisions, Nebraska Legislature. https://nebraskalegislature.gov/laws/statutes.php?statute=8-2702 §§8-2702(3), (11), (13), (22), (25), (30)–(31); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2703 §§8-2703(1)–(3), (7), (12)–(14), (17); https://nebraskalegislature.gov/laws/statutes.php?statute=8-2704; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2709; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2720; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2721; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2723; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2724; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2725; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2726; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2727; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2728; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2732; https://nebraskalegislature.gov/laws/statutes.php?statute=8-2734. \nNebraska Legislature\n+13","Version/effective status and actual access":"Current official codification freshly read October 25, 2026 Pacific. §§8-2702 and 8-2703 display an operative date of July 18, 2026. Source histories differ by section; no claim is made that the 2026 amendments first created every relevant concept.","Use and limitations; prior relationship":"Controlling state source for the limited processor/administrator gateway. Not a full money-transmission licensing, application, enforcement, or rule audit."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S003","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_NE-P4-S003","Title, issuer, literal URL, and exact pinpoint":"16 C.F.R. §310.4, Federal Trade Commission rule in eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4, paragraphs (a)(5)(i)(A)–(C) and (a)(5)(ii)(A)–(E). \neCFR","Version/effective status and actual access":"eCFR displayed Title 16 current through October 22, 2026 and last amended October 19, 2026; freshly opened October 25.","Use and limitations; prior relationship":"Conditional federal overlay only. Reuses S_NE-P2-S001 and the PASS-03 wording correction. No full TSR coverage or exemptions rerun."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S004","urls":["https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5","https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.7"],"researcher_record":{"Source ID":"S_NE-P4-S004","Title, issuer, literal URL, and exact pinpoint":"12 C.F.R. §§330.5 and 330.7, Federal Deposit Insurance Corporation. https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.5, paragraphs (a)(1)–(2), (b)(1)–(3); https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-330/section-330.7, paragraphs (a)–(c). \neCFR\n+1","Version/effective status and actual access":"eCFR displayed Title 12 current through October 22, 2026 and last amended October 2, 2026; freshly read October 25.","Use and limitations; prior relationship":"Governs FDIC recognition of deposit ownership/fiduciary interests. Does not establish Nebraska account ownership, actual insurance, provider solvency protection, or coverage at a specific institution."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S005","urls":["https://uscode.house.gov/us/usc/119-124/t11/s541/"],"researcher_record":{"Source ID":"S_NE-P4-S005","Title, issuer, literal URL, and exact pinpoint":"11 U.S.C. §541, Office of the Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t11/s541/, subsections (a)(1), (b)(1), and (d). \nU.S. Code","Version/effective status and actual access":"Text states laws in effect through Public Law 119-124, October 15, 2026; freshly read October 25.","Use and limitations; prior relationship":"Governs bankruptcy-estate interests generally. No Nebraska Chapter 69 bankruptcy case, tracing decision, or provider insolvency record was reviewed."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S006","urls":["https://sos.nebraska.gov/licensing/debt-management-statutes","https://sos.nebraska.gov/licensing/debt-management-statutes?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NE-P4-S006","Title, issuer, literal URL, and exact pinpoint":"Debt Management Statutes, Nebraska Secretary of State. https://sos.nebraska.gov/licensing/debt-management-statutes, entries for §§69-1201–69-1217. \nNebraska Secretary of State","Version/effective status and actual access":"Current agency navigation page accessed October 25; page metadata contains an older submission date that is not a legal effective date.","Use and limitations; prior relationship":"Navigation only; not an independent interpretation or substitute for the Legislature text. Prior alias S_NE-P1-S003."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S007","urls":["https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents","https://rules.nebraska.gov/rules?agencyId=61&titleId=201","https://rules.nebraska.gov/docket","https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf"],"researcher_record":{"Source ID":"S_NE-P4-S007","Title, issuer, literal URL, and exact pinpoint":"Current Title 433 routes and annual index: https://sos.nebraska.gov/index-rules-and-regulations-and-guidance-documents; https://rules.nebraska.gov/rules?agencyId=61&titleId=201; https://rules.nebraska.gov/docket; https://nebraskalegislature.gov/FloorDocs/109/PDF/Agencies/Secretary_of_State/667_20260219-091348.pdf.","Version/effective status and actual access":"PASS-02 access history preserved: HTML index identified Title 433; dynamic catalog produced a JavaScript shell; docket produced distinct shell/403 observations; annual document was a dated snapshot with limited extraction/view history. P4 did not repeat the same inaccessible loop.","Use and limitations; prior relationship":"Failed/not-complete current-rule route. No complete current Title 433 DMP account rule, docket, or adoption-order universe authenticated. Prior aliases S_NE-P2-S004–S007."},"coordinator_verification_status":"dated_access_history_reused_current_rules_not_authenticated","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S008","urls":["https://nebraskalegislature.gov/FloorDocs/108/PDF/Agencies/Legislative_Council/707_20231218-113223.pdf"],"researcher_record":{"Source ID":"S_NE-P4-S008","Title, issuer, literal URL, and exact pinpoint":"2023 Occupational Regulation Review—Secretary of State programs, Nebraska Legislative Council. https://nebraskalegislature.gov/FloorDocs/108/PDF/Agencies/Legislative_Council/707_20231218-113223.pdf, printed/report pp. 3–4.","Version/effective status and actual access":"Dated December 2023; freshly read and visually inspected October 25, 2026.","Use and limitations; prior relationship":"Secondary official historical/context source only. It identifies rulemaking authority and Title assignments but describes an incomplete review; it is not current rule text or proof of no later rule."},"coordinator_verification_status":"fresh_parsed_official_historical_secondary_only_pdfindices3_4_no_coordinator_pixels","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S009","urls":["https://www.nebraska.gov/apps-courts-epub/"],"researcher_record":{"Source ID":"S_NE-P4-S009","Title, issuer, literal URL, and exact pinpoint":"Bounded public interpretation search routes, including Nebraska appellate publication repository https://www.nebraska.gov/apps-courts-epub/ and exact-term searches across official Nebraska Legislature, SOS, Judicial Branch, Attorney General, and NDBF domains for “evidences thereof,” §§69-1201, 69-1210, 69-1213, third-party account, administrator, and processor terms.","Version/effective status and actual access":"Search-only work on October 25, 2026. No on-point controlling interpretation was located.","Use and limitations; prior relationship":"Negative search result only; not an exhaustive commercial citator, administrative-file, trial-docket, or records-request search and not proof that no interpretation exists."},"coordinator_verification_status":"researcher_bounded_negative_search_attributed_not_rerun_no_absence_conclusion","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_NE-P4-S010","urls":["https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act","https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NE-P4-S010","Title, issuer, literal URL, and exact pinpoint":"Nebraska Money Transmitters Act index, Nebraska Department of Banking and Finance. https://ndbf.nebraska.gov/industries/nebraska-money-transmitters-act. \nNebraska Banking and Finance","Version/effective status and actual access":"Current agency navigation page accessed October 25, 2026.","Use and limitations; prior relationship":"Used only to confirm the agency’s current statutory navigation. Operative Legislature text controls. Older NDBF PDFs surfaced by search were not relied upon because they predate the 2025–2026 recodification."},"coordinator_verification_status":"scoped_primary_core_supported_with_explicit_rule_interpretation_account_and_actual_fact_holds","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"coverage":[{"topic":"Chapter 69 custody entry point","researcher_record":{"Funds/account issue":"Chapter 69 custody entry point","Status":"Answered","Claim IDs":"C001–C002","Exact missing evidence or next action":"Apply to actual service and flow facts."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Direct licensee custody","researcher_record":{"Funds/account issue":"Direct licensee custody","Status":"Answered","Claim IDs":"C002, C005–C006","Exact missing evidence or next action":"Actual bank and ledger evidence for a provider-specific conclusion."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"“Evidences thereof”","researcher_record":{"Funds/account issue":"“Evidences thereof”","Status":"Unresolved","Claim IDs":"C003","Exact missing evidence or next action":"Controlling decision, official interpretation, enforcement order, or modern account-control facts."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Affiliate or processor attributed receipt","researcher_record":{"Funds/account issue":"Affiliate or processor attributed receipt","Status":"Unresolved","Claim IDs":"C003, C026","Exact missing evidence or next action":"Entity chart, agency agreement, bank customer, ACH rights, payment authority, and Nebraska interpretation."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Consumer-owned designated account","researcher_record":{"Funds/account issue":"Consumer-owned designated account","Status":"Partial/held","Claim IDs":"C003–C004, C032","Exact missing evidence or next action":"Account agreement, administrator contract, provider authority, federal coverage, and state interpretation."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Truly negotiation-only flow","researcher_record":{"Funds/account issue":"Truly negotiation-only flow","Status":"Answered only as textual boundary","Claim IDs":"C004","Exact missing evidence or next action":"Full legality and market-access pass remains required."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Separate debtor-benefit bank account","researcher_record":{"Funds/account issue":"Separate debtor-benefit bank account","Status":"Answered","Claim IDs":"C005–C006","Exact missing evidence or next action":"No further action for literal statutory requirement."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Separation from operating funds","researcher_record":{"Funds/account issue":"Separation from operating funds","Status":"Answered textually","Claim IDs":"C005","Exact missing evidence or next action":"Actual bank statements and accounting evidence for implementation."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"One account per consumer","researcher_record":{"Funds/account issue":"One account per consumer","Status":"Not required by verified text","Claim IDs":"C007","Exact missing evidence or next action":"Current rule/order or approved-form evidence could add requirements."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Cross-consumer pooling and shortage netting","researcher_record":{"Funds/account issue":"Cross-consumer pooling and shortage netting","Status":"Unresolved","Claim IDs":"C007, C011","Exact missing evidence or next action":"Formal authority and actual accounting controls."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Numerical deposit deadline","researcher_record":{"Funds/account issue":"Numerical deposit deadline","Status":"Unresolved","Claim IDs":"C008","Exact missing evidence or next action":"Current Title 433 rule, order, guidance, or approved contract."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Fifteen-day remittance","researcher_record":{"Funds/account issue":"Fifteen-day remittance","Status":"Answered","Claim IDs":"C009","Exact missing evidence or next action":"Actual receipt and payment dates."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Seven-day cash remittance","researcher_record":{"Funds/account issue":"Seven-day cash remittance","Status":"Answered","Claim IDs":"C009","Exact missing evidence or next action":"Actual payment form and receipt date."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Reasonable accumulation","researcher_record":{"Funds/account issue":"Reasonable accumulation","Status":"Answered textually; application fact-dependent","Claim IDs":"C009","Exact missing evidence or next action":"Creditor amount, reasonableness, and per-receipt dates."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Thirty-five-day maximum","researcher_record":{"Funds/account issue":"Thirty-five-day maximum","Status":"Answered","Claim IDs":"C009","Exact missing evidence or next action":"Actual receipt chronology."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Fee withdrawal endpoint","researcher_record":{"Funds/account issue":"Fee withdrawal endpoint","Status":"Answered conditionally","Claim IDs":"C006, C010","Exact missing evidence or next action":"Contract, state earning, federal earning, allocation, and authorization."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Initial $25 treatment","researcher_record":{"Funds/account issue":"Initial $25 treatment","Status":"Excluded/preserved hold","Claim IDs":"Prior P2/P3","Exact missing evidence or next action":"Current rule or controlling interpretation; not reopened."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Cancellation compensation","researcher_record":{"Funds/account issue":"Cancellation compensation","Status":"Excluded except principal separation","Claim IDs":"C020; prior P2/P3","Exact missing evidence or next action":"Contract, federal earning, account terms, and state interpretation."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"“Fees and costs”","researcher_record":{"Funds/account issue":"“Fees and costs”","Status":"Unresolved","Claim IDs":"C010","Exact missing evidence or next action":"Rule, approved contract, decision, or formal interpretation defining permissible costs."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Bank location and charter","researcher_record":{"Funds/account issue":"Bank location and charter","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"Current rule/order and actual account agreement."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"FDIC/NCUA requirement under Chapter 69","researcher_record":{"Funds/account issue":"FDIC/NCUA requirement under Chapter 69","Status":"Not established","Claim IDs":"C011, C013","Exact missing evidence or next action":"State authority; actual institution and insurance status."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Account-title wording","researcher_record":{"Funds/account issue":"Account-title wording","Status":"Unresolved","Claim IDs":"C011–C012","Exact missing evidence or next action":"Rule/order and bank documents."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Legal and beneficial ownership","researcher_record":{"Funds/account issue":"Legal and beneficial ownership","Status":"Unresolved","Claim IDs":"C012–C014","Exact missing evidence or next action":"Bank/account contracts, state property/trust law, tracing, and case authority."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Chapter 69 statutory trust","researcher_record":{"Funds/account issue":"Chapter 69 statutory trust","Status":"Not established","Claim IDs":"C012","Exact missing evidence or next action":"Controlling Nebraska authority."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"FDIC pass-through treatment","researcher_record":{"Funds/account issue":"FDIC pass-through treatment","Status":"Partial federal framework","Claim IDs":"C013","Exact missing evidence or next action":"Bank records, fiduciary disclosure, beneficial-interest records, aggregation, and institution status."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Bankruptcy exclusion/priority","researcher_record":{"Funds/account issue":"Bankruptcy exclusion/priority","Status":"Partial/held","Claim IDs":"C012, C014","Exact missing evidence or next action":"Provider bankruptcy facts, trust creation, tracing, setoff, and controlling court decision."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Interest ownership","researcher_record":{"Funds/account issue":"Interest ownership","Status":"Unresolved under state law","Claim IDs":"C011, C032","Exact missing evidence or next action":"Account contract/rule; TSR result only when federally covered."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Reserves and shortages","researcher_record":{"Funds/account issue":"Reserves and shortages","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"Rule, bank contract, processor agreement, bond/insolvency pass."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Chargebacks and ACH reversals","researcher_record":{"Funds/account issue":"Chargebacks and ACH reversals","Status":"Unresolved","Claim IDs":"C011","Exact missing evidence or next action":"ACH authorization, NACHA/bank terms, account agreement, actual posting records."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Bank and administrator fees","researcher_record":{"Funds/account issue":"Bank and administrator fees","Status":"Unresolved","Claim IDs":"C010–C011","Exact missing evidence or next action":"Contract and legal pass-through authority."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"General transaction records","researcher_record":{"Funds/account issue":"General transaction records","Status":"Answered","Claim IDs":"C015","Exact missing evidence or next action":"Actual records for compliance test."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Per-debtor ledger contents","researcher_record":{"Funds/account issue":"Per-debtor ledger contents","Status":"Answered","Claim IDs":"C016","Exact missing evidence or next action":"Exact format remains operational choice unless a rule exists."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Reconciliation frequency","researcher_record":{"Funds/account issue":"Reconciliation frequency","Status":"Unresolved for Chapter 69","Claim IDs":"C016, C019","Exact missing evidence or next action":"Current rule/manual; money-transmitter requirements do not automatically apply."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Requested written statements","researcher_record":{"Funds/account issue":"Requested written statements","Status":"Answered","Claim IDs":"C017","Exact missing evidence or next action":"Actual request and statement content."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Verbal accounting","researcher_record":{"Funds/account issue":"Verbal accounting","Status":"Answered","Claim IDs":"C017","Exact missing evidence or next action":"Actual request and normal-business-hours facts."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Automatic/monthly/online access","researcher_record":{"Funds/account issue":"Automatic/monthly/online access","Status":"Not established","Claim IDs":"C017","Exact missing evidence or next action":"Contract or current rule."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Secretary examinations","researcher_record":{"Funds/account issue":"Secretary examinations","Status":"Answered","Claim IDs":"C018","Exact missing evidence or next action":"Provider-specific examination records excluded."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Account change/closure notice","researcher_record":{"Funds/account issue":"Account change/closure notice","Status":"Unresolved","Claim IDs":"C019","Exact missing evidence or next action":"Current rule, order, regulator manual, or provider order."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Cancellation return route","researcher_record":{"Funds/account issue":"Cancellation return route","Status":"Answered in part","Claim IDs":"C020","Exact missing evidence or next action":"Contract, actual authorization, current balance, and recipient."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Cancellation-specific state deadline","researcher_record":{"Funds/account issue":"Cancellation-specific state deadline","Status":"Unresolved","Claim IDs":"C020","Exact missing evidence or next action":"Rule, order, case, or contract; 35-day ceiling remains separate."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Failed enrollment","researcher_record":{"Funds/account issue":"Failed enrollment","Status":"Partial","Claim IDs":"C022","Exact missing evidence or next action":"Payment purpose, approval, contract formation, and actual receipt facts."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Rejected creditor proposal","researcher_record":{"Funds/account issue":"Rejected creditor proposal","Status":"Partial","Claim IDs":"C022","Exact missing evidence or next action":"Creditor acceptance, accumulation need, consumer instructions, contract."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Already remitted funds","researcher_record":{"Funds/account issue":"Already remitted funds","Status":"Answered accounting boundary","Claim IDs":"C021","Exact missing evidence or next action":"Evidence that remittance was completed/final."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Provider cessation/insolvency","researcher_record":{"Funds/account issue":"Provider cessation/insolvency","Status":"Partial","Claim IDs":"C023","Exact missing evidence or next action":"Regulator/court order, bank freeze, account records, successor arrangement."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Money-transmission basic gateway","researcher_record":{"Funds/account issue":"Money-transmission basic gateway","Status":"Answered","Claim IDs":"C024","Exact missing evidence or next action":"Actual entity and transaction facts."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"In-scope DMP exemption","researcher_record":{"Funds/account issue":"In-scope DMP exemption","Status":"Answered textually","Claim IDs":"C025","Exact missing evidence or next action":"Actual license, entity, scope, and Nebraska transaction nexus."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Independent administrator status","researcher_record":{"Funds/account issue":"Independent administrator status","Status":"Unresolved until facts supplied","Claim IDs":"C026–C028","Exact missing evidence or next action":"License, delegate contract, exemption agreement, loss allocation."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Agent-of-payee exception","researcher_record":{"Funds/account issue":"Agent-of-payee exception","Status":"Partial/conditional","Claim IDs":"C027","Exact missing evidence or next action":"Payee agreement, public holding-out, discharge, loss risk, underlying goods/services."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Intermediary-processor exception","researcher_record":{"Funds/account issue":"Intermediary-processor exception","Status":"Partial/conditional","Claim IDs":"C027","Exact missing evidence or next action":"Principal entity’s license/exemption, sender receipt, sole responsibility."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Bank-service-provider exception","researcher_record":{"Funds/account issue":"Bank-service-provider exception","Status":"Partial/conditional","Claim IDs":"C027","Exact missing evidence or next action":"Written bank agreement and full assumption of risk/legal responsibility."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Authorized delegate structure","researcher_record":{"Funds/account issue":"Authorized delegate structure","Status":"Answered textually","Claim IDs":"C028","Exact missing evidence or next action":"Actual licensee, filed delegate status, contract, and scope."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Money-transmitter records","researcher_record":{"Funds/account issue":"Money-transmitter records","Status":"Answered conditionally","Claim IDs":"C029","Exact missing evidence or next action":"Applies only to licensed MT branch."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Money-transmitter refunds","researcher_record":{"Funds/account issue":"Money-transmitter refunds","Status":"Answered conditionally","Claim IDs":"C030","Exact missing evidence or next action":"Written request and every statutory exception."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Money-transmitter insolvency trust","researcher_record":{"Funds/account issue":"Money-transmitter insolvency trust","Status":"Answered conditionally","Claim IDs":"C031","Exact missing evidence or next action":"Actual licensed MT, permissible investments, outstanding obligations."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Conditional TSR dedicated account","researcher_record":{"Funds/account issue":"Conditional TSR dedicated account","Status":"Answered as overlay","Claim IDs":"C032–C033","Exact missing evidence or next action":"TSR coverage, account, administrator, request, earned fees, pending items."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Withdrawal from service versus bank closure","researcher_record":{"Funds/account issue":"Withdrawal from service versus bank closure","Status":"Answered","Claim IDs":"C033","Exact missing evidence or next action":"Actual bank/ACH rights remain contractual and otherwise legal."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Current Title 433 account rules","researcher_record":{"Funds/account issue":"Current Title 433 account rules","Status":"Unresolved","Claim IDs":"C034","Exact missing evidence or next action":"Accessible official complete current Title 433, docket, and adoption orders."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Bond claims","researcher_record":{"Funds/account issue":"Bond claims","Status":"Excluded/later pass","Claim IDs":"—","Exact missing evidence or next action":"Bond form, claimant rights, conditions, surety process, insolvency interaction."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Full contract enforceability","researcher_record":{"Funds/account issue":"Full contract enforceability","Status":"Excluded except necessary return terms","Claim IDs":"—","Exact missing evidence or next action":"Complete provider, consumer, bank, ACH, processor, creditor, and administrator agreements."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Remedies, litigation, limitations, collections, secured sectors, local and tribal law","researcher_record":{"Funds/account issue":"Remedies, litigation, limitations, collections, secured sectors, local and tribal law","Status":"Excluded/later passes","Claim IDs":"—","Exact missing evidence or next action":"Separate authorized research."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"Named-provider/account verification","researcher_record":{"Funds/account issue":"Named-provider/account verification","Status":"Not performed","Claim IDs":"—","Exact missing evidence or next action":"Exact entity, license, administrator, bank, and dated account evidence."},"coordinator_acceptance":"checked_core_with_rule_attribution_account_case_currentness_and_actual_fact_holds_not_component_acceptance","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}