{"meta":{"key":"s_nv--pass-01","task":"S_NV","title":"SNV Nevada Provider Market Access and Consumer Fees","parent_title":"Nevada debt and debt relief law","edition":"pass-01","path":"/research/s_nv--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":7,"claims":30,"sources":7,"review_status":"revise","review_complete":true,"sha256":"62da0222d5e125fc41505f78184dd0cb0d1724eeb49850633514a24d95722586","headings":["A. Substantive findings","1. Nevada has a statutory registration framework that expressly encompasses debt settlement","2. Nevada requires a state authorization analysis before market entry","3. The administrative code adds independent operating conditions","4. Consumer-fee categories differ by service model","5. An executed agreement is a necessary fee condition, not blanket permission to collect immediately","6. Government registration charges are not consumer service-fee ceilings","7. Material discrepancy: registration expiration date","8. Additional controlling statutory findings from the opened text","B. Source register","C. Claim register","D. Worked examples and coverage","Example 1 — Concession-oriented DMP","Example 2 — Settlement proportional-fee arithmetic","Example 3 — Savings-based settlement","Example 4 — Lower-debt and cancellation boundary","Component coverage and gap table","Remaining explicit holds","E. Researcher self-check"],"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_NV/pass-01","facets":{"geography":["us","us-nv"],"debt_type":[],"stage":["settlement"],"subject":["settlement-negotiation","fees-outcomes","provider-licensing","accessibility"]},"scope":"FreshNevadaprovider-access/feescomponentonly; allbroaderstatecategoriesrequired","pending_corrections":0},"markdown":"# S_NV PASS-01 — Nevada Provider Market Access and Consumer Fees\n\nSettleADebt.com | Nevada individual-state investigation | Research date: October 24, 2026 | Baseline: October 22, 2026 | Regular Chat, public-source research\n\nScope: Nevada debt-management and debt-settlement provider classification, lawful market entry, consumer charges, fee timing, exemptions, regulator procedures, and bounded calculations.\n\nResearch status: PARTIAL — material primary-law findings established; exact adjusted consumer-fee ceilings and several authorization conditions remain unresolved.\n\n## A. Substantive findings\n\n### 1. Nevada has a statutory registration framework that expressly encompasses debt settlement\n\nNevada's Uniform Debt-Management Services Act, NRS Chapter 676A, provides a regulatory framework for debt-management providers. The chapter expressly addresses both debt-management plans and debt-settlement services.\n\nThis is an important distinction for SettleADebt.com: Nevada cannot be classified as either an unrestricted debt-settlement market or a state where every form of settlement activity is categorically prohibited.\n\nThe statutory framework recognizes debt-settlement services, but recognition does not establish that any particular provider is authorized to furnish them. Registration, exemptions, operational restrictions, and federal requirements must be evaluated separately.\n\nPrimary authority:\n\n- S_NV-P1-S001: [Nevada Revised Statutes, Chapter 676A](https://www.leg.state.nv.us/NRS/NRS-676A.html?utm_source=chatgpt.com)\n- S_NV-P1-S002: [Nevada Administrative Code, Chapter 676A](https://www.leg.state.nv.us/NAC/NAC-676A.html?utm_source=chatgpt.com)\n\nThe chapter includes specific consumer protections for settlement arrangements. For example, NRS 676A.700(1)(b) restricts a provider from settling a debt for more than 50% of its outstanding amount without the individual's assent after the creditor has assented. This is a settlement-consent restriction, not a requirement that every creditor accept a 50% settlement. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\n### 2. Nevada requires a state authorization analysis before market entry\n\nThe Nevada Financial Institutions Division (FID) maintains an operational licensing page specifically for Uniform Debt Management Services.\n\nThe regulator identifies the Nationwide Multistate Licensing System and Registry (NMLS) as its current initial-application and renewal submission channel, using the company MU1 form.\n\nThe published process includes Nevada-specific requirements, forms for counselors and debt specialists, and trust-account documentation.\n\nCritical distinction: NMLS availability is evidence of an application process, not evidence that an applicant has obtained a registration or that every proposed business model qualifies.\n\nSource:\n\n- S_NV-P1-S003: [Nevada FID — Uniform Debt Management Services](https://www.fid.nv.gov/licensing/uniform-debt-management-services/?utm_source=chatgpt.com)\n\nThe regulator's operational page states that registrations expire December 31 and identifies November 1–December 31 as the renewal period. Fid NV\n\n### 3. The administrative code adds independent operating conditions\n\nNAC 676A.170 imposes restrictions beyond the existence of a state registration.\n\nA registered provider must possess other required state or local licenses and permits, comply with applicable planning and zoning ordinances, and avoid furnishing covered services in Nevada from locations omitted from its registration application.\n\nConsequently, Nevada registration alone does not necessarily establish complete operational permission for every office, location, or activity.\n\nNAC 676A.140 also addresses limited circumstances under which an expired registration can be extended or reinstated. Its conditions must be satisfied; an expired registration does not automatically remain effective. DEBT-MANAGEMENT SERVICES\n\n### 4. Consumer-fee categories differ by service model\n\nNevada's statute distinguishes plans involving creditor concessions on finance charges or delinquency fees from debt-settlement arrangements.\n\nFor the concession-oriented debt-management-plan category, NRS 676A.580(4)(a) specifies, subject to statutory dollar adjustments:\n\n- A consultation, credit-report, account-setup, or similar fee with a statutory base ceiling of $50.\n- A monthly fee with a statutory base ceiling of $10 per remaining account, subject to a $50 monthly aggregate ceiling.\n\nThese are unadjusted statutory figures, not verified October 2026 operative ceilings.\n\nThe statute expressly makes these amounts subject to adjustment under NRS 676A.730(6). The applicable adjustment history must therefore be reconciled before publishing a current maximum.\n\nThe complete operative settlement-specific fee provisions, any applicable exceptions, and the current adjustment notices are not yet sufficiently verified to state a reliable maximum settlement fee. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\n### 5. An executed agreement is a necessary fee condition, not blanket permission to collect immediately\n\nNRS 676A.580 provides that a provider cannot impose charges or receive payment for debt-management services before the provider and individual sign a compliant agreement.\n\nThat rule establishes a minimum contractual prerequisite.\n\nIt does not independently authorize advance fees, override additional Nevada fee conditions, or displace federal Telemarketing Sales Rule restrictions.\n\nThe statute also contains a distinct rule for educational or counseling charges where the individual assents to an agreement, including a possible Commissioner authorization based on the nature and extent of the counseling. The exact exception must be considered before describing counseling as categorically free or categorically chargeable. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\n### 6. Government registration charges are not consumer service-fee ceilings\n\nNevada FID's published fee schedule identifies the following amounts for Uniform Debt-Management Services:\n\n| Government charge | Published amount |\n| --- | --- |\n| Application/investigation | $2,000 |\n| Initial annual registration | $1,000 |\n| Subsequent annual renewal | $1,500 |\n| Examination/regulatory | $75 per examiner-hour |\n\nThese amounts concern the provider's regulatory expenses. They do not establish permission to bill equivalent amounts to a consumer.\n\nThe schedule is identified as a July 19, 2024 document; its continued applicability must be compared with current NAC 676A.120, .130, and .260. Fid NV+1\n\n### 7. Material discrepancy: registration expiration date\n\nThe sources reveal a concrete current-law reconciliation issue.\n\n| Authority | Stated expiration |\n| --- | --- |\n| NAC 676A.130(1), published regulation | June 30 annually |\n| FID licensing page, updated August 28, 2026 | December 31 |\n\nThe difference is not cosmetic. It affects registration continuity and whether an apparently expired provider can continue operating.\n\nNAC 676A.130 appears in a regulatory chapter marked revised September 2018, although the online compilation was refreshed April 13, 2026. The agency webpage has a later update date, but a webpage update alone does not amend a regulation.\n\nDisposition: HOLD the operative expiration date pending review of statutory amendments, subsequent rulemaking, and the NMLS transition notice. Do not select December 31 solely because it appears on the newer webpage. DEBT-MANAGEMENT SERVICES+1\n\n### 8. Additional controlling statutory findings from the opened text\n\nThe full NRS Chapter 676A page was subsequently opened. Its header identifies the compilation as revised October 6, 2026, incorporating legislation through 2025. This establishes a stronger primary-text basis than the initial search excerpts, although it does not independently establish that every potentially relevant 2026 agency action has been identified.\n\nClassification and account custody. NRS 676A.130 distinguishes concession-based debt-management plans from principal-reduction settlement plans. NRS 676A.140 defines debt-management services broadly enough to include intermediary services, credit counseling, debt-management plans, and settlement services. NRS 676A.150 specifically describes a settlement arrangement involving periodic deposits into an FDIC-insured account owned by the individual and not controlled by the provider. The presence or absence of custody therefore matters, but a provider cannot assume that avoiding custody removes it from the law. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\nExemptions and territorial reach. NRS 676A.270 contains an express resident-knowledge limitation, an exemption for services receiving no compensation from either individuals or creditors, and specified institutional or professional-course exclusions. NRS 676A.140 excludes qualifying attorney-client legal services, CPA-client accounting services, and certain regulated financial-planning services from the service definition. Neither ordinary nonprofit status nor merely retaining an attorney establishes a universal exemption. A provider serving Nevada residents remotely remains subject to the resident-based registration test in NRS 676A.300. UNIFORM DEBT-MANAGEMENT SERVICES ACT+1\n\nSettlement-fee timing and calculation. NRS 676A.580(6) expressly establishes three cumulative conditions before requesting or receiving settlement fees: an executed settlement or other valid contractual agreement for at least one debt, at least one payment by the individual under that agreement, and a qualifying proportional or savings-based fee calculation.\n\nThe two statutory calculation methods are:\n\nFi=FtotalDiDtotalF_i=F_{\\text{total}}\\frac{D_i}{D_{\\text{total}}}Fi​=Ftotal​Dtotal​Di​​where enrolled balances are measured when enrolled; or\n\nFi=r(Di−Pi)F_i=r(D_i-P_i)Fi​=r(Di​−Pi​)where rrr is a uniform savings-fee percentage across debts and PiP_iPi​ is the amount actually paid to satisfy the debt.\n\nThe statute does not supply a universal numerical percentage ceiling for these methods in the inspected subsection. This does not establish that any arbitrarily high contracted fee is lawful. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\nOther fees and refunds. NRS 676A.580(4)(b) identifies a statutory base $100 limit for qualifying counseling where no agreement is accepted, subject to adjustment or Commissioner approval for a larger amount. Subsection (5) requires a refund of that counseling fee if an agreement is accepted within 90 days after completion or termination of counseling. Subsection (7) sets a statutory base ceiling for dishonored-payment charges at the lesser of $25 or the amount otherwise permitted by law, again subject to adjustment. NRS 676A.570(8) separately addresses prompt return of undistributed funds after termination or plan failure, less fees actually payable under NRS 676A.580. UNIFORM DEBT-MANAGEMENT SERVICES ACT\n\nThe federal TSR debt-relief and credit-repair provisions were not separately opened in this pass. Nevada's statutory fee timing is therefore established here, but independent federal applicability and exact federal conditions remain held.\n\n## B. Source register\n\nAll access checks below occurred October 24, 2026. The dates describing source versions are not access dates.\n\n| Source ID | Authority, literal URL and pinpoint | Version, access and limitation |\n| --- | --- | --- |\n| S_NV-P1-S001 | Nevada Legislature, NRS Chapter 676A. `https://www.leg.state.nv.us/nrs/nrs-676a.html` — §§676A.100–.150, .200–.230, .270, .300–.320, .570–.590, .610, .700, .730 | Opened and read selected operative passages. Compilation revised Oct. 6, 2026, through 2025 legislation. Not every section or amendment history audited. |\n| S_NV-P1-S002 | Nevada Legislature, NAC Chapter 676A. `https://www.leg.state.nv.us/Nac/NAC-676A.html` — §§676A.060, .110–.170, .260 | Opened and read selected passages. Chapter revised Sept. 2018; online compilation refreshed Apr. 13, 2026. Underlying adoption orders not read. |\n| S_NV-P1-S003 | Nevada Financial Institutions Division, Uniform Debt Management Services. `https://www.fid.nv.gov/licensing/uniform-debt-management-services/` — How to Obtain or Renew; General Forms; Important Dates | Opened and read. Page updated Aug. 28, 2026. Operational guidance, not independent legal authority. |\n| S_NV-P1-S004 | Nevada FID, Financial Institutions Division Fees. `https://fid.nv.gov/uploadedFiles/fidnvgov/content/Resources/NFID%20FEES%207.19.24.pdf` — Uniform Debt-Management Services row | Search-rendered PDF text inspected; original PDF not separately opened and visually verified. Historical schedule dated July 19, 2024. |\n| S_NV-P1-S005 | Nevada FID, application checklist. `https://fid.nv.gov/uploadedfiles/fidnvgov/content/Licensing/Uniform-Debt-Management_Services/676A-Checklist.pdf` — page 1, initial registration | Discovery/search-rendered text only. Historical instructions; not proof of current submission requirements. |\n| S_NV-P1-S006 | Nevada administrative rulemaking R050-10, referenced in NAC Chapter 676A, §§.060–.170 | Locator only. Complete adoption order not opened; direct original-document URL not established. |\n| S_NV-P1-S007 | Nevada administrative rulemaking R054-16, referenced in NAC 676A.260 | Locator only. Complete amendment order not opened; direct original-document URL not established. |\n\nThe federal TSR, CROA, later adjustment schedules, current NMLS state checklist, provider register, and controlling judicial decisions are not assigned falsely verified source IDs. They remain explicit retrieval gaps.\n\n## C. Claim register\n\nConfidence describes support for the precise assertion, not authorization to launch a business.\n\n| Claim ID | Precise assertion | Source/pinpoint | Status and qualifications |\n| --- | --- | --- | --- |\n| S_NV-P1-C001 | Nevada distinguishes concession DMPs from principal-reduction settlement plans. | S001 §§.130–.150 | High; classification depends on actual conduct. |\n| S_NV-P1-C002 | Covered intermediary services include counseling, DMPs and settlement. | S001 §.140 | High; statutory exclusions apply. |\n| S_NV-P1-C003 | Statutory settlement definition specifies a consumer-owned, provider-uncontrolled insured account. | S001 §.150 | High; unusual custody arrangements require separate classification. |\n| S_NV-P1-C004 | Qualifying attorney legal services and CPA accounting services fall outside the defined service. | S001 §.140(1)–(2) | High; only within the specified professional relationship and services. |\n| S_NV-P1-C005 | Specified financial-planning services are excluded conditionally. | S001 §.140(3) | Partial; implementing professional qualification needs verification. |\n| S_NV-P1-C006 | Resident knowledge determines important territorial boundaries. | S001 §§.270(1)–(2), .300(1) | High; includes remote providers. |\n| S_NV-P1-C007 | Entirely uncompensated qualifying services are excluded. | S001 §.270(2)(b) | High; compensation from creditors also matters. |\n| S_NV-P1-C008 | Specified banks, regulated affiliates, court-related actors and incidental bill-payment providers have conditional exclusions. | S001 §.270(3) | High; regular-course condition applies. |\n| S_NV-P1-C009 | Covered providers must register before serving known Nevada residents. | S001 §.300(1) | High; exceptions apply. |\n| S_NV-P1-C010 | Employees or agents of a registered provider receive a limited registration exception. | S001 §.300(2) | High; principal registration must exist. |\n| S_NV-P1-C011 | Registration applications involve financial, insurance, bond and disclosure requirements. | S001 §§.310–.320 | High for inspected text; full application package not audited. |\n| S_NV-P1-C012 | Current FID instructions route applications and renewals through NMLS. | S003, application section | High operational confidence; no individual authorization established. |\n| S_NV-P1-C013 | NAC requires other applicable permits and properly disclosed business locations. | S002 §.170 | High. |\n| S_NV-P1-C014 | Government application fee is $2,000 plus a $1,000 proratable initial registration charge. | S002 §.120 | High for codified rule; current administrative processing fees require reconciliation. |\n| S_NV-P1-C015 | NAC specifies $1,500 annual renewal and $1,500 reinstatement fees. | S002 §.130 | High for codified amounts. |\n| S_NV-P1-C016 | NAC and FID conflict on June 30 versus December 31 expiration. | S002 §.130; S003 Important Dates | Confirmed conflict; operative date held. |\n| S_NV-P1-C017 | State statute prohibits imposing consumer service charges outside §.580. | S001 §.580(1) | High. |\n| S_NV-P1-C018 | A compliant signed agreement is required before service charges. | S001 §.580(2) | High; not sufficient by itself. |\n| S_NV-P1-C019 | Concession DMPs have statutory base $50 setup and $10/account monthly limits, capped at $50/month. | S001 §.580(4)(a) | High for base values; adjusted 2026 ceilings held. |\n| S_NV-P1-C020 | No-agreement counseling has a statutory base $100 ceiling, with conditional Commissioner approval above it. | S001 §.580(4)(b) | High for statutory structure; adjusted amount held. |\n| S_NV-P1-C021 | Qualifying counseling fees are refunded if agreement assent occurs within the specified 90-day window. | S001 §.580(5) | High; applies to fees under subsection (4)(b). |\n| S_NV-P1-C022 | Settlement fees require an executed settlement and an actual payment under it. | S001 §.580(6)(a)–(b) | High; both conditions necessary. |\n| S_NV-P1-C023 | Settlement fees must use qualifying proportional enrolled-debt allocation or uniform savings percentage. | S001 §.580(6)(c) | High; contractual reasonableness and other laws unresolved. |\n| S_NV-P1-C024 | Dishonored-payment charge has a statutory base lesser-of-$25-or-other-law limit. | S001 §.580(7) | High for base rule; current adjustment held. |\n| S_NV-P1-C025 | Termination/plan failure triggers prompt refund of undistributed funds less legally payable fees. | S001 §.570(8) | High within statutory trust/distribution context. |\n| S_NV-P1-C026 | Unlawful fees or missing required registration can make agreements voidable. | S001 §.610(1)–(2) | High; remedies otherwise reserved for later pass. |\n| S_NV-P1-C027 | State rule requires publication of annually adjusted dollar amounts. | S002 §.060 | High; actual 2026 published amounts not located. |\n| S_NV-P1-C028 | FID publishes an NMLS application procedure, not proof of provider approval. | S003; S001 §.300(3) | High; current provider lookup not performed. |\n| S_NV-P1-C029 | Nevada restricts settlements above 50% without subsequent individual assent. | S001 §.700(1)(b) | High; consent restriction, not fee ceiling. |\n| S_NV-P1-C030 | Federal TSR and conditional credit-repair requirements may independently affect fees. | Federal sources not opened | Held: no verified Nevada-specific federal-overlap conclusion. |\n\n## D. Worked examples and coverage\n\nThe examples below illustrate statutory classification and arithmetic. They do not assert that the hypothetical provider is registered or that a particular fee contract is lawful.\n\n### Example 1 — Concession-oriented DMP\n\nAssume a compliant concession plan with four participating accounts.\n\nStatutory base monthly calculation:\n\n- Number of remaining accounts: 4\n- Base per-account amount: $10\n- Product: 4 × $10 = $40\n- Base aggregate ceiling: $50\n- Illustrative result: min($40, $50) = $40 per month\n\nIf six accounts remain, the base calculation becomes min($60, $50) = $50.\n\nBoth figures are unadjusted statutory illustrations. Actual October 2026 permissible charges remain held pending the Commissioner's adjustment schedule, the signed agreement, and any applicable federal restrictions.\n\n### Example 2 — Settlement proportional-fee arithmetic\n\nAssume an illustrative contract for $20,000 in enrolled debt with a $3,000 total contracted fee. This is not an assertion that $3,000 is a lawful Nevada fee.\n\n| Debt | Enrolled balance | Allocation | Illustrative allocated fee |\n| --- | --- | --- | --- |\n| A | $4,000 | 20% | $600 |\n| B | $6,000 | 30% | $900 |\n| C | $10,000 | 50% | $1,500 |\n| Total | $20,000 | 100% | $3,000 |\n\nAssume Debt A has an executed settlement agreement and the consumer has made the first payment required under it. Under the proportional formula, $600 is the calculated allocation to Debt A.\n\nIf Debt B has not yet satisfied both performance triggers, its $900 allocation is not earned merely because Debt A qualified. The same applies to Debt C.\n\nAfter A qualifies:\n\n- Potentially earned under the illustrated allocation: $600\n- Not yet earned: $2,400\n- Maximum total illustrative contract fee: $3,000\n\nIf Debt B later independently satisfies the triggers, cumulative calculated earnings become $1,500, leaving $1,500 unearned.\n\nThis is arithmetic and performance-trigger consistency only. The example does not establish the underlying $3,000 contract's legality, the finality of a partial settlement, or permission to collect under independently applicable federal law.\n\n### Example 3 — Savings-based settlement\n\nAssume a uniform 20% savings-fee rate for all debts in the program.\n\nDebt A:\n\n- Enrolled amount: $4,000\n- Amount actually paid to satisfy it: $2,400\n- Savings: $1,600\n- Illustrative fee: $1,600 × 20% = $320\n\nDebt B:\n\n- Enrolled amount: $6,000\n- Amount actually paid to satisfy it: $3,000\n- Savings: $3,000\n- Illustrative fee: $3,000 × 20% = $600\n\nIf both debts independently satisfy the statutory triggers, the calculated cumulative fee is $920.\n\nA different percentage cannot be substituted for Debt B merely because it produces more revenue. This example uses the savings method throughout and does not combine it with the $3,000 fixed-fee contract in Example 2.\n\n### Example 4 — Lower-debt and cancellation boundary\n\nAssume an individual has a single $2,000 debt and has accumulated $500 toward a possible settlement. No creditor has entered into an executed settlement agreement.\n\nUnder NRS 676A.580(6), the provider cannot claim a settlement fee merely because the individual accumulated $500 or because negotiations began.\n\nIf the agreement is terminated, the statutory refund analysis must identify funds actually held, amounts already paid to creditors, and any fees legally payable. On these assumptions, no settlement performance fee has been established as earned.\n\nThe precise refund route depends on account structure and the applicable agreement; it cannot be calculated solely from the $500 balance.\n\n### Component coverage and gap table\n\n| Scope | Status | Claims | Exact missing evidence / next investigation |\n| --- | --- | --- | --- |\n| Core DMP versus settlement definitions | Answered | C001–C003 | Test unusual hybrid arrangements against full statutory text and decisions. |\n| Custodial versus noncustodial settlement | Partial | C003, C017 | Evaluate provider-controlled funds, third-party accounts and actual transaction flows. |\n| Consumer/business-purpose boundary | Partial | C002, C006 | Verify application to business-purpose obligations and statutory meaning of individual. |\n| Nevada resident and remote-provider nexus | Answered in principal part | C006, C009 | Apply to specific lead-generation, referral and contracting models. |\n| Registration requirement | Answered | C009–C010 | Verify named provider status separately. |\n| Attorney/CPA/financial-planner exceptions | Partial | C004–C005 | Review professional-services boundaries and implementing regulations. |\n| Nonprofit and creditor-funded models | Partial | C007–C008, C019 | Review compensation flows, creditor donations and provider relationships. |\n| Institutional and other exemptions | Partial | C008 | Verify every §.270 exception against intended model. |\n| Registration application | Partial | C011–C012, C014 | Read current NMLS Nevada checklist and transition notice. |\n| Provider registry | Unresolved | C028 | Retrieve Commissioner's public list or NMLS Consumer Access record for a named entity. |\n| Registration expiration | Unresolved | C016 | Reconcile June 30/December 31 conflict through operative amendments and agency orders. |\n| Government application/renewal fees | Partial | C014–C015 | Check current NMLS charges and operative assessment rules. |\n| DMP consumer-fee ceilings | Partial | C019, C027 | Retrieve actual 2026 annual adjusted dollar schedule. |\n| Counseling and no-agreement branch | Partial | C020–C021 | Verify current adjusted ceiling, waivers, Commissioner approvals and exceptions. |\n| Settlement proportional fee | Answered as formula | C022–C023 | Verify specific contract, enrollment balances and independently applicable law. |\n| Settlement savings fee | Answered as formula | C022–C023 | Verify satisfaction amount and consistent rate across debts. |\n| Advance-fee timing | Partial | C018, C022, C030 | Read exact current federal TSR provisions and exemptions. |\n| Credit-repair representations | Unresolved | C030 |  |\n\n\n\nNo fresh browsing was performed for this continuation. It completes the truncated October 24, 2026 record without upgrading any unread or unresolved source.\n\n| Scope | Status | Claims | Exact missing evidence / next investigation |\n| --- | --- | --- | --- |\n| Credit-repair representations | Unresolved | C030 | Open and actually read the current official CROA provisions and the federal TSR provisions applicable separately to debt-relief and credit-repair services; then test coverage against the provider’s actual representations, sales channel, promised results, and services. P1 opened no federal source, assigned no federal source ID, and verified no federal literal URL or pinpoint. Do not infer universal CROA or TSR coverage, a universal exemption, or a state bond/trust exception to federal requirements. |\n| Annual adjustment of consumer-fee amounts | Unresolved | C019, C020, C024, C027 | Retrieve and read the Commissioner’s actual adjustment notice or other operative publication establishing the amounts effective during the relevant 2026 period. Reconcile its effective date, calculation period, covered statutory amounts, rounding, and any superseded notices. Until then, the statutory base figures remain historical calculation inputs rather than verified current ceilings. |\n| Settlement above 50% of the outstanding debt | Answered in principal part | C029 | Apply the restriction to the actual creditor-approved settlement and document the individual’s assent after creditor assent. A later agreement-and-recordkeeping pass must determine the required form and proof of that assent. The provision is not a promise that a creditor will settle at or below 50% and is not a consumer-fee ceiling. |\n| Dishonored-payment charge | Partial | C024, C027 | Determine the currently adjusted Nevada amount and identify the separate “amount otherwise permitted by law” applicable to the payment instrument and transaction. Do not publish the statutory base $25 figure as the verified October 2026 maximum. |\n| Counseling-fee refund and 90-day branch | Partial | C020, C021, C027 | Verify the current adjusted counseling ceiling, the exact start and end of the 90-day period, any Commissioner-approved amount, the qualifying counseling completion or termination event, and whether the later accepted agreement is the agreement contemplated by the statute. |\n| Termination, plan failure and return of undistributed funds | Partial | C025 | Inspect the actual agreement, account ownership, custody structure, creditor disbursements, fees already lawfully earned, and the complete termination provisions before calculating a refund. No fee becomes payable merely because money was deposited, negotiations occurred, or one consumer payment was made without the applicable settlement-performance conditions. |\n| Full agreement, disclosures and cancellation requirements | Deferred except where necessary to fee timing | C018, C021, C022, C026 | Read the complete enacted agreement, disclosure, cancellation and recordkeeping provisions and all applicable regulations. P1 established only the fee-related prerequisites needed for this component; it did not approve any form agreement or cancellation language. |\n| Funds custody, trust accounts and third-party payment arrangements | Partial and deferred | C003, C011, C025 | Classify the intended flow of funds, including consumer-owned accounts, provider control, payment processors, dedicated-account providers and direct creditor payments. Read all operative trust-account provisions, current forms and exceptions. The statutory settlement definition’s consumer-owned, provider-uncontrolled account language does not resolve every hybrid arrangement. |\n| Bond, insurance, financial-condition and application requirements | Partial and deferred | C011, C012, C014, C015 | Read the complete current statutory requirements, operative regulations, current NMLS Nevada checklist, required forms and any amount-adjustment or waiver provisions. P1 established that such application conditions exist but did not verify a complete launch checklist or satisfaction by a particular applicant. |\n| Full remedies, enforcement, voidability, penalties and limitations | Partial and deferred | C026 | Read the complete administrative and private-remedy provisions, defenses, restitution or refund rules, civil penalties, criminal provisions if any, limitation periods, standing rules and relevant decisions. C026 supports only the limited voidability proposition recorded in P1. |\n| Full operative regulations and adoption history | Unresolved | C013, C014, C015, C016, C027 | Open and read the complete R050-10 and R054-16 adoption orders and any later rulemaking affecting Chapter 676A. Confirm amendment history, effective dates, codification, fee adjustments and whether later authority resolves the June 30 versus December 31 expiration conflict. S006 and S007 remain locator-only records. |\n| Registration expiration date | Unresolved | C016 | Reconcile NAC 676A.130’s June 30 language with FID’s August 28, 2026 webpage stating December 31. Required evidence includes any intervening statute, adopted regulation, transition order, NMLS notice or other legally operative instrument. A newer webpage date does not itself amend the NAC. |\n| Current NMLS application and renewal procedure | Partial | C012, C028 | Open the current Nevada NMLS company checklist, amendment and renewal instructions, transition notices, required forms, filing fees and location rules. The FID webpage establishes an operational submission route but not the complete current legal or procedural package. |\n| Named-provider registration or authorization | Unresolved | C028 | Search the legally relevant Nevada public list and/or current NMLS Consumer Access record for the exact legal entity and trade names; verify registration number, status, effective and expiration dates, approved locations, authority type and any public disciplinary limitations. P1 performed no named-provider lookup and makes no claim that any provider is authorized. |\n| Formal agency interpretations and controlling decisions | Unresolved | No verified P1 claim assigned | Locate and read controlling Nevada appellate decisions, relevant federal decisions applying Nevada law, formal Attorney General material if applicable, and authoritative FID interpretations concerning coverage, remote providers, exemptions, fee allocation and timing. No case or formal interpretation was read in P1, so no negative case-law finding may be inferred. |\n| Contract-specific lawful fee and launch determination | Unresolved | C009, C012, C017, C018, C022, C023, C028, C030 | Obtain the actual legal entity, service model, consumer geography, debt types, compensation flows, sales channels, agreement, fee method, account structure, creditor-payment evidence and registration status. Then test every element against current Nevada law and independently applicable federal law. The worked examples establish arithmetic and trigger discipline only; they do not authorize a contract, fee percentage, provider or launch. |\n| Local, tribal, secured-debt, sector-specific and special-creditor rules | Excluded from P1; required later | No verified P1 claim assigned | Investigate applicable local licensing, tribal jurisdiction, secured obligations, mortgage or foreclosure services, tax debts, student loans, medical debts, regulated financial institutions and other sector-specific regimes. P1 made no finding that these categories are covered, exempt or unrestricted. |\n| Collection, litigation, limitations and complete exemption analysis | Excluded from P1; required later | No verified P1 claim assigned | Complete separate passes for debt collection, creditor communications, litigation conduct, limitations periods, every statutory exemption, enforcement, remedies and interactions with other Nevada chapters. The limited exemptions reviewed for market-access classification are not a complete Nevada exemption opinion. |\n| Proposed, future-effective, stayed, withdrawn or superseded authority | Unresolved currentness check | C016, C027 | Check session laws, rulemaking dockets, adopted-but-not-yet-codified regulations, adjustment notices and transition materials effective after the compilations inspected. Keep proposal, adoption, effective date and webpage-update date distinct. |\n| State, coordinator or publication acceptance | Not established | No claim assigned | No Nevada launch approval, A066 acceptance, coordinator acceptance, publication readiness or legal opinion follows from P1 or this continuation. All unresolved items and broader state categories remain open. |\n\n### Remaining explicit holds\n\nThe following holds remain unchanged from the preserved first segment:\n\n- The exact October 2026 adjusted consumer-fee amounts were not located or verified.\n- The June 30 versus December 31 registration-expiration conflict was not resolved.\n- The current NMLS Nevada checklist, transition materials and named-provider status were not opened or verified.\n- The federal TSR debt-relief provisions, TSR credit-repair provisions and CROA were not opened or assigned verified source IDs or pinpoints.\n- The R050-10 and R054-16 adoption orders were not opened.\n- Controlling court decisions and formal agency interpretations were not researched.\n- The July 19, 2024 FID fee-schedule PDF was not visually opened and verified; only search-rendered text was inspected.\n- No actual contract, fee percentage, account structure or provider was approved.\n- Agreement, funds, bond, remedies, collection, litigation, limitations, complete exemptions, secured debt, sector-specific, local and tribal issues remain required later passes.\n\nThese holds are neither negative findings nor implied permission.\n\n## E. Researcher self-check\n\nThis continuation was reconstructed solely from the preserved P1 record. **No fresh web access or additional source review occurred for this continuation.** The research-access date remains October 24, 2026, Pacific time.\n\n**Actually opened and read:** S_NV-P1-S003, the Nevada FID Uniform Debt Management Services page, was opened and read as rendered for the operational statements recorded in P1.\n\n**Opened with selected operative passages read:** S_NV-P1-S001, the NRS Chapter 676A compilation, and S_NV-P1-S002, the NAC Chapter 676A compilation, were opened. Only the identified provisions and compilation information were read for this component; neither entire chapter received a section-by-section audit.\n\n**Discovery or search-rendered material only:** S_NV-P1-S004, the July 19, 2024 FID fee-schedule PDF, was inspected through search-rendered text but was not opened and visually checked page by page. S_NV-P1-S005, the historical application checklist, remained discovery/search-rendered material and was not treated as a verified current checklist.\n\n**Locator only and not substantively read:** S_NV-P1-S006, rulemaking R050-10, and S_NV-P1-S007, rulemaking R054-16, were identified from the NAC references but the complete adoption orders were not opened.\n\n**Not read or not performed:** No current federal TSR or CROA provision was opened; no current annual Nevada fee-adjustment notice was obtained; no current NMLS Nevada checklist or transition notice was read; no named-provider registry lookup was performed; no controlling judicial decision or formal agency interpretation was read; and no complete agreement, funds, bond, remedies, local, tribal, secured-debt, sector-specific, collection, litigation or limitations review was completed.\n\nThis was **not an independent review**. It was a focused provider-access and consumer-fees component, followed by a missing-output continuation. It did not create local files, submit an application, contact a regulator, verify a provider, authorize publication or establish launch readiness. Every broader Nevada category identified above remains required.\n\n**END S_NV PASS-01**\n\n**END S_NV PASS-01-CONTINUATION-01**\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Government charge","Published amount"],["Application/investigation","$2,000"],["Initial annual registration","$1,000"],["Subsequent annual renewal","$1,500"],["Examination/regulatory","$75 per examiner-hour"]],"segment":1,"original_table_index":0},{"headers":[],"index":1,"links":[],"row_links":[[],[],[]],"rows":[["Authority","Stated expiration"],["NAC 676A.130(1), published regulation","June 30 annually"],["FID licensing page, updated August 28, 2026","December 31"]],"segment":1,"original_table_index":1},{"headers":[],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Source ID","Authority, literal URL and pinpoint","Version, access and limitation"],["S_NV-P1-S001","Nevada Legislature, NRS Chapter 676A. https://www.leg.state.nv.us/nrs/nrs-676a.html — §§676A.100–.150, .200–.230, .270, .300–.320, .570–.590, .610, .700, .730","Opened and read selected operative passages. Compilation revised Oct. 6, 2026, through 2025 legislation. Not every section or amendment history audited."],["S_NV-P1-S002","Nevada Legislature, NAC Chapter 676A. https://www.leg.state.nv.us/Nac/NAC-676A.html — §§676A.060, .110–.170, .260","Opened and read selected passages. Chapter revised Sept. 2018; online compilation refreshed Apr. 13, 2026. Underlying adoption orders not read."],["S_NV-P1-S003","Nevada Financial Institutions Division, Uniform Debt Management Services. https://www.fid.nv.gov/licensing/uniform-debt-management-services/ — How to Obtain or Renew; General Forms; Important Dates","Opened and read. Page updated Aug. 28, 2026. Operational guidance, not independent legal authority."],["S_NV-P1-S004","Nevada FID, Financial Institutions Division Fees. https://fid.nv.gov/uploadedFiles/fidnvgov/content/Resources/NFID%20FEES%207.19.24.pdf — Uniform Debt-Management Services row","Search-rendered PDF text inspected; original PDF not separately opened and visually verified. Historical schedule dated July 19, 2024."],["S_NV-P1-S005","Nevada FID, application checklist. https://fid.nv.gov/uploadedfiles/fidnvgov/content/Licensing/Uniform-Debt-Management_Services/676A-Checklist.pdf — page 1, initial registration","Discovery/search-rendered text only. Historical instructions; not proof of current submission requirements."],["S_NV-P1-S006","Nevada administrative rulemaking R050-10, referenced in NAC Chapter 676A, §§.060–.170","Locator only. Complete adoption order not opened; direct original-document URL not established."],["S_NV-P1-S007","Nevada administrative rulemaking R054-16, referenced in NAC 676A.260","Locator only. Complete amendment order not opened; direct original-document URL not established."]],"segment":1,"original_table_index":2},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Source/pinpoint","Status and qualifications"],["S_NV-P1-C001","Nevada distinguishes concession DMPs from principal-reduction settlement plans.","S001 §§.130–.150","High; classification depends on actual conduct."],["S_NV-P1-C002","Covered intermediary services include counseling, DMPs and settlement.","S001 §.140","High; statutory exclusions apply."],["S_NV-P1-C003","Statutory settlement definition specifies a consumer-owned, provider-uncontrolled insured account.","S001 §.150","High; unusual custody arrangements require separate classification."],["S_NV-P1-C004","Qualifying attorney legal services and CPA accounting services fall outside the defined service.","S001 §.140(1)–(2)","High; only within the specified professional relationship and services."],["S_NV-P1-C005","Specified financial-planning services are excluded conditionally.","S001 §.140(3)","Partial; implementing professional qualification needs verification."],["S_NV-P1-C006","Resident knowledge determines important territorial boundaries.","S001 §§.270(1)–(2), .300(1)","High; includes remote providers."],["S_NV-P1-C007","Entirely uncompensated qualifying services are excluded.","S001 §.270(2)(b)","High; compensation from creditors also matters."],["S_NV-P1-C008","Specified banks, regulated affiliates, court-related actors and incidental bill-payment providers have conditional exclusions.","S001 §.270(3)","High; regular-course condition applies."],["S_NV-P1-C009","Covered providers must register before serving known Nevada residents.","S001 §.300(1)","High; exceptions apply."],["S_NV-P1-C010","Employees or agents of a registered provider receive a limited registration exception.","S001 §.300(2)","High; principal registration must exist."],["S_NV-P1-C011","Registration applications involve financial, insurance, bond and disclosure requirements.","S001 §§.310–.320","High for inspected text; full application package not audited."],["S_NV-P1-C012","Current FID instructions route applications and renewals through NMLS.","S003, application section","High operational confidence; no individual authorization established."],["S_NV-P1-C013","NAC requires other applicable permits and properly disclosed business locations.","S002 §.170","High."],["S_NV-P1-C014","Government application fee is $2,000 plus a $1,000 proratable initial registration charge.","S002 §.120","High for codified rule; current administrative processing fees require reconciliation."],["S_NV-P1-C015","NAC specifies $1,500 annual renewal and $1,500 reinstatement fees.","S002 §.130","High for codified amounts."],["S_NV-P1-C016","NAC and FID conflict on June 30 versus December 31 expiration.","S002 §.130; S003 Important Dates","Confirmed conflict; operative date held."],["S_NV-P1-C017","State statute prohibits imposing consumer service charges outside §.580.","S001 §.580(1)","High."],["S_NV-P1-C018","A compliant signed agreement is required before service charges.","S001 §.580(2)","High; not sufficient by itself."],["S_NV-P1-C019","Concession DMPs have statutory base $50 setup and $10/account monthly limits, capped at $50/month.","S001 §.580(4)(a)","High for base values; adjusted 2026 ceilings held."],["S_NV-P1-C020","No-agreement counseling has a statutory base $100 ceiling, with conditional Commissioner approval above it.","S001 §.580(4)(b)","High for statutory structure; adjusted amount held."],["S_NV-P1-C021","Qualifying counseling fees are refunded if agreement assent occurs within the specified 90-day window.","S001 §.580(5)","High; applies to fees under subsection (4)(b)."],["S_NV-P1-C022","Settlement fees require an executed settlement and an actual payment under it.","S001 §.580(6)(a)–(b)","High; both conditions necessary."],["S_NV-P1-C023","Settlement fees must use qualifying proportional enrolled-debt allocation or uniform savings percentage.","S001 §.580(6)(c)","High; contractual reasonableness and other laws unresolved."],["S_NV-P1-C024","Dishonored-payment charge has a statutory base lesser-of-$25-or-other-law limit.","S001 §.580(7)","High for base rule; current adjustment held."],["S_NV-P1-C025","Termination/plan failure triggers prompt refund of undistributed funds less legally payable fees.","S001 §.570(8)","High within statutory trust/distribution context."],["S_NV-P1-C026","Unlawful fees or missing required registration can make agreements voidable.","S001 §.610(1)–(2)","High; remedies otherwise reserved for later pass."],["S_NV-P1-C027","State rule requires publication of annually adjusted dollar amounts.","S002 §.060","High; actual 2026 published amounts not located."],["S_NV-P1-C028","FID publishes an NMLS application procedure, not proof of provider approval.","S003; S001 §.300(3)","High; current provider lookup not performed."],["S_NV-P1-C029","Nevada restricts settlements above 50% without subsequent individual assent.","S001 §.700(1)(b)","High; consent restriction, not fee ceiling."],["S_NV-P1-C030","Federal TSR and conditional credit-repair requirements may independently affect fees.","Federal sources not opened","Held: no verified Nevada-specific federal-overlap conclusion."]],"segment":1,"original_table_index":3},{"headers":[],"index":4,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Debt","Enrolled balance","Allocation","Illustrative allocated fee"],["A","$4,000","20%","$600"],["B","$6,000","30%","$900"],["C","$10,000","50%","$1,500"],["Total","$20,000","100%","$3,000"]],"segment":1,"original_table_index":4},{"headers":[],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Scope","Status","Claims","Exact missing evidence / next investigation"],["Core DMP versus settlement definitions","Answered","C001–C003","Test unusual hybrid arrangements against full statutory text and decisions."],["Custodial versus noncustodial settlement","Partial","C003, C017","Evaluate provider-controlled funds, third-party accounts and actual transaction flows."],["Consumer/business-purpose boundary","Partial","C002, C006","Verify application to business-purpose obligations and statutory meaning of individual."],["Nevada resident and remote-provider nexus","Answered in principal part","C006, C009","Apply to specific lead-generation, referral and contracting models."],["Registration requirement","Answered","C009–C010","Verify named provider status separately."],["Attorney/CPA/financial-planner exceptions","Partial","C004–C005","Review professional-services boundaries and implementing regulations."],["Nonprofit and creditor-funded models","Partial","C007–C008, C019","Review compensation flows, creditor donations and provider relationships."],["Institutional and other exemptions","Partial","C008","Verify every §.270 exception against intended model."],["Registration application","Partial","C011–C012, C014","Read current NMLS Nevada checklist and transition notice."],["Provider registry","Unresolved","C028","Retrieve Commissioner's public list or NMLS Consumer Access record for a named entity."],["Registration expiration","Unresolved","C016","Reconcile June 30/December 31 conflict through operative amendments and agency orders."],["Government application/renewal fees","Partial","C014–C015","Check current NMLS charges and operative assessment rules."],["DMP consumer-fee ceilings","Partial","C019, C027","Retrieve actual 2026 annual adjusted dollar schedule."],["Counseling and no-agreement branch","Partial","C020–C021","Verify current adjusted ceiling, waivers, Commissioner approvals and exceptions."],["Settlement proportional fee","Answered as formula","C022–C023","Verify specific contract, enrollment balances and independently applicable law."],["Settlement savings fee","Answered as formula","C022–C023","Verify satisfaction amount and consistent rate across debts."],["Advance-fee timing","Partial","C018, C022, C030","Read exact current federal TSR provisions and exemptions."],["Credit-repair representations","Unresolved","C030",""]],"segment":1,"original_table_index":5},{"headers":["Scope","Status","Claims","Exact missing evidence / next investigation"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Scope","Status","Claims","Exact missing evidence / next investigation"],["Credit-repair representations","Unresolved","C030","Open and actually read the current official CROA provisions and the federal TSR provisions applicable separately to debt-relief and credit-repair services; then test coverage against the provider’s actual representations, sales channel, promised results, and services. P1 opened no federal source, assigned no federal source ID, and verified no federal literal URL or pinpoint. Do not infer universal CROA or TSR coverage, a universal exemption, or a state bond/trust exception to federal requirements."],["Annual adjustment of consumer-fee amounts","Unresolved","C019, C020, C024, C027","Retrieve and read the Commissioner’s actual adjustment notice or other operative publication establishing the amounts effective during the relevant 2026 period. Reconcile its effective date, calculation period, covered statutory amounts, rounding, and any superseded notices. Until then, the statutory base figures remain historical calculation inputs rather than verified current ceilings."],["Settlement above 50% of the outstanding debt","Answered in principal part","C029","Apply the restriction to the actual creditor-approved settlement and document the individual’s assent after creditor assent. A later agreement-and-recordkeeping pass must determine the required form and proof of that assent. The provision is not a promise that a creditor will settle at or below 50% and is not a consumer-fee ceiling."],["Dishonored-payment charge","Partial","C024, C027","Determine the currently adjusted Nevada amount and identify the separate “amount otherwise permitted by law” applicable to the payment instrument and transaction. Do not publish the statutory base $25 figure as the verified October 2026 maximum."],["Counseling-fee refund and 90-day branch","Partial","C020, C021, C027","Verify the current adjusted counseling ceiling, the exact start and end of the 90-day period, any Commissioner-approved amount, the qualifying counseling completion or termination event, and whether the later accepted agreement is the agreement contemplated by the statute."],["Termination, plan failure and return of undistributed funds","Partial","C025","Inspect the actual agreement, account ownership, custody structure, creditor disbursements, fees already lawfully earned, and the complete termination provisions before calculating a refund. No fee becomes payable merely because money was deposited, negotiations occurred, or one consumer payment was made without the applicable settlement-performance conditions."],["Full agreement, disclosures and cancellation requirements","Deferred except where necessary to fee timing","C018, C021, C022, C026","Read the complete enacted agreement, disclosure, cancellation and recordkeeping provisions and all applicable regulations. P1 established only the fee-related prerequisites needed for this component; it did not approve any form agreement or cancellation language."],["Funds custody, trust accounts and third-party payment arrangements","Partial and deferred","C003, C011, C025","Classify the intended flow of funds, including consumer-owned accounts, provider control, payment processors, dedicated-account providers and direct creditor payments. Read all operative trust-account provisions, current forms and exceptions. The statutory settlement definition’s consumer-owned, provider-uncontrolled account language does not resolve every hybrid arrangement."],["Bond, insurance, financial-condition and application requirements","Partial and deferred","C011, C012, C014, C015","Read the complete current statutory requirements, operative regulations, current NMLS Nevada checklist, required forms and any amount-adjustment or waiver provisions. P1 established that such application conditions exist but did not verify a complete launch checklist or satisfaction by a particular applicant."],["Full remedies, enforcement, voidability, penalties and limitations","Partial and deferred","C026","Read the complete administrative and private-remedy provisions, defenses, restitution or refund rules, civil penalties, criminal provisions if any, limitation periods, standing rules and relevant decisions. C026 supports only the limited voidability proposition recorded in P1."],["Full operative regulations and adoption history","Unresolved","C013, C014, C015, C016, C027","Open and read the complete R050-10 and R054-16 adoption orders and any later rulemaking affecting Chapter 676A. Confirm amendment history, effective dates, codification, fee adjustments and whether later authority resolves the June 30 versus December 31 expiration conflict. S006 and S007 remain locator-only records."],["Registration expiration date","Unresolved","C016","Reconcile NAC 676A.130’s June 30 language with FID’s August 28, 2026 webpage stating December 31. Required evidence includes any intervening statute, adopted regulation, transition order, NMLS notice or other legally operative instrument. A newer webpage date does not itself amend the NAC."],["Current NMLS application and renewal procedure","Partial","C012, C028","Open the current Nevada NMLS company checklist, amendment and renewal instructions, transition notices, required forms, filing fees and location rules. The FID webpage establishes an operational submission route but not the complete current legal or procedural package."],["Named-provider registration or authorization","Unresolved","C028","Search the legally relevant Nevada public list and/or current NMLS Consumer Access record for the exact legal entity and trade names; verify registration number, status, effective and expiration dates, approved locations, authority type and any public disciplinary limitations. P1 performed no named-provider lookup and makes no claim that any provider is authorized."],["Formal agency interpretations and controlling decisions","Unresolved","No verified P1 claim assigned","Locate and read controlling Nevada appellate decisions, relevant federal decisions applying Nevada law, formal Attorney General material if applicable, and authoritative FID interpretations concerning coverage, remote providers, exemptions, fee allocation and timing. No case or formal interpretation was read in P1, so no negative case-law finding may be inferred."],["Contract-specific lawful fee and launch determination","Unresolved","C009, C012, C017, C018, C022, C023, C028, C030","Obtain the actual legal entity, service model, consumer geography, debt types, compensation flows, sales channels, agreement, fee method, account structure, creditor-payment evidence and registration status. Then test every element against current Nevada law and independently applicable federal law. The worked examples establish arithmetic and trigger discipline only; they do not authorize a contract, fee percentage, provider or launch."],["Local, tribal, secured-debt, sector-specific and special-creditor rules","Excluded from P1; required later","No verified P1 claim assigned","Investigate applicable local licensing, tribal jurisdiction, secured obligations, mortgage or foreclosure services, tax debts, student loans, medical debts, regulated financial institutions and other sector-specific regimes. P1 made no finding that these categories are covered, exempt or unrestricted."],["Collection, litigation, limitations and complete exemption analysis","Excluded from P1; required later","No verified P1 claim assigned","Complete separate passes for debt collection, creditor communications, litigation conduct, limitations periods, every statutory exemption, enforcement, remedies and interactions with other Nevada chapters. The limited exemptions reviewed for market-access classification are not a complete Nevada exemption opinion."],["Proposed, future-effective, stayed, withdrawn or superseded authority","Unresolved currentness check","C016, C027","Check session laws, rulemaking dockets, adopted-but-not-yet-codified regulations, adjustment notices and transition materials effective after the compilations inspected. Keep proposal, adoption, effective date and webpage-update date distinct."],["State, coordinator or publication acceptance","Not established","No claim assigned","No Nevada launch approval, A066 acceptance, coordinator acceptance, publication readiness or legal opinion follows from P1 or this continuation. All unresolved items and broader state categories remain open."]],"segment":2,"original_table_index":0}],"claims":[{"claim_id":"S_NV-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C001","Precise assertion":"Nevada distinguishes concession DMPs from principal-reduction settlement plans.","Source/pinpoint":"S001 §§.130–.150","Status and qualifications":"High; classification depends on actual conduct."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C002","Precise assertion":"Covered intermediary services include counseling, DMPs and settlement.","Source/pinpoint":"S001 §.140","Status and qualifications":"High; statutory exclusions apply."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C003","Precise assertion":"Statutory settlement definition specifies a consumer-owned, provider-uncontrolled insured account.","Source/pinpoint":"S001 §.150","Status and qualifications":"High; unusual custody arrangements require separate classification."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C004","Precise assertion":"Qualifying attorney legal services and CPA accounting services fall outside the defined service.","Source/pinpoint":"S001 §.140(1)–(2)","Status and qualifications":"High; only within the specified professional relationship and services."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C005","Precise assertion":"Specified financial-planning services are excluded conditionally.","Source/pinpoint":"S001 §.140(3)","Status and qualifications":"Partial; implementing professional qualification needs verification."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C006","Precise assertion":"Resident knowledge determines important territorial boundaries.","Source/pinpoint":"S001 §§.270(1)–(2), .300(1)","Status and qualifications":"High; includes remote providers."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C007","Precise assertion":"Entirely uncompensated qualifying services are excluded.","Source/pinpoint":"S001 §.270(2)(b)","Status and qualifications":"High; compensation from creditors also matters."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C008","Precise assertion":"Specified banks, regulated affiliates, court-related actors and incidental bill-payment providers have conditional exclusions.","Source/pinpoint":"S001 §.270(3)","Status and qualifications":"High; regular-course condition applies."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C009","Precise assertion":"Covered providers must register before serving known Nevada residents.","Source/pinpoint":"S001 §.300(1)","Status and qualifications":"High; exceptions apply."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C010","Precise assertion":"Employees or agents of a registered provider receive a limited registration exception.","Source/pinpoint":"S001 §.300(2)","Status and qualifications":"High; principal registration must exist."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C011","Precise assertion":"Registration applications involve financial, insurance, bond and disclosure requirements.","Source/pinpoint":"S001 §§.310–.320","Status and qualifications":"High for inspected text; full application package not audited."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C012","Precise assertion":"Current FID instructions route applications and renewals through NMLS.","Source/pinpoint":"S003, application section","Status and qualifications":"High operational confidence; no individual authorization established."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C013","Precise assertion":"NAC requires other applicable permits and properly disclosed business locations.","Source/pinpoint":"S002 §.170","Status and qualifications":"High."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C014","Precise assertion":"Government application fee is $2,000 plus a $1,000 proratable initial registration charge.","Source/pinpoint":"S002 §.120","Status and qualifications":"High for codified rule; current administrative processing fees require reconciliation."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C015","Precise assertion":"NAC specifies $1,500 annual renewal and $1,500 reinstatement fees.","Source/pinpoint":"S002 §.130","Status and qualifications":"High for codified amounts."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C016","Precise assertion":"NAC and FID conflict on June 30 versus December 31 expiration.","Source/pinpoint":"S002 §.130; S003 Important Dates","Status and qualifications":"Confirmed conflict; operative date held."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C017","Precise assertion":"State statute prohibits imposing consumer service charges outside §.580.","Source/pinpoint":"S001 §.580(1)","Status and qualifications":"High."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C018","Precise assertion":"A compliant signed agreement is required before service charges.","Source/pinpoint":"S001 §.580(2)","Status and qualifications":"High; not sufficient by itself."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C019","Precise assertion":"Concession DMPs have statutory base $50 setup and $10/account monthly limits, capped at $50/month.","Source/pinpoint":"S001 §.580(4)(a)","Status and qualifications":"High for base values; adjusted 2026 ceilings held."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C020","Precise assertion":"No-agreement counseling has a statutory base $100 ceiling, with conditional Commissioner approval above it.","Source/pinpoint":"S001 §.580(4)(b)","Status and qualifications":"High for statutory structure; adjusted amount held."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C021","Precise assertion":"Qualifying counseling fees are refunded if agreement assent occurs within the specified 90-day window.","Source/pinpoint":"S001 §.580(5)","Status and qualifications":"High; applies to fees under subsection (4)(b)."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C022","Precise assertion":"Settlement fees require an executed settlement and an actual payment under it.","Source/pinpoint":"S001 §.580(6)(a)–(b)","Status and qualifications":"High; both conditions necessary."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C023","Precise assertion":"Settlement fees must use qualifying proportional enrolled-debt allocation or uniform savings percentage.","Source/pinpoint":"S001 §.580(6)(c)","Status and qualifications":"High; contractual reasonableness and other laws unresolved."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C024","Precise assertion":"Dishonored-payment charge has a statutory base lesser-of-$25-or-other-law limit.","Source/pinpoint":"S001 §.580(7)","Status and qualifications":"High for base rule; current adjustment held."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C025","Precise assertion":"Termination/plan failure triggers prompt refund of undistributed funds less legally payable fees.","Source/pinpoint":"S001 §.570(8)","Status and qualifications":"High within statutory trust/distribution context."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C026","Precise assertion":"Unlawful fees or missing required registration can make agreements voidable.","Source/pinpoint":"S001 §.610(1)–(2)","Status and qualifications":"High; remedies otherwise reserved for later pass."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C027","Precise assertion":"State rule requires publication of annually adjusted dollar amounts.","Source/pinpoint":"S002 §.060","Status and qualifications":"High; actual 2026 published amounts not located."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C028","Precise assertion":"FID publishes an NMLS application procedure, not proof of provider approval.","Source/pinpoint":"S003; S001 §.300(3)","Status and qualifications":"High; current provider lookup not performed."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C029","Precise assertion":"Nevada restricts settlements above 50% without subsequent individual assent.","Source/pinpoint":"S001 §.700(1)(b)","Status and qualifications":"High; consent restriction, not fee ceiling."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_NV-P1-C030","Precise assertion":"Federal TSR and conditional credit-repair requirements may independently affect fees.","Source/pinpoint":"Federal sources not opened","Status and qualifications":"Held: no verified Nevada-specific federal-overlap conclusion."},"coordinator_verification_status":"reviewed_with_material_expiration_repealed140_accountcontrol_secureddebt_and_current_adjustment_holds;originalcellunchanged","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_NV-P1-S001","urls":["https://www.leg.state.nv.us/nrs/nrs-676a.html"],"researcher_record":{"Source ID":"S_NV-P1-S001","Authority, literal URL and pinpoint":"Nevada Legislature, NRS Chapter 676A. https://www.leg.state.nv.us/nrs/nrs-676a.html — §§676A.100–.150, .200–.230, .270, .300–.320, .570–.590, .610, .700, .730","Version, access and limitation":"Opened and read selected operative passages. Compilation revised Oct. 6, 2026, through 2025 legislation. Not every section or amendment history audited."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S002","urls":["https://www.leg.state.nv.us/Nac/NAC-676A.html"],"researcher_record":{"Source ID":"S_NV-P1-S002","Authority, literal URL and pinpoint":"Nevada Legislature, NAC Chapter 676A. https://www.leg.state.nv.us/Nac/NAC-676A.html — §§676A.060, .110–.170, .260","Version, access and limitation":"Opened and read selected passages. Chapter revised Sept. 2018; online compilation refreshed Apr. 13, 2026. Underlying adoption orders not read."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S003","urls":["https://www.fid.nv.gov/licensing/uniform-debt-management-services/"],"researcher_record":{"Source ID":"S_NV-P1-S003","Authority, literal URL and pinpoint":"Nevada Financial Institutions Division, Uniform Debt Management Services. https://www.fid.nv.gov/licensing/uniform-debt-management-services/ — How to Obtain or Renew; General Forms; Important Dates","Version, access and limitation":"Opened and read. Page updated Aug. 28, 2026. Operational guidance, not independent legal authority."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S004","urls":["https://fid.nv.gov/uploadedFiles/fidnvgov/content/Resources/NFID%20FEES%207.19.24.pdf"],"researcher_record":{"Source ID":"S_NV-P1-S004","Authority, literal URL and pinpoint":"Nevada FID, Financial Institutions Division Fees. https://fid.nv.gov/uploadedFiles/fidnvgov/content/Resources/NFID%20FEES%207.19.24.pdf — Uniform Debt-Management Services row","Version, access and limitation":"Search-rendered PDF text inspected; original PDF not separately opened and visually verified. Historical schedule dated July 19, 2024."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S005","urls":["https://fid.nv.gov/uploadedfiles/fidnvgov/content/Licensing/Uniform-Debt-Management_Services/676A-Checklist.pdf"],"researcher_record":{"Source ID":"S_NV-P1-S005","Authority, literal URL and pinpoint":"Nevada FID, application checklist. https://fid.nv.gov/uploadedfiles/fidnvgov/content/Licensing/Uniform-Debt-Management_Services/676A-Checklist.pdf — page 1, initial registration","Version, access and limitation":"Discovery/search-rendered text only. Historical instructions; not proof of current submission requirements."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S006","urls":[],"researcher_record":{"Source ID":"S_NV-P1-S006","Authority, literal URL and pinpoint":"Nevada administrative rulemaking R050-10, referenced in NAC Chapter 676A, §§.060–.170","Version, access and limitation":"Locator only. Complete adoption order not opened; direct original-document URL not established."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P1-S007","urls":[],"researcher_record":{"Source ID":"S_NV-P1-S007","Authority, literal URL and pinpoint":"Nevada administrative rulemaking R054-16, referenced in NAC 676A.260","Version, access and limitation":"Locator only. Complete amendment order not opened; direct original-document URL not established."},"coordinator_verification_status":"see_exact_selected_primary_approved_R09823_statutory370_stale_compilation_adjustment_gaps_and_explicit_reuse_in_reviews/S_NV-pass-01-source-checks.json","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Core DMP versus settlement definitions","researcher_record":{"Scope":"Core DMP versus settlement definitions","Status":"Answered","Claims":"C001–C003","Exact missing evidence / next investigation":"Test unusual hybrid arrangements against full statutory text and decisions."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial versus noncustodial settlement","researcher_record":{"Scope":"Custodial versus noncustodial settlement","Status":"Partial","Claims":"C003, C017","Exact missing evidence / next investigation":"Evaluate provider-controlled funds, third-party accounts and actual transaction flows."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business-purpose boundary","researcher_record":{"Scope":"Consumer/business-purpose boundary","Status":"Partial","Claims":"C002, C006","Exact missing evidence / next investigation":"Verify application to business-purpose obligations and statutory meaning of individual."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nevada resident and remote-provider nexus","researcher_record":{"Scope":"Nevada resident and remote-provider nexus","Status":"Answered in principal part","Claims":"C006, C009","Exact missing evidence / next investigation":"Apply to specific lead-generation, referral and contracting models."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Registration requirement","researcher_record":{"Scope":"Registration requirement","Status":"Answered","Claims":"C009–C010","Exact missing evidence / next investigation":"Verify named provider status separately."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney/CPA/financial-planner exceptions","researcher_record":{"Scope":"Attorney/CPA/financial-planner exceptions","Status":"Partial","Claims":"C004–C005","Exact missing evidence / next investigation":"Review professional-services boundaries and implementing regulations."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit and creditor-funded models","researcher_record":{"Scope":"Nonprofit and creditor-funded models","Status":"Partial","Claims":"C007–C008, C019","Exact missing evidence / next investigation":"Review compensation flows, creditor donations and provider relationships."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Institutional and other exemptions","researcher_record":{"Scope":"Institutional and other exemptions","Status":"Partial","Claims":"C008","Exact missing evidence / next investigation":"Verify every §.270 exception against intended model."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Registration application","researcher_record":{"Scope":"Registration application","Status":"Partial","Claims":"C011–C012, C014","Exact missing evidence / next investigation":"Read current NMLS Nevada checklist and transition notice."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Provider registry","researcher_record":{"Scope":"Provider registry","Status":"Unresolved","Claims":"C028","Exact missing evidence / next investigation":"Retrieve Commissioner's public list or NMLS Consumer Access record for a named entity."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Registration expiration","researcher_record":{"Scope":"Registration expiration","Status":"Unresolved","Claims":"C016","Exact missing evidence / next investigation":"Reconcile June 30/December 31 conflict through operative amendments and agency orders."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Government application/renewal fees","researcher_record":{"Scope":"Government application/renewal fees","Status":"Partial","Claims":"C014–C015","Exact missing evidence / next investigation":"Check current NMLS charges and operative assessment rules."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"DMP consumer-fee ceilings","researcher_record":{"Scope":"DMP consumer-fee ceilings","Status":"Partial","Claims":"C019, C027","Exact missing evidence / next investigation":"Retrieve actual 2026 annual adjusted dollar schedule."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Counseling and no-agreement branch","researcher_record":{"Scope":"Counseling and no-agreement branch","Status":"Partial","Claims":"C020–C021","Exact missing evidence / next investigation":"Verify current adjusted ceiling, waivers, Commissioner approvals and exceptions."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement proportional fee","researcher_record":{"Scope":"Settlement proportional fee","Status":"Answered as formula","Claims":"C022–C023","Exact missing evidence / next investigation":"Verify specific contract, enrollment balances and independently applicable law."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement savings fee","researcher_record":{"Scope":"Settlement savings fee","Status":"Answered as formula","Claims":"C022–C023","Exact missing evidence / next investigation":"Verify satisfaction amount and consistent rate across debts."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Advance-fee timing","researcher_record":{"Scope":"Advance-fee timing","Status":"Partial","Claims":"C018, C022, C030","Exact missing evidence / next investigation":"Read exact current federal TSR provisions and exemptions."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Credit-repair representations","researcher_record":{"Scope":"Credit-repair representations","Status":"Unresolved","Claims":"C030","Exact missing evidence / next investigation":"Open and actually read the current official CROA provisions and the federal TSR provisions applicable separately to debt-relief and credit-repair services; then test coverage against the provider’s actual representations, sales channel, promised results, and services. P1 opened no federal source, assigned no federal source ID, and verified no federal literal URL or pinpoint. Do not infer universal CROA or TSR coverage, a universal exemption, or a state bond/trust exception to federal requirements."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Annual adjustment of consumer-fee amounts","researcher_record":{"Scope":"Annual adjustment of consumer-fee amounts","Status":"Unresolved","Claims":"C019, C020, C024, C027","Exact missing evidence / next investigation":"Retrieve and read the Commissioner’s actual adjustment notice or other operative publication establishing the amounts effective during the relevant 2026 period. Reconcile its effective date, calculation period, covered statutory amounts, rounding, and any superseded notices. Until then, the statutory base figures remain historical calculation inputs rather than verified current ceilings."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement above 50% of the outstanding debt","researcher_record":{"Scope":"Settlement above 50% of the outstanding debt","Status":"Answered in principal part","Claims":"C029","Exact missing evidence / next investigation":"Apply the restriction to the actual creditor-approved settlement and document the individual’s assent after creditor assent. A later agreement-and-recordkeeping pass must determine the required form and proof of that assent. The provision is not a promise that a creditor will settle at or below 50% and is not a consumer-fee ceiling."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Dishonored-payment charge","researcher_record":{"Scope":"Dishonored-payment charge","Status":"Partial","Claims":"C024, C027","Exact missing evidence / next investigation":"Determine the currently adjusted Nevada amount and identify the separate “amount otherwise permitted by law” applicable to the payment instrument and transaction. Do not publish the statutory base $25 figure as the verified October 2026 maximum."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Counseling-fee refund and 90-day branch","researcher_record":{"Scope":"Counseling-fee refund and 90-day branch","Status":"Partial","Claims":"C020, C021, C027","Exact missing evidence / next investigation":"Verify the current adjusted counseling ceiling, the exact start and end of the 90-day period, any Commissioner-approved amount, the qualifying counseling completion or termination event, and whether the later accepted agreement is the agreement contemplated by the statute."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Termination, plan failure and return of undistributed funds","researcher_record":{"Scope":"Termination, plan failure and return of undistributed funds","Status":"Partial","Claims":"C025","Exact missing evidence / next investigation":"Inspect the actual agreement, account ownership, custody structure, creditor disbursements, fees already lawfully earned, and the complete termination provisions before calculating a refund. No fee becomes payable merely because money was deposited, negotiations occurred, or one consumer payment was made without the applicable settlement-performance conditions."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full agreement, disclosures and cancellation requirements","researcher_record":{"Scope":"Full agreement, disclosures and cancellation requirements","Status":"Deferred except where necessary to fee timing","Claims":"C018, C021, C022, C026","Exact missing evidence / next investigation":"Read the complete enacted agreement, disclosure, cancellation and recordkeeping provisions and all applicable regulations. P1 established only the fee-related prerequisites needed for this component; it did not approve any form agreement or cancellation language."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Funds custody, trust accounts and third-party payment arrangements","researcher_record":{"Scope":"Funds custody, trust accounts and third-party payment arrangements","Status":"Partial and deferred","Claims":"C003, C011, C025","Exact missing evidence / next investigation":"Classify the intended flow of funds, including consumer-owned accounts, provider control, payment processors, dedicated-account providers and direct creditor payments. Read all operative trust-account provisions, current forms and exceptions. The statutory settlement definition’s consumer-owned, provider-uncontrolled account language does not resolve every hybrid arrangement."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Bond, insurance, financial-condition and application requirements","researcher_record":{"Scope":"Bond, insurance, financial-condition and application requirements","Status":"Partial and deferred","Claims":"C011, C012, C014, C015","Exact missing evidence / next investigation":"Read the complete current statutory requirements, operative regulations, current NMLS Nevada checklist, required forms and any amount-adjustment or waiver provisions. P1 established that such application conditions exist but did not verify a complete launch checklist or satisfaction by a particular applicant."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full remedies, enforcement, voidability, penalties and limitations","researcher_record":{"Scope":"Full remedies, enforcement, voidability, penalties and limitations","Status":"Partial and deferred","Claims":"C026","Exact missing evidence / next investigation":"Read the complete administrative and private-remedy provisions, defenses, restitution or refund rules, civil penalties, criminal provisions if any, limitation periods, standing rules and relevant decisions. C026 supports only the limited voidability proposition recorded in P1."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Full operative regulations and adoption history","researcher_record":{"Scope":"Full operative regulations and adoption history","Status":"Unresolved","Claims":"C013, C014, C015, C016, C027","Exact missing evidence / next investigation":"Open and read the complete R050-10 and R054-16 adoption orders and any later rulemaking affecting Chapter 676A. Confirm amendment history, effective dates, codification, fee adjustments and whether later authority resolves the June 30 versus December 31 expiration conflict. S006 and S007 remain locator-only records."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Registration expiration date","researcher_record":{"Scope":"Registration expiration date","Status":"Unresolved","Claims":"C016","Exact missing evidence / next investigation":"Reconcile NAC 676A.130’s June 30 language with FID’s August 28, 2026 webpage stating December 31. Required evidence includes any intervening statute, adopted regulation, transition order, NMLS notice or other legally operative instrument. A newer webpage date does not itself amend the NAC."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Current NMLS application and renewal procedure","researcher_record":{"Scope":"Current NMLS application and renewal procedure","Status":"Partial","Claims":"C012, C028","Exact missing evidence / next investigation":"Open the current Nevada NMLS company checklist, amendment and renewal instructions, transition notices, required forms, filing fees and location rules. The FID webpage establishes an operational submission route but not the complete current legal or procedural package."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider registration or authorization","researcher_record":{"Scope":"Named-provider registration or authorization","Status":"Unresolved","Claims":"C028","Exact missing evidence / next investigation":"Search the legally relevant Nevada public list and/or current NMLS Consumer Access record for the exact legal entity and trade names; verify registration number, status, effective and expiration dates, approved locations, authority type and any public disciplinary limitations. P1 performed no named-provider lookup and makes no claim that any provider is authorized."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Formal agency interpretations and controlling decisions","researcher_record":{"Scope":"Formal agency interpretations and controlling decisions","Status":"Unresolved","Claims":"No verified P1 claim assigned","Exact missing evidence / next investigation":"Locate and read controlling Nevada appellate decisions, relevant federal decisions applying Nevada law, formal Attorney General material if applicable, and authoritative FID interpretations concerning coverage, remote providers, exemptions, fee allocation and timing. No case or formal interpretation was read in P1, so no negative case-law finding may be inferred."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Contract-specific lawful fee and launch determination","researcher_record":{"Scope":"Contract-specific lawful fee and launch determination","Status":"Unresolved","Claims":"C009, C012, C017, C018, C022, C023, C028, C030","Exact missing evidence / next investigation":"Obtain the actual legal entity, service model, consumer geography, debt types, compensation flows, sales channels, agreement, fee method, account structure, creditor-payment evidence and registration status. Then test every element against current Nevada law and independently applicable federal law. The worked examples establish arithmetic and trigger discipline only; they do not authorize a contract, fee percentage, provider or launch."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Local, tribal, secured-debt, sector-specific and special-creditor rules","researcher_record":{"Scope":"Local, tribal, secured-debt, sector-specific and special-creditor rules","Status":"Excluded from P1; required later","Claims":"No verified P1 claim assigned","Exact missing evidence / next investigation":"Investigate applicable local licensing, tribal jurisdiction, secured obligations, mortgage or foreclosure services, tax debts, student loans, medical debts, regulated financial institutions and other sector-specific regimes. P1 made no finding that these categories are covered, exempt or unrestricted."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Collection, litigation, limitations and complete exemption analysis","researcher_record":{"Scope":"Collection, litigation, limitations and complete exemption analysis","Status":"Excluded from P1; required later","Claims":"No verified P1 claim assigned","Exact missing evidence / next investigation":"Complete separate passes for debt collection, creditor communications, litigation conduct, limitations periods, every statutory exemption, enforcement, remedies and interactions with other Nevada chapters. The limited exemptions reviewed for market-access classification are not a complete Nevada exemption opinion."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"Proposed, future-effective, stayed, withdrawn or superseded authority","researcher_record":{"Scope":"Proposed, future-effective, stayed, withdrawn or superseded authority","Status":"Unresolved currentness check","Claims":"C016, C027","Exact missing evidence / next investigation":"Check session laws, rulemaking dockets, adopted-but-not-yet-codified regulations, adjustment notices and transition materials effective after the compilations inspected. Keep proposal, adoption, effective date and webpage-update date distinct."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"},{"topic":"State, coordinator or publication acceptance","researcher_record":{"Scope":"State, coordinator or publication acceptance","Status":"Not established","Claims":"No claim assigned","Exact missing evidence / next investigation":"No Nevada launch approval, A066 acceptance, coordinator acceptance, publication readiness or legal opinion follows from P1 or this continuation. All unresolved items and broader state categories remain open."},"coordinator_acceptance":"reviewed_partial_with_material_corrections_no_component_or_parent_acceptance","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}