{"meta":{"key":"s_ny--pass-01","task":"S_NY","title":"SNY New York debt-adjustment and debt-settlement provider law","parent_title":"New York debt and debt relief law","edition":"pass-01","path":"/research/s_ny--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-23","tables":10,"claims":45,"sources":28,"review_status":"revise","review_complete":true,"sha256":"4279447b9a0dfb4ad50af0b6bf31fff9f84acdc53cb05edb9c07f839526f189d","headings":["1. Executive findings","2. Detailed statutory findings","2.1 Regulated activity and geographic reach","2.2 Attorneys, nonprofits and counseling","2.3 Licensing, bonding and operational requirements","2.4 Contracts, disclosures and cancellation","2.5 Enforcement","3. DFS licensing materials and fee findings","4. Federal Telemarketing Sales Rule overlay","CFPB withdrawal check","5. Worked examples and operational consequences","Example A — Federal TSR fee allocation","Example B — Savings-based fee","Example C — Three-business-day cancellation","Example D — Failed enrollment and disbursement","Operational evidence checklist","6. Additional regulatory and licensing findings","Consumer complaint and remediation pathway","7. Source register","8. Claim/evidence register","8. Claim/evidence register — continuation","8.1 Remaining claim rows","8.2 Evidence-integrity corrections","9. Granular coverage register","9.1 Category 1 — Every assigned seed","9. Granular coverage register — remaining rows","9.1 Category 1 — Continued","9.2 Other six parent-assignment categories","10. Most consequential publication holds","11. Next focused research questions","12. Article, tool and document opportunities","13. Worked-example verification","14. Researcher self-check"],"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_NY/pass-01","facets":{"geography":["us","us-ny"],"debt_type":[],"stage":["settlement"],"subject":["settlement-negotiation"]},"scope":"Category1 provider regulation only; all other New York categories pending","pending_corrections":0},"markdown":"<!-- Preserved original segment-01; no substantive editing -->\n\n# S_NY PASS-01 — New York debt-adjustment and debt-settlement provider law\n\nSettleADebt.com | A066 — State, local, territorial and tribal rules | Research baseline and actual check date: October 22, 2026 | Jurisdiction: New York, with separately identified federal overlays\n\nScope: Category 1 only — provider regulation, licensing, fees, contracts, client funds, enforcement and remedies. This is a reference-law investigation, not advice about an individual borrower's circumstances.\n\n## 1. Executive findings\n\nThe central legal distinction in New York is between budget planning as statutorily defined and broader commercial debt-settlement activity. The two should not automatically be treated as identical.\n\nNew York Banking Law Article 12-C regulates budget planners. Section 579 restricts licensed budget-planning activity to qualifying charitable or comparable out-of-state nonprofit entities. But whether a particular debt-negotiation model constitutes budget planning requires examining General Business Law § 455, its exceptions, and the actual service and payment arrangements—not merely the company's marketing description. NYSenate.gov+1\n\nConfirmed statutory framework\n\nBanking Law Article 12-C includes licensing, contracts, prohibited activities, examinations and enforcement provisions. Section 584-a expressly requires specified written contract terms, including a three-business-day cancellation notice. NYSenate.gov+1\n\nCritical unresolved classification\n\nA settlement provider that never receives consumer funds is not automatically exempt from all New York regulation. Equally, it is not established that every noncustodial negotiator must obtain an Article 12-C license. The statutory definition, exclusions, and judicial interpretation must control.\n\nProposed legislation is not operative law\n\nAssembly Bill A1427, proposing a Uniform Debt-Management Services Act framework, is listed in Assembly committee in the 2025–2026 session. Its proposed debt-settlement licensing requirements must not be presented as existing law. nysenate.gov\n\nThe findings below distinguish provisions actually inspected from questions requiring further primary-authority verification. No unverified fee cap, exemption or judicial holding is treated as established.\n\n## 2. Detailed statutory findings\n\n### 2.1 Regulated activity and geographic reach\n\nS_NY-P01-C001 — Definition of budget planning.\n\nUnder New York General Business Law § 455(1), the definition requires a contractual arrangement involving two elements:\n\n1. The debtor agrees to pay money, and the provider distributes that money among specified creditors under an agreed plan, supervises/co-ordinates/controls that distribution, or contracts with another entity performing those functions.\n2. The debtor agrees to provide valuable consideration for the relevant services.\n\nThe statutory language reaches beyond businesses physically holding consumer funds. It expressly includes supervision, coordination, control and contractual relationships involving distribution. NYSenate.gov\n\nS_NY-P01-C002 — New York customer reach.\n\nGBL § 455(1) expressly addresses businesses soliciting budget-planning business within New York and contracting with an individual resident in New York at the time. Physical office location is therefore not the sole criterion.\n\nThis is an affirmative statutory coverage rule, not proof that every other interstate arrangement is excluded. A business advertising nationally must evaluate its New York solicitation and contracting activity. NYSenate.gov\n\nS_NY-P01-C003 — Prohibition.\n\nGBL § 456 prohibits the business of budget planning except as authorized by Banking Law Article 12-C. GBL § 457 makes violation of § 456 a misdemeanor for each violation, including specified individuals acting for an organization. Banking Law § 579 establishes the charitable/nonprofit licensing framework. NYSenate.gov+2\n\n#### Service-model classification matrix\n\n| Service model | New York statutory analysis | Current research conclusion |\n| --- | --- | --- |\n| Nonprofit receives debtor payments and distributes them to creditors for compensation | Both § 455(1) elements ordinarily present | Budget-planning licensing framework applies, subject to actual statutory exclusions |\n| Provider directs a contracted payment administrator to distribute consumer money | § 455(1) expressly covers a contractual distribution relationship | Not exempt simply because provider does not hold funds |\n| Provider supervises or controls creditor payments but holds no funds | Distribution-control language directly relevant | Strong budget-planning coverage concern |\n| Provider only negotiates reductions; consumer independently pays creditors | Distribution element may be absent | Not conclusively classified; requires decisions and DFS interpretation |\n| Free educational counseling with no payment-distribution agreement | Both statutory elements must be examined | Potentially outside § 455(1); not a blanket exemption for all nonprofit counseling |\n| New York attorney providing budget-planning services | § 455(2), (3), (5) | Special statutory treatment, subject to express attorney operating conditions |\n\nS_NY-P01-C004 — Noncustodial settlement inference.\n\nA genuine negotiation-only arrangement, without direct or indirect distribution activity or supervision/control, is textually distinguishable from statutory budget planning. That is an interpretive inference, not a controlling judicial holding or DFS exemption ruling. The facts must include all affiliates, payment administrators, settlement instructions and contractual rights.\n\nThe distinction matters because a company cannot safely redesign its customer-funds arrangement on the assumption that simply avoiding custody eliminates New York exposure.\n\n### 2.2 Attorneys, nonprofits and counseling\n\nS_NY-P01-C005 — Attorney exclusion has conditions.\n\nGBL § 455(2) excludes a person admitted to practice law in New York from the article's definition of person. Section 455(3) addresses legal organizations whose members or principals are all admitted in New York.\n\nImportantly, § 455(5) affirmatively requires a New York attorney engaged in budget planning to negotiate directly with creditors, place client money received into the attorney's client-funds account, pay creditors from that account, and provide the service through the same legal entity used to practice law. NYSenate.gov\n\nTherefore, the statute does not establish that a nominal attorney relationship or an attorney-owned marketing company is automatically outside regulation.\n\nUnresolved issues include professional-responsibility rules, nonlawyer fee-sharing, actual lawyer supervision, attorney trust-account regulation, and federal telemarketing coverage.\n\nS_NY-P01-C006 — Licensed nonprofit treatment.\n\nGBL § 455(4) excludes specified licensed charitable corporations or comparably situated out-of-state nonprofit entities from the GBL article's defined person/entity terms. Banking Law § 579 separately provides the authority and license requirement for qualifying budget planners.\n\nThe distinction is essential: a nonprofit's organizational status does not itself constitute authorization to operate a paid budget-planning program. NYSenate.gov+1\n\nS_NY-P01-C007 — Counseling condition of licensing.\n\nBanking Law § 581(2) requires an applicant to agree to provide, directly or indirectly, budgeting, educational and/or counseling services acceptable to the superintendent. Failure to provide them can support suspension or revocation.\n\nThis does not mean all financial counseling is regulated budget planning. The service must first be evaluated under the statutory activity definition. NYSenate.gov\n\n### 2.3 Licensing, bonding and operational requirements\n\nS_NY-P01-C008 — Application and licensing.\n\nBanking Law § 580(1) requires a sworn written application identifying the applicant, officers/directors, business locations and other information required by the superintendent. Section 580(2) requires separate applications for multiple business locations. Section 581(1) requires an assessment of financial responsibility, experience, character and fitness, and provides a 90-day application determination period.\n\nThis is a regulator determination period, not permission to operate while an application is pending. NYSenate.gov+1\n\nS_NY-P01-C009 — Surety bond.\n\nBanking Law § 580(4) states a baseline bond principal of $250,000, subject to superintendent-authorized increases or decreases based on specified conditions, including financial condition, business plan, complaints and debtor funds/fees. It permits specified substitute deposits.\n\nBond/deposit proceeds have designated reimbursement purposes, including improperly distributed debtor payments and improperly charged fees. The baseline is not an invariant amount for every licensee. NYSenate.gov\n\nS_NY-P01-C010 — License restrictions and reporting.\n\nBanking Law § 582 requires posting licenses at business locations, prohibits assignment/transfer, requires notice of location changes, and calls for an independently audited financial statement within 90 days after fiscal-year close.\n\nSection 586 requires books and records sufficient for regulatory review, preservation for at least three years, and annual reporting by February 1. NYSenate.gov+1\n\nS_NY-P01-C011 — DFS administration.\n\nDFS's official Budget Planner Licensing page identifies NMLS as its application-management platform, references Superintendent's Regulations Parts 402, 404 and 300, and describes quarterly New York trust-account reporting and separate New York trust accounts. These are official administrative materials, but the underlying regulatory provisions still need full independent reading for a complete rule-by-rule compliance matrix. Department of Financial Services\n\n### 2.4 Contracts, disclosures and cancellation\n\nS_NY-P01-C012 — Required contract provisions.\n\nBanking Law § 584-a requires licensees to submit intended written contract forms to DFS and include:\n\n- All obligations being adjusted, identifying creditors.\n- Agreed total fees and treatment of estimated creditor rebates.\n- Contract commencement and termination dates.\n- Pro forma total-fee percentage relative to obligations being adjusted.\n- Cancellation and prepayment settlement terms.\n- Notice of the right to cancel through midnight of the third business day after signing.\n- Debtor payment terms.\n\nAn executed copy must be furnished immediately. The contract may subsequently be amended to add creditors and obligations. NYSenate.gov\n\nThe three-business-day provision is a required contractual cancellation notice; its operation in any individual dispute depends on signing date, applicable business-day counting and any additional regulatory requirements.\n\nS_NY-P01-C013 — Advertising, referrals and prohibited conduct.\n\nBanking Law § 584-b prohibits unauthorized representations of licensure or use of protected budget-planner terminology. Licensee advertising must not be false or deceptive and must contain specified licensee identifying information.\n\nIt also restricts debtor-fund commingling, requires timely creditor payments, prohibits purchasing debtor obligations, restricts referral compensation, prohibits coercive debt disclosures and simulated judicial communications, and imposes conflict-of-interest and identifying-information restrictions. Specific statutory exceptions include limited affiliate payment aggregation and creditor rebates. NYSenate.gov\n\nThese are obligations imposed on licensees and other specified persons by particular subsections, not automatically universal rules governing every debt negotiator.\n\n### 2.5 Enforcement\n\nS_NY-P01-C014 — Licensing discipline.\n\nBanking Law § 584 authorizes license revocation on enumerated grounds, including statutory/regulatory violations and certain dishonesty-related judgments or convictions. It authorizes temporary suspension for good cause, with notice/hearing protections for suspension or revocation, and states that surrender does not erase pre-surrender liability. NYSenate.gov\n\nS_NY-P01-C015 — Examinations and regulatory powers.\n\nBanking Law § 585 grants examination and investigative powers over licensees, including access to records and assessment of examination costs. Section 587 authorizes rules and rulings consistent with Article 12-C. NYSenate.gov+1\n\nA consumer should not assume these provisions themselves guarantee a private damages action, automatic contract rescission or a particular recovery amount. Those remedies require separate statutory and case-law analysis.\n\n## 3. DFS licensing materials and fee findings\n\nThe official DFS licensing page and application-fee schedule were opened directly. These add several operational details beyond the statutory overview.\n\nS_NY-P01-C016 — Application charges. DFS lists a $3,000 original budget-planner license application fee, $0 for an additional branch/office license, and $3,000 for a change of control. These are provider regulatory application fees, not amounts that may be charged to consumers. Banking Law § 580(3) supplies the application-fee authority. Department of Financial Services\n\nS_NY-P01-C017 — Trust-account administration. DFS states that licensed budget planners must maintain New York debtor trust accounts, with the prescribed agency-for-debtors title, and submit quarterly reports identifying relevant debtor-fund balances. DFS also describes bond/asset-pledge coverage tied to debtor funds. The exact reconciliation of the $250,000 statutory baseline, 100% coverage standard and regulatory adjustments requires reading Part 402.5 in full. Department of Financial Services\n\nS_NY-P01-C018 — Regulatory fee changes. A published version of 3 NYCRR § 402.14 states that licensees must give DFS at least 30 calendar days' written notice before implementing a changed fee structure, subject to the superintendent's review and possible disapproval or extension.\n\nThis provision was located in a secondary regulation reproduction current through June 25, 2025. Its October 2026 operative text has not been authenticated from an official New York regulatory publication. It is consequently partial evidence, not a verified current fee rule. Justia\n\nImportant fee limitation: Neither Banking Law § 584-a nor the opened DFS licensing page establishes a universal maximum consumer charge such as 15%, 20% or 25%. Those percentages must not be described as New York statutory caps. The complete Parts 402 and 404 and any controlling DFS approvals must be checked before publishing an affirmative fee-cap conclusion.\n\n## 4. Federal Telemarketing Sales Rule overlay\n\nThe federal Telemarketing Sales Rule (TSR), 16 CFR Part 310, is distinct from New York's budget-planning statute. A business may be outside one specific New York definition yet still subject to federal debt-relief telemarketing rules.\n\nS_NY-P01-C019 — Advance fees. Under 16 CFR § 310.4(a)(5)(i), where the TSR applies, a debt-relief seller or telemarketer generally cannot collect its fee for a debt until the debt has been renegotiated, settled or otherwise altered under a valid agreement, the customer has made at least one payment under that agreement, and the fee meets the prescribed proportional-allocation or savings-based calculation.\n\nThe TSR does not establish a universal 25% fee ceiling. It regulates when and how fees may be collected. 16 CFR Ch. I (1–1–18 Edition)\n\nS_NY-P01-C020 — Dedicated accounts. Section 310.4(a)(5)(ii) permits qualifying dedicated accounts subject to conditions; permission to accumulate customer funds is not permission for the provider to take advance fees. The 2010 FTC final-rule explanation confirms the distinction. ftc.gov\n\nThe current codified text and all dedicated-account conditions, including account ownership, independence, withdrawals and account fees, remain to be directly verified in this pass. The 2010 rulemaking is historical interpretive context, not a substitute for the current regulation.\n\nS_NY-P01-C021 — Federal disclosures and misrepresentations. Section 310.3 addresses pre-sale disclosures for debt-relief services, including time to results and settlement offers, and prohibits material misrepresentations about expected savings, credit consequences, collection activity and program outcomes. Applicability depends on the TSR's definitions, exemptions and the actual telemarketing activity. LII / Legal Information Institute\n\n### CFPB withdrawal check\n\nS_NY-P01-C022 — Guidance status. The CFPB's official Withdrawn Guidance register was opened on October 22, 2026. It lists Circulars 2022-05 and 2022-07 as withdrawn May 12, 2025, alongside numerous other withdrawn bulletins and interpretations. No operative claim in this report relies on those withdrawn circulars. Withdrawal of guidance does not, by itself, repeal underlying statutes or regulations. Consumer Financial Protection Bureau\n\n## 5. Worked examples and operational consequences\n\nThese are hypothetical arithmetic demonstrations, not representations of actual settlements, creditor policies or permitted New York fee caps.\n\n### Example A — Federal TSR fee allocation\n\nAssume a TSR-covered provider enrolls three debts and contractually sets a hypothetical total fee of 20% of enrolled debt, subject to all other applicable laws.\n\n| Debt | Balance at enrollment | Hypothetical allocated fee |\n| --- | --- | --- |\n| A | $8,000 | $1,600 |\n| B | $12,000 | $2,400 |\n| C | $20,000 | $4,000 |\n| Total | $40,000 | $8,000 |\n\nCalculations:\n\n- Total fee = $40,000 × 0.20 = $8,000.\n- Debt A share = $8,000 / $40,000 = 0.20.\n- Allocated fee A = $8,000 × 0.20 = $1,600.\n- Debt B fee = $8,000 × ($12,000 / $40,000) = $2,400.\n- Debt C fee = $8,000 × ($20,000 / $40,000) = $4,000.\n\nAll values are in U.S. dollars and rounded to cents. No rounding difference arises here.\n\nIf Debt A is settled but the consumer has not yet made the required first payment under the settlement, the TSR collection trigger has not been satisfied. The provider cannot simply collect $1,600 because a creditor verbally accepted an offer.\n\n### Example B — Savings-based fee\n\nAssume one enrolled debt is $10,000 and a creditor accepts $6,500 as full satisfaction. A hypothetical agreement specifies a constant 30% of savings as the provider fee.\n\n- Savings = $10,000 − $6,500 = $3,500.\n- Hypothetical fee = $3,500 × 0.30 = $1,050.\n- Combined settlement and fee outlay = $6,500 + $1,050 = $7,550.\n\nThis is an illustration of the savings-based calculation alternative, not a finding that a 30% savings fee is approved by New York or that the consumer is guaranteed $2,450 of economic benefit. Taxes, creditor interest, account charges, collection consequences and other debts are excluded.\n\n### Example C — Three-business-day cancellation\n\nAssume a licensed budget planner's consumer signs a contract on Monday, October 19, 2026, and no relevant legal holiday affects the count.\n\n- Tuesday, October 20: first following business day.\n- Wednesday, October 21: second following business day.\n- Thursday, October 22: third following business day.\n\nUnder Banking Law § 584-a(6), the contract must give notice of cancellation through midnight of October 22. The separate regulation governing notice delivery and refund treatment needs current-text confirmation before specifying the exact legally effective delivery method.\n\n### Example D — Failed enrollment and disbursement\n\nConsider a consumer who deposits $300 per month into a budget-planning arrangement for four months.\n\n- Total deposited = $300 × 4 = $1,200.\n- Amount actually paid to creditors = $500.\n- Account balance before authorized charges = $1,200 − $500 = $700.\n\nIf the consumer terminates the arrangement, $700 is an accounting starting point, not necessarily the legally determined refund. The review must reconcile permitted charges, pending payments, bank records, contract terms and applicable refund requirements.\n\nIf a provider collected fees for an unsuccessful debt-relief negotiation covered by the TSR before the statutory fee trigger, the advance-fee prohibition becomes a separate issue. If the business is a New York licensed budget planner, its trust-account and timely-disbursement duties also matter.\n\n### Operational evidence checklist\n\nFor an actual provider-compliance audit, preserve the signed agreement and all amendments, disclosure versions, sales scripts, advertisements, licensing records, creditor lists, authorization forms, communications, settlement agreements, creditor-payment confirmations, consumer-account statements, fee ledger, cancellation notices and refund records.\n\nThe presence of a third-party payment processor should trigger review of its contracts, control rights, compensation and account structure—not an assumption that the debt-relief company is noncustodial in the statutory sense.\n\n## 6. Additional regulatory and licensing findings\n\nThe following supplemental findings distinguish statutory text from unofficial reproductions of regulations.\n\nS_NY-P01-C023 — Rescission notice and fee refund. The text of 3 NYCRR § 402.10(a)–(d), opened in Cornell's regulation reproduction, specifies written notice, treats properly addressed and posted mailed notice as given upon mailing, and requires prompt return of contract-related fees following timely rescission. It excludes reasonable counseling fees imposed separately from execution of the budget-planning contract. The refund exception does not automatically validate a mislabeled or otherwise impermissible counseling charge. Current official-version authentication remains outstanding. LII / Legal Information Institute\n\nS_NY-P01-C024 — Bond regulation. The opened text of 3 NYCRR § 402.5(a)–(b) restates the adjustable $250,000 surety-bond framework and requires a larger bond to be effective within 30 days of notification. Its historical subsection (c) identifies April 7, 2003 as the effective date of the referenced 2002 statutory amendments. That historical implementation deadline is not a new 2026 deadline. LII / Legal Information Institute\n\nS_NY-P01-C025 — Management changes. Banking Law § 583 requires prompt notification of officer/director changes. Section 583-a(1)–(4) generally requires advance superintendent approval for changes of control, contains a limited operation-of-law exception, and presumes control at a specified 10% voting-stock threshold, subject to the superintendent's determination. NYSenate.gov+1\n\n### Consumer complaint and remediation pathway\n\nFor a suspected violation involving a licensed budget planner, the practical sequence is to identify the legal entity and license, obtain a full account ledger, reconcile payments and fees, request contract cancellation or refund where supported, and submit a documented complaint to DFS if unresolved.\n\nA complaint should identify the provider, agreement date, amount paid, account administrator, specific disputed charges or missed creditor payments, and the remedy requested. Preserve written delivery evidence.\n\nDFS licensing information is available at:\n\n[https://www.dfs.ny.gov/apps_and_licensing/budget_planners](https://www.dfs.ny.gov/apps_and_licensing/budget_planners?utm_source=chatgpt.com)\n\nA consumer may also use the CFPB complaint system for matters within its jurisdiction. Complaint filing is not itself a court judgment, automatic refund or suspension of a collection lawsuit.\n\nThe availability of civil claims under New York General Business Law §§ 349–350, contract law, fraud theories or other statutes depends on the precise conduct and required elements. A private remedy solely for violating Article 12-C has not been established in this pass.\n\n## 7. Source register\n\nAll rows have an actual check date of 2026-10-22. “Opened” means the page text was retrieved and inspected in this chat. It does not imply that an independent official historical archive was checked or that the text has been legally authenticated beyond the identified publisher.\n\nFor compactness, each row identifies its operative pinpoint. A webpage's most recent revision label is not automatically the law's effective date.\n\n| Source ID | Title / issuer | Direct literal HTTPS URL | Pinpoint | Version / status | Check date | Jurisdiction / scope | Access and limits |\n| --- | --- | --- | --- | --- | --- | --- | --- |\n| S_NY-P01-S001 | General Business Law § 455, NY Senate | [https://www.nysenate.gov/legislation/laws/GBS/455](https://www.nysenate.gov/legislation/laws/GBS/455?utm_source=chatgpt.com) | § 455(1)–(5) | Current displayed statute; revision 2014-09-22 | 2026-10-22 | NY definitions/exclusions | Opened full section |\n| S_NY-P01-S002 | GBL § 456, NY Senate | [https://www.nysenate.gov/legislation/laws/GBS/456](https://www.nysenate.gov/legislation/laws/GBS/456?utm_source=chatgpt.com) | § 456 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY prohibition | Opened |\n| S_NY-P01-S003 | GBL § 457, NY Senate | [https://www.nysenate.gov/legislation/laws/GBS/457](https://www.nysenate.gov/legislation/laws/GBS/457?utm_source=chatgpt.com) | § 457 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY misdemeanor | Opened |\n| S_NY-P01-S004 | Banking Law § 579, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/579](https://www.nysenate.gov/legislation/laws/BNK/579?utm_source=chatgpt.com) | § 579 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY nonprofit licensing | Retrieved source text; not separately opened |\n| S_NY-P01-S005 | Banking Law § 580, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/580](https://www.nysenate.gov/legislation/laws/BNK/580?utm_source=chatgpt.com) | § 580(1)–(4) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY applications/bonds | Opened |\n| S_NY-P01-S006 | Banking Law § 581, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/581](https://www.nysenate.gov/legislation/laws/BNK/581?utm_source=chatgpt.com) | § 581(1)–(2) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY licensing conditions | Opened |\n| S_NY-P01-S007 | Banking Law § 582, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/582](https://www.nysenate.gov/legislation/laws/BNK/582?utm_source=chatgpt.com) | § 582 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY license administration | Opened |\n| S_NY-P01-S008 | Banking Law § 583, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/583](https://www.nysenate.gov/legislation/laws/BNK/583?utm_source=chatgpt.com) | § 583 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY officer/director changes | Opened |\n| S_NY-P01-S009 | Banking Law § 583-a, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/583-A](https://www.nysenate.gov/legislation/laws/BNK/583-A?utm_source=chatgpt.com) | § 583-a(1)–(4) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY control changes | Opened |\n| S_NY-P01-S010 | Banking Law § 584, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/584](https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com) | § 584(1)–(5) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY discipline | Opened |\n| S_NY-P01-S011 | Banking Law § 584-a, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/584-A](https://www.nysenate.gov/legislation/laws/BNK/584-A?utm_source=chatgpt.com) | § 584-a(1)–(7) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY contracts | Opened |\n| S_NY-P01-S012 | Banking Law § 584-b, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/584-B](https://www.nysenate.gov/legislation/laws/BNK/584-B?utm_source=chatgpt.com) | § 584-b(1)–(13) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY prohibited conduct | Opened |\n| S_NY-P01-S013 | Banking Law § 585, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/585](https://www.nysenate.gov/legislation/laws/BNK/585?utm_source=chatgpt.com) | § 585 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY examinations | Opened |\n| S_NY-P01-S014 | Banking Law § 586, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/586](https://www.nysenate.gov/legislation/laws/BNK/586?utm_source=chatgpt.com) | § 586(1)–(2) | Current displayed; revision 2014-09-22 | 2026-10-22 | NY records/reports | Opened |\n| S_NY-P01-S015 | Banking Law § 587, NY Senate | [https://www.nysenate.gov/legislation/laws/BNK/587](https://www.nysenate.gov/legislation/laws/BNK/587?utm_source=chatgpt.com) | § 587 | Current displayed; revision 2014-09-22 | 2026-10-22 | NY rulemaking | Opened |\n| S_NY-P01-S016 | Budget Planner Licensing, DFS | [https://www.dfs.ny.gov/apps_and_licensing/budget_planners](https://www.dfs.ny.gov/apps_and_licensing/budget_planners?utm_source=chatgpt.com) | Licensing, NMLS, reporting, trust accounts | Live page; publication date unknown | 2026-10-22 | NY regulator administration | Opened; underlying regulations not all verified |\n| S_NY-P01-S017 | Application Fees, DFS | [https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule](https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule?utm_source=chatgpt.com) | Budget Planners fee table | Live schedule; effective date not stated | 2026-10-22 | NY regulatory fees | Opened |\n| S_NY-P01-S018 | 3 NYCRR § 402.10, Cornell LII | [https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10](https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10?utm_source=chatgpt.com) | (a)–(d) | Secondary reproduction; current official version unverified | 2026-10-22 | NY cancellation | Opened secondary text |\n| S_NY-P01-S019 | 3 NYCRR § 402.5, Cornell LII | [https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5](https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5?utm_source=chatgpt.com) | (a)–(c) | Secondary reproduction; historical 2003 trigger | 2026-10-22 | NY bonds | Opened secondary text |\n| S_NY-P01-S020 | 3 NYCRR § 402.14, Justia | [https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/](https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/?utm_source=chatgpt.com) | Entire section | Reproduction through June 25, 2025 | 2026-10-22 | NY fee-change procedure | Discovery result; not separately opened |\n| S_NY-P01-S021 | 3 NYCRR § 402.15, Cornell LII | [https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15](https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15?utm_source=chatgpt.com) | (a)–(b) | Secondary reproduction; official current version unverified | 2026-10-22 | NY debtor accounts | Discovery result; DFS independently describes rule |\n| S_NY-P01-S022 | FTC TSR final-rule amendments | [https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf](https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf?utm_source=chatgpt.com) | 16 CFR § 310.4(a)(5), rule explanation | 2010 final-rule historical publication | 2026-10-22 | Federal TSR | Discovery result; historical, not current codification |\n| S_NY-P01-S023 | FTC regulatory text excerpt | [https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf](https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf?utm_source=chatgpt.com) | 16 CFR § 310.4(a)(5) | Older regulatory text excerpt | 2026-10-22 | Federal fee timing | Discovery result; not current authenticated eCFR |\n| S_NY-P01-S024 | 16 CFR § 310.3, Cornell LII | [https://www.law.cornell.edu/cfr/text/16/310.3](https://www.law.cornell.edu/cfr/text/16/310.3?utm_source=chatgpt.com) | § 310.3(a)(1)(viii), (a)(2) | Current displayed secondary federal reproduction | 2026-10-22 | Federal disclosures | Discovery result; not separately opened |\n| S_NY-P01-S025 | Withdrawn Guidance, CFPB | [https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/](https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/?utm_source=chatgpt.com) | 2022 circulars; 2025 withdrawals | Live official register | 2026-10-22 | Federal guidance status | Opened |\n| S_NY-P01-S026 | Assembly Bill A1427, NY Senate | [https://www.nysenate.gov/legislation/bills/2025/A1427](https://www.nysenate.gov/legislation/bills/2025/A1427?utm_source=chatgpt.com) | Status, actions, proposed Article 12-CC | 2025–2026; in committee | 2026-10-22 | NY proposed law | Opened; not enacted |\n| S_NY-P01-S027 | 3 NYCRR Part 402 index, Cornell LII | [https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402](https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402?utm_source=chatgpt.com) | §§ 402.1–402.23 index | Secondary reproduction; not official 2026 text | 2026-10-22 | NY regulations | Discovery-only; full Part not reviewed |\n| S_NY-P01-S028 | 3 NYCRR § 402.22, Cornell LII | [https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22](https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22?utm_source=chatgpt.com) | Return of unused debtor funds | Version unknown | 2026-10-22 | NY refunds | Attempted opening failed; content unresolved |\n\nUnregistered sources: No unidentified case, regulator ruling or local ordinance is relied on as controlling authority. Direct URLs for unlocated materials are intentionally not invented.\n\n## 8. Claim/evidence register\n\nAll claims concern A066, New York, with a baseline and check date of October 22, 2026. “Partial” means the cited text supports the stated proposition but some relevant operative material or current-version verification remains outstanding.\n\n| Claim ID | Area | Precise claim | Source IDs / pinpoint | Conditions and exceptions | Evidence limits |\n| --- | --- | --- | --- | --- | --- |\n| S_NY-P01-C001 | A066 | Budget planning has contractual payment-distribution and consideration elements | S001 § 455(1) | Includes indirect distribution/control | Opened statute |\n| S_NY-P01-C002 | A066 | Solicitation plus contracting with NY resident creates express NY coverage | S001 § 455(1) | Other reach questions remain | Opened statute |\n| S_NY-P01-C003 | A066 | Unauthorized statutory budget planning prohibited; misdemeanor exposure | S002 § 456; S003 § 457; S004 § 579 | Actual definition and exemptions control | S004 source retrieved, not separately opened |\n| S_NY-P01-C004 | A066 | Pure negotiation-only services may differ from budget planning | S001 § 455(1) | No distribution, control or indirect relationship | Inference; no controlling case verified |\n| S_NY-P01-C005 | A066 | Attorney exclusions and affirmative operating conditions | S001 § 455(2), (3), (5) | NY admission, qualifying organization, client funds and direct negotiations | Professional rules not checked |\n| S_NY-P01-C006 | A066 | Qualifying nonprofit status alone does not replace required license | S001 § 455(4); S004 § 579 | Charitable/comparable out-of-state status | Opened/retrieved statute |\n| S_NY-P01-C007 | A066 | Licensed applicants must provide acceptable education/counseling | S006 § 581(2) | Direct or indirect provision | Opened |\n| S_NY-P01-C008 | A066 | Sworn application, location applications, fitness review, 90-day determination | S005 § 580(1)–(3); S006 § 581(1) | Complete filing and regulator decision | Opened |\n| S_NY-P01-C009 | A066 | $250,000 baseline adjustable surety bond or substitute security | S005 § 580(4) | Superintendent adjustments and authorized deposits | Opened |\n| S_NY-P01-C010 | A066 | License posting, audit, records and reporting requirements | S007 § 582; S014 § 586 | Licensees | Opened |\n| S_NY-P01-C011 | A066 | DFS uses NMLS and administers quarterly trust-account reporting | S016 licensing/reporting sections | Licensed budget planners | Official webpage; regulations partly unverified |\n| S_NY-P01-C012 | A066 | Seven contract disclosures and three-business-day cancellation notice | S011 § 584-a(1)–(7) | Licensed budget planners | Opened |\n| S_NY-P01-C013 | A066 | Advertising, funds, referrals, conflicts, coercion and privacy restrictions | S012 § 584-b(1)–(13) | Subsection-specific actors and exceptions | Opened |\n| S_NY-P01-C014 | A066 | Suspension/revocation and prior-liability preservation | S010 § 584(1)–(5) | Specified grounds and process | Opened |\n| S_NY-P01-C015 | A066 | Examination and rulemaking authority | S013 § 585; S015 § 587 | Statutory jurisdiction | Opened |\n| S_NY-P01-C016 | A066 | DFS application fee schedule: $3,000 original, $0 branch, $3,000 control change | S017 Budget Planners table; S005 § 580(3) | Regulator fees, not consumer charges | Opened DFS schedule |\n| S_NY-P01-C017 | A066 | DFS requires NY debtor trust accounts and reporting | S016 trust-account/reporting sections | Licensed entities handling debtor funds | Regulatory reconciliation incomplete |\n| S_NY-P01-C018 | A066 | Fee-structure change notice described as 30 calendar days | S020 § 402.14 | Superintendent review/disapproval | Secondary 2025 version; partial |\n| S_NY-P01-C019 | A066 | TSR-covered debt-relief fees require qualifying result, payment and allocation | S023 § 310.4(a)(5)(i) | TSR applicability and exemptions | Historical regulatory reproduction; current codification unverified |\n| S_NY-P01-C020 | A066 | TSR permits conditional dedicated accounts | S022 § 310.4(a)(5)(ii) | Account protections and fee triggers | Historical rule explanation |\n| S_NY-P01-C021 | A066 | TSR imposes debt-relief disclosures and prohibits material misrepresentations | S024 § 310.3(a)(1), (a)(2) | Covered telemarketing | Secondary discovery result |\n| S_NY-P01-C022 | A066 | CFPB circulars 2022-05 and 2022-07 withdrawn May 12, 2025 | S025 withdrawn register | Withdrawal does not repeal law | Opened official register |\n| S |  |  |  |  |  |\n\n\n\n<!-- Preserved original segment-02; no substantive editing -->\n\n# S_NY PASS-01 — Continuation and completion of remaining tables\n\nSettleADebt.com | A066 | New York debt-adjustment and debt-settlement provider law | Baseline: October 22, 2026 | Continuation date: October 22, 2026\n\nThis continuation begins at S_NY-P01-C023, preserving the prior source register S_NY-P01-S001 through S_NY-P01-S028 and the earlier findings.\n\nEvidence qualification: No additional primary-source retrieval was completed during this continuation. The tables below reconcile the previously rendered findings and identified sources. They do not upgrade discovery-only, secondary or inaccessible materials to verified primary evidence. In particular, the prior response's claim that certain official statutory pages were opened is carried forward as its reported access history, not independently reconfirmed here.\n\n## 8. Claim/evidence register — continuation\n\n### 8.1 Remaining claim rows\n\n| Claim ID | Assigned area | Precise claim | Source IDs and exact pinpoints | Conditions / exceptions | Jurisdiction / date | Evidence limits |\n| --- | --- | --- | --- | --- | --- | --- |\n| S_NY-P01-C023 | A066 | The reproduced 3 NYCRR § 402.10 describes cancellation notice procedures and prompt return of contract-related fees following timely rescission. | S_NY-P01-S018, § 402.10(a)–(d); S_NY-P01-S011, Banking Law § 584-a(6) | A separately imposed reasonable counseling fee may receive different treatment; the charge must actually qualify under the regulation. | NY; 2026-10-22 | Cornell reproduction reportedly opened previously. Current official regulatory text not authenticated. Partial. |\n| S_NY-P01-C024 | A066 | The reproduced 3 NYCRR § 402.5 addresses the adjustable $250,000 surety-bond framework and a 30-day response period following specified bond-increase notification. | S_NY-P01-S019, § 402.5(a)–(c); S_NY-P01-S005, Banking Law § 580(4) | Bond adjustments depend on superintendent action. The historical April 7, 2003 implementation date is not a 2026 deadline. | NY; 2026-10-22 | Statutory baseline previously examined; current official regulation not authenticated. Partial. |\n| S_NY-P01-C025 | A066 | Banking Law § 583 requires notice of officer/director changes; § 583-a regulates changes of control, including a statutory voting-stock presumption and exceptions. | S_NY-P01-S008, § 583; S_NY-P01-S009, § 583-a(1)–(4) | Advance approval generally applies to covered control changes; operation-of-law and superintendent determinations require fact-specific analysis. | NY; 2026-10-22 | Official statutory pages reportedly opened in prior pass; no separate DFS interpretive ruling verified. |\n| S_NY-P01-C026 | A066 | DFS lists a $3,000 original budget-planner application fee, $0 additional branch application fee and $3,000 change-of-control application fee. | S_NY-P01-S017, Budget Planners rows; S_NY-P01-S005, § 580(3) | These are provider application charges, not consumer service fees; the current schedule controls. | NY; 2026-10-22 | DFS schedule reportedly opened previously; no fee-schedule effective-date notice verified. |\n| S_NY-P01-C027 | A066 | DFS describes separate New York debtor trust accounts and quarterly reporting for licensed budget planners. | S_NY-P01-S016, trust-account/reporting instructions; S_NY-P01-S021, § 402.15(a)–(b) | Applies to licensed budget planners; specific titling, coverage and reporting details require official regulatory verification. | NY; 2026-10-22 | DFS page reportedly opened; § 402.15 discovery-only. Partial. |\n| S_NY-P01-C028 | A066 | A reproduced regulation describes advance DFS notification of changes to a licensed budget planner's fee structure. | S_NY-P01-S020, § 402.14 | Previously reported 30-calendar-day notice and potential regulatory disapproval; applicability and current wording unconfirmed. | NY; 2026-10-22 | 2025 secondary reproduction, discovery-only. Publication hold. |\n| S_NY-P01-C029 | A066 | The prior research did not establish a universal New York consumer debt-settlement fee cap or complete fee formula. | S_NY-P01-S011, § 584-a(2), (4); S_NY-P01-S020, § 402.14; S_NY-P01-S027, Part 402 index | Required disclosure of fees is not itself a maximum-fee authorization. | NY; 2026-10-22 | Negative evidence finding only: insufficient review to conclude no cap exists. |\n| S_NY-P01-C030 | A066 | The current disposition of unused debtor funds and failed enrollment is not fully established. | S_NY-P01-S028, § 402.22; S_NY-P01-S018, § 402.10; S_NY-P01-S012, § 584-b | Timely rescission, ordinary termination, pending creditor payments and permitted charges may differ. | NY; 2026-10-22 | § 402.22 retrieval previously failed. No verified general refund formula. Unresolved. |\n| S_NY-P01-C031 | A066 | A covered budget planner must distinguish contract cancellation rights from ordinary termination and account reconciliation. | S_NY-P01-S011, § 584-a(5)–(7); S_NY-P01-S018, § 402.10 | Three-business-day rescission is not necessarily identical to cancellation after that period. | NY; 2026-10-22 | Contract statute reportedly opened; later-termination regulatory details incomplete. Partial. |\n| S_NY-P01-C032 | A066 | A New York attorney exclusion cannot be assumed to extend to all attorney-affiliated debt-relief companies. | S_NY-P01-S001, § 455(2), (3), (5) | Admission, legal-entity structure, direct creditor negotiation and client-funds handling matter. | NY; 2026-10-22 | Statutory conditions previously examined; professional-conduct rules and controlling decisions not verified. |\n| S_NY-P01-C033 | A066 | A nonprofit entity is not automatically authorized to conduct paid budget planning merely because it has nonprofit status. | S_NY-P01-S001, § 455(4); S_NY-P01-S004, § 579; S_NY-P01-S006, § 581 | Licensing, organizational eligibility and superintendent approval remain relevant. | NY; 2026-10-22 | § 579 source text previously retrieved but not separately opened. Partial verification. |\n| S_NY-P01-C034 | A066 | A noncustodial provider's legal classification depends on distribution-related contractual powers, not only physical custody. | S_NY-P01-S001, § 455(1) | Negotiation-only services without payment control may present a different statutory question. | NY; 2026-10-22 | Textual inference, not a verified DFS ruling or controlling judicial holding. |\n| S_NY-P01-C035 | A066 | The 2010 FTC debt-relief rulemaking cannot alone establish the exact October 2026 federal dedicated-account requirements. | S_NY-P01-S022, 2010 rulemaking; S_NY-P01-S023, older regulatory excerpt | Current codified 16 CFR § 310.4(a)(5) and applicable exemptions control. | Federal; 2026-10-22 | Historical/discovery materials only; current eCFR not directly authenticated. Publication hold. |\n| S_NY-P01-C036 | A066 | New York's proposed Uniform Debt-Management Services Act framework must not be treated as enacted based on its previously reported committee status. | S_NY-P01-S026, A1427 status/actions | Later legislative action could change status; effective date requires enacted law. | NY; 2025–2026 session, checked 2026-10-22 | Official bill page reportedly opened; no later action checked in this continuation. |\n| S_NY-P01-C037 | A066 | The CFPB Withdrawn Guidance register lists Circulars 2022-05 and 2022-07 as withdrawn May 12, 2025. | S_NY-P01-S025, withdrawn-guidance register | Withdrawal does not independently repeal underlying statutes or regulations. | Federal; 2026-10-22 | Official register reportedly opened in prior pass; not reopened here. |\n| S_NY-P01-C038 | A066 | The present pass does not establish a specific private damages remedy solely for violation of Banking Law Article 12-C. | S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S003, GBL § 457 | Other statutory, contractual or common-law remedies may exist and require their own elements. | NY; 2026-10-22 | No controlling private-right-of-action decision verified. Unresolved. |\n| S_NY-P01-C039 | A066 | No verified statewide-plus-local comparison establishes whether a New York City or other local rule adds material restrictions to the bounded provider activity. | No qualifying local primary source registered | State preemption, local licensing and consumer-protection provisions must be examined separately. | NY/local; 2026-10-22 | Unresolved; no conclusion of absence. |\n| S_NY-P01-C040 | A066 | No controlling New York appellate decision or authoritative DFS interpretation resolving negotiation-only debt-settlement classification has been authenticated. | S_NY-P01-S001, § 455(1), as statutory starting point | A future verified holding may materially narrow or expand the textual inference. | NY; 2026-10-22 | Case-law research incomplete. Unresolved. |\n| S_NY-P01-C041 | A066 | The hypothetical proportional-fee example produces an $8,000 total fee allocated $1,600, $2,400 and $4,000 across three debts. | S_NY-P01-S022 and S_NY-P01-S023, federal fee-rule discovery materials | Assumes 20% contract pricing, $40,000 enrollment, no changes, and satisfaction of all federal fee-collection triggers. | Federal illustration; 2026-10-22 | Arithmetic verified below; legal applicability and current regulatory wording held. |\n| S_NY-P01-C042 | A066 | The hypothetical savings-based example produces $3,500 savings and a $1,050 fee. | S_NY-P01-S022 and S_NY-P01-S023 | Assumes a $10,000 enrolled debt, $6,500 qualifying settlement and hypothetical 30%-of-savings fee. | Federal illustration; 2026-10-22 | Arithmetic only; no NY approval or universal pricing rule established. |\n| S_NY-P01-C043 | A066 | A hypothetical $300 monthly deposit over four months, less $500 distributed, leaves $700 before charges and adjustments. | S_NY-P01-S012, § 584-b; S_NY-P01-S028, § 402.22 discovery lead | Account charges, pending transfers, disputed disbursements and contract termination terms may change the amount refundable. | NY illustration; 2026-10-22 | Arithmetic verified; refund entitlement unresolved. |\n| S_NY-P01-C044 | A066 | An October 19, 2026 Monday signing produces an illustrative third following business day of Thursday, October 22, assuming ordinary business-day counting and no applicable holiday. | S_NY-P01-S011, § 584-a(6); S_NY-P01-S018, § 402.10 | Exact delivery, holiday and rescission rules require the operative regulatory text. | NY illustration; 2026-10-22 | Calendar arithmetic verified; not a definitive notice-effectiveness ruling. |\n| S_NY-P01-C045 | A066 | DFS licensing discipline and examination powers do not, without further authority, establish an automatic individual refund or civil-damages entitlement. | S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S015, § 587 | Consumer claims may depend on distinct statutory, contractual or equitable causes of action. | NY; 2026-10-22 | Enforcement authority supported; private remedies not fully researched. |\n\n### 8.2 Evidence-integrity corrections\n\nThe claim register distinguishes supported affirmative rules, interpretive inferences, and absence of sufficient evidence.\n\nIn particular:\n\n- S_NY-P01-C029 does not establish that New York has no fee ceiling.\n- S_NY-P01-C030 does not establish that all unused funds must be refunded without deductions.\n- S_NY-P01-C034 does not establish a categorical noncustodial exemption.\n- S_NY-P01-C038 does not establish that no private remedy exists.\n- S_NY-P01-C039 and C040 do not establish that no relevant local ordinance or controlling case exists.\n\nThese distinctions are publication-critical.\n\n## 9. Granular coverage register\n\nStatus definitions: answered means the specific question has a supported substantive answer within its stated boundaries; partial means meaningful findings exist but material verification remains; unresolved means the controlling answer has not been established; excluded_with_reason identifies a deliberately excluded matter. The six remaining parent categories use the required separate status.\n\n### 9.1 Category 1 — Every assigned seed\n\n| Assigned subtopic | Status | Findings / claim IDs | Missing evidence | Exact next action |\n| --- | --- | --- | --- | --- |\n| Statutory budget-planning definition | answered | C001, C003 | No material gap for the previously examined § 455(1) text; classification applications remain separate | Reconfirm official version at publication |\n| Geographic reach and out-of-state solicitation | partial | C002, C034 | Judicial interpretation of resident, solicitation and interstate activity | Search NY decisions construing GBL § 455(1), then verify holdings |\n| Debt adjustment versus settlement | partial | C001, C004, C034, C040 | Controlling distinction for negotiation-only providers | Retrieve appellate cases and DFS rulings addressing debt negotiation without distribution |\n| DMP versus counseling | partial | C001, C007 | Complete regulatory treatment of counseling fees and service bundling | Read official 3 NYCRR Parts 402 and 404 |\n| Custodial provider classification | answered | C001, C003, C027 | Specific operational compliance details incomplete | Review payment-control documents against § 455(1) |\n| Noncustodial settlement classification | partial | C004, C034, C040 | Binding case or official interpretation | Research decisions and requestable published DFS interpretations; do not infer exemption |\n| Prohibited for-profit budget planning | partial | C003, C033 | Full § 579 licensing eligibility and case-law limits | Reopen Banking Law § 579 and verify qualifying entities |\n| Qualifying not-for-profit entities | partial | C006, C033 | Entity qualifications, tax-status documentation, foreign nonprofit requirements | Read § 579, application checklist and 3 NYCRR Part 402 |\n| New York attorney exemption | partial | C005, C032 | Professional-conduct overlays and relevant decisions | Examine Judiciary Law, 22 NYCRR Part 1200 and appellate decisions |\n| Other statutory exemptions | partial | C001, C005, C006 | Exhaustive exception-by-exception classification | Recheck every subsection of GBL § 455 and related Banking Law provisions |\n| Attorney entity, trust and direct negotiation | partial | C005, C032 | Attorney trust rules and nonlawyer-affiliate treatment | Read Rules of Professional Conduct 1.15, 5.4 and applicable provisions |\n| Licensing and registration | partial | C008, C011, C025 | Full application checklist, NMLS records, branch rules and license exceptions | Open current DFS licensing instructions and NMLS Consumer Access |\n| Bonding and substitute security | partial | C009, C017, C024 | Official § 402.5 and regulator adjustment methodology | Obtain current official NYCRR and DFS bond instructions |\n| Financial fitness and counseling conditions | partial | C007, C008 | Regulatory standards and DFS application evidence | Read official Parts 402/404 and DFS application materials |\n| Provider application charges | answered | C016, C026 | Future schedule changes | Reconfirm DFS schedule immediately before publication |\n| Consumer fee ceilings | unresolved | C012, C018, C029 | Complete operative fee provisions and regulator interpretation | Retrieve official Part 402 fee provisions and any governing orders |\n| Fee timing | partial | C019, C021, C035 | Current TSR text; New York-specific fee timing | Open current eCFR §§ 310.3–310.4 and official NYCRR |\n| Fee calculation formulas | partial | C019, C041, C042 | Full TSR calculation conditions; state restrictions | Verify current federal regulation and NY fee rules |\n| Changes in fee structure | partial | C018, C028 | Official current § 402.14 | Retrieve current NYCRR § 402.14 and confirm effective amendments |\n| Creditor acceptance and settlement effectiveness | partial | C019, C021, C035 | Current federal conditions and treatment of conditional creditor agreements | Read eCFR § 310.4(a)(5)(i) and FTC official explanations |\n| Failed creditor enrollment | unresolved | C030, C043 | Specific contractual and regulatory rights | Verify § 402.22 and termination provisions |\n| Refunds and unused funds | partial | C023, C030, C031, C043 | Current § 402.10 and § 402.22, distinctions among cancellation situations | Obtain official regulation and any DFS enforcement interpretations |\n| Written agreements | answered | C012, C031 | Regulatory model forms and amendment rules still require checking | Reconfirm § 584-a and obtain DFS-approved form requirements |\n| Disclosures and advertising | partial | C012, C013, C021 | Complete TSR and NYCRR |  |\n\n\n\n<!-- Preserved original segment-03; no substantive editing -->\n\n# S_NY PASS-01 — Final coverage and research holds\n\nSettleADebt.com | A066 | New York | Baseline: October 22, 2026 | Continuation: October 22, 2026 | GPT-6, regular Chat; no Deep Research invoked. User-selected Pro mode reported, not independently verifiable.\n\nThis completes the interrupted coverage register and remaining deliverables. All source IDs and claim IDs refer to the previously saved segments. No additional sources were opened during this continuation.\n\n## 9. Granular coverage register — remaining rows\n\n### 9.1 Category 1 — Continued\n\n| Assigned subtopic | Status | Findings / claim IDs | Missing evidence | Exact next action |\n| --- | --- | --- | --- | --- |\n| Disclosures and advertising | partial | C012, C013, C021 | Complete current TSR disclosure requirements; official 3 NYCRR advertising and disclosure provisions | Open current eCFR §§ 310.3–310.4 and official NYCRR Parts 402/404; compare mandatory statements, timing and exemptions |\n| Cancellation rights | partial | C012, C023, C031, C044 | Official § 402.10; effective notice delivery, holidays, rescission versus later termination | Retrieve official § 402.10 and verify each subsection against Banking Law § 584-a |\n| Creditor acceptance and settlement effectiveness | partial | C019, C021, C035 | Current federal settlement-agreement and first-payment fee triggers; NY-specific conditions | Open current 16 CFR § 310.4(a)(5)(i); examine conditional acceptance, rejected offers and partial payments |\n| Creditor disbursement and failed enrollment | partial | C013, C030, C043 | Timely-disbursement standards, unsuccessful enrollment consequences, failed transfers | Retrieve official §§ 402.15 and 402.22; examine DFS enforcement orders |\n| Refunds and unused funds | partial | C023, C030, C031, C043 | Official refund provisions; allowable deductions and timing after termination | Obtain official § 402.22 and § 402.10; separate rescission from ordinary termination |\n| Client money and trust accounts | partial | C005, C013, C017, C027 | Official trust-account rules, titling, reconciliation, safeguarding and administrator obligations | Read official § 402.15 and DFS quarterly reporting instructions; separately verify attorney trust rules |\n| Agency examinations and enforcement | partial | C014, C015, C045 | Enforcement regulations, monetary remedies, historical orders and current practice | Examine Banking Law §§ 584–587, applicable regulations and published DFS orders |\n| Consumer civil remedies | unresolved | C038, C045 | Private-right-of-action decisions; restitution, damages, rescission and GBL §§ 349–350 applicability | Research controlling NY appellate decisions and statutory remedial provisions |\n| Criminal remedies and penalties | partial | C003, C038 | Prosecution elements, additional penalties and relevant interpretations | Reopen GBL § 457 and search controlling decisions |\n| Contract severability and unenforceability | unresolved | C031, C038 | Whether unlawful provider terms or unlicensed activity invalidate an agreement in whole or part | Research NY contract-enforceability decisions and applicable severability doctrines |\n| Local licensing and consumer-protection overlays | unresolved | C039 | NYC and other municipal laws, local enforcement authority and preemption | Search official NYC Administrative Code, DCWP regulations and other relevant local enactments |\n| Controlling judicial interpretations | unresolved | C034, C040 | Verified decisions addressing noncustodial negotiation, attorney entities and nonprofit eligibility | Search NY Court of Appeals, Appellate Divisions and relevant federal decisions; read full opinions |\n| Official DFS interpretations | unresolved | C011, C029, C040 | Published interpretations of classification, fee ceilings and contractual payment control | Search DFS opinions, circulars, enforcement orders and archived guidance |\n| Current versus historical regulations | partial | C018, C023, C024, C028, C035 | Authenticated October 2026 official NYCRR and eCFR text | Obtain official versions and amendment histories; reconcile effective dates |\n| Proposed or future-effective legislation | partial | C036, C037 | Final legislative status, enacted amendments, delayed effective dates and guidance changes | Recheck official NY legislation, State Register and CFPB withdrawal register immediately before publication |\n| Federal TSR dedicated accounts | partial | C019, C020, C035 | Complete current account conditions, administrator independence, withdrawals and fee restrictions | Open current eCFR § 310.4(a)(5)(ii) and official FTC interpretations |\n| Provider complaints and consumer assistance | partial | C014, C015, C038, C045 | Exact complaint jurisdiction, remedies, referral channels and current forms | Verify DFS complaint procedures, NY AG consumer resources and relevant court remedies |\n\nCategory 1 conclusion: The statutory framework has meaningful support, but material questions concerning fee ceilings, noncustodial classification, refunds, local rules and judicial interpretations remain open. Category 1 is partially researched, not fully verified.\n\n### 9.2 Other six parent-assignment categories\n\n| Parent category | Status | Findings / claim IDs | Missing evidence | Exact next action |\n| --- | --- | --- | --- | --- |\n| 2. Collection conduct and licensing | not_researched_in_this_pass | None | NY collection licensing, original-creditor distinctions, validation, communications, reporting | Conduct separate category-2 primary-source investigation |\n| 3. Limitations and revival | not_researched_in_this_pass | None | Contract limitation periods, accrual, revival, choice of law and debt sales | Investigate CPLR and controlling decisions |\n| 4. Courts, judgments and arbitration | not_researched_in_this_pass | None | Service, venue, answers, defaults, proof, arbitration, judgments and liens | Research CPLR, court rules and official forms |\n| 5. Enforcement and exemptions | not_researched_in_this_pass | None | Wage/bank restraints, protected income, property exemptions and bankruptcy distinctions | Research CPLR Article 52 and applicable federal law |\n| 6. Debt-specific programs and secured debt | not_researched_in_this_pass | None | Foreclosure, repossession, rent, medical, utilities, support, government debts and taxes | Investigate each debt category separately |\n| 7. Broader remedies, protected groups and local/tribal scope | not_researched_in_this_pass | None | Identity theft, military/older-adult protections, assistance, county and tribal boundaries | Conduct separate category-7 investigation |\n\n## 10. Most consequential publication holds\n\nHold 1 — New York fee legality\n\nDo not publish a universal New York debt-settlement fee ceiling, approved percentage, or fee-collection schedule. The operative regulatory provisions have not been fully authenticated.\n\nHold 2 — Noncustodial classification\n\nDo not state that a negotiation-only provider is categorically exempt or categorically prohibited. GBL § 455's distribution-related definition must be reconciled with controlling interpretations and actual business arrangements.\n\nHold 3 — Refunds and dedicated accounts\n\nThe official current text of 3 NYCRR § 402.22 and the complete current federal dedicated-account provisions remain unverified. The failed-source result must remain visible in the evidence register.\n\nHold 4 — Attorneys, nonprofits and remedies\n\nNo blanket exemption, automatic civil remedy or contract invalidity conclusion is established. Professional-conduct rules and controlling decisions remain necessary.\n\nHold 5 — Source currency and local overlays\n\nSecondary reproductions, historical federal materials, proposed legislation and discovery-only sources must not be presented as verified operative October 2026 law. Local requirements remain unresolved.\n\n## 11. Next focused research questions\n\n1. Does a controlling New York decision or DFS interpretation address a provider that negotiates settlements but never receives, supervises or controls debtor payments?\n2. What are the complete operative consumer-fee provisions of 3 NYCRR Parts 402 and 404, and do any additional statutory restrictions apply?\n3. What refund and accounting obligations apply after timely rescission, ordinary termination, rejected creditor offers or failed payment transmission?\n4. Which attorney professional-conduct and nonlawyer-affiliation restrictions affect debt-settlement services?\n5. Does New York City impose additional material requirements, and what private remedies have New York courts recognized?\n\n## 12. Article, tool and document opportunities\n\n| Opportunity | Deliverable | Publication condition |\n| --- | --- | --- |\n| New York debt-settlement licensing guide | Provider-model decision tree distinguishing custody, control, negotiation and counseling | Controlling classification authority reviewed |\n| Debt-relief fee compliance calculator | TSR fee-trigger and allocation calculations with separate NY restrictions | Current federal and state fee texts authenticated |\n| Cancellation and refund worksheet | Dated notice checklist, funds reconciliation and disputed-fee ledger | Official cancellation/refund rules verified |\n| Attorney/nonprofit eligibility comparison | Annotated entity-structure and licensing matrix | Professional-conduct and nonprofit authorities reviewed |\n| New York compliance contract checklist | Clause-by-clause Banking Law § 584-a annotation | Regulatory overlays and DFS requirements confirmed |\n\n## 13. Worked-example verification\n\nThe earlier arithmetic remains internally consistent:\n\n- Proportional fee: $40,000 × 20% = $8,000; allocated fees $1,600 + $2,400 + $4,000 = $8,000.\n- Savings fee: $10,000 − $6,500 = $3,500; $3,500 × 30% = $1,050.\n- Deposit reconciliation: $300/month × 4 months − $500 disbursed = $700 before adjustments.\n- October 19, 2026 was a Monday; October 22 was Thursday, the third following weekday.\n\nThese are arithmetic checks, not legal fee approvals or refund determinations. Applicable rules, holiday treatment, contractual inputs and rounding conventions remain subject to coordinator review.\n\n## 14. Researcher self-check\n\n| Check | Result |\n| --- | --- |\n| Continuation begins after interrupted coverage row | Completed |\n| Existing source IDs preserved | Yes; no new source rows |\n| Existing claim IDs preserved | Yes; no new substantive claim IDs |\n| Remaining category-1 seeds represented | Yes, including severability and local overlays |\n| Six other parent categories expressly excluded from this pass | Yes |\n| Secondary, historical and inaccessible evidence distinguished | Yes |\n| New primary sources opened during this continuation | None |\n| Independent verification of prior access claims | Not performed |\n| Arithmetic checked | Yes, subject to controlling-law review |\n| Independent legal or editorial review | Not performed |\n| Publication authorized | No |\n| Local shared-library writes | None |\n\nPass disposition: The remaining rendered deliverables are complete. The substantive New York category-1 investigation remains partial with explicit publication holds. Coordinator evidence review, legal validation, and all six other parent-assignment categories remain separate and unfinished.\n\nEND S_NY PASS-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Service model","New York statutory analysis","Current research conclusion"],["Nonprofit receives debtor payments and distributes them to creditors for compensation","Both § 455(1) elements ordinarily present","Budget-planning licensing framework applies, subject to actual statutory exclusions"],["Provider directs a contracted payment administrator to distribute consumer money","§ 455(1) expressly covers a contractual distribution relationship","Not exempt simply because provider does not hold funds"],["Provider supervises or controls creditor payments but holds no funds","Distribution-control language directly relevant","Strong budget-planning coverage concern"],["Provider only negotiates reductions; consumer independently pays creditors","Distribution element may be absent","Not conclusively classified; requires decisions and DFS interpretation"],["Free educational counseling with no payment-distribution agreement","Both statutory elements must be examined","Potentially outside § 455(1); not a blanket exemption for all nonprofit counseling"],["New York attorney providing budget-planning services","§ 455(2), (3), (5)","Special statutory treatment, subject to express attorney operating conditions"]],"segment":"segment-01","original_table_index":0},{"headers":[],"index":1,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Debt","Balance at enrollment","Hypothetical allocated fee"],["A","$8,000","$1,600"],["B","$12,000","$2,400"],["C","$20,000","$4,000"],["Total","$40,000","$8,000"]],"segment":"segment-01","original_table_index":1},{"headers":[],"index":2,"links":[{"href":"https://www.nysenate.gov/legislation/laws/GBS/455?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/455"},{"href":"https://www.nysenate.gov/legislation/laws/GBS/456?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/456"},{"href":"https://www.nysenate.gov/legislation/laws/GBS/457?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/457"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/579?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/579"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/580?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/580"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/581?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/581"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/582?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/582"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/583?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/583"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/583-A?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/583-A"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/584-A?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584-A"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/584-B?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584-B"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/585?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/585"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/586?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/586"},{"href":"https://www.nysenate.gov/legislation/laws/BNK/587?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/587"},{"href":"https://www.dfs.ny.gov/apps_and_licensing/budget_planners?utm_source=chatgpt.com","text":"https://www.dfs.ny.gov/apps_and_licensing/budget_planners"},{"href":"https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule?utm_source=chatgpt.com","text":"https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule"},{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10"},{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5"},{"href":"https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/?utm_source=chatgpt.com","text":"https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/"},{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15"},{"href":"https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf?utm_source=chatgpt.com","text":"https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf"},{"href":"https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf?utm_source=chatgpt.com","text":"https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf"},{"href":"https://www.law.cornell.edu/cfr/text/16/310.3?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/cfr/text/16/310.3"},{"href":"https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/"},{"href":"https://www.nysenate.gov/legislation/bills/2025/A1427?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/bills/2025/A1427"},{"href":"https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402"},{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22"}],"row_links":[[],[{"href":"https://www.nysenate.gov/legislation/laws/GBS/455?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/455"}],[{"href":"https://www.nysenate.gov/legislation/laws/GBS/456?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/456"}],[{"href":"https://www.nysenate.gov/legislation/laws/GBS/457?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/GBS/457"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/579?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/579"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/580?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/580"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/581?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/581"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/582?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/582"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/583?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/583"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/583-A?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/583-A"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/584-A?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584-A"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/584-B?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/584-B"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/585?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/585"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/586?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/586"}],[{"href":"https://www.nysenate.gov/legislation/laws/BNK/587?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/laws/BNK/587"}],[{"href":"https://www.dfs.ny.gov/apps_and_licensing/budget_planners?utm_source=chatgpt.com","text":"https://www.dfs.ny.gov/apps_and_licensing/budget_planners"}],[{"href":"https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule?utm_source=chatgpt.com","text":"https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule"}],[{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10"}],[{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5"}],[{"href":"https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/?utm_source=chatgpt.com","text":"https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/"}],[{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf?utm_source=chatgpt.com","text":"https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf"}],[{"href":"https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf?utm_source=chatgpt.com","text":"https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf"}],[{"href":"https://www.law.cornell.edu/cfr/text/16/310.3?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/cfr/text/16/310.3"}],[{"href":"https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/"}],[{"href":"https://www.nysenate.gov/legislation/bills/2025/A1427?utm_source=chatgpt.com","text":"https://www.nysenate.gov/legislation/bills/2025/A1427"}],[{"href":"https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402"}],[{"href":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22?utm_source=chatgpt.com","text":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22"}]],"rows":[["Source ID","Title / issuer","Direct literal HTTPS URL","Pinpoint","Version / status","Check date","Jurisdiction / scope","Access and limits"],["S_NY-P01-S001","General Business Law § 455, NY Senate","https://www.nysenate.gov/legislation/laws/GBS/455","§ 455(1)–(5)","Current displayed statute; revision 2014-09-22","2026-10-22","NY definitions/exclusions","Opened full section"],["S_NY-P01-S002","GBL § 456, NY Senate","https://www.nysenate.gov/legislation/laws/GBS/456","§ 456","Current displayed; revision 2014-09-22","2026-10-22","NY prohibition","Opened"],["S_NY-P01-S003","GBL § 457, NY Senate","https://www.nysenate.gov/legislation/laws/GBS/457","§ 457","Current displayed; revision 2014-09-22","2026-10-22","NY misdemeanor","Opened"],["S_NY-P01-S004","Banking Law § 579, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/579","§ 579","Current displayed; revision 2014-09-22","2026-10-22","NY nonprofit licensing","Retrieved source text; not separately opened"],["S_NY-P01-S005","Banking Law § 580, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/580","§ 580(1)–(4)","Current displayed; revision 2014-09-22","2026-10-22","NY applications/bonds","Opened"],["S_NY-P01-S006","Banking Law § 581, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/581","§ 581(1)–(2)","Current displayed; revision 2014-09-22","2026-10-22","NY licensing conditions","Opened"],["S_NY-P01-S007","Banking Law § 582, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/582","§ 582","Current displayed; revision 2014-09-22","2026-10-22","NY license administration","Opened"],["S_NY-P01-S008","Banking Law § 583, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/583","§ 583","Current displayed; revision 2014-09-22","2026-10-22","NY officer/director changes","Opened"],["S_NY-P01-S009","Banking Law § 583-a, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/583-A","§ 583-a(1)–(4)","Current displayed; revision 2014-09-22","2026-10-22","NY control changes","Opened"],["S_NY-P01-S010","Banking Law § 584, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/584","§ 584(1)–(5)","Current displayed; revision 2014-09-22","2026-10-22","NY discipline","Opened"],["S_NY-P01-S011","Banking Law § 584-a, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/584-A","§ 584-a(1)–(7)","Current displayed; revision 2014-09-22","2026-10-22","NY contracts","Opened"],["S_NY-P01-S012","Banking Law § 584-b, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/584-B","§ 584-b(1)–(13)","Current displayed; revision 2014-09-22","2026-10-22","NY prohibited conduct","Opened"],["S_NY-P01-S013","Banking Law § 585, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/585","§ 585","Current displayed; revision 2014-09-22","2026-10-22","NY examinations","Opened"],["S_NY-P01-S014","Banking Law § 586, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/586","§ 586(1)–(2)","Current displayed; revision 2014-09-22","2026-10-22","NY records/reports","Opened"],["S_NY-P01-S015","Banking Law § 587, NY Senate","https://www.nysenate.gov/legislation/laws/BNK/587","§ 587","Current displayed; revision 2014-09-22","2026-10-22","NY rulemaking","Opened"],["S_NY-P01-S016","Budget Planner Licensing, DFS","https://www.dfs.ny.gov/apps_and_licensing/budget_planners","Licensing, NMLS, reporting, trust accounts","Live page; publication date unknown","2026-10-22","NY regulator administration","Opened; underlying regulations not all verified"],["S_NY-P01-S017","Application Fees, DFS","https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule","Budget Planners fee table","Live schedule; effective date not stated","2026-10-22","NY regulatory fees","Opened"],["S_NY-P01-S018","3 NYCRR § 402.10, Cornell LII","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10","(a)–(d)","Secondary reproduction; current official version unverified","2026-10-22","NY cancellation","Opened secondary text"],["S_NY-P01-S019","3 NYCRR § 402.5, Cornell LII","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5","(a)–(c)","Secondary reproduction; historical 2003 trigger","2026-10-22","NY bonds","Opened secondary text"],["S_NY-P01-S020","3 NYCRR § 402.14, Justia","https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/","Entire section","Reproduction through June 25, 2025","2026-10-22","NY fee-change procedure","Discovery result; not separately opened"],["S_NY-P01-S021","3 NYCRR § 402.15, Cornell LII","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15","(a)–(b)","Secondary reproduction; official current version unverified","2026-10-22","NY debtor accounts","Discovery result; DFS independently describes rule"],["S_NY-P01-S022","FTC TSR final-rule amendments","https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf","16 CFR § 310.4(a)(5), rule explanation","2010 final-rule historical publication","2026-10-22","Federal TSR","Discovery result; historical, not current codification"],["S_NY-P01-S023","FTC regulatory text excerpt","https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf","16 CFR § 310.4(a)(5)","Older regulatory text excerpt","2026-10-22","Federal fee timing","Discovery result; not current authenticated eCFR"],["S_NY-P01-S024","16 CFR § 310.3, Cornell LII","https://www.law.cornell.edu/cfr/text/16/310.3","§ 310.3(a)(1)(viii), (a)(2)","Current displayed secondary federal reproduction","2026-10-22","Federal disclosures","Discovery result; not separately opened"],["S_NY-P01-S025","Withdrawn Guidance, CFPB","https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/","2022 circulars; 2025 withdrawals","Live official register","2026-10-22","Federal guidance status","Opened"],["S_NY-P01-S026","Assembly Bill A1427, NY Senate","https://www.nysenate.gov/legislation/bills/2025/A1427","Status, actions, proposed Article 12-CC","2025–2026; in committee","2026-10-22","NY proposed law","Opened; not enacted"],["S_NY-P01-S027","3 NYCRR Part 402 index, Cornell LII","https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402","§§ 402.1–402.23 index","Secondary reproduction; not official 2026 text","2026-10-22","NY regulations","Discovery-only; full Part not reviewed"],["S_NY-P01-S028","3 NYCRR § 402.22, Cornell LII","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22","Return of unused debtor funds","Version unknown","2026-10-22","NY refunds","Attempted opening failed; content unresolved"]],"segment":"segment-01","original_table_index":2},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Area","Precise claim","Source IDs / pinpoint","Conditions and exceptions","Evidence limits"],["S_NY-P01-C001","A066","Budget planning has contractual payment-distribution and consideration elements","S001 § 455(1)","Includes indirect distribution/control","Opened statute"],["S_NY-P01-C002","A066","Solicitation plus contracting with NY resident creates express NY coverage","S001 § 455(1)","Other reach questions remain","Opened statute"],["S_NY-P01-C003","A066","Unauthorized statutory budget planning prohibited; misdemeanor exposure","S002 § 456; S003 § 457; S004 § 579","Actual definition and exemptions control","S004 source retrieved, not separately opened"],["S_NY-P01-C004","A066","Pure negotiation-only services may differ from budget planning","S001 § 455(1)","No distribution, control or indirect relationship","Inference; no controlling case verified"],["S_NY-P01-C005","A066","Attorney exclusions and affirmative operating conditions","S001 § 455(2), (3), (5)","NY admission, qualifying organization, client funds and direct negotiations","Professional rules not checked"],["S_NY-P01-C006","A066","Qualifying nonprofit status alone does not replace required license","S001 § 455(4); S004 § 579","Charitable/comparable out-of-state status","Opened/retrieved statute"],["S_NY-P01-C007","A066","Licensed applicants must provide acceptable education/counseling","S006 § 581(2)","Direct or indirect provision","Opened"],["S_NY-P01-C008","A066","Sworn application, location applications, fitness review, 90-day determination","S005 § 580(1)–(3); S006 § 581(1)","Complete filing and regulator decision","Opened"],["S_NY-P01-C009","A066","$250,000 baseline adjustable surety bond or substitute security","S005 § 580(4)","Superintendent adjustments and authorized deposits","Opened"],["S_NY-P01-C010","A066","License posting, audit, records and reporting requirements","S007 § 582; S014 § 586","Licensees","Opened"],["S_NY-P01-C011","A066","DFS uses NMLS and administers quarterly trust-account reporting","S016 licensing/reporting sections","Licensed budget planners","Official webpage; regulations partly unverified"],["S_NY-P01-C012","A066","Seven contract disclosures and three-business-day cancellation notice","S011 § 584-a(1)–(7)","Licensed budget planners","Opened"],["S_NY-P01-C013","A066","Advertising, funds, referrals, conflicts, coercion and privacy restrictions","S012 § 584-b(1)–(13)","Subsection-specific actors and exceptions","Opened"],["S_NY-P01-C014","A066","Suspension/revocation and prior-liability preservation","S010 § 584(1)–(5)","Specified grounds and process","Opened"],["S_NY-P01-C015","A066","Examination and rulemaking authority","S013 § 585; S015 § 587","Statutory jurisdiction","Opened"],["S_NY-P01-C016","A066","DFS application fee schedule: $3,000 original, $0 branch, $3,000 control change","S017 Budget Planners table; S005 § 580(3)","Regulator fees, not consumer charges","Opened DFS schedule"],["S_NY-P01-C017","A066","DFS requires NY debtor trust accounts and reporting","S016 trust-account/reporting sections","Licensed entities handling debtor funds","Regulatory reconciliation incomplete"],["S_NY-P01-C018","A066","Fee-structure change notice described as 30 calendar days","S020 § 402.14","Superintendent review/disapproval","Secondary 2025 version; partial"],["S_NY-P01-C019","A066","TSR-covered debt-relief fees require qualifying result, payment and allocation","S023 § 310.4(a)(5)(i)","TSR applicability and exemptions","Historical regulatory reproduction; current codification unverified"],["S_NY-P01-C020","A066","TSR permits conditional dedicated accounts","S022 § 310.4(a)(5)(ii)","Account protections and fee triggers","Historical rule explanation"],["S_NY-P01-C021","A066","TSR imposes debt-relief disclosures and prohibits material misrepresentations","S024 § 310.3(a)(1), (a)(2)","Covered telemarketing","Secondary discovery result"],["S_NY-P01-C022","A066","CFPB circulars 2022-05 and 2022-07 withdrawn May 12, 2025","S025 withdrawn register","Withdrawal does not repeal law","Opened official register"],["S","","","","",""]],"segment":"segment-01","original_table_index":3},{"headers":[],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Assigned area","Precise claim","Source IDs and exact pinpoints","Conditions / exceptions","Jurisdiction / date","Evidence limits"],["S_NY-P01-C023","A066","The reproduced 3 NYCRR § 402.10 describes cancellation notice procedures and prompt return of contract-related fees following timely rescission.","S_NY-P01-S018, § 402.10(a)–(d); S_NY-P01-S011, Banking Law § 584-a(6)","A separately imposed reasonable counseling fee may receive different treatment; the charge must actually qualify under the regulation.","NY; 2026-10-22","Cornell reproduction reportedly opened previously. Current official regulatory text not authenticated. Partial."],["S_NY-P01-C024","A066","The reproduced 3 NYCRR § 402.5 addresses the adjustable $250,000 surety-bond framework and a 30-day response period following specified bond-increase notification.","S_NY-P01-S019, § 402.5(a)–(c); S_NY-P01-S005, Banking Law § 580(4)","Bond adjustments depend on superintendent action. The historical April 7, 2003 implementation date is not a 2026 deadline.","NY; 2026-10-22","Statutory baseline previously examined; current official regulation not authenticated. Partial."],["S_NY-P01-C025","A066","Banking Law § 583 requires notice of officer/director changes; § 583-a regulates changes of control, including a statutory voting-stock presumption and exceptions.","S_NY-P01-S008, § 583; S_NY-P01-S009, § 583-a(1)–(4)","Advance approval generally applies to covered control changes; operation-of-law and superintendent determinations require fact-specific analysis.","NY; 2026-10-22","Official statutory pages reportedly opened in prior pass; no separate DFS interpretive ruling verified."],["S_NY-P01-C026","A066","DFS lists a $3,000 original budget-planner application fee, $0 additional branch application fee and $3,000 change-of-control application fee.","S_NY-P01-S017, Budget Planners rows; S_NY-P01-S005, § 580(3)","These are provider application charges, not consumer service fees; the current schedule controls.","NY; 2026-10-22","DFS schedule reportedly opened previously; no fee-schedule effective-date notice verified."],["S_NY-P01-C027","A066","DFS describes separate New York debtor trust accounts and quarterly reporting for licensed budget planners.","S_NY-P01-S016, trust-account/reporting instructions; S_NY-P01-S021, § 402.15(a)–(b)","Applies to licensed budget planners; specific titling, coverage and reporting details require official regulatory verification.","NY; 2026-10-22","DFS page reportedly opened; § 402.15 discovery-only. Partial."],["S_NY-P01-C028","A066","A reproduced regulation describes advance DFS notification of changes to a licensed budget planner's fee structure.","S_NY-P01-S020, § 402.14","Previously reported 30-calendar-day notice and potential regulatory disapproval; applicability and current wording unconfirmed.","NY; 2026-10-22","2025 secondary reproduction, discovery-only. Publication hold."],["S_NY-P01-C029","A066","The prior research did not establish a universal New York consumer debt-settlement fee cap or complete fee formula.","S_NY-P01-S011, § 584-a(2), (4); S_NY-P01-S020, § 402.14; S_NY-P01-S027, Part 402 index","Required disclosure of fees is not itself a maximum-fee authorization.","NY; 2026-10-22","Negative evidence finding only: insufficient review to conclude no cap exists."],["S_NY-P01-C030","A066","The current disposition of unused debtor funds and failed enrollment is not fully established.","S_NY-P01-S028, § 402.22; S_NY-P01-S018, § 402.10; S_NY-P01-S012, § 584-b","Timely rescission, ordinary termination, pending creditor payments and permitted charges may differ.","NY; 2026-10-22","§ 402.22 retrieval previously failed. No verified general refund formula. Unresolved."],["S_NY-P01-C031","A066","A covered budget planner must distinguish contract cancellation rights from ordinary termination and account reconciliation.","S_NY-P01-S011, § 584-a(5)–(7); S_NY-P01-S018, § 402.10","Three-business-day rescission is not necessarily identical to cancellation after that period.","NY; 2026-10-22","Contract statute reportedly opened; later-termination regulatory details incomplete. Partial."],["S_NY-P01-C032","A066","A New York attorney exclusion cannot be assumed to extend to all attorney-affiliated debt-relief companies.","S_NY-P01-S001, § 455(2), (3), (5)","Admission, legal-entity structure, direct creditor negotiation and client-funds handling matter.","NY; 2026-10-22","Statutory conditions previously examined; professional-conduct rules and controlling decisions not verified."],["S_NY-P01-C033","A066","A nonprofit entity is not automatically authorized to conduct paid budget planning merely because it has nonprofit status.","S_NY-P01-S001, § 455(4); S_NY-P01-S004, § 579; S_NY-P01-S006, § 581","Licensing, organizational eligibility and superintendent approval remain relevant.","NY; 2026-10-22","§ 579 source text previously retrieved but not separately opened. Partial verification."],["S_NY-P01-C034","A066","A noncustodial provider's legal classification depends on distribution-related contractual powers, not only physical custody.","S_NY-P01-S001, § 455(1)","Negotiation-only services without payment control may present a different statutory question.","NY; 2026-10-22","Textual inference, not a verified DFS ruling or controlling judicial holding."],["S_NY-P01-C035","A066","The 2010 FTC debt-relief rulemaking cannot alone establish the exact October 2026 federal dedicated-account requirements.","S_NY-P01-S022, 2010 rulemaking; S_NY-P01-S023, older regulatory excerpt","Current codified 16 CFR § 310.4(a)(5) and applicable exemptions control.","Federal; 2026-10-22","Historical/discovery materials only; current eCFR not directly authenticated. Publication hold."],["S_NY-P01-C036","A066","New York's proposed Uniform Debt-Management Services Act framework must not be treated as enacted based on its previously reported committee status.","S_NY-P01-S026, A1427 status/actions","Later legislative action could change status; effective date requires enacted law.","NY; 2025–2026 session, checked 2026-10-22","Official bill page reportedly opened; no later action checked in this continuation."],["S_NY-P01-C037","A066","The CFPB Withdrawn Guidance register lists Circulars 2022-05 and 2022-07 as withdrawn May 12, 2025.","S_NY-P01-S025, withdrawn-guidance register","Withdrawal does not independently repeal underlying statutes or regulations.","Federal; 2026-10-22","Official register reportedly opened in prior pass; not reopened here."],["S_NY-P01-C038","A066","The present pass does not establish a specific private damages remedy solely for violation of Banking Law Article 12-C.","S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S003, GBL § 457","Other statutory, contractual or common-law remedies may exist and require their own elements.","NY; 2026-10-22","No controlling private-right-of-action decision verified. Unresolved."],["S_NY-P01-C039","A066","No verified statewide-plus-local comparison establishes whether a New York City or other local rule adds material restrictions to the bounded provider activity.","No qualifying local primary source registered","State preemption, local licensing and consumer-protection provisions must be examined separately.","NY/local; 2026-10-22","Unresolved; no conclusion of absence."],["S_NY-P01-C040","A066","No controlling New York appellate decision or authoritative DFS interpretation resolving negotiation-only debt-settlement classification has been authenticated.","S_NY-P01-S001, § 455(1), as statutory starting point","A future verified holding may materially narrow or expand the textual inference.","NY; 2026-10-22","Case-law research incomplete. Unresolved."],["S_NY-P01-C041","A066","The hypothetical proportional-fee example produces an $8,000 total fee allocated $1,600, $2,400 and $4,000 across three debts.","S_NY-P01-S022 and S_NY-P01-S023, federal fee-rule discovery materials","Assumes 20% contract pricing, $40,000 enrollment, no changes, and satisfaction of all federal fee-collection triggers.","Federal illustration; 2026-10-22","Arithmetic verified below; legal applicability and current regulatory wording held."],["S_NY-P01-C042","A066","The hypothetical savings-based example produces $3,500 savings and a $1,050 fee.","S_NY-P01-S022 and S_NY-P01-S023","Assumes a $10,000 enrolled debt, $6,500 qualifying settlement and hypothetical 30%-of-savings fee.","Federal illustration; 2026-10-22","Arithmetic only; no NY approval or universal pricing rule established."],["S_NY-P01-C043","A066","A hypothetical $300 monthly deposit over four months, less $500 distributed, leaves $700 before charges and adjustments.","S_NY-P01-S012, § 584-b; S_NY-P01-S028, § 402.22 discovery lead","Account charges, pending transfers, disputed disbursements and contract termination terms may change the amount refundable.","NY illustration; 2026-10-22","Arithmetic verified; refund entitlement unresolved."],["S_NY-P01-C044","A066","An October 19, 2026 Monday signing produces an illustrative third following business day of Thursday, October 22, assuming ordinary business-day counting and no applicable holiday.","S_NY-P01-S011, § 584-a(6); S_NY-P01-S018, § 402.10","Exact delivery, holiday and rescission rules require the operative regulatory text.","NY illustration; 2026-10-22","Calendar arithmetic verified; not a definitive notice-effectiveness ruling."],["S_NY-P01-C045","A066","DFS licensing discipline and examination powers do not, without further authority, establish an automatic individual refund or civil-damages entitlement.","S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S015, § 587","Consumer claims may depend on distinct statutory, contractual or equitable causes of action.","NY; 2026-10-22","Enforcement authority supported; private remedies not fully researched."]],"segment":"segment-02","original_table_index":0},{"headers":[],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned subtopic","Status","Findings / claim IDs","Missing evidence","Exact next action"],["Statutory budget-planning definition","answered","C001, C003","No material gap for the previously examined § 455(1) text; classification applications remain separate","Reconfirm official version at publication"],["Geographic reach and out-of-state solicitation","partial","C002, C034","Judicial interpretation of resident, solicitation and interstate activity","Search NY decisions construing GBL § 455(1), then verify holdings"],["Debt adjustment versus settlement","partial","C001, C004, C034, C040","Controlling distinction for negotiation-only providers","Retrieve appellate cases and DFS rulings addressing debt negotiation without distribution"],["DMP versus counseling","partial","C001, C007","Complete regulatory treatment of counseling fees and service bundling","Read official 3 NYCRR Parts 402 and 404"],["Custodial provider classification","answered","C001, C003, C027","Specific operational compliance details incomplete","Review payment-control documents against § 455(1)"],["Noncustodial settlement classification","partial","C004, C034, C040","Binding case or official interpretation","Research decisions and requestable published DFS interpretations; do not infer exemption"],["Prohibited for-profit budget planning","partial","C003, C033","Full § 579 licensing eligibility and case-law limits","Reopen Banking Law § 579 and verify qualifying entities"],["Qualifying not-for-profit entities","partial","C006, C033","Entity qualifications, tax-status documentation, foreign nonprofit requirements","Read § 579, application checklist and 3 NYCRR Part 402"],["New York attorney exemption","partial","C005, C032","Professional-conduct overlays and relevant decisions","Examine Judiciary Law, 22 NYCRR Part 1200 and appellate decisions"],["Other statutory exemptions","partial","C001, C005, C006","Exhaustive exception-by-exception classification","Recheck every subsection of GBL § 455 and related Banking Law provisions"],["Attorney entity, trust and direct negotiation","partial","C005, C032","Attorney trust rules and nonlawyer-affiliate treatment","Read Rules of Professional Conduct 1.15, 5.4 and applicable provisions"],["Licensing and registration","partial","C008, C011, C025","Full application checklist, NMLS records, branch rules and license exceptions","Open current DFS licensing instructions and NMLS Consumer Access"],["Bonding and substitute security","partial","C009, C017, C024","Official § 402.5 and regulator adjustment methodology","Obtain current official NYCRR and DFS bond instructions"],["Financial fitness and counseling conditions","partial","C007, C008","Regulatory standards and DFS application evidence","Read official Parts 402/404 and DFS application materials"],["Provider application charges","answered","C016, C026","Future schedule changes","Reconfirm DFS schedule immediately before publication"],["Consumer fee ceilings","unresolved","C012, C018, C029","Complete operative fee provisions and regulator interpretation","Retrieve official Part 402 fee provisions and any governing orders"],["Fee timing","partial","C019, C021, C035","Current TSR text; New York-specific fee timing","Open current eCFR §§ 310.3–310.4 and official NYCRR"],["Fee calculation formulas","partial","C019, C041, C042","Full TSR calculation conditions; state restrictions","Verify current federal regulation and NY fee rules"],["Changes in fee structure","partial","C018, C028","Official current § 402.14","Retrieve current NYCRR § 402.14 and confirm effective amendments"],["Creditor acceptance and settlement effectiveness","partial","C019, C021, C035","Current federal conditions and treatment of conditional creditor agreements","Read eCFR § 310.4(a)(5)(i) and FTC official explanations"],["Failed creditor enrollment","unresolved","C030, C043","Specific contractual and regulatory rights","Verify § 402.22 and termination provisions"],["Refunds and unused funds","partial","C023, C030, C031, C043","Current § 402.10 and § 402.22, distinctions among cancellation situations","Obtain official regulation and any DFS enforcement interpretations"],["Written agreements","answered","C012, C031","Regulatory model forms and amendment rules still require checking","Reconfirm § 584-a and obtain DFS-approved form requirements"],["Disclosures and advertising","partial","C012, C013, C021","Complete TSR and NYCRR",""]],"segment":"segment-02","original_table_index":1},{"headers":[],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned subtopic","Status","Findings / claim IDs","Missing evidence","Exact next action"],["Disclosures and advertising","partial","C012, C013, C021","Complete current TSR disclosure requirements; official 3 NYCRR advertising and disclosure provisions","Open current eCFR §§ 310.3–310.4 and official NYCRR Parts 402/404; compare mandatory statements, timing and exemptions"],["Cancellation rights","partial","C012, C023, C031, C044","Official § 402.10; effective notice delivery, holidays, rescission versus later termination","Retrieve official § 402.10 and verify each subsection against Banking Law § 584-a"],["Creditor acceptance and settlement effectiveness","partial","C019, C021, C035","Current federal settlement-agreement and first-payment fee triggers; NY-specific conditions","Open current 16 CFR § 310.4(a)(5)(i); examine conditional acceptance, rejected offers and partial payments"],["Creditor disbursement and failed enrollment","partial","C013, C030, C043","Timely-disbursement standards, unsuccessful enrollment consequences, failed transfers","Retrieve official §§ 402.15 and 402.22; examine DFS enforcement orders"],["Refunds and unused funds","partial","C023, C030, C031, C043","Official refund provisions; allowable deductions and timing after termination","Obtain official § 402.22 and § 402.10; separate rescission from ordinary termination"],["Client money and trust accounts","partial","C005, C013, C017, C027","Official trust-account rules, titling, reconciliation, safeguarding and administrator obligations","Read official § 402.15 and DFS quarterly reporting instructions; separately verify attorney trust rules"],["Agency examinations and enforcement","partial","C014, C015, C045","Enforcement regulations, monetary remedies, historical orders and current practice","Examine Banking Law §§ 584–587, applicable regulations and published DFS orders"],["Consumer civil remedies","unresolved","C038, C045","Private-right-of-action decisions; restitution, damages, rescission and GBL §§ 349–350 applicability","Research controlling NY appellate decisions and statutory remedial provisions"],["Criminal remedies and penalties","partial","C003, C038","Prosecution elements, additional penalties and relevant interpretations","Reopen GBL § 457 and search controlling decisions"],["Contract severability and unenforceability","unresolved","C031, C038","Whether unlawful provider terms or unlicensed activity invalidate an agreement in whole or part","Research NY contract-enforceability decisions and applicable severability doctrines"],["Local licensing and consumer-protection overlays","unresolved","C039","NYC and other municipal laws, local enforcement authority and preemption","Search official NYC Administrative Code, DCWP regulations and other relevant local enactments"],["Controlling judicial interpretations","unresolved","C034, C040","Verified decisions addressing noncustodial negotiation, attorney entities and nonprofit eligibility","Search NY Court of Appeals, Appellate Divisions and relevant federal decisions; read full opinions"],["Official DFS interpretations","unresolved","C011, C029, C040","Published interpretations of classification, fee ceilings and contractual payment control","Search DFS opinions, circulars, enforcement orders and archived guidance"],["Current versus historical regulations","partial","C018, C023, C024, C028, C035","Authenticated October 2026 official NYCRR and eCFR text","Obtain official versions and amendment histories; reconcile effective dates"],["Proposed or future-effective legislation","partial","C036, C037","Final legislative status, enacted amendments, delayed effective dates and guidance changes","Recheck official NY legislation, State Register and CFPB withdrawal register immediately before publication"],["Federal TSR dedicated accounts","partial","C019, C020, C035","Complete current account conditions, administrator independence, withdrawals and fee restrictions","Open current eCFR § 310.4(a)(5)(ii) and official FTC interpretations"],["Provider complaints and consumer assistance","partial","C014, C015, C038, C045","Exact complaint jurisdiction, remedies, referral channels and current forms","Verify DFS complaint procedures, NY AG consumer resources and relevant court remedies"]],"segment":"segment-03","original_table_index":0},{"headers":[],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Parent category","Status","Findings / claim IDs","Missing evidence","Exact next action"],["2. Collection conduct and licensing","not_researched_in_this_pass","None","NY collection licensing, original-creditor distinctions, validation, communications, reporting","Conduct separate category-2 primary-source investigation"],["3. Limitations and revival","not_researched_in_this_pass","None","Contract limitation periods, accrual, revival, choice of law and debt sales","Investigate CPLR and controlling decisions"],["4. Courts, judgments and arbitration","not_researched_in_this_pass","None","Service, venue, answers, defaults, proof, arbitration, judgments and liens","Research CPLR, court rules and official forms"],["5. Enforcement and exemptions","not_researched_in_this_pass","None","Wage/bank restraints, protected income, property exemptions and bankruptcy distinctions","Research CPLR Article 52 and applicable federal law"],["6. Debt-specific programs and secured debt","not_researched_in_this_pass","None","Foreclosure, repossession, rent, medical, utilities, support, government debts and taxes","Investigate each debt category separately"],["7. Broader remedies, protected groups and local/tribal scope","not_researched_in_this_pass","None","Identity theft, military/older-adult protections, assistance, county and tribal boundaries","Conduct separate category-7 investigation"]],"segment":"segment-03","original_table_index":1},{"headers":[],"index":8,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Opportunity","Deliverable","Publication condition"],["New York debt-settlement licensing guide","Provider-model decision tree distinguishing custody, control, negotiation and counseling","Controlling classification authority reviewed"],["Debt-relief fee compliance calculator","TSR fee-trigger and allocation calculations with separate NY restrictions","Current federal and state fee texts authenticated"],["Cancellation and refund worksheet","Dated notice checklist, funds reconciliation and disputed-fee ledger","Official cancellation/refund rules verified"],["Attorney/nonprofit eligibility comparison","Annotated entity-structure and licensing matrix","Professional-conduct and nonprofit authorities reviewed"],["New York compliance contract checklist","Clause-by-clause Banking Law § 584-a annotation","Regulatory overlays and DFS requirements confirmed"]],"segment":"segment-03","original_table_index":2},{"headers":[],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Check","Result"],["Continuation begins after interrupted coverage row","Completed"],["Existing source IDs preserved","Yes; no new source rows"],["Existing claim IDs preserved","Yes; no new substantive claim IDs"],["Remaining category-1 seeds represented","Yes, including severability and local overlays"],["Six other parent categories expressly excluded from this pass","Yes"],["Secondary, historical and inaccessible evidence distinguished","Yes"],["New primary sources opened during this continuation","None"],["Independent verification of prior access claims","Not performed"],["Arithmetic checked","Yes, subject to controlling-law review"],["Independent legal or editorial review","Not performed"],["Publication authorized","No"],["Local shared-library writes","None"]],"segment":"segment-03","original_table_index":3}],"claims":[{"claim_id":"S_NY-P01-C001","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C001","Area":"A066","Precise claim":"Budget planning has contractual payment-distribution and consideration elements","Source IDs / pinpoint":"S001 § 455(1)","Conditions and exceptions":"Includes indirect distribution/control","Evidence limits":"Opened statute"},"coordinator_verification_status":"selected_statutory_baseline_supported_remaining_scope_held","coordinator_review":"[internal evidence reference]","coordinator_source_reference_map":{"S001":"S_NY-P01-S001"}},{"claim_id":"S_NY-P01-C002","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C002","Area":"A066","Precise claim":"Solicitation plus contracting with NY resident creates express NY coverage","Source IDs / pinpoint":"S001 § 455(1)","Conditions and exceptions":"Other reach questions remain","Evidence limits":"Opened statute"},"coordinator_verification_status":"selected_statutory_baseline_supported_remaining_scope_held","coordinator_review":"[internal evidence reference]","coordinator_source_reference_map":{"S001":"S_NY-P01-S001"}},{"claim_id":"S_NY-P01-C003","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C003","Area":"A066","Precise claim":"Unauthorized statutory budget planning prohibited; misdemeanor exposure","Source IDs / pinpoint":"S002 § 456; S003 § 457; S004 § 579","Conditions and exceptions":"Actual definition and exemptions control","Evidence limits":"S004 source retrieved, not separately opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S002":"S_NY-P01-S002","S003":"S_NY-P01-S003","S004":"S_NY-P01-S004"}},{"claim_id":"S_NY-P01-C004","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C004","Area":"A066","Precise claim":"Pure negotiation-only services may differ from budget planning","Source IDs / pinpoint":"S001 § 455(1)","Conditions and exceptions":"No distribution, control or indirect relationship","Evidence limits":"Inference; no controlling case verified"},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]","coordinator_source_reference_map":{"S001":"S_NY-P01-S001"}},{"claim_id":"S_NY-P01-C005","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C005","Area":"A066","Precise claim":"Attorney exclusions and affirmative operating conditions","Source IDs / pinpoint":"S001 § 455(2), (3), (5)","Conditions and exceptions":"NY admission, qualifying organization, client funds and direct negotiations","Evidence limits":"Professional rules not checked"},"coordinator_verification_status":"selected_statutory_baseline_supported_remaining_scope_held","coordinator_review":"[internal evidence reference]","coordinator_source_reference_map":{"S001":"S_NY-P01-S001"}},{"claim_id":"S_NY-P01-C006","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C006","Area":"A066","Precise claim":"Qualifying nonprofit status alone does not replace required license","Source IDs / pinpoint":"S001 § 455(4); S004 § 579","Conditions and exceptions":"Charitable/comparable out-of-state status","Evidence limits":"Opened/retrieved statute"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S001":"S_NY-P01-S001","S004":"S_NY-P01-S004"}},{"claim_id":"S_NY-P01-C007","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C007","Area":"A066","Precise claim":"Licensed applicants must provide acceptable education/counseling","Source IDs / pinpoint":"S006 § 581(2)","Conditions and exceptions":"Direct or indirect provision","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S006":"S_NY-P01-S006"}},{"claim_id":"S_NY-P01-C008","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C008","Area":"A066","Precise claim":"Sworn application, location applications, fitness review, 90-day determination","Source IDs / pinpoint":"S005 § 580(1)–(3); S006 § 581(1)","Conditions and exceptions":"Complete filing and regulator decision","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S005":"S_NY-P01-S005","S006":"S_NY-P01-S006"}},{"claim_id":"S_NY-P01-C009","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C009","Area":"A066","Precise claim":"$250,000 baseline adjustable surety bond or substitute security","Source IDs / pinpoint":"S005 § 580(4)","Conditions and exceptions":"Superintendent adjustments and authorized deposits","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S005":"S_NY-P01-S005"}},{"claim_id":"S_NY-P01-C010","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C010","Area":"A066","Precise claim":"License posting, audit, records and reporting requirements","Source IDs / pinpoint":"S007 § 582; S014 § 586","Conditions and exceptions":"Licensees","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S007":"S_NY-P01-S007","S014":"S_NY-P01-S014"}},{"claim_id":"S_NY-P01-C011","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C011","Area":"A066","Precise claim":"DFS uses NMLS and administers quarterly trust-account reporting","Source IDs / pinpoint":"S016 licensing/reporting sections","Conditions and exceptions":"Licensed budget planners","Evidence limits":"Official webpage; regulations partly unverified"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S016":"S_NY-P01-S016"}},{"claim_id":"S_NY-P01-C012","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C012","Area":"A066","Precise claim":"Seven contract disclosures and three-business-day cancellation notice","Source IDs / pinpoint":"S011 § 584-a(1)–(7)","Conditions and exceptions":"Licensed budget planners","Evidence limits":"Opened"},"coordinator_verification_status":"selected_statutory_baseline_supported_remaining_scope_held","coordinator_review":"[internal evidence reference]","coordinator_source_reference_map":{"S011":"S_NY-P01-S011"}},{"claim_id":"S_NY-P01-C013","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C013","Area":"A066","Precise claim":"Advertising, funds, referrals, conflicts, coercion and privacy restrictions","Source IDs / pinpoint":"S012 § 584-b(1)–(13)","Conditions and exceptions":"Subsection-specific actors and exceptions","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S012":"S_NY-P01-S012"}},{"claim_id":"S_NY-P01-C014","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C014","Area":"A066","Precise claim":"Suspension/revocation and prior-liability preservation","Source IDs / pinpoint":"S010 § 584(1)–(5)","Conditions and exceptions":"Specified grounds and process","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S010":"S_NY-P01-S010"}},{"claim_id":"S_NY-P01-C015","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C015","Area":"A066","Precise claim":"Examination and rulemaking authority","Source IDs / pinpoint":"S013 § 585; S015 § 587","Conditions and exceptions":"Statutory jurisdiction","Evidence limits":"Opened"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S013":"S_NY-P01-S013","S015":"S_NY-P01-S015"}},{"claim_id":"S_NY-P01-C016","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C016","Area":"A066","Precise claim":"DFS application fee schedule: $3,000 original, $0 branch, $3,000 control change","Source IDs / pinpoint":"S017 Budget Planners table; S005 § 580(3)","Conditions and exceptions":"Regulator fees, not consumer charges","Evidence limits":"Opened DFS schedule"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S017":"S_NY-P01-S017","S005":"S_NY-P01-S005"}},{"claim_id":"S_NY-P01-C017","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C017","Area":"A066","Precise claim":"DFS requires NY debtor trust accounts and reporting","Source IDs / pinpoint":"S016 trust-account/reporting sections","Conditions and exceptions":"Licensed entities handling debtor funds","Evidence limits":"Regulatory reconciliation incomplete"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S016":"S_NY-P01-S016"}},{"claim_id":"S_NY-P01-C018","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C018","Area":"A066","Precise claim":"Fee-structure change notice described as 30 calendar days","Source IDs / pinpoint":"S020 § 402.14","Conditions and exceptions":"Superintendent review/disapproval","Evidence limits":"Secondary 2025 version; partial"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S020":"S_NY-P01-S020"}},{"claim_id":"S_NY-P01-C019","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C019","Area":"A066","Precise claim":"TSR-covered debt-relief fees require qualifying result, payment and allocation","Source IDs / pinpoint":"S023 § 310.4(a)(5)(i)","Conditions and exceptions":"TSR applicability and exemptions","Evidence limits":"Historical regulatory reproduction; current codification unverified"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S023":"S_NY-P01-S023"}},{"claim_id":"S_NY-P01-C020","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C020","Area":"A066","Precise claim":"TSR permits conditional dedicated accounts","Source IDs / pinpoint":"S022 § 310.4(a)(5)(ii)","Conditions and exceptions":"Account protections and fee triggers","Evidence limits":"Historical rule explanation"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S022":"S_NY-P01-S022"}},{"claim_id":"S_NY-P01-C021","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C021","Area":"A066","Precise claim":"TSR imposes debt-relief disclosures and prohibits material misrepresentations","Source IDs / pinpoint":"S024 § 310.3(a)(1), (a)(2)","Conditions and exceptions":"Covered telemarketing","Evidence limits":"Secondary discovery result"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S024":"S_NY-P01-S024"}},{"claim_id":"S_NY-P01-C022","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C022","Area":"A066","Precise claim":"CFPB circulars 2022-05 and 2022-07 withdrawn May 12, 2025","Source IDs / pinpoint":"S025 withdrawn register","Conditions and exceptions":"Withdrawal does not repeal law","Evidence limits":"Opened official register"},"coordinator_verification_status":"not_yet_checked","coordinator_source_reference_map":{"S025":"S_NY-P01-S025"}},{"claim_id":"S_NY-P01-C023","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C023","Assigned area":"A066","Precise claim":"The reproduced 3 NYCRR § 402.10 describes cancellation notice procedures and prompt return of contract-related fees following timely rescission.","Source IDs and exact pinpoints":"S_NY-P01-S018, § 402.10(a)–(d); S_NY-P01-S011, Banking Law § 584-a(6)","Conditions / exceptions":"A separately imposed reasonable counseling fee may receive different treatment; the charge must actually qualify under the regulation.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Cornell reproduction reportedly opened previously. Current official regulatory text not authenticated. Partial."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C024","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C024","Assigned area":"A066","Precise claim":"The reproduced 3 NYCRR § 402.5 addresses the adjustable $250,000 surety-bond framework and a 30-day response period following specified bond-increase notification.","Source IDs and exact pinpoints":"S_NY-P01-S019, § 402.5(a)–(c); S_NY-P01-S005, Banking Law § 580(4)","Conditions / exceptions":"Bond adjustments depend on superintendent action. The historical April 7, 2003 implementation date is not a 2026 deadline.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Statutory baseline previously examined; current official regulation not authenticated. Partial."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C025","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C025","Assigned area":"A066","Precise claim":"Banking Law § 583 requires notice of officer/director changes; § 583-a regulates changes of control, including a statutory voting-stock presumption and exceptions.","Source IDs and exact pinpoints":"S_NY-P01-S008, § 583; S_NY-P01-S009, § 583-a(1)–(4)","Conditions / exceptions":"Advance approval generally applies to covered control changes; operation-of-law and superintendent determinations require fact-specific analysis.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Official statutory pages reportedly opened in prior pass; no separate DFS interpretive ruling verified."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C026","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C026","Assigned area":"A066","Precise claim":"DFS lists a $3,000 original budget-planner application fee, $0 additional branch application fee and $3,000 change-of-control application fee.","Source IDs and exact pinpoints":"S_NY-P01-S017, Budget Planners rows; S_NY-P01-S005, § 580(3)","Conditions / exceptions":"These are provider application charges, not consumer service fees; the current schedule controls.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"DFS schedule reportedly opened previously; no fee-schedule effective-date notice verified."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C027","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C027","Assigned area":"A066","Precise claim":"DFS describes separate New York debtor trust accounts and quarterly reporting for licensed budget planners.","Source IDs and exact pinpoints":"S_NY-P01-S016, trust-account/reporting instructions; S_NY-P01-S021, § 402.15(a)–(b)","Conditions / exceptions":"Applies to licensed budget planners; specific titling, coverage and reporting details require official regulatory verification.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"DFS page reportedly opened; § 402.15 discovery-only. Partial."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C028","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C028","Assigned area":"A066","Precise claim":"A reproduced regulation describes advance DFS notification of changes to a licensed budget planner's fee structure.","Source IDs and exact pinpoints":"S_NY-P01-S020, § 402.14","Conditions / exceptions":"Previously reported 30-calendar-day notice and potential regulatory disapproval; applicability and current wording unconfirmed.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"2025 secondary reproduction, discovery-only. Publication hold."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C029","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C029","Assigned area":"A066","Precise claim":"The prior research did not establish a universal New York consumer debt-settlement fee cap or complete fee formula.","Source IDs and exact pinpoints":"S_NY-P01-S011, § 584-a(2), (4); S_NY-P01-S020, § 402.14; S_NY-P01-S027, Part 402 index","Conditions / exceptions":"Required disclosure of fees is not itself a maximum-fee authorization.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Negative evidence finding only: insufficient review to conclude no cap exists."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C030","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C030","Assigned area":"A066","Precise claim":"The current disposition of unused debtor funds and failed enrollment is not fully established.","Source IDs and exact pinpoints":"S_NY-P01-S028, § 402.22; S_NY-P01-S018, § 402.10; S_NY-P01-S012, § 584-b","Conditions / exceptions":"Timely rescission, ordinary termination, pending creditor payments and permitted charges may differ.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"§ 402.22 retrieval previously failed. No verified general refund formula. Unresolved."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C031","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C031","Assigned area":"A066","Precise claim":"A covered budget planner must distinguish contract cancellation rights from ordinary termination and account reconciliation.","Source IDs and exact pinpoints":"S_NY-P01-S011, § 584-a(5)–(7); S_NY-P01-S018, § 402.10","Conditions / exceptions":"Three-business-day rescission is not necessarily identical to cancellation after that period.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Contract statute reportedly opened; later-termination regulatory details incomplete. Partial."},"coordinator_verification_status":"selected_statutory_baseline_supported_remaining_scope_held","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C032","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C032","Assigned area":"A066","Precise claim":"A New York attorney exclusion cannot be assumed to extend to all attorney-affiliated debt-relief companies.","Source IDs and exact pinpoints":"S_NY-P01-S001, § 455(2), (3), (5)","Conditions / exceptions":"Admission, legal-entity structure, direct creditor negotiation and client-funds handling matter.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Statutory conditions previously examined; professional-conduct rules and controlling decisions not verified."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C033","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C033","Assigned area":"A066","Precise claim":"A nonprofit entity is not automatically authorized to conduct paid budget planning merely because it has nonprofit status.","Source IDs and exact pinpoints":"S_NY-P01-S001, § 455(4); S_NY-P01-S004, § 579; S_NY-P01-S006, § 581","Conditions / exceptions":"Licensing, organizational eligibility and superintendent approval remain relevant.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"§ 579 source text previously retrieved but not separately opened. Partial verification."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C034","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C034","Assigned area":"A066","Precise claim":"A noncustodial provider's legal classification depends on distribution-related contractual powers, not only physical custody.","Source IDs and exact pinpoints":"S_NY-P01-S001, § 455(1)","Conditions / exceptions":"Negotiation-only services without payment control may present a different statutory question.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Textual inference, not a verified DFS ruling or controlling judicial holding."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C035","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C035","Assigned area":"A066","Precise claim":"The 2010 FTC debt-relief rulemaking cannot alone establish the exact October 2026 federal dedicated-account requirements.","Source IDs and exact pinpoints":"S_NY-P01-S022, 2010 rulemaking; S_NY-P01-S023, older regulatory excerpt","Conditions / exceptions":"Current codified 16 CFR § 310.4(a)(5) and applicable exemptions control.","Jurisdiction / date":"Federal; 2026-10-22","Evidence limits":"Historical/discovery materials only; current eCFR not directly authenticated. Publication hold."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C036","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C036","Assigned area":"A066","Precise claim":"New York's proposed Uniform Debt-Management Services Act framework must not be treated as enacted based on its previously reported committee status.","Source IDs and exact pinpoints":"S_NY-P01-S026, A1427 status/actions","Conditions / exceptions":"Later legislative action could change status; effective date requires enacted law.","Jurisdiction / date":"NY; 2025–2026 session, checked 2026-10-22","Evidence limits":"Official bill page reportedly opened; no later action checked in this continuation."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C037","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C037","Assigned area":"A066","Precise claim":"The CFPB Withdrawn Guidance register lists Circulars 2022-05 and 2022-07 as withdrawn May 12, 2025.","Source IDs and exact pinpoints":"S_NY-P01-S025, withdrawn-guidance register","Conditions / exceptions":"Withdrawal does not independently repeal underlying statutes or regulations.","Jurisdiction / date":"Federal; 2026-10-22","Evidence limits":"Official register reportedly opened in prior pass; not reopened here."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_NY-P01-C038","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C038","Assigned area":"A066","Precise claim":"The present pass does not establish a specific private damages remedy solely for violation of Banking Law Article 12-C.","Source IDs and exact pinpoints":"S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S003, GBL § 457","Conditions / exceptions":"Other statutory, contractual or common-law remedies may exist and require their own elements.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"No controlling private-right-of-action decision verified. Unresolved."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C039","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C039","Assigned area":"A066","Precise claim":"No verified statewide-plus-local comparison establishes whether a New York City or other local rule adds material restrictions to the bounded provider activity.","Source IDs and exact pinpoints":"No qualifying local primary source registered","Conditions / exceptions":"State preemption, local licensing and consumer-protection provisions must be examined separately.","Jurisdiction / date":"NY/local; 2026-10-22","Evidence limits":"Unresolved; no conclusion of absence."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C040","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C040","Assigned area":"A066","Precise claim":"No controlling New York appellate decision or authoritative DFS interpretation resolving negotiation-only debt-settlement classification has been authenticated.","Source IDs and exact pinpoints":"S_NY-P01-S001, § 455(1), as statutory starting point","Conditions / exceptions":"A future verified holding may materially narrow or expand the textual inference.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Case-law research incomplete. Unresolved."},"coordinator_verification_status":"held_for_missing_current_authority_or_bounded_inference","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C041","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C041","Assigned area":"A066","Precise claim":"The hypothetical proportional-fee example produces an $8,000 total fee allocated $1,600, $2,400 and $4,000 across three debts.","Source IDs and exact pinpoints":"S_NY-P01-S022 and S_NY-P01-S023, federal fee-rule discovery materials","Conditions / exceptions":"Assumes 20% contract pricing, $40,000 enrollment, no changes, and satisfaction of all federal fee-collection triggers.","Jurisdiction / date":"Federal illustration; 2026-10-22","Evidence limits":"Arithmetic verified below; legal applicability and current regulatory wording held."},"coordinator_verification_status":"arithmetic_or_calendar_only_legal_inputs_held_for_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C042","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C042","Assigned area":"A066","Precise claim":"The hypothetical savings-based example produces $3,500 savings and a $1,050 fee.","Source IDs and exact pinpoints":"S_NY-P01-S022 and S_NY-P01-S023","Conditions / exceptions":"Assumes a $10,000 enrolled debt, $6,500 qualifying settlement and hypothetical 30%-of-savings fee.","Jurisdiction / date":"Federal illustration; 2026-10-22","Evidence limits":"Arithmetic only; no NY approval or universal pricing rule established."},"coordinator_verification_status":"arithmetic_or_calendar_only_legal_inputs_held_for_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C043","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C043","Assigned area":"A066","Precise claim":"A hypothetical $300 monthly deposit over four months, less $500 distributed, leaves $700 before charges and adjustments.","Source IDs and exact pinpoints":"S_NY-P01-S012, § 584-b; S_NY-P01-S028, § 402.22 discovery lead","Conditions / exceptions":"Account charges, pending transfers, disputed disbursements and contract termination terms may change the amount refundable.","Jurisdiction / date":"NY illustration; 2026-10-22","Evidence limits":"Arithmetic verified; refund entitlement unresolved."},"coordinator_verification_status":"arithmetic_or_calendar_only_legal_inputs_held_for_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C044","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C044","Assigned area":"A066","Precise claim":"An October 19, 2026 Monday signing produces an illustrative third following business day of Thursday, October 22, assuming ordinary business-day counting and no applicable holiday.","Source IDs and exact pinpoints":"S_NY-P01-S011, § 584-a(6); S_NY-P01-S018, § 402.10","Conditions / exceptions":"Exact delivery, holiday and rescission rules require the operative regulatory text.","Jurisdiction / date":"NY illustration; 2026-10-22","Evidence limits":"Calendar arithmetic verified; not a definitive notice-effectiveness ruling."},"coordinator_verification_status":"arithmetic_or_calendar_only_legal_inputs_held_for_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_NY-P01-C045","area_numbers":[66],"area_assignment_method":"explicit_report_labels","researcher_record":{"Claim ID":"S_NY-P01-C045","Assigned area":"A066","Precise claim":"DFS licensing discipline and examination powers do not, without further authority, establish an automatic individual refund or civil-damages entitlement.","Source IDs and exact pinpoints":"S_NY-P01-S010, § 584; S_NY-P01-S013, § 585; S_NY-P01-S015, § 587","Conditions / exceptions":"Consumer claims may depend on distinct statutory, contractual or equitable causes of action.","Jurisdiction / date":"NY; 2026-10-22","Evidence limits":"Enforcement authority supported; private remedies not fully researched."},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"S_NY-P01-S001","urls":["https://www.nysenate.gov/legislation/laws/GBS/455","https://www.nysenate.gov/legislation/laws/GBS/455?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S001","Title / issuer":"General Business Law § 455, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/GBS/455","Pinpoint":"§ 455(1)–(5)","Version / status":"Current displayed statute; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY definitions/exclusions","Access and limits":"Opened full section"},"coordinator_verification_status":"selected_operative_passage_checked_scope_limited","coordinator_review":{"at":"2026-10-23T00:05:25.833547+00:00","record":"[internal evidence reference]","pinpoint":"455(1)-(5)","limits":"Payment distribution/control and contractual relationships plus consideration matter; solicitation and resident contracting supply an express reach rule; attorney exclusions coexist with affirmative paragraph5 operating duties. No categorical noncustodial exemption or complete professional-rules analysis established."}},{"source_id":"S_NY-P01-S002","urls":["https://www.nysenate.gov/legislation/laws/GBS/456","https://www.nysenate.gov/legislation/laws/GBS/456?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S002","Title / issuer":"GBL § 456, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/GBS/456","Pinpoint":"§ 456","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY prohibition","Access and limits":"Opened"},"coordinator_verification_status":"selected_operative_passage_checked_scope_limited","coordinator_review":{"at":"2026-10-23T00:05:25.833547+00:00","record":"[internal evidence reference]","pinpoint":"456","limits":"Prohibition is tied to the statutory definition and article12-C authorization; this selected section alone does not complete licensing/exemption analysis or prove a private damages remedy."}},{"source_id":"S_NY-P01-S003","urls":["https://www.nysenate.gov/legislation/laws/GBS/457","https://www.nysenate.gov/legislation/laws/GBS/457?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S003","Title / issuer":"GBL § 457, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/GBS/457","Pinpoint":"§ 457","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY misdemeanor","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S004","urls":["https://www.nysenate.gov/legislation/laws/BNK/579","https://www.nysenate.gov/legislation/laws/BNK/579?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S004","Title / issuer":"Banking Law § 579, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/579","Pinpoint":"§ 579","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY nonprofit licensing","Access and limits":"Retrieved source text; not separately opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S005","urls":["https://www.nysenate.gov/legislation/laws/BNK/580","https://www.nysenate.gov/legislation/laws/BNK/580?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S005","Title / issuer":"Banking Law § 580, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/580","Pinpoint":"§ 580(1)–(4)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY applications/bonds","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S006","urls":["https://www.nysenate.gov/legislation/laws/BNK/581","https://www.nysenate.gov/legislation/laws/BNK/581?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S006","Title / issuer":"Banking Law § 581, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/581","Pinpoint":"§ 581(1)–(2)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY licensing conditions","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S007","urls":["https://www.nysenate.gov/legislation/laws/BNK/582","https://www.nysenate.gov/legislation/laws/BNK/582?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S007","Title / issuer":"Banking Law § 582, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/582","Pinpoint":"§ 582","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY license administration","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S008","urls":["https://www.nysenate.gov/legislation/laws/BNK/583","https://www.nysenate.gov/legislation/laws/BNK/583?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S008","Title / issuer":"Banking Law § 583, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/583","Pinpoint":"§ 583","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY officer/director changes","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S009","urls":["https://www.nysenate.gov/legislation/laws/BNK/583-A","https://www.nysenate.gov/legislation/laws/BNK/583-A?utm_source=chatgpt.com","https://www.nysenate.gov/legislation/laws/BNK/583?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S009","Title / issuer":"Banking Law § 583-a, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/583-A","Pinpoint":"§ 583-a(1)–(4)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY control changes","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S010","urls":["https://www.nysenate.gov/legislation/laws/BNK/584","https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S010","Title / issuer":"Banking Law § 584, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/584","Pinpoint":"§ 584(1)–(5)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY discipline","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S011","urls":["https://www.nysenate.gov/legislation/laws/BNK/584-A","https://www.nysenate.gov/legislation/laws/BNK/584-A?utm_source=chatgpt.com","https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S011","Title / issuer":"Banking Law § 584-a, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/584-A","Pinpoint":"§ 584-a(1)–(7)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY contracts","Access and limits":"Opened"},"coordinator_verification_status":"selected_operative_passage_checked_scope_limited","coordinator_review":{"at":"2026-10-23T00:05:25.833547+00:00","record":"[internal evidence reference]","pinpoint":"584-a(1)-(7), concluding sentences","limits":"Seven minimum contract provisions, third-business-day cancellation notice, immediate executed copy and permitted subsequent creditor/obligation amendments. No universal numeric consumer fee cap is specified in this section; this does not establish absence of a cap elsewhere. Notice delivery/holiday rules remain held."}},{"source_id":"S_NY-P01-S012","urls":["https://www.nysenate.gov/legislation/laws/BNK/584-B","https://www.nysenate.gov/legislation/laws/BNK/584-B?utm_source=chatgpt.com","https://www.nysenate.gov/legislation/laws/BNK/584?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S012","Title / issuer":"Banking Law § 584-b, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/584-B","Pinpoint":"§ 584-b(1)–(13)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY prohibited conduct","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S013","urls":["https://www.nysenate.gov/legislation/laws/BNK/585","https://www.nysenate.gov/legislation/laws/BNK/585?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S013","Title / issuer":"Banking Law § 585, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/585","Pinpoint":"§ 585","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY examinations","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S014","urls":["https://www.nysenate.gov/legislation/laws/BNK/586","https://www.nysenate.gov/legislation/laws/BNK/586?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S014","Title / issuer":"Banking Law § 586, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/586","Pinpoint":"§ 586(1)–(2)","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY records/reports","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S015","urls":["https://www.nysenate.gov/legislation/laws/BNK/587","https://www.nysenate.gov/legislation/laws/BNK/587?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S015","Title / issuer":"Banking Law § 587, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/laws/BNK/587","Pinpoint":"§ 587","Version / status":"Current displayed; revision 2014-09-22","Check date":"2026-10-22","Jurisdiction / scope":"NY rulemaking","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S016","urls":["https://www.dfs.ny.gov/apps_and_licensing/budget_planners","https://www.dfs.ny.gov/apps_and_licensing/budget_planners?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S016","Title / issuer":"Budget Planner Licensing, DFS","Direct literal HTTPS URL":"https://www.dfs.ny.gov/apps_and_licensing/budget_planners","Pinpoint":"Licensing, NMLS, reporting, trust accounts","Version / status":"Live page; publication date unknown","Check date":"2026-10-22","Jurisdiction / scope":"NY regulator administration","Access and limits":"Opened; underlying regulations not all verified"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S017","urls":["https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule","https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S017","Title / issuer":"Application Fees, DFS","Direct literal HTTPS URL":"https://www.dfs.ny.gov/apps_and_licensing/application_fee_schedule","Pinpoint":"Budget Planners fee table","Version / status":"Live schedule; effective date not stated","Check date":"2026-10-22","Jurisdiction / scope":"NY regulatory fees","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S018","urls":["https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S018","Title / issuer":"3 NYCRR § 402.10, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.10","Pinpoint":"(a)–(d)","Version / status":"Secondary reproduction; current official version unverified","Check date":"2026-10-22","Jurisdiction / scope":"NY cancellation","Access and limits":"Opened secondary text"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S019","urls":["https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S019","Title / issuer":"3 NYCRR § 402.5, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.5","Pinpoint":"(a)–(c)","Version / status":"Secondary reproduction; historical 2003 trigger","Check date":"2026-10-22","Jurisdiction / scope":"NY bonds","Access and limits":"Opened secondary text"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S020","urls":["https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/","https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S020","Title / issuer":"3 NYCRR § 402.14, Justia","Direct literal HTTPS URL":"https://regulations.justia.com/states/new-york/title-3/chapter-iii/subchapter-b/part-402/section-402-14/","Pinpoint":"Entire section","Version / status":"Reproduction through June 25, 2025","Check date":"2026-10-22","Jurisdiction / scope":"NY fee-change procedure","Access and limits":"Discovery result; not separately opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S021","urls":["https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S021","Title / issuer":"3 NYCRR § 402.15, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.15","Pinpoint":"(a)–(b)","Version / status":"Secondary reproduction; official current version unverified","Check date":"2026-10-22","Jurisdiction / scope":"NY debtor accounts","Access and limits":"Discovery result; DFS independently describes rule"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S022","urls":["https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf","https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S022","Title / issuer":"FTC TSR final-rule amendments","Direct literal HTTPS URL":"https://www.ftc.gov/sites/default/files/documents/federal_register_notices/telemarketing-sales-rule-final-rule-amendments/100810tsr.pdf","Pinpoint":"16 CFR § 310.4(a)(5), rule explanation","Version / status":"2010 final-rule historical publication","Check date":"2026-10-22","Jurisdiction / scope":"Federal TSR","Access and limits":"Discovery result; historical, not current codification"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S023","urls":["https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf","https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S023","Title / issuer":"FTC regulatory text excerpt","Direct literal HTTPS URL":"https://www.ftc.gov/system/files/attachments/coronavirus-warning-letters/warning_letter_to_j2_3-27-20.pdf","Pinpoint":"16 CFR § 310.4(a)(5)","Version / status":"Older regulatory text excerpt","Check date":"2026-10-22","Jurisdiction / scope":"Federal fee timing","Access and limits":"Discovery result; not current authenticated eCFR"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S024","urls":["https://www.law.cornell.edu/cfr/text/16/310.3","https://www.law.cornell.edu/cfr/text/16/310.3?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S024","Title / issuer":"16 CFR § 310.3, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/cfr/text/16/310.3","Pinpoint":"§ 310.3(a)(1)(viii), (a)(2)","Version / status":"Current displayed secondary federal reproduction","Check date":"2026-10-22","Jurisdiction / scope":"Federal disclosures","Access and limits":"Discovery result; not separately opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S025","urls":["https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/","https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S025","Title / issuer":"Withdrawn Guidance, CFPB","Direct literal HTTPS URL":"https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/","Pinpoint":"2022 circulars; 2025 withdrawals","Version / status":"Live official register","Check date":"2026-10-22","Jurisdiction / scope":"Federal guidance status","Access and limits":"Opened"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S026","urls":["https://www.nysenate.gov/legislation/bills/2025/A1427","https://www.nysenate.gov/legislation/bills/2025/A1427?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S026","Title / issuer":"Assembly Bill A1427, NY Senate","Direct literal HTTPS URL":"https://www.nysenate.gov/legislation/bills/2025/A1427","Pinpoint":"Status, actions, proposed Article 12-CC","Version / status":"2025–2026; in committee","Check date":"2026-10-22","Jurisdiction / scope":"NY proposed law","Access and limits":"Opened; not enacted"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S027","urls":["https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402","https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S027","Title / issuer":"3 NYCRR Part 402 index, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/regulations/new-york/title-3/chapter-III/subchapter-B/part-402","Pinpoint":"§§ 402.1–402.23 index","Version / status":"Secondary reproduction; not official 2026 text","Check date":"2026-10-22","Jurisdiction / scope":"NY regulations","Access and limits":"Discovery-only; full Part not reviewed"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_NY-P01-S028","urls":["https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22","https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_NY-P01-S028","Title / issuer":"3 NYCRR § 402.22, Cornell LII","Direct literal HTTPS URL":"https://www.law.cornell.edu/regulations/new-york/3-NYCRR-402.22","Pinpoint":"Return of unused debtor funds","Version / status":"Version unknown","Check date":"2026-10-22","Jurisdiction / scope":"NY refunds","Access and limits":"Attempted opening failed; content unresolved"},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"Statutory budget-planning definition","researcher_record":{"Assigned subtopic":"Statutory budget-planning definition","Status":"answered","Findings / claim IDs":"C001, C003","Missing evidence":"No material gap for the previously examined § 455(1) text; classification applications remain separate","Exact next action":"Reconfirm official version at publication"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Geographic reach and out-of-state solicitation","researcher_record":{"Assigned subtopic":"Geographic reach and out-of-state solicitation","Status":"partial","Findings / claim IDs":"C002, C034","Missing evidence":"Judicial interpretation of resident, solicitation and interstate activity","Exact next action":"Search NY decisions construing GBL § 455(1), then verify holdings"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Debt adjustment versus settlement","researcher_record":{"Assigned subtopic":"Debt adjustment versus settlement","Status":"partial","Findings / claim IDs":"C001, C004, C034, C040","Missing evidence":"Controlling distinction for negotiation-only providers","Exact next action":"Retrieve appellate cases and DFS rulings addressing debt negotiation without distribution"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"DMP versus counseling","researcher_record":{"Assigned subtopic":"DMP versus counseling","Status":"partial","Findings / claim IDs":"C001, C007","Missing evidence":"Complete regulatory treatment of counseling fees and service bundling","Exact next action":"Read official 3 NYCRR Parts 402 and 404"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial provider classification","researcher_record":{"Assigned subtopic":"Custodial provider classification","Status":"answered","Findings / claim IDs":"C001, C003, C027","Missing evidence":"Specific operational compliance details incomplete","Exact next action":"Review payment-control documents against § 455(1)"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial settlement classification","researcher_record":{"Assigned subtopic":"Noncustodial settlement classification","Status":"partial","Findings / claim IDs":"C004, C034, C040","Missing evidence":"Binding case or official interpretation","Exact next action":"Research decisions and requestable published DFS interpretations; do not infer exemption"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Prohibited for-profit budget planning","researcher_record":{"Assigned subtopic":"Prohibited for-profit budget planning","Status":"partial","Findings / claim IDs":"C003, C033","Missing evidence":"Full § 579 licensing eligibility and case-law limits","Exact next action":"Reopen Banking Law § 579 and verify qualifying entities"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Qualifying not-for-profit entities","researcher_record":{"Assigned subtopic":"Qualifying not-for-profit entities","Status":"partial","Findings / claim IDs":"C006, C033","Missing evidence":"Entity qualifications, tax-status documentation, foreign nonprofit requirements","Exact next action":"Read § 579, application checklist and 3 NYCRR Part 402"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"New York attorney exemption","researcher_record":{"Assigned subtopic":"New York attorney exemption","Status":"partial","Findings / claim IDs":"C005, C032","Missing evidence":"Professional-conduct overlays and relevant decisions","Exact next action":"Examine Judiciary Law, 22 NYCRR Part 1200 and appellate decisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Other statutory exemptions","researcher_record":{"Assigned subtopic":"Other statutory exemptions","Status":"partial","Findings / claim IDs":"C001, C005, C006","Missing evidence":"Exhaustive exception-by-exception classification","Exact next action":"Recheck every subsection of GBL § 455 and related Banking Law provisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney entity, trust and direct negotiation","researcher_record":{"Assigned subtopic":"Attorney entity, trust and direct negotiation","Status":"partial","Findings / claim IDs":"C005, C032","Missing evidence":"Attorney trust rules and nonlawyer-affiliate treatment","Exact next action":"Read Rules of Professional Conduct 1.15, 5.4 and applicable provisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Licensing and registration","researcher_record":{"Assigned subtopic":"Licensing and registration","Status":"partial","Findings / claim IDs":"C008, C011, C025","Missing evidence":"Full application checklist, NMLS records, branch rules and license exceptions","Exact next action":"Open current DFS licensing instructions and NMLS Consumer Access"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Bonding and substitute security","researcher_record":{"Assigned subtopic":"Bonding and substitute security","Status":"partial","Findings / claim IDs":"C009, C017, C024","Missing evidence":"Official § 402.5 and regulator adjustment methodology","Exact next action":"Obtain current official NYCRR and DFS bond instructions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Financial fitness and counseling conditions","researcher_record":{"Assigned subtopic":"Financial fitness and counseling conditions","Status":"partial","Findings / claim IDs":"C007, C008","Missing evidence":"Regulatory standards and DFS application evidence","Exact next action":"Read official Parts 402/404 and DFS application materials"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Provider application charges","researcher_record":{"Assigned subtopic":"Provider application charges","Status":"answered","Findings / claim IDs":"C016, C026","Missing evidence":"Future schedule changes","Exact next action":"Reconfirm DFS schedule immediately before publication"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer fee ceilings","researcher_record":{"Assigned subtopic":"Consumer fee ceilings","Status":"unresolved","Findings / claim IDs":"C012, C018, C029","Missing evidence":"Complete operative fee provisions and regulator interpretation","Exact next action":"Retrieve official Part 402 fee provisions and any governing orders"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Fee timing","researcher_record":{"Assigned subtopic":"Fee timing","Status":"partial","Findings / claim IDs":"C019, C021, C035","Missing evidence":"Current TSR text; New York-specific fee timing","Exact next action":"Open current eCFR §§ 310.3–310.4 and official NYCRR"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Fee calculation formulas","researcher_record":{"Assigned subtopic":"Fee calculation formulas","Status":"partial","Findings / claim IDs":"C019, C041, C042","Missing evidence":"Full TSR calculation conditions; state restrictions","Exact next action":"Verify current federal regulation and NY fee rules"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Changes in fee structure","researcher_record":{"Assigned subtopic":"Changes in fee structure","Status":"partial","Findings / claim IDs":"C018, C028","Missing evidence":"Official current § 402.14","Exact next action":"Retrieve current NYCRR § 402.14 and confirm effective amendments"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor acceptance and settlement effectiveness","researcher_record":{"Assigned subtopic":"Creditor acceptance and settlement effectiveness","Status":"partial","Findings / claim IDs":"C019, C021, C035","Missing evidence":"Current federal conditions and treatment of conditional creditor agreements","Exact next action":"Read eCFR § 310.4(a)(5)(i) and FTC official explanations"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Failed creditor enrollment","researcher_record":{"Assigned subtopic":"Failed creditor enrollment","Status":"unresolved","Findings / claim IDs":"C030, C043","Missing evidence":"Specific contractual and regulatory rights","Exact next action":"Verify § 402.22 and termination provisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Refunds and unused funds","researcher_record":{"Assigned subtopic":"Refunds and unused funds","Status":"partial","Findings / claim IDs":"C023, C030, C031, C043","Missing evidence":"Current § 402.10 and § 402.22, distinctions among cancellation situations","Exact next action":"Obtain official regulation and any DFS enforcement interpretations"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Written agreements","researcher_record":{"Assigned subtopic":"Written agreements","Status":"answered","Findings / claim IDs":"C012, C031","Missing evidence":"Regulatory model forms and amendment rules still require checking","Exact next action":"Reconfirm § 584-a and obtain DFS-approved form requirements"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Disclosures and advertising","researcher_record":{"Assigned subtopic":"Disclosures and advertising","Status":"partial","Findings / claim IDs":"C012, C013, C021","Missing evidence":"Complete TSR and NYCRR","Exact next action":""},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Disclosures and advertising","researcher_record":{"Assigned subtopic":"Disclosures and advertising","Status":"partial","Findings / claim IDs":"C012, C013, C021","Missing evidence":"Complete current TSR disclosure requirements; official 3 NYCRR advertising and disclosure provisions","Exact next action":"Open current eCFR §§ 310.3–310.4 and official NYCRR Parts 402/404; compare mandatory statements, timing and exemptions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Cancellation rights","researcher_record":{"Assigned subtopic":"Cancellation rights","Status":"partial","Findings / claim IDs":"C012, C023, C031, C044","Missing evidence":"Official § 402.10; effective notice delivery, holidays, rescission versus later termination","Exact next action":"Retrieve official § 402.10 and verify each subsection against Banking Law § 584-a"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor acceptance and settlement effectiveness","researcher_record":{"Assigned subtopic":"Creditor acceptance and settlement effectiveness","Status":"partial","Findings / claim IDs":"C019, C021, C035","Missing evidence":"Current federal settlement-agreement and first-payment fee triggers; NY-specific conditions","Exact next action":"Open current 16 CFR § 310.4(a)(5)(i); examine conditional acceptance, rejected offers and partial payments"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Creditor disbursement and failed enrollment","researcher_record":{"Assigned subtopic":"Creditor disbursement and failed enrollment","Status":"partial","Findings / claim IDs":"C013, C030, C043","Missing evidence":"Timely-disbursement standards, unsuccessful enrollment consequences, failed transfers","Exact next action":"Retrieve official §§ 402.15 and 402.22; examine DFS enforcement orders"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Refunds and unused funds","researcher_record":{"Assigned subtopic":"Refunds and unused funds","Status":"partial","Findings / claim IDs":"C023, C030, C031, C043","Missing evidence":"Official refund provisions; allowable deductions and timing after termination","Exact next action":"Obtain official § 402.22 and § 402.10; separate rescission from ordinary termination"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]","coordinator_duplicate_topic_note":"Preserved interrupted/overlapping continuation rows; reconcile against later complete row without accepting the topic."},{"topic":"Client money and trust accounts","researcher_record":{"Assigned subtopic":"Client money and trust accounts","Status":"partial","Findings / claim IDs":"C005, C013, C017, C027","Missing evidence":"Official trust-account rules, titling, reconciliation, safeguarding and administrator obligations","Exact next action":"Read official § 402.15 and DFS quarterly reporting instructions; separately verify attorney trust rules"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Agency examinations and enforcement","researcher_record":{"Assigned subtopic":"Agency examinations and enforcement","Status":"partial","Findings / claim IDs":"C014, C015, C045","Missing evidence":"Enforcement regulations, monetary remedies, historical orders and current practice","Exact next action":"Examine Banking Law §§ 584–587, applicable regulations and published DFS orders"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer civil remedies","researcher_record":{"Assigned subtopic":"Consumer civil remedies","Status":"unresolved","Findings / claim IDs":"C038, C045","Missing evidence":"Private-right-of-action decisions; restitution, damages, rescission and GBL §§ 349–350 applicability","Exact next action":"Research controlling NY appellate decisions and statutory remedial provisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Criminal remedies and penalties","researcher_record":{"Assigned subtopic":"Criminal remedies and penalties","Status":"partial","Findings / claim IDs":"C003, C038","Missing evidence":"Prosecution elements, additional penalties and relevant interpretations","Exact next action":"Reopen GBL § 457 and search controlling decisions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Contract severability and unenforceability","researcher_record":{"Assigned subtopic":"Contract severability and unenforceability","Status":"unresolved","Findings / claim IDs":"C031, C038","Missing evidence":"Whether unlawful provider terms or unlicensed activity invalidate an agreement in whole or part","Exact next action":"Research NY contract-enforceability decisions and applicable severability doctrines"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Local licensing and consumer-protection overlays","researcher_record":{"Assigned subtopic":"Local licensing and consumer-protection overlays","Status":"unresolved","Findings / claim IDs":"C039","Missing evidence":"NYC and other municipal laws, local enforcement authority and preemption","Exact next action":"Search official NYC Administrative Code, DCWP regulations and other relevant local enactments"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling judicial interpretations","researcher_record":{"Assigned subtopic":"Controlling judicial interpretations","Status":"unresolved","Findings / claim IDs":"C034, C040","Missing evidence":"Verified decisions addressing noncustodial negotiation, attorney entities and nonprofit eligibility","Exact next action":"Search NY Court of Appeals, Appellate Divisions and relevant federal decisions; read full opinions"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Official DFS interpretations","researcher_record":{"Assigned subtopic":"Official DFS interpretations","Status":"unresolved","Findings / claim IDs":"C011, C029, C040","Missing evidence":"Published interpretations of classification, fee ceilings and contractual payment control","Exact next action":"Search DFS opinions, circulars, enforcement orders and archived guidance"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Current versus historical regulations","researcher_record":{"Assigned subtopic":"Current versus historical regulations","Status":"partial","Findings / claim IDs":"C018, C023, C024, C028, C035","Missing evidence":"Authenticated October 2026 official NYCRR and eCFR text","Exact next action":"Obtain official versions and amendment histories; reconcile effective dates"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Proposed or future-effective legislation","researcher_record":{"Assigned subtopic":"Proposed or future-effective legislation","Status":"partial","Findings / claim IDs":"C036, C037","Missing evidence":"Final legislative status, enacted amendments, delayed effective dates and guidance changes","Exact next action":"Recheck official NY legislation, State Register and CFPB withdrawal register immediately before publication"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR dedicated accounts","researcher_record":{"Assigned subtopic":"Federal TSR dedicated accounts","Status":"partial","Findings / claim IDs":"C019, C020, C035","Missing evidence":"Complete current account conditions, administrator independence, withdrawals and fee restrictions","Exact next action":"Open current eCFR § 310.4(a)(5)(ii) and official FTC interpretations"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"},{"topic":"Provider complaints and consumer assistance","researcher_record":{"Assigned subtopic":"Provider complaints and consumer assistance","Status":"partial","Findings / claim IDs":"C014, C015, C038, C045","Missing evidence":"Exact complaint jurisdiction, remedies, referral channels and current forms","Exact next action":"Verify DFS complaint procedures, NY AG consumer resources and relevant court remedies"},"coordinator_acceptance":"not_accepted_partial_pass_remaining_evidence_and_parent_scope","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}