{"meta":{"key":"s_nv--pass-05","task":"S_NV","title":"SNV Bounded P04 account-money corrections","parent_title":"Nevada debt and debt relief law","edition":"pass-05","path":"/research/s_nv--pass-05/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-27","tables":7,"claims":4,"sources":5,"review_status":"scoped_review_complete_requested_repairs_addressed_with_holds","review_complete":true,"sha256":"f06dd06bdc058c760e50d848a7fd2433d4c9160f722058a078be6ef03b340e61","headings":["A. Limited source-use register","B. Precise narrative and matrix replacements","R1 — Provider control is not identical to administrator affiliation","R2 — Separate the cancellation period, refund duties, and civil recovery","R3 — Federal receipt requirement","R4 — Complete the payee-agent predicate","R5 — Both voluntary-contribution restrictions","C. Affected claim replacements only","D. Affected trigger-table rows only","E. Example replacements only","F. Affected coverage replacements only","G. Exact affected-entry crosswalk","Researcher self-check and unchanged holds"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","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-05","facets":{"geography":["us","us-nv"],"debt_type":[],"stage":[],"subject":[]},"scope":"Bounded reviewedP04state/federalcontrol/30dayrefund/TSRreceipt/payeeagent/contribution qualifications only","pending_corrections":0},"markdown":"# S_NV PASS-05 — Bounded P04 account-money corrections\n\n**Fresh primary-source access: October 27, 2026, Pacific (America/Los_Angeles).** This patch changes only the entries identified below. P04’s original provenance, access history, unaffected findings, claim identities, examples, and remaining holds are preserved. No individual source-fetch timestamps are asserted.\n\n## A. Limited source-use register\n\nEach document has one source identity despite its multiple relevant provisions.\n\n| P05 source-use ID / prior alias | Issuer, document, and complete literal URL | Exact passages used | Version, fresh/reused status, and limits |\n| --- | --- | --- | --- |\n| **S_NV-P5-S001** / P4-S001 | Nevada Legislature, **NRS Chapter 676A**. https://www.leg.state.nv.us/NRS/NRS-676A.html | §§676A.150(2); .540(4), (7); **complete .550(1)–(3)**; .570(8); **complete .590 and .610**; .620(2); .700(2) introductory language and (i)(1); .720; .760(5)–(6). Related §700 referral/affiliate provisions were checked without expanding their P04 claims. | **Fresh selected reading.** Compilation header: October 6, 2026, “2025” edition. This is not a whole-chapter, legislative-history, case-law, or later-law certification. [Nevada Legislature+2](https://www.leg.state.nv.us/NRS/NRS-676A.html) |\n| **S_NV-P5-S002** / P4-S002 | Nevada Legislature, **NAC Chapter 676A**. https://www.leg.state.nv.us/NAC/NAC-676A.html | NAC 676A.180(4), including its R050-10 adoption notation. | **Fresh selected reading.** Page refresh April 13, 2026; chapter revision September 2018. Only the relevant anti-evasion provision is used; known stale registration provisions are not restored or relied upon. [Nevada Legislature+1](https://www.leg.state.nv.us/NAC/NAC-676A.html) |\n| **S_NV-P5-S003** / P4-S005 | Nevada Legislature, **NRS Chapter 671**. https://www.leg.state.nv.us/NRS/NRS-671.html | Current §671.020 introductory qualification and **complete subsection (3), including (a)–(c)**. | **Fresh selected reading.** Compilation header April 15, 2026. Used the version expressly effective **through December 31, 2029**, not the January 1, 2030 branch. No actual actor, license, or exemption was investigated. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-671.html) |\n| **S_NV-P5-S004** / P4-S010 | Office of the Federal Register/GPO, **16 CFR 310.4**, implementing the FTC’s Telemarketing Sales Rule. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | Complete §310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E), particularly **(ii)(C)** and **(ii)(E)**. | **Fresh selected reading.** Display states Title 16 is current through **October 23, 2026**, last amended October 19, 2026; eCFR describes itself as authoritative but unofficial. P04’s earlier October 22 display remains its historical record. No intervening Federal Register or full-TSR audit is asserted. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_NV-P5-S005** / P4-S003 | Nevada Legislature, **Adopted Regulation R050-10A**. https://www.leg.state.nv.us/register/2010Register/R050-10A.pdf | §8(4), **printed page 4 / zero-based PDF index 3**. | **Supplied/reused P04 selected-read provenance only; not reopened or visually inspected in P05.** P04 records the October 15, 2010 effective date. No whole-order or subsequent-rulemaking review is newly claimed. Section 6 is not needed for this patch. |\n\n## B. Precise narrative and matrix replacements\n\n### R1 — Provider control is not identical to administrator affiliation\n\nReplace only the identified model-matrix row with the following. Its existing row identity is retained.\n\n| Model | Who owns or controls the money? | Nevada Chapter 676A treatment | Chapter 671 / federal overlay | Status |\n| --- | --- | --- | --- | --- |\n| **Provider-, affiliate-, or captive-processor-controlled settlement account** | Distinguish **ownership of the individual’s account**, **ownership of the administrator entity**, and **actual account-control powers**. The settlement account must remain individual-owned. | The provider may not, **directly or indirectly**, have an ownership interest in or any control of the individual’s settlement account. Using an agent, affiliate, or subsidiary to evade that prohibition is forbidden. However, an administrator’s relationship to the provider is not, by itself, a separately established categorical Nevada affiliation ban. This does not permit nonconsumer account ownership or create an affiliate safe harbor. | When the TSR dedicated-account provision applies, it separately requires an administrator that is not owned or controlled by, or affiliated in any way with, the debt-relief service. Chapter 671 status remains a separate factual inquiry. | **Nevada result depends on actual ownership/control and evasion facts; federal administrator-affiliation restriction applies conditionally.** C020/C022/C023/C030 retain their identities. |\n\n**Authority:** S001, §§676A.150(2), .700(2) introductory language and (i)(1), .720; S002, NAC 676A.180(4); S004, §310.4(a)(5)(ii)(C). Delegation does not remove the provider’s liability, but that principle must not be rewritten as a blanket state-law ban on every affiliated administrator. [Nevada Legislature+4](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\n### R2 — Separate the cancellation period, refund duties, and civil recovery\n\nUse this replacement for the affected cancellation discussion:\n\nNRS 676A.550(1) provides the ordinary cancellation right before midnight of the third business day after assent. Specified noncompliance with §550(2), §540, or §700 extends the cancellation right to 30 days after assent. Cancellation requires notice in a record; mailed notice is given when mailed. The emergency-waiver requirements of §550(3) remain applicable.\n\nThe mandatory notice in §550(2) expressly promises refund of all money already paid for cancellation **within the three-day period**. The extended 30-day cancellation right does not, by that language alone, establish an identical automatic all-money refund. It also does not establish that no refund is due. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\nThe necessary separate money provisions remain relevant: §540(4) requires the specified termination protections, and §540(7) makes those rights and obligations effective even when omitted from the agreement. Section 570(8) addresses prompt return of money not paid to creditors, less fees actually payable under §580; §620(2) requires immediate return of the individual’s trust money upon termination. Apply each provision to its trigger and the actual ledger rather than treating every previously paid fee as retainable—or every historical payment as automatically refundable. [Nevada Legislature+3](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\n**Civil recovery is a different branch.** Under §760(5), a provider’s violation of an individual’s §550 rights can support recovery **in a civil action** of money paid or deposited under the agreement, **excluding amounts paid to creditors**, subject to applicable statutory qualifications, including §760(6). This is not an automatic all-money-refund rule triggered merely by invoking the 30-day period. Section 610 also has its own voidability predicates—unauthorized charges/payments or missing required registration—which must not be presumed from an agreement defect alone. No additional remedies conclusion is made here. [Nevada Legislature+1](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\n### R3 — Federal receipt requirement\n\nReplace the affected seven-business-day wording throughout the identified P04 entries with:\n\nWhen §310.4(a)(5)(ii)(E) applies, the customer may withdraw from the debt-relief service without penalty and **must receive** all account funds, except amounts earned in compliance with §310.4(a)(5)(i)(A)–(C), within seven business days of the customer’s request.\n\n“Returned or made available” is not retained as an alternative formulation. Service withdrawal remains distinct from unresolved bank-account closure, ACH-revocation, and card-access mechanics. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### R4 — Complete the payee-agent predicate\n\nReplace the payee-agent bullet in P04 §A.5 with:\n\nThe current NRS 671.020(3) exemption concerns a person appointed as a payee’s agent to collect and process payment for **goods or services, other than money transmission, provided by the payee to the payor**. It additionally requires: a written payee-agent agreement directing collection and processing on the payee’s behalf; the payee’s public identification of the agent as accepting those payments; and treatment of receipt by the agent as receipt by the payee, extinguishing the payor’s obligation without remittance-loss risk to the payor. All predicates must be established, subject to §671.020’s introductory qualification.\n\nNo creditor-payment or processor arrangement is classified by this patch. The other conditional C025 findings are preserved, not freshly expanded. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-671.html)\n\n### R5 — Both voluntary-contribution restrictions\n\nReplace P04 §A.7’s voluntary-contribution paragraph with:\n\nNRS 676A.590 prohibits soliciting a voluntary contribution from the individual **or an affiliate of that individual** for services provided to the individual. Separately, although the provision permits accepting voluntary contributions from an individual, until 30 days after plan completion or termination aggregate receipts from or for that individual cannot exceed the amount chargeable under §580. The no-solicitation rule is not limited to that 30-day period. Expiration of the aggregate-cap period does not establish unrestricted contribution permission, and no current permissible amount is established here. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\n## C. Affected claim replacements only\n\nThe existing **S_NV-P4-C…** identities are retained. These are amendments, not new claims or renumbered records.\n\n| Existing claim ID | Replacement assertion | Source/pinpoint | Qualification |\n| --- | --- | --- | --- |\n| **S_NV-P4-C016** | Section 550 supplies an ordinary three-business-day cancellation right and a 30-day right for the specified agreement defects. The required notice expressly promises an all-money refund for the three-day period. Refund or recovery in the extended branch requires the separate statutory basis and facts described in **R2**; §760(5) is a conditional civil-recovery provision excluding creditor payments. | S001, §§550(1)–(3), 540(4), (7), 570(8), 610, 620(2), 760(5)–(6). | **Textual distinction established; no automatic identical 30-day refund established.** No categorical no-refund conclusion. [Nevada Legislature+1](https://www.leg.state.nv.us/NRS/NRS-676A.html) |\n| **S_NV-P4-C025** | Preserve the existing conditional-exemption framework. The payee-agent branch additionally requires the underlying payment to concern goods or **non-money-transmission services supplied by the payee to the payor**, together with every appointment, written-agreement, public-holding-out, discharge, and no-loss condition in **R4**. | S003, current §671.020 opening qualification and (3)(a)–(c). | **Missing predicate corrected.** Other P04 exemption findings, including the bounded no-categorical-676A-exemption finding, are carried forward without a new full-list audit. No actor classified. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-671.html) |\n| **S_NV-P4-C030** | Conditional TSR dedicated-account requirements remain cumulative. They include customer ownership and accrued interest, administrator independence, and referral-compensation restrictions. Upon the customer’s service-withdrawal request, the customer **must receive** all account funds except amounts actually earned under §310.4(a)(5)(i)(A)–(C), within seven business days. | S004, §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E). | **Receipt wording corrected.** Actual TSR coverage, affiliation, earning, and receipt facts remain unresolved; bank mechanics are not supplied by this wording. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_NV-P4-C034** | Section 590 separately prohibits solicitation from the individual or the individual’s affiliate and restricts aggregate acceptance through the stated post-plan period. Neither the acceptance language nor expiration of that period removes the solicitation prohibition or establishes a lawful contribution amount. | S001, complete §676A.590. | **No-solicitation limb added.** Existing aggregate-cap finding and adjusted-fee hold remain. [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-676A.html) |\n\n**C020, C022, and C023 retain their existing assertions and identities.** Their connection to the corrected matrix is R1: provider ownership/control, anti-evasion, delegation liability, and particular affiliate/referral restrictions are not interchangeable with the federal administrator-affiliation condition.\n\n## D. Affected trigger-table rows only\n\n| Existing trigger identity | Replacement money result | Timing | Necessary qualification |\n| --- | --- | --- | --- |\n| **Timely statutory cancellation** | Preserve the required all-money-refund promise for the three-day cancellation branch. For the extended 30-day branch, distinguish the cancellation right from the separate refund and civil-recovery provisions in R2. | Ordinary cancellation: before midnight of the third business day after assent. Specified defects: within 30 days after assent. No new universal refund deadline is asserted. | Emergency-waiver rules remain. Section 760(5) requires violation of §550 rights and concerns civil recovery, with an exception for creditor payments; it is not a universal automatic-refund rule. **C016.** [Nevada Legislature+1](https://www.leg.state.nv.us/NRS/NRS-676A.html) |\n| **Covered federal TSR customer withdraws from service** | Customer **must receive** all account funds except amounts earned under §310.4(a)(5)(i)(A)–(C). | Within seven business days of the customer’s request. | Conditional TSR applicability; no substitution of mere availability for receipt; no determination of bank closure or ACH/card mechanics. **C030.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n## E. Example replacements only\n\nThe stipulated amounts and arithmetic are unchanged. These corrections concern legal predicates and the required result, not scalar calculations.\n\n| Existing example | Preserved inputs/result | Exact replacement for the affected ending |\n| --- | --- | --- |\n| **E05 — Timely cancellation** | Timely cancellation within three business days; no emergency waiver; no creditor payment; **$400 paid and $400 refund**. | “A defect-based cancellation within the extended 30-day period establishes the cancellation right, but does not by itself establish the same automatic all-money refund. Any monetary result in that separate branch must be supported by the applicable refund or civil-recovery provision and its facts, as distinguished in R2. No separate 30-day monetary example is calculated here.” **C016; S001 §550 and R2 cross-references.** [Nevada Legislature](https://www.leg.state.nv.us/NRS/NRS-676A.html) |\n| **E07 — Consumer-owned settlement account with no performance event** | **$3,000** account balance; no executed settlement; no qualifying payment; no earned fee established. | “If the TSR provision applies and the customer requests withdrawal from the debt-relief service, the customer **must receive the full $3,000 within seven business days of the request**. Merely describing the money as ‘made available’ does not replace that receipt requirement. Bank-account closure, ACH revocation, and card-access mechanics remain unresolved.” **C030; S004 §310.4(a)(5)(ii)(E).** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n\n## F. Affected coverage replacements only\n\nThese retain P04’s existing **Scope** identities; unlisted rows are unchanged.\n\n| Scope | Status | Claims | Exact missing evidence / next investigation |\n| --- | --- | --- | --- |\n| **Provider settlement-account control** | Answered prohibition; actual facts held | C020–C022 | Establish actual direct or indirect provider ownership/control, separately from administrator affiliation. Consumer ownership remains required; no affiliate safe harbor follows. |\n| **Third-party administrator independence** | Partial; state/federal distinction corrected | C020, C022–C023, C030 | Separate actual Nevada control/evasion facts from conditional federal administrator ownership, control, affiliation, and referral-compensation requirements. No actual administrator approved. |\n| **Affiliate pass-through** | Answered as no automatic loophole; no categorical Nevada affiliation ban inferred | C022–C023, C030 | Identify actual delegated powers, provider control, evasive structure, ownership, and compensation. Apply federal affiliation restriction only when its coverage predicates are met. |\n| **Timely cancellation refund** | Three-day promise answered; extended-branch monetary result conditional | C016 | Establish assent, notice, identified defect, waiver, money held, creditor payments, actual fee entitlement, and the particular refund or civil-recovery basis. Do not presume §760(5) liability from cancellation alone. |\n| **Payee-agent exemption** | Complete predicate stated; actual qualification unresolved | C025 | Establish underlying payee-supplied goods or non-transmission services, appointment, written direction, public holding-out, extinguishment on agent receipt, and no remittance-loss risk to the payor. |\n| **Federal dedicated-account conditions** | Answered conditionally; actual compliance unresolved | C030 | Retain all account conditions. Obtain actual coverage, affiliation, compensation, earning, request, and receipt evidence; do not treat Nevada compliance as federal compliance. |\n| **Federal seven-business-day return** | Answered conditionally as **customer receipt** | C030 | Establish request date, applicable business-day calculation, lawful earned amounts, and when the customer actually received the balance—not merely when a release was initiated or availability asserted. |\n| **Voluntary-contribution treatment** | Both statutory limbs answered; amount and facts held | C034 | Establish whether solicitation occurred, whose affiliate was involved, contribution timing, aggregate receipts, and the amount lawfully chargeable under §580. Current adjusted amounts remain unresolved. |\n\n**Sources for these limited coverage amendments:** R1/S001–S002/S004; R2/S001; R3/S004; R4/S003; R5/S001. [Nevada Legislature+6](https://www.leg.state.nv.us/NRS/NRS-676A.html)\n\n## G. Exact affected-entry crosswalk\n\n| Correction | Affected P04 entries | Replacement / preservation instruction |\n| --- | --- | --- |\n| **1 — State control versus federal affiliation** | Model row **“Provider-, affiliate-, or captive-processor-controlled settlement account”**; linked use of C020/C022/C023/C030; coverage rows **“Provider settlement-account control,” “Third-party administrator independence,” “Affiliate pass-through.”** | Replace the model row with **R1** and the identified coverage rows with §F. C020/C022/C023 remain unchanged; do not derive a standalone Nevada affiliation ban from them. |\n| **2 — Cancellation/refund distinction** | Cancellation discussion identified in the request as **“section3.5”**; rendered P04 §A.7’s **“Timely statutory cancellation”** trigger; **C016**; **E05 final 30-day sentence**; **“Timely cancellation refund”** coverage row. | Apply **R2**, C016 replacement, §D trigger row, E05 replacement ending, and §F coverage row. Preserve the stipulated three-business-day **$400** result. |\n| **3 — Customer must receive funds** | P04 §A.6’s seven-business-day account condition; §A.7’s **“Covered federal TSR customer withdraws from service”** trigger; **C030**; **E07 ending**; the two affected federal coverage rows. | Apply **R3**, C030 replacement, §D federal trigger, E07 replacement ending, and §F federal rows. Preserve **$3,000** and zero-earned-fee assumptions. |\n| **4 — Underlying payee transaction** | P04 §A.5 payee-agent bullet; **C025**; **“Payee-agent exemption”** coverage row. | Apply **R4**, C025’s limited amendment, and the corresponding §F row. Preserve other bounded exemption findings; do not classify an actual entity. |\n| **5 — No solicitation of contributions** | P04 §A.7 voluntary-contribution paragraph; **C034**; **“Voluntary-contribution treatment”** coverage row. | Apply **R5**, C034 replacement, and the corresponding §F row. Preserve the aggregate-cap and current-adjusted-amount qualifications. |\n\n## Researcher self-check and unchanged holds\n\nFour official HTML documents were freshly accessed for the specified passages. Complete §676A.550, §676A.590, §676A.610, current §671.020(3), and §310.4(a)(5)(i)–(ii) were read, together with the necessary selected cross-references. R050-10A is identified only as **reused P04 selected-read provenance**; no PDF was reopened or newly visually inspected. No whole chapter, complete remedy framework, citator, subsequent-law universe, or actual account/entity record was reviewed. This is **not an independent review**.\n\nAll other holds remain: account ownership/control, commingling, interest, insurance and pass-through coverage, actual custody, actor licensing, lawful fee earning, adjusted amounts, TSR entity/campaign facts, records, insolvency and lien priority, money transmission, security, remedies, courts, limitations, collection, garnishment, secured and other sectors, local/tribal and remaining parent dimensions. Original files and provenance are unchanged. No new component, state, parent, A066, operational, or publication acceptance is established.\n\n**END S_NV PASS-05**\n\n","tables":[{"headers":["P05 source-use ID / prior alias","Issuer, document, and complete literal URL","Exact passages used","Version, fresh/reused status, and limits"],"index":0,"links":[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+2"},{"href":"https://www.leg.state.nv.us/NAC/NAC-676A.html","text":"Nevada Legislature\n+1"},{"href":"https://www.leg.state.nv.us/NRS/NRS-671.html","text":"Nevada Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],"row_links":[[],[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+2"}],[{"href":"https://www.leg.state.nv.us/NAC/NAC-676A.html","text":"Nevada Legislature\n+1"}],[{"href":"https://www.leg.state.nv.us/NRS/NRS-671.html","text":"Nevada Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+1"}],[]],"rows":[["P05 source-use ID / prior alias","Issuer, document, and complete literal URL","Exact passages used","Version, fresh/reused status, and limits"],["S_NV-P5-S001 / P4-S001","Nevada Legislature, NRS Chapter 676A. https://www.leg.state.nv.us/NRS/NRS-676A.html","§§676A.150(2); .540(4), (7); complete .550(1)–(3); .570(8); complete .590 and .610; .620(2); .700(2) introductory language and (i)(1); .720; .760(5)–(6). Related §700 referral/affiliate provisions were checked without expanding their P04 claims.","Fresh selected reading. Compilation header: October 6, 2026, “2025” edition. This is not a whole-chapter, legislative-history, case-law, or later-law certification. \nNevada Legislature\n+2"],["S_NV-P5-S002 / P4-S002","Nevada Legislature, NAC Chapter 676A. https://www.leg.state.nv.us/NAC/NAC-676A.html","NAC 676A.180(4), including its R050-10 adoption notation.","Fresh selected reading. Page refresh April 13, 2026; chapter revision September 2018. Only the relevant anti-evasion provision is used; known stale registration provisions are not restored or relied upon. \nNevada Legislature\n+1"],["S_NV-P5-S003 / P4-S005","Nevada Legislature, NRS Chapter 671. https://www.leg.state.nv.us/NRS/NRS-671.html","Current §671.020 introductory qualification and complete subsection (3), including (a)–(c).","Fresh selected reading. Compilation header April 15, 2026. Used the version expressly effective through December 31, 2029, not the January 1, 2030 branch. No actual actor, license, or exemption was investigated. \nNevada Legislature"],["S_NV-P5-S004 / P4-S010","Office of the Federal Register/GPO, 16 CFR 310.4, implementing the FTC’s Telemarketing Sales Rule. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Complete §310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E), particularly (ii)(C) and (ii)(E).","Fresh selected reading. Display states Title 16 is current through October 23, 2026, last amended October 19, 2026; eCFR describes itself as authoritative but unofficial. P04’s earlier October 22 display remains its historical record. No intervening Federal Register or full-TSR audit is asserted. \neCFR\n+1"],["S_NV-P5-S005 / P4-S003","Nevada Legislature, Adopted Regulation R050-10A. https://www.leg.state.nv.us/register/2010Register/R050-10A.pdf","§8(4), printed page 4 / zero-based PDF index 3.","Supplied/reused P04 selected-read provenance only; not reopened or visually inspected in P05. P04 records the October 15, 2010 effective date. No whole-order or subsequent-rulemaking review is newly claimed. Section 6 is not needed for this patch."]]},{"headers":["Model","Who owns or controls the money?","Nevada Chapter 676A treatment","Chapter 671 / federal overlay","Status"],"index":1,"links":[],"row_links":[[],[]],"rows":[["Model","Who owns or controls the money?","Nevada Chapter 676A treatment","Chapter 671 / federal overlay","Status"],["Provider-, affiliate-, or captive-processor-controlled settlement account","Distinguish ownership of the individual’s account, ownership of the administrator entity, and actual account-control powers. The settlement account must remain individual-owned.","The provider may not, directly or indirectly, have an ownership interest in or any control of the individual’s settlement account. Using an agent, affiliate, or subsidiary to evade that prohibition is forbidden. However, an administrator’s relationship to the provider is not, by itself, a separately established categorical Nevada affiliation ban. This does not permit nonconsumer account ownership or create an affiliate safe harbor.","When the TSR dedicated-account provision applies, it separately requires an administrator that is not owned or controlled by, or affiliated in any way with, the debt-relief service. Chapter 671 status remains a separate factual inquiry.","Nevada result depends on actual ownership/control and evasion facts; federal administrator-affiliation restriction applies conditionally. C020/C022/C023/C030 retain their identities."]]},{"headers":["Existing claim ID","Replacement assertion","Source/pinpoint","Qualification"],"index":2,"links":[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+1"},{"href":"https://www.leg.state.nv.us/NRS/NRS-671.html","text":"Nevada Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature"}],"row_links":[[],[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+1"}],[{"href":"https://www.leg.state.nv.us/NRS/NRS-671.html","text":"Nevada Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature"}]],"rows":[["Existing claim ID","Replacement assertion","Source/pinpoint","Qualification"],["S_NV-P4-C016","Section 550 supplies an ordinary three-business-day cancellation right and a 30-day right for the specified agreement defects. The required notice expressly promises an all-money refund for the three-day period. Refund or recovery in the extended branch requires the separate statutory basis and facts described in R2; §760(5) is a conditional civil-recovery provision excluding creditor payments.","S001, §§550(1)–(3), 540(4), (7), 570(8), 610, 620(2), 760(5)–(6).","Textual distinction established; no automatic identical 30-day refund established. No categorical no-refund conclusion. \nNevada Legislature\n+1"],["S_NV-P4-C025","Preserve the existing conditional-exemption framework. The payee-agent branch additionally requires the underlying payment to concern goods or non-money-transmission services supplied by the payee to the payor, together with every appointment, written-agreement, public-holding-out, discharge, and no-loss condition in R4.","S003, current §671.020 opening qualification and (3)(a)–(c).","Missing predicate corrected. Other P04 exemption findings, including the bounded no-categorical-676A-exemption finding, are carried forward without a new full-list audit. No actor classified. \nNevada Legislature"],["S_NV-P4-C030","Conditional TSR dedicated-account requirements remain cumulative. They include customer ownership and accrued interest, administrator independence, and referral-compensation restrictions. Upon the customer’s service-withdrawal request, the customer must receive all account funds except amounts actually earned under §310.4(a)(5)(i)(A)–(C), within seven business days.","S004, §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E).","Receipt wording corrected. Actual TSR coverage, affiliation, earning, and receipt facts remain unresolved; bank mechanics are not supplied by this wording. \neCFR"],["S_NV-P4-C034","Section 590 separately prohibits solicitation from the individual or the individual’s affiliate and restricts aggregate acceptance through the stated post-plan period. Neither the acceptance language nor expiration of that period removes the solicitation prohibition or establishes a lawful contribution amount.","S001, complete §676A.590.","No-solicitation limb added. Existing aggregate-cap finding and adjusted-fee hold remain. \nNevada Legislature"]]},{"headers":["Existing trigger identity","Replacement money result","Timing","Necessary qualification"],"index":3,"links":[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],"row_links":[[],[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}]],"rows":[["Existing trigger identity","Replacement money result","Timing","Necessary qualification"],["Timely statutory cancellation","Preserve the required all-money-refund promise for the three-day cancellation branch. For the extended 30-day branch, distinguish the cancellation right from the separate refund and civil-recovery provisions in R2.","Ordinary cancellation: before midnight of the third business day after assent. Specified defects: within 30 days after assent. No new universal refund deadline is asserted.","Emergency-waiver rules remain. Section 760(5) requires violation of §550 rights and concerns civil recovery, with an exception for creditor payments; it is not a universal automatic-refund rule. C016. \nNevada Legislature\n+1"],["Covered federal TSR customer withdraws from service","Customer must receive all account funds except amounts earned under §310.4(a)(5)(i)(A)–(C).","Within seven business days of the customer’s request.","Conditional TSR applicability; no substitution of mere availability for receipt; no determination of bank closure or ACH/card mechanics. C030. \neCFR"]]},{"headers":["Existing example","Preserved inputs/result","Exact replacement for the affected ending"],"index":4,"links":[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],"row_links":[[],[{"href":"https://www.leg.state.nv.us/NRS/NRS-676A.html","text":"Nevada Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}]],"rows":[["Existing example","Preserved inputs/result","Exact replacement for the affected ending"],["E05 — Timely cancellation","Timely cancellation within three business days; no emergency waiver; no creditor payment; $400 paid and $400 refund.","“A defect-based cancellation within the extended 30-day period establishes the cancellation right, but does not by itself establish the same automatic all-money refund. Any monetary result in that separate branch must be supported by the applicable refund or civil-recovery provision and its facts, as distinguished in R2. No separate 30-day monetary example is calculated here.” C016; S001 §550 and R2 cross-references. \nNevada Legislature"],["E07 — Consumer-owned settlement account with no performance event","$3,000 account balance; no executed settlement; no qualifying payment; no earned fee established.","“If the TSR provision applies and the customer requests withdrawal from the debt-relief service, the customer must receive the full $3,000 within seven business days of the request. Merely describing the money as ‘made available’ does not replace that receipt requirement. Bank-account closure, ACH revocation, and card-access mechanics remain unresolved.” C030; S004 §310.4(a)(5)(ii)(E). \neCFR"]]},{"headers":["Scope","Status","Claims","Exact missing evidence / next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Scope","Status","Claims","Exact missing evidence / next investigation"],["Provider settlement-account control","Answered prohibition; actual facts held","C020–C022","Establish actual direct or indirect provider ownership/control, separately from administrator affiliation. Consumer ownership remains required; no affiliate safe harbor follows."],["Third-party administrator independence","Partial; state/federal distinction corrected","C020, C022–C023, C030","Separate actual Nevada control/evasion facts from conditional federal administrator ownership, control, affiliation, and referral-compensation requirements. No actual administrator approved."],["Affiliate pass-through","Answered as no automatic loophole; no categorical Nevada affiliation ban inferred","C022–C023, C030","Identify actual delegated powers, provider control, evasive structure, ownership, and compensation. Apply federal affiliation restriction only when its coverage predicates are met."],["Timely cancellation refund","Three-day promise answered; extended-branch monetary result conditional","C016","Establish assent, notice, identified defect, waiver, money held, creditor payments, actual fee entitlement, and the particular refund or civil-recovery basis. Do not presume §760(5) liability from cancellation alone."],["Payee-agent exemption","Complete predicate stated; actual qualification unresolved","C025","Establish underlying payee-supplied goods or non-transmission services, appointment, written direction, public holding-out, extinguishment on agent receipt, and no remittance-loss risk to the payor."],["Federal dedicated-account conditions","Answered conditionally; actual compliance unresolved","C030","Retain all account conditions. Obtain actual coverage, affiliation, compensation, earning, request, and receipt evidence; do not treat Nevada compliance as federal compliance."],["Federal seven-business-day return","Answered conditionally as customer receipt","C030","Establish request date, applicable business-day calculation, lawful earned amounts, and when the customer actually received the balance—not merely when a release was initiated or availability asserted."],["Voluntary-contribution treatment","Both statutory limbs answered; amount and facts held","C034","Establish whether solicitation occurred, whose affiliate was involved, contribution timing, aggregate receipts, and the amount lawfully chargeable under §580. Current adjusted amounts remain unresolved."]]},{"headers":["Correction","Affected P04 entries","Replacement / preservation instruction"],"index":6,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Correction","Affected P04 entries","Replacement / preservation instruction"],["1 — State control versus federal affiliation","Model row “Provider-, affiliate-, or captive-processor-controlled settlement account”; linked use of C020/C022/C023/C030; coverage rows “Provider settlement-account control,” “Third-party administrator independence,” “Affiliate pass-through.”","Replace the model row with R1 and the identified coverage rows with §F. C020/C022/C023 remain unchanged; do not derive a standalone Nevada affiliation ban from them."],["2 — Cancellation/refund distinction","Cancellation discussion identified in the request as “section3.5”; rendered P04 §A.7’s “Timely statutory cancellation” trigger; C016; E05 final 30-day sentence; “Timely cancellation refund” coverage row.","Apply R2, C016 replacement, §D trigger row, E05 replacement ending, and §F coverage row. Preserve the stipulated three-business-day $400 result."],["3 — Customer must receive funds","P04 §A.6’s seven-business-day account condition; §A.7’s “Covered federal TSR customer withdraws from service” trigger; C030; E07 ending; the two affected federal coverage rows.","Apply R3, C030 replacement, §D federal trigger, E07 replacement ending, and §F federal rows. Preserve $3,000 and zero-earned-fee assumptions."],["4 — Underlying payee transaction","P04 §A.5 payee-agent bullet; C025; “Payee-agent exemption” coverage row.","Apply R4, C025’s limited amendment, and the corresponding §F row. Preserve other bounded exemption findings; do not classify an actual entity."],["5 — No solicitation of contributions","P04 §A.7 voluntary-contribution paragraph; C034; “Voluntary-contribution treatment” coverage row.","Apply R5, C034 replacement, and the corresponding §F row. Preserve the aggregate-cap and current-adjusted-amount qualifications."]]}],"claims":[{"claim_id":"S_NV-P4-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_NV-P4-C016","Replacement assertion":"Section 550 supplies an ordinary three-business-day cancellation right and a 30-day right for the specified agreement defects. The required notice expressly promises an all-money refund for the three-day period. Refund or recovery in the extended branch requires the separate statutory basis and facts described in R2; §760(5) is a conditional civil-recovery provision excluding creditor payments.","Source/pinpoint":"S001, §§550(1)–(3), 540(4), (7), 570(8), 610, 620(2), 760(5)–(6).","Qualification":"Textual distinction established; no automatic identical 30-day refund established. No categorical no-refund conclusion. \nNevada Legislature\n+1"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_P04_claim":true,"coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P4-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_NV-P4-C025","Replacement assertion":"Preserve the existing conditional-exemption framework. The payee-agent branch additionally requires the underlying payment to concern goods or non-money-transmission services supplied by the payee to the payor, together with every appointment, written-agreement, public-holding-out, discharge, and no-loss condition in R4.","Source/pinpoint":"S003, current §671.020 opening qualification and (3)(a)–(c).","Qualification":"Missing predicate corrected. Other P04 exemption findings, including the bounded no-categorical-676A-exemption finding, are carried forward without a new full-list audit. No actor classified. \nNevada Legislature"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_P04_claim":true,"coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P4-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_NV-P4-C030","Replacement assertion":"Conditional TSR dedicated-account requirements remain cumulative. They include customer ownership and accrued interest, administrator independence, and referral-compensation restrictions. Upon the customer’s service-withdrawal request, the customer must receive all account funds except amounts actually earned under §310.4(a)(5)(i)(A)–(C), within seven business days.","Source/pinpoint":"S004, §310.4(a)(5)(i)(A)–(C), (ii)(A)–(E).","Qualification":"Receipt wording corrected. Actual TSR coverage, affiliation, earning, and receipt facts remain unresolved; bank mechanics are not supplied by this wording. \neCFR"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_P04_claim":true,"coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NV-P4-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_NV-P4-C034","Replacement assertion":"Section 590 separately prohibits solicitation from the individual or the individual’s affiliate and restricts aggregate acceptance through the stated post-plan period. Neither the acceptance language nor expiration of that period removes the solicitation prohibition or establishes a lawful contribution amount.","Source/pinpoint":"S001, complete §676A.590.","Qualification":"No-solicitation limb added. Existing aggregate-cap finding and adjusted-fee hold remain. \nNevada Legislature"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_P04_claim":true,"coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_NV-P5-S001","urls":["https://www.leg.state.nv.us/NRS/NRS-676A.html"],"researcher_record":{"P05 source-use ID / prior alias":"S_NV-P5-S001 / P4-S001","Issuer, document, and complete literal URL":"Nevada Legislature, NRS Chapter 676A. https://www.leg.state.nv.us/NRS/NRS-676A.html","Exact passages used":"§§676A.150(2); .540(4), (7); complete .550(1)–(3); .570(8); complete .590 and .610; .620(2); .700(2) introductory language and (i)(1); .720; .760(5)–(6). Related §700 referral/affiliate provisions were checked without expanding their P04 claims.","Version, fresh/reused status, and limits":"Fresh selected reading. Compilation header: October 6, 2026, “2025” edition. This is not a whole-chapter, legislative-history, case-law, or later-law certification. \nNevada Legislature\n+2"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","literal_source_alias_preserved":"S_NV-P5-S001 / P4-S001","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P5-S002","urls":["https://www.leg.state.nv.us/NAC/NAC-676A.html"],"researcher_record":{"P05 source-use ID / prior alias":"S_NV-P5-S002 / P4-S002","Issuer, document, and complete literal URL":"Nevada Legislature, NAC Chapter 676A. https://www.leg.state.nv.us/NAC/NAC-676A.html","Exact passages used":"NAC 676A.180(4), including its R050-10 adoption notation.","Version, fresh/reused status, and limits":"Fresh selected reading. Page refresh April 13, 2026; chapter revision September 2018. Only the relevant anti-evasion provision is used; known stale registration provisions are not restored or relied upon. \nNevada Legislature\n+1"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","literal_source_alias_preserved":"S_NV-P5-S002 / P4-S002","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P5-S003","urls":["https://www.leg.state.nv.us/NRS/NRS-671.html"],"researcher_record":{"P05 source-use ID / prior alias":"S_NV-P5-S003 / P4-S005","Issuer, document, and complete literal URL":"Nevada Legislature, NRS Chapter 671. https://www.leg.state.nv.us/NRS/NRS-671.html","Exact passages used":"Current §671.020 introductory qualification and complete subsection (3), including (a)–(c).","Version, fresh/reused status, and limits":"Fresh selected reading. Compilation header April 15, 2026. Used the version expressly effective through December 31, 2029, not the January 1, 2030 branch. No actual actor, license, or exemption was investigated. \nNevada Legislature"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","literal_source_alias_preserved":"S_NV-P5-S003 / P4-S005","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P5-S004","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"P05 source-use ID / prior alias":"S_NV-P5-S004 / P4-S010","Issuer, document, and complete literal URL":"Office of the Federal Register/GPO, 16 CFR 310.4, implementing the FTC’s Telemarketing Sales Rule. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact passages used":"Complete §310.4(a)(5)(i)(A)–(C) and (ii)(A)–(E), particularly (ii)(C) and (ii)(E).","Version, fresh/reused status, and limits":"Fresh selected reading. Display states Title 16 is current through October 23, 2026, last amended October 19, 2026; eCFR describes itself as authoritative but unofficial. P04’s earlier October 22 display remains its historical record. No intervening Federal Register or full-TSR audit is asserted. \neCFR\n+1"},"coordinator_verification_status":"bounded_requested_correction_checked_with_retained_holds","literal_source_alias_preserved":"S_NV-P5-S004 / P4-S010","coordinator_review":"[internal evidence reference]"},{"source_id":"S_NV-P5-S005","urls":["https://www.leg.state.nv.us/register/2010Register/R050-10A.pdf"],"researcher_record":{"P05 source-use ID / prior alias":"S_NV-P5-S005 / P4-S003","Issuer, document, and complete literal URL":"Nevada Legislature, Adopted Regulation R050-10A. https://www.leg.state.nv.us/register/2010Register/R050-10A.pdf","Exact passages used":"§8(4), printed page 4 / zero-based PDF index 3.","Version, fresh/reused status, and limits":"Supplied/reused P04 selected-read provenance only; not reopened or visually inspected in P05. P04 records the October 15, 2010 effective date. No whole-order or subsequent-rulemaking review is newly claimed. Section 6 is not needed for this patch."},"coordinator_verification_status":"explicit_dated_reuse_selected_primary_body_no_new_PDF_access","literal_source_alias_preserved":"S_NV-P5-S005 / P4-S003","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Provider settlement-account control","researcher_record":{"Scope":"Provider settlement-account control","Status":"Answered prohibition; actual facts held","Claims":"C020–C022","Exact missing evidence / next investigation":"Establish actual direct or indirect provider ownership/control, separately from administrator affiliation. Consumer ownership remains required; no affiliate safe harbor follows."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Third-party administrator independence","researcher_record":{"Scope":"Third-party administrator independence","Status":"Partial; state/federal distinction corrected","Claims":"C020, C022–C023, C030","Exact missing evidence / next investigation":"Separate actual Nevada control/evasion facts from conditional federal administrator ownership, control, affiliation, and referral-compensation requirements. No actual administrator approved."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Affiliate pass-through","researcher_record":{"Scope":"Affiliate pass-through","Status":"Answered as no automatic loophole; no categorical Nevada affiliation ban inferred","Claims":"C022–C023, C030","Exact missing evidence / next investigation":"Identify actual delegated powers, provider control, evasive structure, ownership, and compensation. Apply federal affiliation restriction only when its coverage predicates are met."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Timely cancellation refund","researcher_record":{"Scope":"Timely cancellation refund","Status":"Three-day promise answered; extended-branch monetary result conditional","Claims":"C016","Exact missing evidence / next investigation":"Establish assent, notice, identified defect, waiver, money held, creditor payments, actual fee entitlement, and the particular refund or civil-recovery basis. Do not presume §760(5) liability from cancellation alone."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Payee-agent exemption","researcher_record":{"Scope":"Payee-agent exemption","Status":"Complete predicate stated; actual qualification unresolved","Claims":"C025","Exact missing evidence / next investigation":"Establish underlying payee-supplied goods or non-transmission services, appointment, written direction, public holding-out, extinguishment on agent receipt, and no remittance-loss risk to the payor."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Federal dedicated-account conditions","researcher_record":{"Scope":"Federal dedicated-account conditions","Status":"Answered conditionally; actual compliance unresolved","Claims":"C030","Exact missing evidence / next investigation":"Retain all account conditions. Obtain actual coverage, affiliation, compensation, earning, request, and receipt evidence; do not treat Nevada compliance as federal compliance."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Federal seven-business-day return","researcher_record":{"Scope":"Federal seven-business-day return","Status":"Answered conditionally as customer receipt","Claims":"C030","Exact missing evidence / next investigation":"Establish request date, applicable business-day calculation, lawful earned amounts, and when the customer actually received the balance—not merely when a release was initiated or availability asserted."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"},{"topic":"Voluntary-contribution treatment","researcher_record":{"Scope":"Voluntary-contribution treatment","Status":"Both statutory limbs answered; amount and facts held","Claims":"C034","Exact missing evidence / next investigation":"Establish whether solicitation occurred, whose affiliate was involved, contribution timing, aggregate receipts, and the amount lawfully chargeable under §580. Current adjusted amounts remain unresolved."},"coordinator_acceptance":"bounded_requested_correction_checked_with_retained_holds","replacement_of_existing_coverage":true,"coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T18:25:38.180735+00:00","status":"scoped_review_complete_requested_repairs_addressed_with_holds","review":"[internal evidence reference]","original_pass":"pass-04","raw_originals_unchanged":true,"issue_dispositions":[{"issue":"NV4-01statecontrol/federalaffiliation","status":"ADDRESSED within requested scope","evidence":"P05R1/table1andFfirst3rows;existingC020/C022/C023retained. Providercontrol/anti-evasionnotcategoricalstateaffiliationban;noaffiliate safeharbor."},{"issue":"NV4-02extendedcancellationmoneyresult","status":"ADDRESSED with all stated holds","evidence":"P05R2/C016/trigger/E05/Fseparateright,refundandcivilrecovery;noautomaticidentical30dayrefundandnocategoricalno-refund.760(6)qualificationretained."},{"issue":"NV4-03actualTSRreceipt","status":"ADDRESSED","evidence":"P05R3/C030/trigger/E07/Ftwofederalrows requirecustomerreceipt;bankclosure/ACHheld."},{"issue":"NV4-04payeeagentpredicate","status":"ADDRESSED","evidence":"P05R4/C025/F includesunderlyingnon-transmissiontransactionandallintro/a–cpredicates;actualactorheld."},{"issue":"NV4-05contributionnonsolicitation","status":"ADDRESSED","evidence":"P05R5/C034/F includesindividualORaffiliate;capandtimetreatmentseparate,adjustedamountheld."}],"no_component_acceptance":true},"corrections":[],"resolved_corrections":[],"review_history":[]}