{"meta":{"key":"s_ok--pass-01","task":"S_OK","title":"SOK Oklahoma provider market access and consumer fees","parent_title":"Oklahoma debt and debt relief law","edition":"pass-01","path":"/research/s_ok--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":6,"claims":38,"sources":15,"review_status":"provider_component_reviewed_with_primary_currency_and_scope_holds","review_complete":true,"sha256":"f22e31743cdeb3c826c7744a6351c49b2d4874e6e497bb774d91d5bf9fc27225","headings":["Bottom-line disposition","1. Current classification of debt adjustment, settlement, DMP, credit counseling, and related fee-taking conduct","1.1 Oklahoma debt pooling is a conduct-based prohibition","1.2 The debt-pooling exclusions are narrow and model-specific","1.3 Consumer versus business purpose under the pooling statute","1.4 The separate Credit Services Organization Act","1.5 Custodial and noncustodial boundaries","1.6 Resident and remote-provider nexus","2. Prohibited, licensed, authorized, or exempt status by business model","2.1 Prohibited model","2.2 Licensed model","2.3 CSO definitional exclusions","2.4 Attorney and nonprofit failure cases","2.5 No affirmative pure-settlement safe harbor established","3. Applicable consumer fee structures, limits, indexing, and refunds","3.1 Debt pooling","3.2 Oklahoma CSO consumer fees","3.3 State payment timing","3.4 Trust-account amount and duration","3.5 Cancellation and refunds","3.6 Government charges are not consumer fee ceilings","4. When fees may actually be requested or received","4.1 Oklahoma-only state timing matrix","4.2 Federal TSR debt-relief timing, when applicable","4.3 Federal dedicated-account conditions","4.4 Federal credit-improvement timing","4.5 Conditional CROA overlap","5. Actual regulator permission, public procedure, and lookup evidence","5.1 Issuing regulator","5.2 Current application pathway","5.3 Public lookup","5.4 Official-rule limitation","6. Worked fee and boundary examples","7. Component result and required next investigations","S_OK-P1-S011 direct-section URL inventory","Example 1 — Direct custodial DMP/debt pooling","Example 2 — Oklahoma CSO timing without and with trust-account qualification","Branch A: bond but no qualifying trust account","Branch B: accepted $10,000 bond plus qualifying Oklahoma trust account","Example 3 — Timely Oklahoma cancellation","Example 4 — TSR proportional-to-enrolled-debt allocation","Example 5 — TSR percentage-of-savings method","Example 6 — Lower debt, prior fee, and later cancellation","Example 7 — Settlement signed but no creditor payment","Example 8 — Dedicated account withdrawal","Pass coverage and gap table","Actually read or inspected","Not actually read or not established","Method and assertion controls"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_OK/pass-01","facets":{"geography":["us","us-ok"],"debt_type":[],"stage":["repossession"],"subject":["fees-outcomes","provider-licensing"]},"scope":"First extensive Oklahoma provider market access/consumer-fees component only; all broader state dimensions remain required.","pending_corrections":0},"markdown":"# S_OK PASS-01 — Oklahoma provider market access and consumer fees\n\n**Fresh source-access date:** October 25, 2026, Pacific Daylight Time, America/Los_Angeles.\n**Historical baseline:** October 22, 2026 only; it is not the verification date.\n**Mode used:** regular Chat with GPT-5.6 Sol Pro, the available owner-authorized quality-first fallback; no Deep Research.\n**Component boundary:** provider classification, public market access, consumer-fee amount/timing, operative exceptions, and the minimum related enforcement material necessary to answer those questions. This is not a complete Oklahoma debt-law dossier, not an A066 acceptance, and not legal advice.\n\n## Bottom-line disposition\n\n| Business model | Oklahoma result established in this pass | Fee consequence |\n| --- | --- | --- |\n| Provider contracts with a debtor, receives the debtor’s periodic payments, distributes them among specified creditors under an agreed plan, and receives consideration | **Debt pooling; prohibited**, unless one of the narrow §24-18 exclusions actually applies. This is not an ordinary licensable debt-settlement category. [C001–C004] | No lawful nonexempt fee pathway was established. Calling the result a “$0 fee cap” would be misleading; the underlying covered model is prohibited. |\n| For-profit noncustodial provider seeks a payment extension, forbearance, revised schedule, or other deferral for an individual consumer more than twelve times per calendar year for consideration | Strong textual fit with the **Credit Services Organization Act**, subject to facts and exclusions; DOCC license required. [C008–C010, C013] | No numerical Oklahoma consumer-fee ceiling was located, but disclosure, contract, cancellation, licensing, and payment-timing restrictions apply. |\n| Noncustodial provider negotiates only an immediate lump-sum principal reduction, makes no express or implied credit-improvement representation, does not seek a payment deferral, and never receives or distributes debtor funds | **Unresolved outside-category branch.** The reviewed Oklahoma authorities did not establish that this is a CSO, debt pooling, a separately licensed settlement service, or affirmatively unregulated. [C006, C011, C033] | No Oklahoma fee pathway or cap should be invented. Additional conduct facts and authority are required. |\n| Provider represents that it will improve a consumer’s credit record, history, or rating | Potential Oklahoma CSO coverage and conditional federal credit-repair overlap. [C008, C030–C031] | Oklahoma’s bond/trust exception does not override independently applicable federal advance-fee prohibitions. |\n| Consumer pays periodically into a genuinely independent, consumer-owned dedicated account | Federal TSR may permit the account under specified conditions, but the Oklahoma debt-pooling characterization depends on who legally and practically receives, controls, directs, or distributes the funds. [C006, C029] | Deposits are not automatically earned fees. State classification and federal earning triggers remain separate. |\n| Truly gratuitous counseling, with no money or other valuable consideration from the consumer **or any other source** | Outside the literal Oklahoma CSO definition; debt-pooling analysis still depends on whether the debtor separately pays consideration and the provider handles distributions. [C002, C037] | No fee exists on the stated facts. “Free to the consumer” is insufficient if a creditor or another source pays the provider. |\n| General business-purpose debt | Generally outside the CSO definition, except the individual-agricultural branch, but §§24-15–18 contain no express consumer-purpose limitation. [C005, C009] | Business-purpose debt-pooling coverage is a textual inference, not a case-resolved holding. |\n| Remote/out-of-state provider serving Oklahoma residents | DOCC demonstrably licenses out-of-state CSOs, but the precise transaction-level nexus test was not found in the reviewed statute or rules. [C007, C023] | An out-of-state address is not a safe harbor; the exact solicitation/residency/transaction nexus remains open. |\n\nOklahoma’s official Title 24 compilation still states that it was last updated November 18, 2025. Live OSCN text for §§24-131–133 matched that compilation, and DOCC’s March 2026 licensing page plus October 2026 roster show that the CSO licensing program remains operational. A complete 2026 session-law section concordance was not recovered, so post-November-2025 statutory currentness is **high-confidence but qualified**, not absolute. [Oklahoma Legislature+4](https://www.oklegislature.gov/osStatuesTitle.html)\n\n# A. Substantive answers\n\n## 1. Current classification of debt adjustment, settlement, DMP, credit counseling, and related fee-taking conduct\n\n### 1.1 Oklahoma debt pooling is a conduct-based prohibition\n\nTitle 24, §24-15 prohibits operating a debt-pooling business. Section 24-16 supplies the operative elements:\n\n1. a contract with a particular debtor;\n2. the debtor agrees to make periodic payments to the provider;\n3. the provider will distribute those payments among specified creditors under an agreed plan; and\n4. the debtor agrees to pay the provider valuable consideration for those services or related services.\n\nThe statute therefore turns principally on the contractual fund flow and compensation arrangement, not the marketing label “debt settlement,” “debt management,” “credit counseling,” or “financial wellness.” A provider does not escape §24-16 merely because it also negotiates interest concessions, fee waivers, principal reductions, or revised payment terms. Conversely, a provider that never receives or distributes debtor payments does not satisfy the clearest literal fund-flow elements, although agency, constructive receipt, and account-control theories remain untested here. [C001–C002, C004, C006; S002 §§24-15–16.] [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nSection 24-17 makes violation a misdemeanor, punishable by a $100–$500 fine, up to thirty days in county jail, or both. No ordinary debt-pooling license or registration pathway appears in §§24-15–18. [C001, C027; S002 §24-17.] [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 1.2 The debt-pooling exclusions are narrow and model-specific\n\nSection 24-18 excludes only:\n\n- a retail merchants’ trade association;\n- a nonprofit association formed for the purpose of collecting accounts and exchanging credit information;\n- bankruptcy actions under federal bankruptcy law; and\n- acts of duly licensed attorneys distributing client funds.\n\nA generic nonprofit label is not enough. In particular, the broader 501(c)(3) exclusion in the separate CSO Act does not rewrite §24-18. Likewise, attaching an attorney’s name to a commercial provider is not equivalent to the excluded acts of a duly licensed attorney distributing client funds. [C003, C014; S002 §24-18.] [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThe exclusions should also not be enlarged by analogy. The CSO Act places the burden of proving a claimed exception or definitional exclusion on the claimant, reinforcing the need to test actual entity and activity facts rather than accept a label. [C012; S002 §24-138(B).] [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 1.3 Consumer versus business purpose under the pooling statute\n\nSections 24-15–18 do not state a personal, family, household, or consumer-purpose limitation. Section 24-1 broadly defines a debtor as one liable or potentially liable to pay money because of an existing obligation. That supports a textual inference that the debt-pooling prohibition is not limited to consumer debts. No controlling Oklahoma appellate decision resolving application to a commercial-debt pooling arrangement was found in this pass, so that conclusion remains an inference rather than a case-tested holding. [C005, C036; S002 §§24-1, 15–18.] [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 1.4 The separate Credit Services Organization Act\n\nA “buyer” is an individual. A CSO is a person that, with respect to an extension of credit by others and in return for money or other valuable consideration **from any source**, more than twelve times in a calendar year provides or represents that it will provide:\n\n- credit-record, history, or rating improvement;\n- assistance obtaining an extension of credit; or\n- advice or assistance concerning either service.\n\nAn “extension of credit” includes the right to defer payment of an existing debt or to incur debt and defer payment, offered primarily for personal, family, or household purposes, and also credit offered to a person whose principal occupation is agricultural. [C008–C009, C034; S002 §24-132; S003 live OSCN §24-132.] [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThis yields the following classification rules:\n\n| Conduct | Oklahoma CSO analysis |\n| --- | --- |\n| Negotiating a longer payment period, forbearance, revised installment schedule, or delayed payment obligation for an individual consumer | Strong textual basis for “obtaining an extension of credit,” although no debt-settlement-specific Oklahoma holding was located. The 1987 Attorney General opinion construed the extension-of-credit language broadly enough to cover a third-party loan broker. [C010; S005.] |\n| Advising a consumer how to obtain that deferral | Potentially covered as advice or assistance concerning an extension of credit. |\n| Representing that settlement will improve the consumer’s credit | Independently supports CSO treatment through the credit-improvement branch; federal CROA and TSR credit-repair rules may also apply. [C008, C030–C031.] |\n| Negotiating an immediate lump-sum payoff for less principal, with no deferral and no credit-improvement representation | Not clearly within “obtaining an extension of credit.” No separate Oklahoma settlement-provider category was established. Held. [C011, C033.] |\n| Free counseling | Outside the literal definition only if no valuable consideration comes from **any source**. Creditor-paid “fair share,” lead compensation, affiliate payments, or other indirect value can change the answer. [C037.] |\n| Corporate or ordinary commercial debt | Generally outside because the buyer must be an individual and the credit must be consumer-purpose or within the agricultural branch. |\n| Individual agricultural borrower | Expressly included in the extension-of-credit definition. [C009.] |\n| More than twelve times annually | Express threshold, but the statute does not specify whether the unit is buyers, contracts, services, representations, or transactions. That counting question remains unresolved. [C034.] |\n\nThe Attorney General’s 1987 loan-broker opinion is not a debt-settlement decision, but it confirms that the statutory phrase “extension of credit” was applied according to its broad payment-deferral language rather than confined to classic credit repair. [C010; S005 ¶¶1–6.] [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527)\n\n### 1.5 Custodial and noncustodial boundaries\n\n**Direct custody.** When the debtor periodically pays the provider and the provider pays specified creditors under a plan for consideration, the clearest statutory result is prohibited debt pooling. [C001–C004.]\n\n**No custody.** A negotiator that never receives or distributes debtor funds avoids the clearest §24-16 fund-flow elements. It may nevertheless be a CSO if it obtains payment deferral or markets credit improvement. [C006, C008–C011.]\n\n**Dedicated account.** A consumer-owned account administered by a separate institution does not automatically establish that the debt-relief provider receives or distributes the funds. The unresolved Oklahoma questions include contractual agency, withdrawal authority, payment instructions, beneficial control, affiliate relationships, processor attribution, and whether the debtor’s payment obligation is legally to the provider or only to the independent account institution. No Oklahoma appellate authority resolving those contemporary facts was found. [C006, C029, C036.]\n\n### 1.6 Resident and remote-provider nexus\n\nThe CSO Act requires a license before engaging in CSO business and penalizes unlicensed activity “in this state.” It requires a resident agent for process and contemplates foreign applicants. DOCC’s current roster includes out-of-state locations, proving that non-Oklahoma businesses can and do obtain CSO licenses. The reviewed statute and rule mirror did not state a precise test based on consumer residence, solicitation location, contract formation, service performance, or fund location. [C007, C023; S002 §§24-141–145; S007; S009.] [Oklahoma Legislature+4](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThe debt-pooling provisions likewise contain no express remote-provider nexus rule. Application of §§24-15–18 to an out-of-state provider serving an Oklahoma debtor remains a choice-of-law and territorial-reach question for the later contracts/case-law pass.\n\n## 2. Prohibited, licensed, authorized, or exempt status by business model\n\n### 2.1 Prohibited model\n\nA model satisfying §24-16 is prohibited under §24-15 unless it falls within §24-18. The statutory structure does not authorize DOCC to convert that prohibition into a licensable debt-pooling business. [C001–C004, C014.]\n\nA CSO license evidences authority under the CSO Act. It does not purport to repeal §24-15, enlarge §24-18, or authorize a separate prohibited fund-handling model. A business that fits both statutes must satisfy the CSO Act **and** avoid prohibited debt pooling or establish a real §24-18 exclusion. [C014; S002 §§24-15–18, 141–143.] [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 2.2 Licensed model\n\nSection 24-141 requires a person to obtain a license from the Administrator before engaging in business as a CSO. The Department of Consumer Credit administers the Act. Application and bond, government fees, fitness review, and a decision within sixty days are part of the statutory process. [C013, C023; S002 §§24-140–143.] [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nDOCC’s current public page describes the license as covering work with individuals to improve credit, obtain an extension of credit, or receive related advice and assistance. As of October 15, 2026, DOCC’s public all-locations roster stated that 72 businesses held active CSO licenses. [C023–C024; S006, S008–S009.] [Welcome to Oklahoma's Official Web Site+2](https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html)\n\n### 2.3 CSO definitional exclusions\n\nThe CSO definition excludes:\n\n1. a person authorized and supervised as a lender or extender of credit under state or federal law, and a qualifying HUD-approved lender;\n2. an insured bank, savings-and-loan institution, or credit union, and a subsidiary;\n3. a 501(c)(3) nonprofit;\n4. an Oklahoma-licensed real-estate broker acting within that license;\n5. an Oklahoma-licensed attorney acting within the course and scope of legal practice;\n6. a qualifying SEC- or CFTC-registered broker-dealer acting within that regulatory scope;\n7. a consumer reporting agency under the FCRA;\n8. a person authorized to file electronic income-tax returns who receives no consideration for refund-anticipation loans;\n9. a residential mortgage broker as statutorily defined; and\n10. an insurer authorized in Oklahoma, its affiliates and subsidiaries, and licensed insurance agents.\n\nThese are exclusions from the **CSO definition**, not universal exemptions from debt-pooling law, the TSR, CROA, Oklahoma consumer-protection law, professional-responsibility rules, or other licensing regimes. [C012, C014; S002 §24-132(2)(b).] [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 2.4 Attorney and nonprofit failure cases\n\n- An attorney-affiliated corporation is not automatically excluded. For the CSO exclusion, the person must be licensed to practice in Oklahoma and render the services within the course and scope of legal practice.\n- For debt pooling, the text protects acts of duly licensed attorneys distributing client funds—not every business with attorney ownership, review, referral, or branding.\n- A 501(c)(3) is excluded from the CSO definition, but §24-18’s nonprofit language is materially narrower.\n- Under §24-138(B), the claimant bears the burden of proving an exception or definitional exclusion. [C003, C012.] [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 2.5 No affirmative pure-settlement safe harbor established\n\nNo reviewed primary source created a distinct Oklahoma “debt settlement company” license for a provider that only negotiates noncustodial, immediate principal reductions and avoids both payment deferral and credit-improvement representations. That result is a **classification hold**, not a finding that the model is freely permissible. Other potentially applicable regimes—including deceptive-practices law, unauthorized practice, money transmission, contracts, agency, collection law, and federal law—remain outside or only partly within this pass. [C011, C033.]\n\n## 3. Applicable consumer fee structures, limits, indexing, and refunds\n\n### 3.1 Debt pooling\n\nFor nonexempt conduct satisfying §24-16, the governing result is prohibition. No setup, monthly, distribution, settlement, savings-based, per-debt, or aggregate fee pathway was established. The correct characterization is **“prohibited covered model,” not “lawful with a zero-dollar fee cap.”** [C001–C004, C019.]\n\n### 3.2 Oklahoma CSO consumer fees\n\nThe reviewed operative CSO provisions require disclosure of the payment terms and the total of all payments the buyer will make to the CSO or another person. They regulate when consideration may be charged or received, but they do not state a numerical setup, monthly, per-debt, settlement, percentage-of-savings, percentage-of-enrolled-debt, or aggregate consumer-service fee ceiling. [C018–C019; S002 §§24-133, 135–137.] [Oklahoma Legislature+3](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThe full set of non-revoked Chapter 30 provisions visible in the quarterly Cornell OAC mirror was inspected. No consumer-service fee ceiling or CPI adjustment provision was found there. Because the official Oklahoma Rules portal could not be read in this tool route, the negative rule finding is qualified by that official-current-text gap. [C019, C025; S010–S013.] [Legal Information Institute](https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30)\n\nSection 24-147’s heading includes the word “fees,” but the provision concerns consumer reporting agencies and access to credit histories. It is not a CSO or debt-settlement service-fee schedule. [C032; S002 §24-147.] [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 3.3 State payment timing\n\nSection 24-133(1) prohibits a CSO and its salespersons, agents, representatives, and selling contractors from charging **or receiving** money or other valuable consideration before full and complete performance of the agreed services unless the organization has both:\n\n- a $10,000 surety bond from an admitted surety; and\n- a trust account at a federally insured bank or savings-and-loan association located in Oklahoma.\n\nThe exception removes this particular state timing prohibition; it is not a general declaration that every advance fee is lawful. It does not create a §24-18 debt-pooling exclusion and does not override the TSR, CROA, or another applicable law. [C015, C033; S002 §24-133(1); S003 live OSCN §24-133.] [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThe application instructions operationalize this distinction by requiring evidence of an Oklahoma trust account when upfront consumer funds are collected, while directing applicants that collect no upfront consumer funds to submit a letter saying so. The current application also requires a $10,000 bond for each location. [C015, C017, C023; S007 pp. 5–6.] [Welcome to Oklahoma's Official Web Site+2](https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf)\n\n### 3.4 Trust-account amount and duration\n\nThe statute does not specify a dollar amount to be maintained in the trust account, how deposits are computed, or how long the account must be maintained. In 1987 OK AG 104, the Attorney General concluded that the Administrator lacked delegated authority to invent a specific trust amount or require maintenance until agency release. Therefore:\n\n- the $10,000 figure is the **bond** amount;\n- it must not be copied over as a trust-account balance;\n- no CPI or administrator-created trust amount should be inferred; and\n- the trust account’s purpose, deposit formula, and duration remain statutory gaps unless later valid authority supplies them. [C016; S004 ¶¶7–10.] [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515)\n\n### 3.5 Cancellation and refunds\n\nEvery CSO contract must give the buyer a five-day cancellation right. The prescribed notice states that a payment made under the contract must be returned within ten days after the seller receives the cancellation notice. The quarterly OAC mirror states that the cancellation period does not begin until all disclosures have been properly furnished and defines “days” as calendar days, subject to its computation rule. [C020; S002 §24-137; S011 §§160:30-1-2, 160:30-5-1.] [Oklahoma Legislature+4](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\nThe contract must also describe all promises of full or partial refunds. The Administrator may order refunds of unlawful charges, and a private claimant may obtain actual damages of at least the amount paid, plus reasonable attorney’s fees and costs, with punitive damages potentially available. No general post–five-day, no-fault pro rata refund formula was located in the reviewed provisions. [C021, C027; S002 §§24-137, 139, 145.] [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 3.6 Government charges are not consumer fee ceilings\n\nDOCC currently lists:\n\n- $300 investigation fee;\n- $200 annual license fee;\n- $400 examination fee;\n- $900 total initial government charges;\n- $600 renewal, consisting of the annual and examination fees;\n- $10 per day late charge for up to thirty days after the December 1 renewal deadline;\n- $25 amended or duplicate license fee; and\n- $25 returned-check fee in the rule mirror.\n\nThese are provider-to-government licensing charges. They do not establish what a consumer may be charged. No indexing mechanism was found for either these charges or CSO consumer-service fees. [C022; S006–S007, S012.] [Welcome to Oklahoma's Official Web Site+3](https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html)\n\n## 4. When fees may actually be requested or received\n\n### 4.1 Oklahoma-only state timing matrix\n\n| Circumstances | Oklahoma CSO Act result |\n| --- | --- |\n| No qualifying bond and trust account | The CSO may not charge or receive consideration until full and complete performance of the agreed services. |\n| $10,000 bond plus qualifying Oklahoma trust account | The specific §24-133(1) state advance-payment bar is excepted, but disclosure, contract, cancellation, fraud, licensing, and all independently applicable law remain. |\n| Employee, salesperson, or agent of a compliant organization | Section 24-134 excuses that person from obtaining a separate bond and trust account; it does not exempt the organization or create a new business-model exemption. |\n| Prohibited debt pooling | The CSO timing exception does not legalize the pooling arrangement. |\n| Service also covered by the TSR or CROA | The stricter independently applicable federal rule still controls its own scope. |\n\nSection 24-134 is therefore an employee/agent allocation rule, not a general provider exemption. [C017; S002 §24-134.] [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n“Full and complete performance” is not defined for a multidebt settlement contract in the reviewed Oklahoma material. Without the bond/trust exception, the provider should not assume that settling one debt necessarily completes the services promised under an entire multidebt contract. That contract-specific question remains open.\n\n### 4.2 Federal TSR debt-relief timing, when applicable\n\nThe TSR defines a debt-relief service as a represented program or service to renegotiate, settle, or otherwise alter terms of unsecured debt, including balance, interest, or fee reductions. “Telemarketing” requires a plan, program, or campaign using telephones to induce a purchase and involving more than one interstate telephone call. Thus, the federal rules below are common context, not a finding of universal coverage. [C028; S014, 16 C.F.R. §310.2(o), (hh), (ii).] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nFor a covered debt-relief service, a seller or telemarketer may not request or receive a fee until:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid settlement agreement, DMP, or comparable contractual agreement executed by the customer;\n2. the customer has made at least one payment under that customer-creditor or customer-debt-collector agreement; and\n3. any fee for an individually altered debt is allocated by one of the two prescribed methods:the debt’s enrolled-balance proportion of the total contracted fee; ora constant percentage of actual savings, using the same percentage for each debt.\n\nActual savings equal the enrolled balance minus the amount actually paid to satisfy that debt. The TSR supplies timing and allocation rules, not a maximum percentage. [C028; S014 §310.4(a)(5)(i).] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe triggering payment must be made under the valid customer-creditor or customer-debt-collector agreement. A deposit into a savings or dedicated account, standing alone, is not the required payment to the creditor or collector. Similarly, an unaccepted creditor offer, an unsigned agreement, or a signed agreement followed by no customer payment does not satisfy both triggers.\n\n### 4.3 Federal dedicated-account conditions\n\nThe TSR does not categorically prohibit requiring a consumer to place funds in a dedicated account, but its safe structure requires:\n\n- an insured financial institution;\n- consumer ownership of the funds and accrued interest;\n- an administrator not owned, controlled by, or affiliated with the debt-relief service;\n- no referral compensation between the administrator and service;\n- withdrawal from the service at any time without penalty; and\n- return within seven business days of all account funds except fees already earned in compliance with the debt-relief earning rule.\n\nThat federal account structure does not answer Oklahoma’s separate debt-pooling question. [C029; S014 §310.4(a)(5)(ii).] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 4.4 Federal credit-improvement timing\n\nWhen a covered seller or telemarketer represents that services will remove derogatory information or improve a person’s credit history, record, or rating, §310.4(a)(2) bars both requesting and receiving payment until:\n\n1. the represented time for providing **all** promised goods or services has expired; and\n2. the seller has provided the person a consumer report demonstrating that the promised results were achieved, issued more than six months after those results were achieved.\n\nThe regulation preserves the FCRA permissible-purpose requirement for obtaining a consumer report. [C030; S014 §310.4(a)(2).] [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 4.5 Conditional CROA overlap\n\nCROA can apply where a person uses interstate commerce or the mails, receives consideration, and has an express or implied purpose of improving a consumer’s credit record, history, or rating or provides related advice. Its statutory exclusions include a qualifying 501(c)(3), a creditor restructuring its own debt, and qualifying depository institutions or credit unions and their affiliates or subsidiaries. The text does not contain a general attorney exclusion. [C031, C038; S015, 15 U.S.C. §1679a.] [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1679a/)\n\nFor a covered credit-repair organization, CROA prohibits charging or receiving consideration before the agreed service is fully performed. It also requires a written, dated contract, bars service before the end of the three-business-day period beginning on the signing date, and supplies a three-business-day cancellation right. State law remains applicable except to the extent of an actual inconsistency. [C031; S015 §§1679b, 1679d, 1679e, 1679j.] [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1679b/)\n\nAccordingly, Oklahoma’s bond-and-trust exception cannot be read as permission to collect an advance fee where the TSR, CROA, or another applicable law still bars it. [C033.]\n\n## 5. Actual regulator permission, public procedure, and lookup evidence\n\n### 5.1 Issuing regulator\n\nThe Oklahoma Department of Consumer Credit administers the CSO Act, and the Administrator issues CSO licenses. The current agency page links the Act, rules, application, fee information, bond prerequisite, and a stated processing period of up to sixty days. [C013, C023; S002 §§24-140–143; S006.] [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf)\n\n### 5.2 Current application pathway\n\nThe March 4, 2024 application currently linked by DOCC requires, among other things:\n\n- completed entity and ownership information;\n- a $10,000 bond for each location;\n- financial information;\n- evidence of an Oklahoma trust account when upfront consumer funds are collected, or a letter stating that no upfront funds are collected;\n- entity-formation and foreign-corporation materials where applicable;\n- $900 in initial government charges;\n- separate branch materials and a $600 branch charge; and\n- annual renewal materials and $600 renewal charge by December 1.\n\nThe form is operational guidance and evidence of current procedure. It does not enlarge the underlying statute or prove that any particular proposed product is legally covered by the license. [C017, C022–C024; S007.] [Welcome to Oklahoma's Official Web Site+6](https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf)\n\n### 5.3 Public lookup\n\nDOCC’s regulated-industries page, updated October 19, 2026, links in-state, out-of-state, and all-location CSO rosters. The all-location roster states that each listed business held an active CSO license as of October 15, 2026 and reports 72 active licenses. [C023; S008–S009.] [Welcome to Oklahoma's Official Web Site+1](https://oklahoma.gov/okdocc/licenses-we-regulate.html)\n\nThe roster proves only the public license status shown for the listed legal entity and location on that date. It does **not** establish:\n\n- that every product marketed by the licensee is a CSO service;\n- that a debt-settlement product avoids §24-15;\n- that the licensee qualifies for an attorney, nonprofit, lender, or other exclusion;\n- that a dedicated-account arrangement is lawful;\n- that a named provider complies with the TSR or CROA; or\n- that a marketing statement accurately describes authorization.\n\nNo named-provider status determination was performed. [C024.]\n\n### 5.4 Official-rule limitation\n\nDOCC links to the Oklahoma Administrative Code portal at https://rules.ok.gov/code, but that official portal could not be opened through the available public-web route. The quarterly Cornell mirror was used to inspect Chapter 30’s non-revoked provisions and the government-fee rule, but it is not a substitute for a freshly read official rule export or adoption order. [C025; S010–S013.] [Welcome to Oklahoma's Official Web Site+1](https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html)\n\n## 6. Worked fee and boundary examples\n\nThe detailed calculations are in Part D. The controlling distinctions are:\n\n- A prohibited pooling model does not become lawful because its fee is small.\n- A state CSO fee can be numerically disclosed yet still be premature.\n- Oklahoma’s bond/trust exception and the federal TSR earning trigger are different tests.\n- A dedicated-account deposit is not an earned settlement fee.\n- Under the TSR, prior earnings and the current debt must use the same contractual allocation method and the same original enrolled balances.\n- An accepted settlement without the required customer payment still yields a $0 TSR-earned fee.\n- A timely Oklahoma cancellation requires return of the payment, while no general post–five-day pro rata formula was established. [C015, C019–C021, C028–C029, C033.]\n\n## 7. Component result and required next investigations\n\nThis pass establishes:\n\n- the prohibited custodial debt-pooling category;\n- the separate CSO licensing category;\n- operative statutory exclusions;\n- the absence of a located numerical Oklahoma CSO consumer-service fee ceiling;\n- the state bond/trust payment-timing condition;\n- cancellation and identified refund rules;\n- the public DOCC application and lookup pathway; and\n- conditional federal TSR/CROA timing overlays.\n\nIt does **not** establish a universal answer for every noncustodial principal-reduction provider, every remote transaction, or every dedicated-account structure. Official-current OAC text, complete 2026 session-law reconciliation, contemporary Oklahoma case authority, and several transaction-law dimensions remain open. See the coverage table in Part D.\n\n# B. Source table\n\n| Source ID | Title, issuer, and direct literal URL | Exact pinpoints read | Version/effective status and fresh access | Jurisdiction, use, and limitations |\n| --- | --- | --- | --- | --- |\n| **S_OK-P1-S001** | Oklahoma Statutes index, Oklahoma Legislature. https://www.oklegislature.gov/osStatuesTitle.html | Page note; Title 24 link | Page says statutes last updated **Nov. 18, 2025**. Accessed Oct. 25, 2026 PDT. | Official source for compilation date. It does not itself reconcile 2026 session laws. [Oklahoma Legislature](https://www.oklegislature.gov/osStatuesTitle.html) |\n| **S_OK-P1-S002** | Oklahoma Statutes, Title 24, Debtor and Creditor, Oklahoma Legislature. https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf | §§24-1; 24-15–18; 24-131–148, especially §§132–145; PDF pp. 5, 21–31 | Official compilation associated with S001’s Nov. 18, 2025 update. Accessed and PDF pages visually inspected Oct. 25, 2026 PDT. | Principal Oklahoma statutory source. Post-Nov.-2025 amendment completeness remains qualified. [Oklahoma Legislature+5](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-S003** | OSCN citationized CSO provisions and citationizer, Oklahoma State Courts Network. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71250 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71251 | §§24-131–133; histories; citationizer for §131 | Live pages accessed Oct. 25, 2026 PDT; no explicit current-through date. | Official judiciary source corroborating text and locating the two AG opinions. It is not a legislative-session concordance. [Oklahoma State Courts Network+2](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249) |\n| **S_OK-P1-S004** | 1987 OK AG 104, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515 | ¶¶0, 4–10; decided Oct. 12, 1987 | Official opinion accessed Oct. 25, 2026 PDT. | Establishes lack of authority to prescribe trust-account amount or duration by rule; not a modern debt-settlement classification decision. [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515) |\n| **S_OK-P1-S005** | 1987 OK AG 126, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527 | ¶¶0–6; decided Dec. 14, 1987 | Official opinion accessed Oct. 25, 2026 PDT. | Applies CSO definition to third-party loan brokers and supports broad reading of payment deferral; not a holding about debt settlement. [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527) |\n| **S_OK-P1-S006** | Credit Services Organizations, Oklahoma Department of Consumer Credit. https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html | Statutes/rules, description, 60-day period, $900 charges, one-year period, $10,000 bond | Last modified Mar. 27, 2026; accessed Oct. 25, 2026 PDT. | Current operational page. Procedure and description do not substitute for statutory authority. [Welcome to Oklahoma's Official Web Site](https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html) |\n| **S_OK-P1-S007** | Oklahoma Credit Services Organization License Application, DOCC. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf | Revision date; pp. 5–8: bond, trust, branches, foreign corporations, initial and renewal charges | Form revised Mar. 4, 2024; currently linked by DOCC; accessed and visually inspected Oct. 25, 2026 PDT. | Operational application evidence, not a source of power beyond the Act and valid rules. [Welcome to Oklahoma's Official Web Site+4](https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf) |\n| **S_OK-P1-S008** | Licenses We Regulate, DOCC. https://oklahoma.gov/okdocc/licenses-we-regulate.html | CSO description; roster links; update date | Roster page updated Oct. 19, 2026; accessed Oct. 25, 2026 PDT. | Public lookup entry point. [Welcome to Oklahoma's Official Web Site](https://oklahoma.gov/okdocc/licenses-we-regulate.html) |\n| **S_OK-P1-S009** | DOCC CSO all-locations roster. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf | PDF p. 1 header and full roster | Active-license date Oct. 15, 2026; 72 total; accessed and visually inspected Oct. 25, 2026 PDT. | Proves rostered CSO license status only, not product-level debt-settlement permission or compliance. [Welcome to Oklahoma's Official Web Site+1](https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf) |\n| **S_OK-P1-S010** | Oklahoma Administrative Code official portal. https://rules.ok.gov/code | Attempted Title 160/Chapter 30 route | Fresh access attempt Oct. 25, 2026 PDT failed in the available route. | Official current rule text was not read. This is an express evidence hold. (Invalid URL) |\n| **S_OK-P1-S011** | Cornell LII quarterly mirror, Oklahoma Administrative Code Title 160, Chapter 30. Base: https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30 | §§160:30-1-1, 1-2; 3-1.1, 3-3, 3-3.1–3-3.4; 5-1; 7-1–7-3, 7-5; 9-1–9-2; 11-1–11-6 | Mirror says rules updated quarterly; chapter originally codified Dec. 31, 1991; accessed Oct. 25, 2026 PDT. | Useful secondary rule mirror. Not treated as official-current OAC. Direct section URLs appear below. [Legal Information Institute+4](https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30) |\n| **S_OK-P1-S012** | Cornell LII mirror, OAC §160:5-1-2, Fees. https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2 | Paragraph (6), Credit Services Organizations | Quarterly mirror accessed Oct. 25, 2026 PDT. | Provider-to-government charges only; not a consumer-service fee schedule. [Legal Information Institute](https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2) |\n| **S_OK-P1-S013** | Oklahoma Register archive locator for 16 Ok Reg 2145. https://digitalprairie.ok.gov/digital/api/collection/p16807coll3/id/62163/download | Attempted underlying adoption publication cited by mirror | Fresh access Oct. 25, 2026 returned unsupported JP2/image content; actual adoption text not read. | Discovery-only failed route. Not relied on for substantive rule wording or currentness. (Invalid URL) |\n| **S_OK-P1-S014** | Telemarketing Sales Rule, eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | §310.2(j), (o), (ee), (hh), (ii); §310.4(a)(2), (a)(5) | eCFR displayed Title 16 current through Oct. 22, 2026 and last amended Oct. 19, 2026; accessed Oct. 25, 2026 PDT. | Federal common context only when TSR coverage is independently satisfied. Full exemption analysis remains open. [eCFR+6](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **S_OK-P1-S015** | Credit Repair Organizations Act, U.S. Code, Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s1679a/ https://uscode.house.gov/us/usc/119-124/t15/s1679b/ https://uscode.house.gov/us/usc/119-124/t15/s1679d/ https://uscode.house.gov/us/usc/119-124/t15/s1679e/ https://uscode.house.gov/us/usc/119-124/t15/s1679j/ | 15 U.S.C. §§1679a, 1679b(b), 1679d, 1679e, 1679j | Text in effect through Pub. L. 119-124, Oct. 15, 2026; accessed Oct. 25, 2026 PDT. | Conditional federal credit-repair overlay; no universal debt-settlement coverage assumed. [U.S. Code+5](https://uscode.house.gov/us/usc/119-124/t15/s1679a/) |\n\n### S_OK-P1-S011 direct-section URL inventory\n\nThese were treated as sections of one rule compilation, not as separate invented documents:\n\nPlain text\n```\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-1-1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-1-2\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-1.1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.2\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.3\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.4\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-5-1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-2\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-3\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-5\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-9-1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-9-2\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-1\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-2\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-3\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-4\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-5\nhttps://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-6\n```\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Source IDs and pinpoints | Conditions, exceptions, currentness, and confidence limits |\n| --- | --- | --- | --- |\n| **S_OK-P1-C001** | Oklahoma prohibits engaging in or operating debt pooling. | S002 §24-15, PDF p. 5. | Current in official compilation; post-Nov.-2025 reconciliation qualified. |\n| **S_OK-P1-C002** | Debt pooling requires a debtor contract, periodic debtor payments to the provider, provider distribution among specified creditors under an agreed plan, and debtor-paid consideration for the service or connected services. | S002 §24-16, PDF p. 5. | Every element should be tested against actual contracts and fund flow. [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C003** | The pooling exclusions are limited to the four categories in §24-18. | S002 §24-18, PDF p. 5. | No generic attorney or nonprofit expansion is assumed. [Oklahoma Legislature](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C004** | A marketing label or negotiated creditor concession does not displace §24-16 when its conduct elements are present. | S002 §§24-15–16. | Statutory interpretation from conduct definition; no modern appellate application found. |\n| **S_OK-P1-C005** | Sections 24-15–18 contain no express consumer-purpose limit; application to business debt is supported textually but not resolved by located controlling authority. | S002 §§24-1, 15–18. | Inference; hold for case-law and territorial pass. |\n| **S_OK-P1-C006** | A truly noncustodial negotiator avoids the clearest receipt/distribution elements, but dedicated-account agency, control, and attribution remain unresolved. | S002 §24-16; S014 §310.4(a)(5)(ii). | No Oklahoma dedicated-account decision located. |\n| **S_OK-P1-C007** | DOCC licenses out-of-state CSOs, but the exact remote-transaction nexus was not found. | S002 §§24-142, 145(G); S007 foreign-corporation instructions; S009 roster. | Out-of-state roster presence is operational evidence, not a complete nexus rule. |\n| **S_OK-P1-C008** | A CSO is a compensated person acting with respect to third-party credit more than twelve times annually to improve credit, obtain an extension, or advise/assist concerning either. | S002 §24-132(2)(a); S003 §24-132. | Consideration may come from any source. [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C009** | A buyer is an individual; extension of credit is payment deferral for primarily personal/family/household purposes or for a person principally engaged in agriculture. | S002 §24-132(1), (3). | Ordinary corporate/commercial debts generally outside CSO branch. |\n| **S_OK-P1-C010** | Negotiating payment deferral or a revised schedule can fit “obtaining an extension of credit.” | S002 §24-132; S005 ¶¶1–6. | Strong textual inference; AG opinion concerns loan brokers, not settlement providers. [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527) |\n| **S_OK-P1-C011** | Pure immediate lump-sum principal reduction, without deferral, credit-improvement representation, or fund custody, is not clearly classified by the reviewed Oklahoma authorities. | S002 §§24-16, 132. | Held; no affirmative safe harbor or separate license inferred. |\n| **S_OK-P1-C012** | The ten CSO exclusions are activity/entity-specific, and the claimant bears the burden of proving an exception or definitional exclusion. | S002 §§24-132(2)(b), 138(B). | Exclusions do not migrate automatically to other statutes. [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C013** | A person must obtain a DOCC/Administrator license before engaging in CSO business. | S002 §§24-140–143; S006. | Subject to definitional exclusions and threshold. [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C014** | A CSO license does not authorize otherwise prohibited debt pooling. | S002 §§24-15–18, 141–143. | Structural statutory conclusion; no conflicting authority located. |\n| **S_OK-P1-C015** | Before full and complete performance, a CSO may not charge or receive consideration unless it has both the $10,000 bond and qualifying Oklahoma trust account. | S002 §24-133(1); S003 §24-133. | State condition only; other laws can remain stricter. [Oklahoma Legislature+1](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C016** | Oklahoma law supplies no trust-account amount or duration standard, and the Administrator may not create those terms by rule under the general delegation. | S004 ¶¶7–10. | Official 1987 AG opinion; no later contrary authority located. [Oklahoma State Courts Network](https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515) |\n| **S_OK-P1-C017** | Section 24-134 relieves an employee/agent of a separate bond/trust obligation when the organization complies; the application requires a bond per location and trust evidence or no-upfront-funds letter. | S002 §24-134; S007 pp. 5–6. | Not a provider-model exemption. [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C018** | Precontract disclosure and the written contract must disclose payment terms, total payments, detailed services, performance timing, refund promises, and other specified information. | S002 §§24-135–137. | Applies to covered CSOs. [Oklahoma Legislature+2](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C019** | No numerical Oklahoma CSO consumer-service fee cap or indexing mechanism was located in the reviewed statute or quarterly Chapter 30 mirror. | S002 §§24-131–146; S011 full non-revoked Chapter 30 review. | Qualified by inaccessible official-current OAC and incomplete 2026 section concordance. |\n| **S_OK-P1-C020** | Buyer may cancel within five days; payment must be returned within ten days after seller receives notice; mirror says the cancellation period does not begin until proper disclosures. | S002 §24-137; S011 §§160:30-1-2, 160:30-5-1. | “Days” as calendar days comes from secondary rule mirror pending official verification. |\n| **S_OK-P1-C021** | No general post–five-day pro rata refund formula was located; contract refund promises and refunds of unlawful charges remain operative. | S002 §§24-137, 145. | Later contract/remedies pass required. |\n| **S_OK-P1-C022** | Current $900 initial and $600 renewal amounts are government licensing/examination charges, not consumer fee ceilings. | S006; S007; S012 §160:5-1-2(6). | Rule amount relies partly on quarterly mirror. |\n| **S_OK-P1-C023** | DOCC has a current application and public roster pathway; October 15, 2026 roster reported 72 active CSO licenses. | S006–S009. | Establishes operational public market access for CSO licensing. [Welcome to Oklahoma's Official Web Site](https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf) |\n| **S_OK-P1-C024** | A roster listing proves the stated CSO license status only, not product legality, pooling exemption, federal compliance, or provider-specific authorization for debt settlement. | S009 read with S002. | No named-provider status evaluation conducted. |\n| **S_OK-P1-C025** | Official current OAC text was not recovered; the quarterly Cornell mirror was read instead. | S010–S013. | Material currentness hold; no official-rule claim overstated. |\n| **S_OK-P1-C026** | Oklahoma’s official statutory compilation is dated Nov. 18, 2025; live OSCN and 2026 agency materials corroborate continued administration, but a complete 2026 session-law concordance was not read. | S001, S003, S006, S008–S009. | High-confidence qualified currentness. |\n| **S_OK-P1-C027** | Debt pooling carries misdemeanor penalties; CSO violations can support misdemeanor liability, injunction, private damages, refunds, license action, cease-and-desist relief, and up to $5,000 civil penalty for unlicensed CSO activity. | S002 §§24-17, 138–139, 145. | Full remedies and limitations analysis remains open. [Oklahoma Legislature+3](https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf) |\n| **S_OK-P1-C028** | For a covered TSR debt-relief service, fee earning requires an executed valid debt agreement, one customer payment under it, and compliant proportional or constant-savings allocation. | S014 §§310.2(o), 310.4(a)(5)(i). | TSR coverage and exemptions must be independently established. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **S_OK-P1-C029** | A TSR-compliant dedicated account requires an insured institution, consumer ownership, independent unaffiliated administrator, no referral compensation, penalty-free withdrawal, and seven-business-day return of unearned funds. | S014 §310.4(a)(5)(ii). | Does not resolve Oklahoma pooling classification. |\n| **S_OK-P1-C030** | Covered TSR credit-improvement services cannot request or receive payment until both the represented service period expires and a qualifying later consumer report demonstrates promised results. | S014 §310.4(a)(2). | Includes FCRA permissible-purpose proviso. |\n| **S_OK-P1-C031** | CROA conditionally covers compensated interstate credit-improvement services and bars advance payment before full performance; it also imposes contract and three-business-day timing/cancellation rules. | S015 §§1679a, 1679b, 1679d, 1679e. | No universal debt-settlement coverage assumed. |\n| **S_OK-P1-C032** | Section 24-147 concerns consumer reporting agency disclosures and credit-history fees, not CSO service charges. | S002 §24-147. | Prevents false reliance on the section heading. |\n| **S_OK-P1-C033** | Oklahoma’s bond/trust exception neither legalizes debt pooling nor overrides federal timing; no separate pure-settlement license was established. | S002 §§24-15–18, 133; S014; S015. | Combined legal effect; pure-settlement branch held. |\n| **S_OK-P1-C034** | The meaning of “more than twelve times in a calendar year” is express, but the counting unit is not defined in the reviewed text. | S002 §24-132(2)(a). | Requires agency interpretation or case authority. |\n| **S_OK-P1-C035** | The quarterly rule mirror refers to claimed bond exemptions, but the exact substantive provider-level exemption basis was not established. | S011 §160:30-7-5; S002 §§24-133–134, 143. | Do not infer a general exemption. [Legal Information Institute](https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-5) |\n| **S_OK-P1-C036** | No controlling Oklahoma appellate decision applying §§24-15–18 to a modern debt-settlement/dedicated-account model or applying the CSO Act to debt settlement was located. | S003 citationizer; targeted public OSCN searching. | Search limitation, not proof that no decision exists; commercial citator pass remains. |\n| **S_OK-P1-C037** | Truly gratuitous counseling is outside the literal CSO definition only when no valuable consideration comes from any source. | S002 §24-132(2)(a). | Indirect, creditor, affiliate, or lead compensation can change result. |\n| **S_OK-P1-C038** | A self-creditor is likely outside Oklahoma’s “extension of credit by others” formulation; CROA expressly excludes a creditor restructuring its own debt. | S002 §24-132(2)(a); S015 §1679a(3)(B)(ii). | Oklahoma conclusion is textual inference; CROA exclusion is express. |\n\n# D. Worked examples and scope-coverage table\n\n## Example 1 — Direct custodial DMP/debt pooling\n\n**Inputs**\n\n- Debtor pays provider: $500 each month.\n- Provider retains service charge: $25.\n- Provider distributes remaining $475 among three named creditors under a prearranged plan.\n- No §24-18 exclusion is assumed.\n\n**Base**\n\nPeriodic debtor payment to provider: $500/month.\n\n**Operator**\n\nProvider receives the periodic sum, distributes it among specified creditors, and receives valuable consideration.\n\n**Intermediate**\n\n$500 − $25 = $475 distributed.\n\n**Result**\n\nThe facts satisfy the literal §24-16 elements. Section 24-15 prohibits the covered business absent a real §24-18 exclusion.\n\n**Units and rounding**\n\nDollars per month; no rounding issue.\n\n**Legal consequence**\n\nThe $25 is not validated merely because it is modest. There is no lawful nonexempt fee calculation to perform. The correct result is **prohibited model**, not “maximum fee = $0.” [C001–C004.]\n\n## Example 2 — Oklahoma CSO timing without and with trust-account qualification\n\n**Assumptions**\n\n- The provider is otherwise a covered, licensed, noncustodial CSO.\n- The agreement promises four integrated services for a total contracted fee of $600.\n- Forty percent of internal work is complete.\n- No federal rule is considered in the first branch.\n- The model does not constitute debt pooling.\n\n### Branch A: bond but no qualifying trust account\n\n**Inputs**\n\nContracted fee: $600.\nPerformance completed: 40%.\n\n**Operator**\n\nSection 24-133 bars charging or receiving consideration before full and complete performance unless both the bond and trust conditions are met.\n\n**Arithmetic**\n\n$600 × 40% = $240 represents an internal progress value, but Oklahoma supplies no progress-payment formula.\n\n**Result**\n\nAmount chargeable/receivable at this point under the stated Oklahoma branch: **$0**.\n\nThis is a timing result, not a finding that the service’s lawful total fee is $0.\n\n### Branch B: accepted $10,000 bond plus qualifying Oklahoma trust account\n\nThe particular §24-133 advance-payment barrier is excepted. The total $600 remains subject to:\n\n- contract and total-payment disclosure;\n- five-day cancellation;\n- any promised refund terms;\n- prohibition against fraud or deception;\n- federal TSR or CROA timing if applicable; and\n- the requirement that the underlying activity not be prohibited debt pooling.\n\nOklahoma’s exception does not itself say that all $600 is immediately earned. [C015–C016, C018–C019, C033.]\n\n## Example 3 — Timely Oklahoma cancellation\n\n**Assumptions**\n\n- Otherwise lawful CSO contract.\n- Provider collected $100 on signing under the state bond/trust branch.\n- All required disclosures were properly furnished.\n- Buyer delivers written cancellation on calendar day three.\n- Seller receives the notice that day.\n\n**Base**\n\nPayment received: $100.\n\n**Operator**\n\nTimely five-day cancellation; payment must be returned within ten days following seller’s receipt of notice.\n\n**Result**\n\nRefund due: **$100**.\nDeadline: within ten days after receipt of cancellation notice.\n\n**Rounding**\n\nNone.\n\n**Failure branch**\n\nIf the required disclosures were not properly furnished, the quarterly OAC mirror states that the cancellation period has not begun. Because the official rule portal was unavailable, that branch carries the S010–S011 currentness qualification.\n\n**Later-cancellation branch**\n\nIf cancellation occurs after the statutory five-day period, this example supplies no automatic pro rata formula. Contract refund promises, unlawful-charge relief, other law, and actual performance must be analyzed. [C020–C021.]\n\n## Example 4 — TSR proportional-to-enrolled-debt allocation\n\n**Assumptions**\n\n- TSR applies.\n- The Oklahoma service itself is lawful and is not prohibited pooling.\n- Two debts were enrolled under one contract.\n- Total contracted fee: $2,000.\n- The provider consistently uses the proportional-enrolled-balance method.\n- Debt A has a customer-executed valid settlement agreement, and the customer has made one payment under it.\n- Debt B has not triggered.\n\n**Inputs**\n\nDebt A enrolled balance: $6,000.\nDebt B enrolled balance: $4,000.\nTotal enrolled balance: $10,000.\nTotal contracted fee: $2,000.\n\n**Operator**\n\nFee for Debt A = total contracted fee × Debt A enrolled balance ÷ total enrolled balance.\n\n**Intermediate**\n\n$6,000 ÷ $10,000 = 0.60.\n$2,000 × 0.60 = $1,200.\n\n**Result**\n\nTSR-earned fee for Debt A: **$1,200**.\nFee for Debt B at this time: **$0**.\n\n**Remaining potential allocation**\n\n$2,000 − $1,200 = $800, but that $800 does not become earned until Debt B separately satisfies the required agreement and payment triggers.\n\n**Units and rounding**\n\nDollars; exact result, no rounding.\n\n**State interaction**\n\nIf the Oklahoma CSO lacks the bond/trust qualification and has not fully completed the entire agreed service, Oklahoma §24-133 may still be more restrictive than the debt-by-debt TSR trigger. [C015, C028, C033.]\n\n## Example 5 — TSR percentage-of-savings method\n\n**Assumptions**\n\n- TSR applies.\n- Provider uses a constant 25% savings fee for every debt.\n- Debt A satisfies both federal earning triggers.\n\n**Inputs**\n\nDebt A enrolled balance: $6,000.\nAmount actually paid to satisfy Debt A: $3,000.\nContractual savings percentage: 25%.\n\n**Operator 1: calculate savings**\n\n$6,000 − $3,000 = $3,000 savings.\n\n**Operator 2: apply constant percentage**\n\n$3,000 × 25% = $750.\n\n**Result**\n\nTSR-earned fee for Debt A: **$750**.\n\n**Failure cases**\n\n- The provider cannot use 25% on Debt A and 30% on Debt B.\n- It cannot switch Debt B to the proportional-enrolled-balance method merely because that produces a larger fee under the same contracted program.\n- An unaccepted offer or a signed agreement without the customer’s first payment produces an earned fee of $0.\n- Oklahoma state timing remains independently applicable. [C028.]\n\n## Example 6 — Lower debt, prior fee, and later cancellation\n\n**Assumptions**\n\n- TSR applies.\n- Total contracted fee is $400.\n- The same proportional method and original enrolled balances apply to both debts.\n- Debt B triggers first.\n- Debt A never triggers before cancellation.\n\n**Inputs**\n\nDebt A: $1,200 enrolled.\nDebt B: $800 enrolled.\nTotal enrolled: $2,000.\nTotal contracted fee: $400.\n\n**Debt B operator**\n\n$400 × ($800 ÷ $2,000)\n= $400 × 0.40\n= $160.\n\n**Result after Debt B trigger**\n\nEarned fee for Debt B: **$160**.\n\n**Debt A result at cancellation**\n\nDebt A has no executed-and-paid qualifying agreement. Its TSR-earned fee is **$0**.\n\n**Consistency check**\n\nThe previously earned $160 arose from the same enrolled balances, same total contracted fee, and same proportional allocation method. No second subtraction or method switch is made.\n\n**Refund limitation**\n\nWhether the already earned $160 must nevertheless be returned under Oklahoma contract law, a timely state cancellation, a specific refund promise, or another remedy depends on facts not supplied here. The TSR arithmetic alone does not answer that separate question. [C020–C021, C028.]\n\n## Example 7 — Settlement signed but no creditor payment\n\n**Inputs**\n\n- Enrolled debt: $5,000.\n- Creditor and customer execute a valid settlement for $2,500.\n- Customer has not made any payment under the settlement.\n- Contracted savings fee: 20%.\n\n**Potential arithmetic only**\n\nSavings would be $5,000 − $2,500 = $2,500.\nPotential fee would be $2,500 × 20% = $500.\n\n**Trigger analysis**\n\nThe customer has made no payment under the customer-creditor agreement.\n\n**Actual result**\n\nTSR-earned fee now: **$0**.\n\nThe $500 is merely a potential future amount if all earning conditions are later satisfied. [C028.]\n\n## Example 8 — Dedicated account withdrawal\n\n**Assumptions**\n\n- TSR applies.\n- Consumer deposits $500 in a qualifying independent dedicated account.\n- No debt has yet satisfied the agreement-and-payment triggers.\n- No lawfully earned fee exists.\n- Consumer asks to leave the program.\n\n**Base**\n\nConsumer-owned account balance: $500.\n\n**Lawfully earned fees**\n\n$0.\n\n**Operator**\n\nReturn all funds other than fees lawfully earned under §310.4(a)(5)(i).\n\n**Result**\n\nAmount to return: **$500**, within seven business days of the request.\n\n**Oklahoma hold**\n\nThis federal result does not decide whether the underlying Oklahoma arrangement constitutes debt pooling. The provider’s legal control, payment instructions, agency relationship, account administrator, and creditor-distribution process still require Oklahoma analysis. [C006, C029.]\n\n## Pass coverage and gap table\n\n| Component | Status | Claims | What this pass established | Exact missing evidence or next action |\n| --- | --- | --- | --- | --- |\n| Debt-pooling definition and prohibition | **Answered** | C001–C004 | Elements, prohibition, narrow exclusions, penalty | Later case-law pass should test modern settlement and dedicated-account fact patterns. |\n| Principal reduction versus concession/distribution | **Answered/partial** | C004, C006, C010–C011 | Concessions do not negate pooling; pure noncustodial lump-sum reduction remains outside clear classification | Obtain Oklahoma agency interpretation or controlling case addressing pure noncustodial settlement. |\n| Custodial versus noncustodial models | **Answered/partial** | C002, C006 | Direct receipt/distribution is clearest pooling branch | Resolve agency, constructive receipt, processor attribution, and account-control doctrines. |\n| Consumer/business-purpose boundary | **Partial** | C005, C009 | CSO consumer/agricultural boundary identified; pooling statute has no express purpose limitation | Controlling case or AG/agency authority on commercial debt pooling. |\n| Remote-provider/resident nexus | **Partial** | C007, C023 | Out-of-state licensing is operationally established | Statutory, rule, order, or case stating transaction-level Oklahoma nexus. |\n| CSO definition and annual threshold | **Answered/partial** | C008–C010, C034 | Definition and >12 threshold identified | Interpretation of what is counted “more than twelve times.” |\n| CSO licensing authority | **Answered** | C013, C023 | DOCC regulator, application, bond, fees, public roster | No application filing or provider contact is warranted in this research pass. |\n| Prohibited pooling versus licensed CSO | **Answered** | C014, C033 | CSO license does not cure pooling | Product-specific facts remain necessary. |\n| Entity/activity exclusions | **Answered for operative text** | C003, C012, C038 | Attorney, nonprofit, lender, institutional, self-creditor boundaries identified | Full professional-practice, nonprofit-control, affiliate, and lender-law pass remains. |\n| State consumer fee amounts/caps | **Answered with currentness qualification** | C019, C032 | No numerical service-fee cap or indexing located | Read official-current OAC export and complete 2026 session-law concordance. |\n| State payment timing | **Answered** | C015–C017 | Full-performance rule and bond/trust exception | Interpretation of “full and complete performance” for multidebt contracts. |\n| State cancellation/refund | **Answered/partial** | C020–C021 | Five-day cancellation and ten-day return; unlawful-charge refund authority | Full contract remedies, rescission, restitution, and post-cancellation accounting pass. |\n| Bond and trust mechanics | **Partial** | C015–C017, C035 | $10,000 bond; trust required for state advance-payment branch; AG limit | Official rule text, bond forms, substantive basis for any claimed bond exemption, trust ownership/accounting rules. |\n| Government licensing charges | **Answered** | C022 | Current operational application and mirror amounts | Official-current OAC confirmation. |\n| Public lookup/current market access | **Answered** | C023–C024 | Application route and October 2026 roster | Provider-specific product authorization requires separate evidence; none was attempted. |\n| Federal TSR debt-relief timing | **Answered as common context** | C028–C030 | Definitions, earning triggers, allocation, dedicated account, credit-repair timing | Full TSR exemptions, inbound/outbound coverage, attorney/nonprofit treatment, and federal case law remain open. |\n| CROA overlap | **Answered as conditional context** | C031, C038 | Definition, exclusions, advance-fee, contract and cancellation rules | Debt-settlement-specific federal case-law and entity/factual application remain open. |\n| Official current Oklahoma rules | **Unresolved** | C025 | Failure route preserved; quarterly mirror read | Recover rules.ok.gov official text or certified/current state export; compare section by section. |\n| 2026 Oklahoma statutory amendments | **Partial/unresolved** | C026 | Compilation date and 2026 operational corroboration recorded | Complete official 2026 session-law concordance for §§24-15–18 and 131–148. |\n| Controlling Oklahoma decisions | **Partial/unresolved** | C036 | Two AG opinions read; no controlling modern appellate decision located publicly | Commercial citator and broader OSCN docket/opinion search with statute variations and historical numbering. |\n| Agreement contents beyond fee/timing needs | **Partial by boundary** | C018, C020 | Minimum disclosure and cancellation provisions read | Full agreement-form, electronic contracting, severability, assignment, choice-of-law, and enforceability pass. |\n| Funds, fiduciary, processor, money-transmission law | **Excluded/open** | C006, C029 | Only minimum dedicated-account issue identified | Separate funds/custody/trust/money-transmitter investigation. |\n| Full bond, remedies, examinations, enforcement | **Partial by necessity** | C027 | Minimum penalties/refund/license consequences identified | Complete administrative, criminal, private-right, limitation, and remedial interaction pass. |\n| Collections, creditor conduct, litigation, limitations, judgments, garnishment, exemptions | **Excluded/open** | — | Not investigated except where needed for provider classification | Separate parent-state dimensions. |\n| Secured debt, mortgages, auto, medical, student, tax, utilities, and sector rules | **Excluded/open** | — | No sector-wide conclusions | Separate sector passes. |\n| Local ordinances and tribal law | **Excluded/open** | — | No local or tribal conclusion | Oklahoma municipal, county, and tribal jurisdiction investigation. |\n| Contract, conflicts, territorial reach, and case law | **Excluded/open except identified nexus issue** | C005–C007, C036 | Gaps identified | Dedicated choice-of-law, Oklahoma nexus, arbitration, UPL, and contract-enforcement pass. |\n| Named-provider authorization | **Not performed** | C024 | Public verification method identified | Search exact legal name and location only when separately authorized and product facts are available. |\n\n# E. Researcher self-check\n\n## Actually read or inspected\n\n- The official Oklahoma Title 24 PDF, including §§24-1, 15–18, and 131–148, with visual inspection of the relevant PDF pages.\n- Live OSCN text for §§24-131–133 and the §131 citationizer.\n- 1987 OK AG 104 and 1987 OK AG 126 in full relevant part.\n- DOCC’s current CSO page, application, regulated-industries roster page, and October 15, 2026 all-locations roster, including visual inspection of the application and roster PDFs.\n- Every non-revoked Chapter 30 provision material to licensing, cancellation, bond, records, examination, and enforcement that was visible in the quarterly Cornell mirror, plus the Title 160 government-fee rule.\n- Current eCFR text for 16 C.F.R. §§310.2 and 310.4.\n- Current U.S. Code text for the cited CROA provisions.\n- Targeted official Oklahoma legislative and public OSCN searches for recent amendments and judicial authority.\n\n## Not actually read or not established\n\n- An official-current export of Oklahoma Administrative Code Title 160, because rules.ok.gov failed in the available public-web route.\n- The underlying Oklahoma Register adoption text at 16 Ok Reg 2145, because the archive returned unsupported JP2/image content.\n- A complete section-by-section 2026 Oklahoma session-law concordance.\n- A commercial citator’s complete case history for §§24-15–18 and 131–148.\n- Any nonpublic agency interpretation, examination manual, advisory letter, enforcement file, application file, or provider correspondence.\n- Any named provider’s current product-level authorization, contract, fund flow, federal coverage, or compliance.\n- Full Oklahoma funds, bond, remedies, collections, limitations, litigation, property-exemption, secured-debt, sector, local, tribal, contract, choice-of-law, or case-law dimensions.\n\n## Method and assertion controls\n\n- Discovery snippets were not treated as operative law.\n- The DOCC application and roster were used as procedural evidence, not as substitutes for statutory permission.\n- The Cornell rule mirror was expressly identified as secondary and was not represented as the official current OAC.\n- The 2025 statutory-compilation date was not silently converted into an October 2026 current-through date.\n- No CPI calculation, adjusted consumer fee, trust-account amount, fee ceiling, exemption, or refund formula was invented.\n- No CSO license was treated as authority to conduct prohibited debt pooling.\n- State fee ceilings and state timing were kept separate from federal TSR and CROA timing.\n- Worked examples distinguish arithmetic validity, contractual consistency, actual earning triggers, state model legality, and unresolved refund interpretation.\n- No application was filed, no person or agency was contacted, no account or permission was changed, no other Chat was created, and no private borrower information was used.\n- No local file was written, and this response is not represented as independently reviewed or publication-ready.\n- All remaining Oklahoma parent-state dimensions remain open; no state-level or A066 acceptance is implied.\n\nEND S_OK PASS-01.\n\n","tables":[{"headers":["Business model","Oklahoma result established in this pass","Fee consequence"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Oklahoma result established in this pass","Fee consequence"],["Provider contracts with a debtor, receives the debtor’s periodic payments, distributes them among specified creditors under an agreed plan, and receives consideration","Debt pooling; prohibited, unless one of the narrow §24-18 exclusions actually applies. This is not an ordinary licensable debt-settlement category. [C001–C004]","No lawful nonexempt fee pathway was established. Calling the result a “$0 fee cap” would be misleading; the underlying covered model is prohibited."],["For-profit noncustodial provider seeks a payment extension, forbearance, revised schedule, or other deferral for an individual consumer more than twelve times per calendar year for consideration","Strong textual fit with the Credit Services Organization Act, subject to facts and exclusions; DOCC license required. [C008–C010, C013]","No numerical Oklahoma consumer-fee ceiling was located, but disclosure, contract, cancellation, licensing, and payment-timing restrictions apply."],["Noncustodial provider negotiates only an immediate lump-sum principal reduction, makes no express or implied credit-improvement representation, does not seek a payment deferral, and never receives or distributes debtor funds","Unresolved outside-category branch. The reviewed Oklahoma authorities did not establish that this is a CSO, debt pooling, a separately licensed settlement service, or affirmatively unregulated. [C006, C011, C033]","No Oklahoma fee pathway or cap should be invented. Additional conduct facts and authority are required."],["Provider represents that it will improve a consumer’s credit record, history, or rating","Potential Oklahoma CSO coverage and conditional federal credit-repair overlap. [C008, C030–C031]","Oklahoma’s bond/trust exception does not override independently applicable federal advance-fee prohibitions."],["Consumer pays periodically into a genuinely independent, consumer-owned dedicated account","Federal TSR may permit the account under specified conditions, but the Oklahoma debt-pooling characterization depends on who legally and practically receives, controls, directs, or distributes the funds. [C006, C029]","Deposits are not automatically earned fees. State classification and federal earning triggers remain separate."],["Truly gratuitous counseling, with no money or other valuable consideration from the consumer or any other source","Outside the literal Oklahoma CSO definition; debt-pooling analysis still depends on whether the debtor separately pays consideration and the provider handles distributions. [C002, C037]","No fee exists on the stated facts. “Free to the consumer” is insufficient if a creditor or another source pays the provider."],["General business-purpose debt","Generally outside the CSO definition, except the individual-agricultural branch, but §§24-15–18 contain no express consumer-purpose limitation. [C005, C009]","Business-purpose debt-pooling coverage is a textual inference, not a case-resolved holding."],["Remote/out-of-state provider serving Oklahoma residents","DOCC demonstrably licenses out-of-state CSOs, but the precise transaction-level nexus test was not found in the reviewed statute or rules. [C007, C023]","An out-of-state address is not a safe harbor; the exact solicitation/residency/transaction nexus remains open."]]},{"headers":["Conduct","Oklahoma CSO analysis"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Conduct","Oklahoma CSO analysis"],["Negotiating a longer payment period, forbearance, revised installment schedule, or delayed payment obligation for an individual consumer","Strong textual basis for “obtaining an extension of credit,” although no debt-settlement-specific Oklahoma holding was located. The 1987 Attorney General opinion construed the extension-of-credit language broadly enough to cover a third-party loan broker. [C010; S005.]"],["Advising a consumer how to obtain that deferral","Potentially covered as advice or assistance concerning an extension of credit."],["Representing that settlement will improve the consumer’s credit","Independently supports CSO treatment through the credit-improvement branch; federal CROA and TSR credit-repair rules may also apply. [C008, C030–C031.]"],["Negotiating an immediate lump-sum payoff for less principal, with no deferral and no credit-improvement representation","Not clearly within “obtaining an extension of credit.” No separate Oklahoma settlement-provider category was established. Held. [C011, C033.]"],["Free counseling","Outside the literal definition only if no valuable consideration comes from any source. Creditor-paid “fair share,” lead compensation, affiliate payments, or other indirect value can change the answer. [C037.]"],["Corporate or ordinary commercial debt","Generally outside because the buyer must be an individual and the credit must be consumer-purpose or within the agricultural branch."],["Individual agricultural borrower","Expressly included in the extension-of-credit definition. [C009.]"],["More than twelve times annually","Express threshold, but the statute does not specify whether the unit is buyers, contracts, services, representations, or transactions. That counting question remains unresolved. [C034.]"]]},{"headers":["Circumstances","Oklahoma CSO Act result"],"index":2,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Circumstances","Oklahoma CSO Act result"],["No qualifying bond and trust account","The CSO may not charge or receive consideration until full and complete performance of the agreed services."],["$10,000 bond plus qualifying Oklahoma trust account","The specific §24-133(1) state advance-payment bar is excepted, but disclosure, contract, cancellation, fraud, licensing, and all independently applicable law remain."],["Employee, salesperson, or agent of a compliant organization","Section 24-134 excuses that person from obtaining a separate bond and trust account; it does not exempt the organization or create a new business-model exemption."],["Prohibited debt pooling","The CSO timing exception does not legalize the pooling arrangement."],["Service also covered by the TSR or CROA","The stricter independently applicable federal rule still controls its own scope."]]},{"headers":["Source ID","Title, issuer, and direct literal URL","Exact pinpoints read","Version/effective status and fresh access","Jurisdiction, use, and limitations"],"index":3,"links":[{"href":"https://www.oklegislature.gov/osStatuesTitle.html","text":"Oklahoma Legislature"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+5"},{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249","text":"Oklahoma State Courts Network\n+2"},{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","text":"Oklahoma State Courts Network"},{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","text":"Oklahoma State Courts Network"},{"href":"https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html","text":"Welcome to Oklahoma's Official Web Site"},{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf","text":"Welcome to Oklahoma's Official Web Site\n+4"},{"href":"https://oklahoma.gov/okdocc/licenses-we-regulate.html","text":"Welcome to Oklahoma's Official Web Site"},{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","text":"Welcome to Oklahoma's Official Web Site\n+1"},{"href":"https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30","text":"Legal Information Institute\n+4"},{"href":"https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2","text":"Legal Information Institute"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+6"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+5"}],"row_links":[[],[{"href":"https://www.oklegislature.gov/osStatuesTitle.html","text":"Oklahoma Legislature"}],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+5"}],[{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249","text":"Oklahoma State Courts Network\n+2"}],[{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","text":"Oklahoma State Courts Network"}],[{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","text":"Oklahoma State Courts Network"}],[{"href":"https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html","text":"Welcome to Oklahoma's Official Web Site"}],[{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf","text":"Welcome to Oklahoma's Official Web Site\n+4"}],[{"href":"https://oklahoma.gov/okdocc/licenses-we-regulate.html","text":"Welcome to Oklahoma's Official Web Site"}],[{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","text":"Welcome to Oklahoma's Official Web Site\n+1"}],[],[{"href":"https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30","text":"Legal Information Institute\n+4"}],[{"href":"https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2","text":"Legal Information Institute"}],[],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+6"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+5"}]],"rows":[["Source ID","Title, issuer, and direct literal URL","Exact pinpoints read","Version/effective status and fresh access","Jurisdiction, use, and limitations"],["S_OK-P1-S001","Oklahoma Statutes index, Oklahoma Legislature. https://www.oklegislature.gov/osStatuesTitle.html","Page note; Title 24 link","Page says statutes last updated Nov. 18, 2025. Accessed Oct. 25, 2026 PDT.","Official source for compilation date. It does not itself reconcile 2026 session laws. \nOklahoma Legislature"],["S_OK-P1-S002","Oklahoma Statutes, Title 24, Debtor and Creditor, Oklahoma Legislature. https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","§§24-1; 24-15–18; 24-131–148, especially §§132–145; PDF pp. 5, 21–31","Official compilation associated with S001’s Nov. 18, 2025 update. Accessed and PDF pages visually inspected Oct. 25, 2026 PDT.","Principal Oklahoma statutory source. Post-Nov.-2025 amendment completeness remains qualified. \nOklahoma Legislature\n+5"],["S_OK-P1-S003","OSCN citationized CSO provisions and citationizer, Oklahoma State Courts Network. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71250 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71251","§§24-131–133; histories; citationizer for §131","Live pages accessed Oct. 25, 2026 PDT; no explicit current-through date.","Official judiciary source corroborating text and locating the two AG opinions. It is not a legislative-session concordance. \nOklahoma State Courts Network\n+2"],["S_OK-P1-S004","1987 OK AG 104, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","¶¶0, 4–10; decided Oct. 12, 1987","Official opinion accessed Oct. 25, 2026 PDT.","Establishes lack of authority to prescribe trust-account amount or duration by rule; not a modern debt-settlement classification decision. \nOklahoma State Courts Network"],["S_OK-P1-S005","1987 OK AG 126, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","¶¶0–6; decided Dec. 14, 1987","Official opinion accessed Oct. 25, 2026 PDT.","Applies CSO definition to third-party loan brokers and supports broad reading of payment deferral; not a holding about debt settlement. \nOklahoma State Courts Network"],["S_OK-P1-S006","Credit Services Organizations, Oklahoma Department of Consumer Credit. https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html","Statutes/rules, description, 60-day period, $900 charges, one-year period, $10,000 bond","Last modified Mar. 27, 2026; accessed Oct. 25, 2026 PDT.","Current operational page. Procedure and description do not substitute for statutory authority. \nWelcome to Oklahoma's Official Web Site"],["S_OK-P1-S007","Oklahoma Credit Services Organization License Application, DOCC. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf","Revision date; pp. 5–8: bond, trust, branches, foreign corporations, initial and renewal charges","Form revised Mar. 4, 2024; currently linked by DOCC; accessed and visually inspected Oct. 25, 2026 PDT.","Operational application evidence, not a source of power beyond the Act and valid rules. \nWelcome to Oklahoma's Official Web Site\n+4"],["S_OK-P1-S008","Licenses We Regulate, DOCC. https://oklahoma.gov/okdocc/licenses-we-regulate.html","CSO description; roster links; update date","Roster page updated Oct. 19, 2026; accessed Oct. 25, 2026 PDT.","Public lookup entry point. \nWelcome to Oklahoma's Official Web Site"],["S_OK-P1-S009","DOCC CSO all-locations roster. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","PDF p. 1 header and full roster","Active-license date Oct. 15, 2026; 72 total; accessed and visually inspected Oct. 25, 2026 PDT.","Proves rostered CSO license status only, not product-level debt-settlement permission or compliance. \nWelcome to Oklahoma's Official Web Site\n+1"],["S_OK-P1-S010","Oklahoma Administrative Code official portal. https://rules.ok.gov/code","Attempted Title 160/Chapter 30 route","Fresh access attempt Oct. 25, 2026 PDT failed in the available route.","Official current rule text was not read. This is an express evidence hold. (Invalid URL)"],["S_OK-P1-S011","Cornell LII quarterly mirror, Oklahoma Administrative Code Title 160, Chapter 30. Base: https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30","§§160:30-1-1, 1-2; 3-1.1, 3-3, 3-3.1–3-3.4; 5-1; 7-1–7-3, 7-5; 9-1–9-2; 11-1–11-6","Mirror says rules updated quarterly; chapter originally codified Dec. 31, 1991; accessed Oct. 25, 2026 PDT.","Useful secondary rule mirror. Not treated as official-current OAC. Direct section URLs appear below. \nLegal Information Institute\n+4"],["S_OK-P1-S012","Cornell LII mirror, OAC §160:5-1-2, Fees. https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2","Paragraph (6), Credit Services Organizations","Quarterly mirror accessed Oct. 25, 2026 PDT.","Provider-to-government charges only; not a consumer-service fee schedule. \nLegal Information Institute"],["S_OK-P1-S013","Oklahoma Register archive locator for 16 Ok Reg 2145. https://digitalprairie.ok.gov/digital/api/collection/p16807coll3/id/62163/download","Attempted underlying adoption publication cited by mirror","Fresh access Oct. 25, 2026 returned unsupported JP2/image content; actual adoption text not read.","Discovery-only failed route. Not relied on for substantive rule wording or currentness. (Invalid URL)"],["S_OK-P1-S014","Telemarketing Sales Rule, eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§310.2(j), (o), (ee), (hh), (ii); §310.4(a)(2), (a)(5)","eCFR displayed Title 16 current through Oct. 22, 2026 and last amended Oct. 19, 2026; accessed Oct. 25, 2026 PDT.","Federal common context only when TSR coverage is independently satisfied. Full exemption analysis remains open. \neCFR\n+6"],["S_OK-P1-S015","Credit Repair Organizations Act, U.S. Code, Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s1679a/ https://uscode.house.gov/us/usc/119-124/t15/s1679b/ https://uscode.house.gov/us/usc/119-124/t15/s1679d/ https://uscode.house.gov/us/usc/119-124/t15/s1679e/ https://uscode.house.gov/us/usc/119-124/t15/s1679j/","15 U.S.C. §§1679a, 1679b(b), 1679d, 1679e, 1679j","Text in effect through Pub. L. 119-124, Oct. 15, 2026; accessed Oct. 25, 2026 PDT.","Conditional federal credit-repair overlay; no universal debt-settlement coverage assumed. \nU.S. Code\n+5"]]},{"headers":["Claim ID","Precise assertion","Source IDs and pinpoints","Conditions, exceptions, currentness, and confidence limits"],"index":4,"links":[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"},{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","text":"Oklahoma State Courts Network"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"},{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","text":"Oklahoma State Courts Network"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+2"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+2"},{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","text":"Welcome to Oklahoma's Official Web Site"},{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+3"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+2"},{"href":"https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-5","text":"Legal Information Institute"}],"row_links":[[],[],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature"}],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature"}],[],[],[],[],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"}],[],[{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","text":"Oklahoma State Courts Network"}],[],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"}],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"}],[],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+1"}],[{"href":"https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","text":"Oklahoma State Courts Network"}],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+2"}],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+2"}],[],[],[],[],[{"href":"https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","text":"Welcome to Oklahoma's Official Web Site"}],[],[],[],[{"href":"https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","text":"Oklahoma Legislature\n+3"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+2"}],[],[],[],[],[],[],[{"href":"https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-5","text":"Legal Information Institute"}],[],[],[]],"rows":[["Claim ID","Precise assertion","Source IDs and pinpoints","Conditions, exceptions, currentness, and confidence limits"],["S_OK-P1-C001","Oklahoma prohibits engaging in or operating debt pooling.","S002 §24-15, PDF p. 5.","Current in official compilation; post-Nov.-2025 reconciliation qualified."],["S_OK-P1-C002","Debt pooling requires a debtor contract, periodic debtor payments to the provider, provider distribution among specified creditors under an agreed plan, and debtor-paid consideration for the service or connected services.","S002 §24-16, PDF p. 5.","Every element should be tested against actual contracts and fund flow. \nOklahoma Legislature"],["S_OK-P1-C003","The pooling exclusions are limited to the four categories in §24-18.","S002 §24-18, PDF p. 5.","No generic attorney or nonprofit expansion is assumed. \nOklahoma Legislature"],["S_OK-P1-C004","A marketing label or negotiated creditor concession does not displace §24-16 when its conduct elements are present.","S002 §§24-15–16.","Statutory interpretation from conduct definition; no modern appellate application found."],["S_OK-P1-C005","Sections 24-15–18 contain no express consumer-purpose limit; application to business debt is supported textually but not resolved by located controlling authority.","S002 §§24-1, 15–18.","Inference; hold for case-law and territorial pass."],["S_OK-P1-C006","A truly noncustodial negotiator avoids the clearest receipt/distribution elements, but dedicated-account agency, control, and attribution remain unresolved.","S002 §24-16; S014 §310.4(a)(5)(ii).","No Oklahoma dedicated-account decision located."],["S_OK-P1-C007","DOCC licenses out-of-state CSOs, but the exact remote-transaction nexus was not found.","S002 §§24-142, 145(G); S007 foreign-corporation instructions; S009 roster.","Out-of-state roster presence is operational evidence, not a complete nexus rule."],["S_OK-P1-C008","A CSO is a compensated person acting with respect to third-party credit more than twelve times annually to improve credit, obtain an extension, or advise/assist concerning either.","S002 §24-132(2)(a); S003 §24-132.","Consideration may come from any source. \nOklahoma Legislature\n+1"],["S_OK-P1-C009","A buyer is an individual; extension of credit is payment deferral for primarily personal/family/household purposes or for a person principally engaged in agriculture.","S002 §24-132(1), (3).","Ordinary corporate/commercial debts generally outside CSO branch."],["S_OK-P1-C010","Negotiating payment deferral or a revised schedule can fit “obtaining an extension of credit.”","S002 §24-132; S005 ¶¶1–6.","Strong textual inference; AG opinion concerns loan brokers, not settlement providers. \nOklahoma State Courts Network"],["S_OK-P1-C011","Pure immediate lump-sum principal reduction, without deferral, credit-improvement representation, or fund custody, is not clearly classified by the reviewed Oklahoma authorities.","S002 §§24-16, 132.","Held; no affirmative safe harbor or separate license inferred."],["S_OK-P1-C012","The ten CSO exclusions are activity/entity-specific, and the claimant bears the burden of proving an exception or definitional exclusion.","S002 §§24-132(2)(b), 138(B).","Exclusions do not migrate automatically to other statutes. \nOklahoma Legislature\n+1"],["S_OK-P1-C013","A person must obtain a DOCC/Administrator license before engaging in CSO business.","S002 §§24-140–143; S006.","Subject to definitional exclusions and threshold. \nOklahoma Legislature\n+1"],["S_OK-P1-C014","A CSO license does not authorize otherwise prohibited debt pooling.","S002 §§24-15–18, 141–143.","Structural statutory conclusion; no conflicting authority located."],["S_OK-P1-C015","Before full and complete performance, a CSO may not charge or receive consideration unless it has both the $10,000 bond and qualifying Oklahoma trust account.","S002 §24-133(1); S003 §24-133.","State condition only; other laws can remain stricter. \nOklahoma Legislature\n+1"],["S_OK-P1-C016","Oklahoma law supplies no trust-account amount or duration standard, and the Administrator may not create those terms by rule under the general delegation.","S004 ¶¶7–10.","Official 1987 AG opinion; no later contrary authority located. \nOklahoma State Courts Network"],["S_OK-P1-C017","Section 24-134 relieves an employee/agent of a separate bond/trust obligation when the organization complies; the application requires a bond per location and trust evidence or no-upfront-funds letter.","S002 §24-134; S007 pp. 5–6.","Not a provider-model exemption. \nOklahoma Legislature\n+2"],["S_OK-P1-C018","Precontract disclosure and the written contract must disclose payment terms, total payments, detailed services, performance timing, refund promises, and other specified information.","S002 §§24-135–137.","Applies to covered CSOs. \nOklahoma Legislature\n+2"],["S_OK-P1-C019","No numerical Oklahoma CSO consumer-service fee cap or indexing mechanism was located in the reviewed statute or quarterly Chapter 30 mirror.","S002 §§24-131–146; S011 full non-revoked Chapter 30 review.","Qualified by inaccessible official-current OAC and incomplete 2026 section concordance."],["S_OK-P1-C020","Buyer may cancel within five days; payment must be returned within ten days after seller receives notice; mirror says the cancellation period does not begin until proper disclosures.","S002 §24-137; S011 §§160:30-1-2, 160:30-5-1.","“Days” as calendar days comes from secondary rule mirror pending official verification."],["S_OK-P1-C021","No general post–five-day pro rata refund formula was located; contract refund promises and refunds of unlawful charges remain operative.","S002 §§24-137, 145.","Later contract/remedies pass required."],["S_OK-P1-C022","Current $900 initial and $600 renewal amounts are government licensing/examination charges, not consumer fee ceilings.","S006; S007; S012 §160:5-1-2(6).","Rule amount relies partly on quarterly mirror."],["S_OK-P1-C023","DOCC has a current application and public roster pathway; October 15, 2026 roster reported 72 active CSO licenses.","S006–S009.","Establishes operational public market access for CSO licensing. \nWelcome to Oklahoma's Official Web Site"],["S_OK-P1-C024","A roster listing proves the stated CSO license status only, not product legality, pooling exemption, federal compliance, or provider-specific authorization for debt settlement.","S009 read with S002.","No named-provider status evaluation conducted."],["S_OK-P1-C025","Official current OAC text was not recovered; the quarterly Cornell mirror was read instead.","S010–S013.","Material currentness hold; no official-rule claim overstated."],["S_OK-P1-C026","Oklahoma’s official statutory compilation is dated Nov. 18, 2025; live OSCN and 2026 agency materials corroborate continued administration, but a complete 2026 session-law concordance was not read.","S001, S003, S006, S008–S009.","High-confidence qualified currentness."],["S_OK-P1-C027","Debt pooling carries misdemeanor penalties; CSO violations can support misdemeanor liability, injunction, private damages, refunds, license action, cease-and-desist relief, and up to $5,000 civil penalty for unlicensed CSO activity.","S002 §§24-17, 138–139, 145.","Full remedies and limitations analysis remains open. \nOklahoma Legislature\n+3"],["S_OK-P1-C028","For a covered TSR debt-relief service, fee earning requires an executed valid debt agreement, one customer payment under it, and compliant proportional or constant-savings allocation.","S014 §§310.2(o), 310.4(a)(5)(i).","TSR coverage and exemptions must be independently established. \neCFR\n+2"],["S_OK-P1-C029","A TSR-compliant dedicated account requires an insured institution, consumer ownership, independent unaffiliated administrator, no referral compensation, penalty-free withdrawal, and seven-business-day return of unearned funds.","S014 §310.4(a)(5)(ii).","Does not resolve Oklahoma pooling classification."],["S_OK-P1-C030","Covered TSR credit-improvement services cannot request or receive payment until both the represented service period expires and a qualifying later consumer report demonstrates promised results.","S014 §310.4(a)(2).","Includes FCRA permissible-purpose proviso."],["S_OK-P1-C031","CROA conditionally covers compensated interstate credit-improvement services and bars advance payment before full performance; it also imposes contract and three-business-day timing/cancellation rules.","S015 §§1679a, 1679b, 1679d, 1679e.","No universal debt-settlement coverage assumed."],["S_OK-P1-C032","Section 24-147 concerns consumer reporting agency disclosures and credit-history fees, not CSO service charges.","S002 §24-147.","Prevents false reliance on the section heading."],["S_OK-P1-C033","Oklahoma’s bond/trust exception neither legalizes debt pooling nor overrides federal timing; no separate pure-settlement license was established.","S002 §§24-15–18, 133; S014; S015.","Combined legal effect; pure-settlement branch held."],["S_OK-P1-C034","The meaning of “more than twelve times in a calendar year” is express, but the counting unit is not defined in the reviewed text.","S002 §24-132(2)(a).","Requires agency interpretation or case authority."],["S_OK-P1-C035","The quarterly rule mirror refers to claimed bond exemptions, but the exact substantive provider-level exemption basis was not established.","S011 §160:30-7-5; S002 §§24-133–134, 143.","Do not infer a general exemption. \nLegal Information Institute"],["S_OK-P1-C036","No controlling Oklahoma appellate decision applying §§24-15–18 to a modern debt-settlement/dedicated-account model or applying the CSO Act to debt settlement was located.","S003 citationizer; targeted public OSCN searching.","Search limitation, not proof that no decision exists; commercial citator pass remains."],["S_OK-P1-C037","Truly gratuitous counseling is outside the literal CSO definition only when no valuable consideration comes from any source.","S002 §24-132(2)(a).","Indirect, creditor, affiliate, or lead compensation can change result."],["S_OK-P1-C038","A self-creditor is likely outside Oklahoma’s “extension of credit by others” formulation; CROA expressly excludes a creditor restructuring its own debt.","S002 §24-132(2)(a); S015 §1679a(3)(B)(ii).","Oklahoma conclusion is textual inference; CROA exclusion is express."]]},{"headers":["Component","Status","Claims","What this pass established","Exact missing evidence or next action"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component","Status","Claims","What this pass established","Exact missing evidence or next action"],["Debt-pooling definition and prohibition","Answered","C001–C004","Elements, prohibition, narrow exclusions, penalty","Later case-law pass should test modern settlement and dedicated-account fact patterns."],["Principal reduction versus concession/distribution","Answered/partial","C004, C006, C010–C011","Concessions do not negate pooling; pure noncustodial lump-sum reduction remains outside clear classification","Obtain Oklahoma agency interpretation or controlling case addressing pure noncustodial settlement."],["Custodial versus noncustodial models","Answered/partial","C002, C006","Direct receipt/distribution is clearest pooling branch","Resolve agency, constructive receipt, processor attribution, and account-control doctrines."],["Consumer/business-purpose boundary","Partial","C005, C009","CSO consumer/agricultural boundary identified; pooling statute has no express purpose limitation","Controlling case or AG/agency authority on commercial debt pooling."],["Remote-provider/resident nexus","Partial","C007, C023","Out-of-state licensing is operationally established","Statutory, rule, order, or case stating transaction-level Oklahoma nexus."],["CSO definition and annual threshold","Answered/partial","C008–C010, C034","Definition and >12 threshold identified","Interpretation of what is counted “more than twelve times.”"],["CSO licensing authority","Answered","C013, C023","DOCC regulator, application, bond, fees, public roster","No application filing or provider contact is warranted in this research pass."],["Prohibited pooling versus licensed CSO","Answered","C014, C033","CSO license does not cure pooling","Product-specific facts remain necessary."],["Entity/activity exclusions","Answered for operative text","C003, C012, C038","Attorney, nonprofit, lender, institutional, self-creditor boundaries identified","Full professional-practice, nonprofit-control, affiliate, and lender-law pass remains."],["State consumer fee amounts/caps","Answered with currentness qualification","C019, C032","No numerical service-fee cap or indexing located","Read official-current OAC export and complete 2026 session-law concordance."],["State payment timing","Answered","C015–C017","Full-performance rule and bond/trust exception","Interpretation of “full and complete performance” for multidebt contracts."],["State cancellation/refund","Answered/partial","C020–C021","Five-day cancellation and ten-day return; unlawful-charge refund authority","Full contract remedies, rescission, restitution, and post-cancellation accounting pass."],["Bond and trust mechanics","Partial","C015–C017, C035","$10,000 bond; trust required for state advance-payment branch; AG limit","Official rule text, bond forms, substantive basis for any claimed bond exemption, trust ownership/accounting rules."],["Government licensing charges","Answered","C022","Current operational application and mirror amounts","Official-current OAC confirmation."],["Public lookup/current market access","Answered","C023–C024","Application route and October 2026 roster","Provider-specific product authorization requires separate evidence; none was attempted."],["Federal TSR debt-relief timing","Answered as common context","C028–C030","Definitions, earning triggers, allocation, dedicated account, credit-repair timing","Full TSR exemptions, inbound/outbound coverage, attorney/nonprofit treatment, and federal case law remain open."],["CROA overlap","Answered as conditional context","C031, C038","Definition, exclusions, advance-fee, contract and cancellation rules","Debt-settlement-specific federal case-law and entity/factual application remain open."],["Official current Oklahoma rules","Unresolved","C025","Failure route preserved; quarterly mirror read","Recover rules.ok.gov official text or certified/current state export; compare section by section."],["2026 Oklahoma statutory amendments","Partial/unresolved","C026","Compilation date and 2026 operational corroboration recorded","Complete official 2026 session-law concordance for §§24-15–18 and 131–148."],["Controlling Oklahoma decisions","Partial/unresolved","C036","Two AG opinions read; no controlling modern appellate decision located publicly","Commercial citator and broader OSCN docket/opinion search with statute variations and historical numbering."],["Agreement contents beyond fee/timing needs","Partial by boundary","C018, C020","Minimum disclosure and cancellation provisions read","Full agreement-form, electronic contracting, severability, assignment, choice-of-law, and enforceability pass."],["Funds, fiduciary, processor, money-transmission law","Excluded/open","C006, C029","Only minimum dedicated-account issue identified","Separate funds/custody/trust/money-transmitter investigation."],["Full bond, remedies, examinations, enforcement","Partial by necessity","C027","Minimum penalties/refund/license consequences identified","Complete administrative, criminal, private-right, limitation, and remedial interaction pass."],["Collections, creditor conduct, litigation, limitations, judgments, garnishment, exemptions","Excluded/open","—","Not investigated except where needed for provider classification","Separate parent-state dimensions."],["Secured debt, mortgages, auto, medical, student, tax, utilities, and sector rules","Excluded/open","—","No sector-wide conclusions","Separate sector passes."],["Local ordinances and tribal law","Excluded/open","—","No local or tribal conclusion","Oklahoma municipal, county, and tribal jurisdiction investigation."],["Contract, conflicts, territorial reach, and case law","Excluded/open except identified nexus issue","C005–C007, C036","Gaps identified","Dedicated choice-of-law, Oklahoma nexus, arbitration, UPL, and contract-enforcement pass."],["Named-provider authorization","Not performed","C024","Public verification method identified","Search exact legal name and location only when separately authorized and product facts are available."]]}],"claims":[{"claim_id":"S_OK-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C001","Precise assertion":"Oklahoma prohibits engaging in or operating debt pooling.","Source IDs and pinpoints":"S002 §24-15, PDF p. 5.","Conditions, exceptions, currentness, and confidence limits":"Current in official compilation; post-Nov.-2025 reconciliation qualified."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C002","Precise assertion":"Debt pooling requires a debtor contract, periodic debtor payments to the provider, provider distribution among specified creditors under an agreed plan, and debtor-paid consideration for the service or connected services.","Source IDs and pinpoints":"S002 §24-16, PDF p. 5.","Conditions, exceptions, currentness, and confidence limits":"Every element should be tested against actual contracts and fund flow. \nOklahoma Legislature"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C003","Precise assertion":"The pooling exclusions are limited to the four categories in §24-18.","Source IDs and pinpoints":"S002 §24-18, PDF p. 5.","Conditions, exceptions, currentness, and confidence limits":"No generic attorney or nonprofit expansion is assumed. \nOklahoma Legislature"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C004","Precise assertion":"A marketing label or negotiated creditor concession does not displace §24-16 when its conduct elements are present.","Source IDs and pinpoints":"S002 §§24-15–16.","Conditions, exceptions, currentness, and confidence limits":"Statutory interpretation from conduct definition; no modern appellate application found."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C005","Precise assertion":"Sections 24-15–18 contain no express consumer-purpose limit; application to business debt is supported textually but not resolved by located controlling authority.","Source IDs and pinpoints":"S002 §§24-1, 15–18.","Conditions, exceptions, currentness, and confidence limits":"Inference; hold for case-law and territorial pass."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C006","Precise assertion":"A truly noncustodial negotiator avoids the clearest receipt/distribution elements, but dedicated-account agency, control, and attribution remain unresolved.","Source IDs and pinpoints":"S002 §24-16; S014 §310.4(a)(5)(ii).","Conditions, exceptions, currentness, and confidence limits":"No Oklahoma dedicated-account decision located."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C007","Precise assertion":"DOCC licenses out-of-state CSOs, but the exact remote-transaction nexus was not found.","Source IDs and pinpoints":"S002 §§24-142, 145(G); S007 foreign-corporation instructions; S009 roster.","Conditions, exceptions, currentness, and confidence limits":"Out-of-state roster presence is operational evidence, not a complete nexus rule."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C008","Precise assertion":"A CSO is a compensated person acting with respect to third-party credit more than twelve times annually to improve credit, obtain an extension, or advise/assist concerning either.","Source IDs and pinpoints":"S002 §24-132(2)(a); S003 §24-132.","Conditions, exceptions, currentness, and confidence limits":"Consideration may come from any source. \nOklahoma Legislature\n+1"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C009","Precise assertion":"A buyer is an individual; extension of credit is payment deferral for primarily personal/family/household purposes or for a person principally engaged in agriculture.","Source IDs and pinpoints":"S002 §24-132(1), (3).","Conditions, exceptions, currentness, and confidence limits":"Ordinary corporate/commercial debts generally outside CSO branch."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C010","Precise assertion":"Negotiating payment deferral or a revised schedule can fit “obtaining an extension of credit.”","Source IDs and pinpoints":"S002 §24-132; S005 ¶¶1–6.","Conditions, exceptions, currentness, and confidence limits":"Strong textual inference; AG opinion concerns loan brokers, not settlement providers. \nOklahoma State Courts Network"},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C011","Precise assertion":"Pure immediate lump-sum principal reduction, without deferral, credit-improvement representation, or fund custody, is not clearly classified by the reviewed Oklahoma authorities.","Source IDs and pinpoints":"S002 §§24-16, 132.","Conditions, exceptions, currentness, and confidence limits":"Held; no affirmative safe harbor or separate license inferred."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C012","Precise assertion":"The ten CSO exclusions are activity/entity-specific, and the claimant bears the burden of proving an exception or definitional exclusion.","Source IDs and pinpoints":"S002 §§24-132(2)(b), 138(B).","Conditions, exceptions, currentness, and confidence limits":"Exclusions do not migrate automatically to other statutes. \nOklahoma Legislature\n+1"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C013","Precise assertion":"A person must obtain a DOCC/Administrator license before engaging in CSO business.","Source IDs and pinpoints":"S002 §§24-140–143; S006.","Conditions, exceptions, currentness, and confidence limits":"Subject to definitional exclusions and threshold. \nOklahoma Legislature\n+1"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]","coordinator_qualification":"24-143C60daysrunsfromfiledfeesORhearingifany andallows writtenextension. Agencyup-to60descriptionisoperationalshorthand, notunqualifiedstatutoryguarantee."},{"claim_id":"S_OK-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C014","Precise assertion":"A CSO license does not authorize otherwise prohibited debt pooling.","Source IDs and pinpoints":"S002 §§24-15–18, 141–143.","Conditions, exceptions, currentness, and confidence limits":"Structural statutory conclusion; no conflicting authority located."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C015","Precise assertion":"Before full and complete performance, a CSO may not charge or receive consideration unless it has both the $10,000 bond and qualifying Oklahoma trust account.","Source IDs and pinpoints":"S002 §24-133(1); S003 §24-133.","Conditions, exceptions, currentness, and confidence limits":"State condition only; other laws can remain stricter. \nOklahoma Legislature\n+1"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C016","Precise assertion":"Oklahoma law supplies no trust-account amount or duration standard, and the Administrator may not create those terms by rule under the general delegation.","Source IDs and pinpoints":"S004 ¶¶7–10.","Conditions, exceptions, currentness, and confidence limits":"Official 1987 AG opinion; no later contrary authority located. \nOklahoma State Courts Network"},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_qualification":"1987AGopinionsandjudicialsubsequenthistorynotreopened. Reportedholdingsretainoriginalresearcherprovenance,notnewcoordinatorverification. Noroster/provider/caseinvestigation."},{"claim_id":"S_OK-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C017","Precise assertion":"Section 24-134 relieves an employee/agent of a separate bond/trust obligation when the organization complies; the application requires a bond per location and trust evidence or no-upfront-funds letter.","Source IDs and pinpoints":"S002 §24-134; S007 pp. 5–6.","Conditions, exceptions, currentness, and confidence limits":"Not a provider-model exemption. \nOklahoma Legislature\n+2"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C018","Precise assertion":"Precontract disclosure and the written contract must disclose payment terms, total payments, detailed services, performance timing, refund promises, and other specified information.","Source IDs and pinpoints":"S002 §§24-135–137.","Conditions, exceptions, currentness, and confidence limits":"Applies to covered CSOs. \nOklahoma Legislature\n+2"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C019","Precise assertion":"No numerical Oklahoma CSO consumer-service fee cap or indexing mechanism was located in the reviewed statute or quarterly Chapter 30 mirror.","Source IDs and pinpoints":"S002 §§24-131–146; S011 full non-revoked Chapter 30 review.","Conditions, exceptions, currentness, and confidence limits":"Qualified by inaccessible official-current OAC and incomplete 2026 section concordance."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C020","Precise assertion":"Buyer may cancel within five days; payment must be returned within ten days after seller receives notice; mirror says the cancellation period does not begin until proper disclosures.","Source IDs and pinpoints":"S002 §24-137; S011 §§160:30-1-2, 160:30-5-1.","Conditions, exceptions, currentness, and confidence limits":"“Days” as calendar days comes from secondary rule mirror pending official verification."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C021","Precise assertion":"No general post–five-day pro rata refund formula was located; contract refund promises and refunds of unlawful charges remain operative.","Source IDs and pinpoints":"S002 §§24-137, 145.","Conditions, exceptions, currentness, and confidence limits":"Later contract/remedies pass required."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C022","Precise assertion":"Current $900 initial and $600 renewal amounts are government licensing/examination charges, not consumer fee ceilings.","Source IDs and pinpoints":"S006; S007; S012 §160:5-1-2(6).","Conditions, exceptions, currentness, and confidence limits":"Rule amount relies partly on quarterly mirror."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_qualification":"Applicationp7hasactive-dutyverifiedlicenseextension/no-furtherpaymentbranch. 900initial/600ordinaryrenewalarenot universalchargesineveryprotectedbranch. Thisnotconsumerfeecap andnoactualfeeeligibilitydetermination."},{"claim_id":"S_OK-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C023","Precise assertion":"DOCC has a current application and public roster pathway; October 15, 2026 roster reported 72 active CSO licenses.","Source IDs and pinpoints":"S006–S009.","Conditions, exceptions, currentness, and confidence limits":"Establishes operational public market access for CSO licensing. \nWelcome to Oklahoma's Official Web Site"},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_roster_limit":"Historic reported roster/provider status not freshly accessed; no provider query."},{"claim_id":"S_OK-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C024","Precise assertion":"A roster listing proves the stated CSO license status only, not product legality, pooling exemption, federal compliance, or provider-specific authorization for debt settlement.","Source IDs and pinpoints":"S009 read with S002.","Conditions, exceptions, currentness, and confidence limits":"No named-provider status evaluation conducted."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_roster_limit":"Historic reported roster/provider status not freshly accessed; no provider query."},{"claim_id":"S_OK-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C025","Precise assertion":"Official current OAC text was not recovered; the quarterly Cornell mirror was read instead.","Source IDs and pinpoints":"S010–S013.","Conditions, exceptions, currentness, and confidence limits":"Material currentness hold; no official-rule claim overstated."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C026","Precise assertion":"Oklahoma’s official statutory compilation is dated Nov. 18, 2025; live OSCN and 2026 agency materials corroborate continued administration, but a complete 2026 session-law concordance was not read.","Source IDs and pinpoints":"S001, S003, S006, S008–S009.","Conditions, exceptions, currentness, and confidence limits":"High-confidence qualified currentness."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_currency_limit":"Nov18,2025indexreconfirmed; operational2026pageisnotfull2026statutoryconcordance."},{"claim_id":"S_OK-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C027","Precise assertion":"Debt pooling carries misdemeanor penalties; CSO violations can support misdemeanor liability, injunction, private damages, refunds, license action, cease-and-desist relief, and up to $5,000 civil penalty for unlicensed CSO activity.","Source IDs and pinpoints":"S002 §§24-17, 138–139, 145.","Conditions, exceptions, currentness, and confidence limits":"Full remedies and limitations analysis remains open. \nOklahoma Legislature\n+3"},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C028","Precise assertion":"For a covered TSR debt-relief service, fee earning requires an executed valid debt agreement, one customer payment under it, and compliant proportional or constant-savings allocation.","Source IDs and pinpoints":"S014 §§310.2(o), 310.4(a)(5)(i).","Conditions, exceptions, currentness, and confidence limits":"TSR coverage and exemptions must be independently established. \neCFR\n+2"},"coordinator_verification_status":"selected_eCFR_text_compared_full_application_exemptions_held","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C029","Precise assertion":"A TSR-compliant dedicated account requires an insured institution, consumer ownership, independent unaffiliated administrator, no referral compensation, penalty-free withdrawal, and seven-business-day return of unearned funds.","Source IDs and pinpoints":"S014 §310.4(a)(5)(ii).","Conditions, exceptions, currentness, and confidence limits":"Does not resolve Oklahoma pooling classification."},"coordinator_verification_status":"selected_eCFR_text_compared_full_application_exemptions_held","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C030","Precise assertion":"Covered TSR credit-improvement services cannot request or receive payment until both the represented service period expires and a qualifying later consumer report demonstrates promised results.","Source IDs and pinpoints":"S014 §310.4(a)(2).","Conditions, exceptions, currentness, and confidence limits":"Includes FCRA permissible-purpose proviso."},"coordinator_verification_status":"selected_eCFR_text_compared_full_application_exemptions_held","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C031","Precise assertion":"CROA conditionally covers compensated interstate credit-improvement services and bars advance payment before full performance; it also imposes contract and three-business-day timing/cancellation rules.","Source IDs and pinpoints":"S015 §§1679a, 1679b, 1679d, 1679e.","Conditions, exceptions, currentness, and confidence limits":"No universal debt-settlement coverage assumed."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C032","Precise assertion":"Section 24-147 concerns consumer reporting agency disclosures and credit-history fees, not CSO service charges.","Source IDs and pinpoints":"S002 §24-147.","Conditions, exceptions, currentness, and confidence limits":"Prevents false reliance on the section heading."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C033","Precise assertion":"Oklahoma’s bond/trust exception neither legalizes debt pooling nor overrides federal timing; no separate pure-settlement license was established.","Source IDs and pinpoints":"S002 §§24-15–18, 133; S014; S015.","Conditions, exceptions, currentness, and confidence limits":"Combined legal effect; pure-settlement branch held."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C034","Precise assertion":"The meaning of “more than twelve times in a calendar year” is express, but the counting unit is not defined in the reviewed text.","Source IDs and pinpoints":"S002 §24-132(2)(a).","Conditions, exceptions, currentness, and confidence limits":"Requires agency interpretation or case authority."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C035","Precise assertion":"The quarterly rule mirror refers to claimed bond exemptions, but the exact substantive provider-level exemption basis was not established.","Source IDs and pinpoints":"S011 §160:30-7-5; S002 §§24-133–134, 143.","Conditions, exceptions, currentness, and confidence limits":"Do not infer a general exemption. \nLegal Information Institute"},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C036","Precise assertion":"No controlling Oklahoma appellate decision applying §§24-15–18 to a modern debt-settlement/dedicated-account model or applying the CSO Act to debt settlement was located.","Source IDs and pinpoints":"S003 citationizer; targeted public OSCN searching.","Conditions, exceptions, currentness, and confidence limits":"Search limitation, not proof that no decision exists; commercial citator pass remains."},"coordinator_verification_status":"whole_text_reviewed_not_fully_primary_verified","coordinator_review":"[internal evidence reference]","coordinator_qualification":"1987AGopinionsandjudicialsubsequenthistorynotreopened. Reportedholdingsretainoriginalresearcherprovenance,notnewcoordinatorverification. Noroster/provider/caseinvestigation."},{"claim_id":"S_OK-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C037","Precise assertion":"Truly gratuitous counseling is outside the literal CSO definition only when no valuable consideration comes from any source.","Source IDs and pinpoints":"S002 §24-132(2)(a).","Conditions, exceptions, currentness, and confidence limits":"Indirect, creditor, affiliate, or lead compensation can change result."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_OK-P1-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_OK-P1-C038","Precise assertion":"A self-creditor is likely outside Oklahoma’s “extension of credit by others” formulation; CROA expressly excludes a creditor restructuring its own debt.","Source IDs and pinpoints":"S002 §24-132(2)(a); S015 §1679a(3)(B)(ii).","Conditions, exceptions, currentness, and confidence limits":"Oklahoma conclusion is textual inference; CROA exclusion is express."},"coordinator_verification_status":"selected_dated_primary_text_compared_subject_to_scope_and_incorporation_holds","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_OK-P1-S001","urls":["https://www.oklegislature.gov/osStatuesTitle.html"],"researcher_record":{"Source ID":"S_OK-P1-S001","Title, issuer, and direct literal URL":"Oklahoma Statutes index, Oklahoma Legislature. https://www.oklegislature.gov/osStatuesTitle.html","Exact pinpoints read":"Page note; Title 24 link","Version/effective status and fresh access":"Page says statutes last updated Nov. 18, 2025. Accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Official source for compilation date. It does not itself reconcile 2026 session laws. \nOklahoma Legislature"},"coordinator_verification_status":"selected_primary_comparison_with_recorded_currency_and_scope_limits","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S002","urls":["https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf"],"researcher_record":{"Source ID":"S_OK-P1-S002","Title, issuer, and direct literal URL":"Oklahoma Statutes, Title 24, Debtor and Creditor, Oklahoma Legislature. https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os24.pdf","Exact pinpoints read":"§§24-1; 24-15–18; 24-131–148, especially §§132–145; PDF pp. 5, 21–31","Version/effective status and fresh access":"Official compilation associated with S001’s Nov. 18, 2025 update. Accessed and PDF pages visually inspected Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Principal Oklahoma statutory source. Post-Nov.-2025 amendment completeness remains qualified. \nOklahoma Legislature\n+5"},"coordinator_verification_status":"selected_primary_comparison_with_recorded_currency_and_scope_limits","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S003","urls":["https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249","https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71250","https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71251"],"researcher_record":{"Source ID":"S_OK-P1-S003","Title, issuer, and direct literal URL":"OSCN citationized CSO provisions and citationizer, Oklahoma State Courts Network. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71249 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71250 https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=71251","Exact pinpoints read":"§§24-131–133; histories; citationizer for §131","Version/effective status and fresh access":"Live pages accessed Oct. 25, 2026 PDT; no explicit current-through date.","Jurisdiction, use, and limitations":"Official judiciary source corroborating text and locating the two AG opinions. It is not a legislative-session concordance. \nOklahoma State Courts Network\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S004","urls":["https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515"],"researcher_record":{"Source ID":"S_OK-P1-S004","Title, issuer, and direct literal URL":"1987 OK AG 104, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61515","Exact pinpoints read":"¶¶0, 4–10; decided Oct. 12, 1987","Version/effective status and fresh access":"Official opinion accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Establishes lack of authority to prescribe trust-account amount or duration by rule; not a modern debt-settlement classification decision. \nOklahoma State Courts Network"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S005","urls":["https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527"],"researcher_record":{"Source ID":"S_OK-P1-S005","Title, issuer, and direct literal URL":"1987 OK AG 126, Oklahoma Attorney General/OSCN. https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=61527","Exact pinpoints read":"¶¶0–6; decided Dec. 14, 1987","Version/effective status and fresh access":"Official opinion accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Applies CSO definition to third-party loan brokers and supports broad reading of payment deferral; not a holding about debt settlement. \nOklahoma State Courts Network"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S006","urls":["https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html"],"researcher_record":{"Source ID":"S_OK-P1-S006","Title, issuer, and direct literal URL":"Credit Services Organizations, Oklahoma Department of Consumer Credit. https://oklahoma.gov/okdocc/licenses-we-regulate/credit-services-organizations.html","Exact pinpoints read":"Statutes/rules, description, 60-day period, $900 charges, one-year period, $10,000 bond","Version/effective status and fresh access":"Last modified Mar. 27, 2026; accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Current operational page. Procedure and description do not substitute for statutory authority. \nWelcome to Oklahoma's Official Web Site"},"coordinator_verification_status":"selected_primary_comparison_with_recorded_currency_and_scope_limits","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S007","urls":["https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf"],"researcher_record":{"Source ID":"S_OK-P1-S007","Title, issuer, and direct literal URL":"Oklahoma Credit Services Organization License Application, DOCC. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/licenses/new-applications/CSO.APPLICATION.3.4.2024.pdf","Exact pinpoints read":"Revision date; pp. 5–8: bond, trust, branches, foreign corporations, initial and renewal charges","Version/effective status and fresh access":"Form revised Mar. 4, 2024; currently linked by DOCC; accessed and visually inspected Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Operational application evidence, not a source of power beyond the Act and valid rules. \nWelcome to Oklahoma's Official Web Site\n+4"},"coordinator_verification_status":"selected_primary_comparison_with_recorded_currency_and_scope_limits","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S008","urls":["https://oklahoma.gov/okdocc/licenses-we-regulate.html"],"researcher_record":{"Source ID":"S_OK-P1-S008","Title, issuer, and direct literal URL":"Licenses We Regulate, DOCC. https://oklahoma.gov/okdocc/licenses-we-regulate.html","Exact pinpoints read":"CSO description; roster links; update date","Version/effective status and fresh access":"Roster page updated Oct. 19, 2026; accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Public lookup entry point. \nWelcome to Oklahoma's Official Web Site"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S009","urls":["https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf"],"researcher_record":{"Source ID":"S_OK-P1-S009","Title, issuer, and direct literal URL":"DOCC CSO all-locations roster. https://oklahoma.gov/content/dam/ok/en/okdocc/documents/rosters/10.15.2026.CSO-ALL.pdf","Exact pinpoints read":"PDF p. 1 header and full roster","Version/effective status and fresh access":"Active-license date Oct. 15, 2026; 72 total; accessed and visually inspected Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Proves rostered CSO license status only, not product-level debt-settlement permission or compliance. \nWelcome to Oklahoma's Official Web Site\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S010","urls":["https://rules.ok.gov/code"],"researcher_record":{"Source ID":"S_OK-P1-S010","Title, issuer, and direct literal URL":"Oklahoma Administrative Code official portal. https://rules.ok.gov/code","Exact pinpoints read":"Attempted Title 160/Chapter 30 route","Version/effective status and fresh access":"Fresh access attempt Oct. 25, 2026 PDT failed in the available route.","Jurisdiction, use, and limitations":"Official current rule text was not read. This is an express evidence hold. (Invalid URL)"},"coordinator_verification_status":"fresh_source_attempt_failed_or_partial_group_other_bodies_notreopened","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S011","urls":["https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30"],"researcher_record":{"Source ID":"S_OK-P1-S011","Title, issuer, and direct literal URL":"Cornell LII quarterly mirror, Oklahoma Administrative Code Title 160, Chapter 30. Base: https://www.law.cornell.edu/regulations/oklahoma/title-160/chapter-30","Exact pinpoints read":"§§160:30-1-1, 1-2; 3-1.1, 3-3, 3-3.1–3-3.4; 5-1; 7-1–7-3, 7-5; 9-1–9-2; 11-1–11-6","Version/effective status and fresh access":"Mirror says rules updated quarterly; chapter originally codified Dec. 31, 1991; accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Useful secondary rule mirror. Not treated as official-current OAC. Direct section URLs appear below. \nLegal Information Institute\n+4"},"coordinator_verification_status":"selected_secondary_mirror_comparison_officialcurrency_held","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S012","urls":["https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2"],"researcher_record":{"Source ID":"S_OK-P1-S012","Title, issuer, and direct literal URL":"Cornell LII mirror, OAC §160:5-1-2, Fees. https://www.law.cornell.edu/regulations/oklahoma/OAC-160-5-1-2","Exact pinpoints read":"Paragraph (6), Credit Services Organizations","Version/effective status and fresh access":"Quarterly mirror accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Provider-to-government charges only; not a consumer-service fee schedule. \nLegal Information Institute"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S013","urls":["https://digitalprairie.ok.gov/digital/api/collection/p16807coll3/id/62163/download"],"researcher_record":{"Source ID":"S_OK-P1-S013","Title, issuer, and direct literal URL":"Oklahoma Register archive locator for 16 Ok Reg 2145. https://digitalprairie.ok.gov/digital/api/collection/p16807coll3/id/62163/download","Exact pinpoints read":"Attempted underlying adoption publication cited by mirror","Version/effective status and fresh access":"Fresh access Oct. 25, 2026 returned unsupported JP2/image content; actual adoption text not read.","Jurisdiction, use, and limitations":"Discovery-only failed route. Not relied on for substantive rule wording or currentness. (Invalid URL)"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_OK-P1-S014","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_OK-P1-S014","Title, issuer, and direct literal URL":"Telemarketing Sales Rule, eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact pinpoints read":"§310.2(j), (o), (ee), (hh), (ii); §310.4(a)(2), (a)(5)","Version/effective status and fresh access":"eCFR displayed Title 16 current through Oct. 22, 2026 and last amended Oct. 19, 2026; accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Federal common context only when TSR coverage is independently satisfied. Full exemption analysis remains open. \neCFR\n+6"},"coordinator_verification_status":"selected_primary_comparison_with_recorded_currency_and_scope_limits","coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"S_OK-P1-S015","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679a/","https://uscode.house.gov/us/usc/119-124/t15/s1679b/","https://uscode.house.gov/us/usc/119-124/t15/s1679d/","https://uscode.house.gov/us/usc/119-124/t15/s1679e/","https://uscode.house.gov/us/usc/119-124/t15/s1679j/"],"researcher_record":{"Source ID":"S_OK-P1-S015","Title, issuer, and direct literal URL":"Credit Repair Organizations Act, U.S. Code, Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-124/t15/s1679a/ https://uscode.house.gov/us/usc/119-124/t15/s1679b/ https://uscode.house.gov/us/usc/119-124/t15/s1679d/ https://uscode.house.gov/us/usc/119-124/t15/s1679e/ https://uscode.house.gov/us/usc/119-124/t15/s1679j/","Exact pinpoints read":"15 U.S.C. §§1679a, 1679b(b), 1679d, 1679e, 1679j","Version/effective status and fresh access":"Text in effect through Pub. L. 119-124, Oct. 15, 2026; accessed Oct. 25, 2026 PDT.","Jurisdiction, use, and limitations":"Conditional federal credit-repair overlay; no universal debt-settlement coverage assumed. \nU.S. Code\n+5"},"coordinator_verification_status":"fresh_source_attempt_failed_or_partial_group_other_bodies_notreopened","coordinator_check_evidence":"[internal evidence reference]"}],"coverage":[{"topic":"Debt-pooling definition and prohibition","researcher_record":{"Component":"Debt-pooling definition and prohibition","Status":"Answered","Claims":"C001–C004","What this pass established":"Elements, prohibition, narrow exclusions, penalty","Exact missing evidence or next action":"Later case-law pass should test modern settlement and dedicated-account fact patterns."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Principal reduction versus concession/distribution","researcher_record":{"Component":"Principal reduction versus concession/distribution","Status":"Answered/partial","Claims":"C004, C006, C010–C011","What this pass established":"Concessions do not negate pooling; pure noncustodial lump-sum reduction remains outside clear classification","Exact missing evidence or next action":"Obtain Oklahoma agency interpretation or controlling case addressing pure noncustodial settlement."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial versus noncustodial models","researcher_record":{"Component":"Custodial versus noncustodial models","Status":"Answered/partial","Claims":"C002, C006","What this pass established":"Direct receipt/distribution is clearest pooling branch","Exact missing evidence or next action":"Resolve agency, constructive receipt, processor attribution, and account-control doctrines."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer/business-purpose boundary","researcher_record":{"Component":"Consumer/business-purpose boundary","Status":"Partial","Claims":"C005, C009","What this pass established":"CSO consumer/agricultural boundary identified; pooling statute has no express purpose limitation","Exact missing evidence or next action":"Controlling case or AG/agency authority on commercial debt pooling."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Remote-provider/resident nexus","researcher_record":{"Component":"Remote-provider/resident nexus","Status":"Partial","Claims":"C007, C023","What this pass established":"Out-of-state licensing is operationally established","Exact missing evidence or next action":"Statutory, rule, order, or case stating transaction-level Oklahoma nexus."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO definition and annual threshold","researcher_record":{"Component":"CSO definition and annual threshold","Status":"Answered/partial","Claims":"C008–C010, C034","What this pass established":"Definition and >12 threshold identified","Exact missing evidence or next action":"Interpretation of what is counted “more than twelve times.”"},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CSO licensing authority","researcher_record":{"Component":"CSO licensing authority","Status":"Answered","Claims":"C013, C023","What this pass established":"DOCC regulator, application, bond, fees, public roster","Exact missing evidence or next action":"No application filing or provider contact is warranted in this research pass."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Prohibited pooling versus licensed CSO","researcher_record":{"Component":"Prohibited pooling versus licensed CSO","Status":"Answered","Claims":"C014, C033","What this pass established":"CSO license does not cure pooling","Exact missing evidence or next action":"Product-specific facts remain necessary."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Entity/activity exclusions","researcher_record":{"Component":"Entity/activity exclusions","Status":"Answered for operative text","Claims":"C003, C012, C038","What this pass established":"Attorney, nonprofit, lender, institutional, self-creditor boundaries identified","Exact missing evidence or next action":"Full professional-practice, nonprofit-control, affiliate, and lender-law pass remains."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State consumer fee amounts/caps","researcher_record":{"Component":"State consumer fee amounts/caps","Status":"Answered with currentness qualification","Claims":"C019, C032","What this pass established":"No numerical service-fee cap or indexing located","Exact missing evidence or next action":"Read official-current OAC export and complete 2026 session-law concordance."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State payment timing","researcher_record":{"Component":"State payment timing","Status":"Answered","Claims":"C015–C017","What this pass established":"Full-performance rule and bond/trust exception","Exact missing evidence or next action":"Interpretation of “full and complete performance” for multidebt contracts."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State cancellation/refund","researcher_record":{"Component":"State cancellation/refund","Status":"Answered/partial","Claims":"C020–C021","What this pass established":"Five-day cancellation and ten-day return; unlawful-charge refund authority","Exact missing evidence or next action":"Full contract remedies, rescission, restitution, and post-cancellation accounting pass."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Bond and trust mechanics","researcher_record":{"Component":"Bond and trust mechanics","Status":"Partial","Claims":"C015–C017, C035","What this pass established":"$10,000 bond; trust required for state advance-payment branch; AG limit","Exact missing evidence or next action":"Official rule text, bond forms, substantive basis for any claimed bond exemption, trust ownership/accounting rules."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Government licensing charges","researcher_record":{"Component":"Government licensing charges","Status":"Answered","Claims":"C022","What this pass established":"Current operational application and mirror amounts","Exact missing evidence or next action":"Official-current OAC confirmation."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Public lookup/current market access","researcher_record":{"Component":"Public lookup/current market access","Status":"Answered","Claims":"C023–C024","What this pass established":"Application route and October 2026 roster","Exact missing evidence or next action":"Provider-specific product authorization requires separate evidence; none was attempted."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR debt-relief timing","researcher_record":{"Component":"Federal TSR debt-relief timing","Status":"Answered as common context","Claims":"C028–C030","What this pass established":"Definitions, earning triggers, allocation, dedicated account, credit-repair timing","Exact missing evidence or next action":"Full TSR exemptions, inbound/outbound coverage, attorney/nonprofit treatment, and federal case law remain open."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CROA overlap","researcher_record":{"Component":"CROA overlap","Status":"Answered as conditional context","Claims":"C031, C038","What this pass established":"Definition, exclusions, advance-fee, contract and cancellation rules","Exact missing evidence or next action":"Debt-settlement-specific federal case-law and entity/factual application remain open."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Official current Oklahoma rules","researcher_record":{"Component":"Official current Oklahoma rules","Status":"Unresolved","Claims":"C025","What this pass established":"Failure route preserved; quarterly mirror read","Exact missing evidence or next action":"Recover rules.ok.gov official text or certified/current state export; compare section by section."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"2026 Oklahoma statutory amendments","researcher_record":{"Component":"2026 Oklahoma statutory amendments","Status":"Partial/unresolved","Claims":"C026","What this pass established":"Compilation date and 2026 operational corroboration recorded","Exact missing evidence or next action":"Complete official 2026 session-law concordance for §§24-15–18 and 131–148."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling Oklahoma decisions","researcher_record":{"Component":"Controlling Oklahoma decisions","Status":"Partial/unresolved","Claims":"C036","What this pass established":"Two AG opinions read; no controlling modern appellate decision located publicly","Exact missing evidence or next action":"Commercial citator and broader OSCN docket/opinion search with statute variations and historical numbering."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement contents beyond fee/timing needs","researcher_record":{"Component":"Agreement contents beyond fee/timing needs","Status":"Partial by boundary","Claims":"C018, C020","What this pass established":"Minimum disclosure and cancellation provisions read","Exact missing evidence or next action":"Full agreement-form, electronic contracting, severability, assignment, choice-of-law, and enforceability pass."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Funds, fiduciary, processor, money-transmission law","researcher_record":{"Component":"Funds, fiduciary, processor, money-transmission law","Status":"Excluded/open","Claims":"C006, C029","What this pass established":"Only minimum dedicated-account issue identified","Exact missing evidence or next action":"Separate funds/custody/trust/money-transmitter investigation."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Full bond, remedies, examinations, enforcement","researcher_record":{"Component":"Full bond, remedies, examinations, enforcement","Status":"Partial by necessity","Claims":"C027","What this pass established":"Minimum penalties/refund/license consequences identified","Exact missing evidence or next action":"Complete administrative, criminal, private-right, limitation, and remedial interaction pass."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Collections, creditor conduct, litigation, limitations, judgments, garnishment, exemptions","researcher_record":{"Component":"Collections, creditor conduct, litigation, limitations, judgments, garnishment, exemptions","Status":"Excluded/open","Claims":"—","What this pass established":"Not investigated except where needed for provider classification","Exact missing evidence or next action":"Separate parent-state dimensions."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt, mortgages, auto, medical, student, tax, utilities, and sector rules","researcher_record":{"Component":"Secured debt, mortgages, auto, medical, student, tax, utilities, and sector rules","Status":"Excluded/open","Claims":"—","What this pass established":"No sector-wide conclusions","Exact missing evidence or next action":"Separate sector passes."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Local ordinances and tribal law","researcher_record":{"Component":"Local ordinances and tribal law","Status":"Excluded/open","Claims":"—","What this pass established":"No local or tribal conclusion","Exact missing evidence or next action":"Oklahoma municipal, county, and tribal jurisdiction investigation."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Contract, conflicts, territorial reach, and case law","researcher_record":{"Component":"Contract, conflicts, territorial reach, and case law","Status":"Excluded/open except identified nexus issue","Claims":"C005–C007, C036","What this pass established":"Gaps identified","Exact missing evidence or next action":"Dedicated choice-of-law, Oklahoma nexus, arbitration, UPL, and contract-enforcement pass."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Named-provider authorization","researcher_record":{"Component":"Named-provider authorization","Status":"Not performed","Claims":"C024","What this pass established":"Public verification method identified","Exact missing evidence or next action":"Search exact legal name and location only when separately authorized and product facts are available."},"coordinator_acceptance":"first_scoped_review_complete_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_OK-P1-scoped-review-20261029","status":"whole_first_scoped_review_complete_with_currency_and_scope_holds","at":"2026-10-29T02:24:18.913442+00:00"}]}