{"meta":{"key":"s_ri--pass-01","task":"S_RI","title":"SRI Rhode Island provider market access and consumer fees","parent_title":"Rhode Island debt and debt relief law","edition":"pass-01","path":"/research/s_ri--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":6,"claims":42,"sources":16,"review_status":"revise","review_complete":true,"sha256":"e958b5cca90febb2010bc813e00afcbfdc024998cc4267df5255c830ad8ecb0c","headings":["Executive determination","1. Classification of debt adjustment, settlement, DMPs, counseling, and related conduct","1.1 The governing functional test","1.2 Custodial versus noncustodial models","1.3 Resident and remote-provider nexus","2. Prohibited, registered, authorized, and exempt business models","2.1 Covered providers have a registration pathway","2.2 The law does not establish a nonprofit-only market","2.3 An attorney connection is not enough","2.4 Express exclusions and conditional exemptions","2.5 Access prerequisites","3. Applicable fee structures and limits","3.1 Critical current-dollar hold","3.2 Consumer-fee matrix","3.3 Fee bases and credits","3.4 Refund and termination conditions","4. When fees may be requested or received","4.1 Rhode Island state-law timing","4.2 Federal TSR timing must be applied separately","4.3 Combined operational rule","5. Actual regulator procedure, lookup, and current market access","5.1 Current public application channel","5.2 Evidence that the program is active","5.3 Inaccessible or unverified procedural material","5.4 No current DMS-specific rule or adjustment notice located","6. Worked fee and boundary examples","Example 1 — DMP with four creditors","Example 2 — Monthly count decreases as creditors leave","Example 3 — Lower-debt settlement setup fee","Example 4 — Per-debt settlement compensation with prior fees","Example 5 — Small settlement savings and prior-fee credit","Example 6 — Two debts and aggregate compensation","Example 7 — Later termination and 65% setup refund","Example 8 — Ordinary three-business-day cancellation","Example 9 — Counseling without an agreement","Example 10 — One-time negotiation with no payment schedule","Example 11 — Natural-person business debt versus entity-only debt","7. Immediate implementation implications for SettleADebt.com","Actually read","Not read or not established"],"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_RI/pass-01","facets":{"geography":["us","us-ri"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Rhode Island provider-access/fees component; every broader state category remains required","pending_corrections":0},"markdown":"# S_RI PASS-01 — Rhode Island provider market access and consumer fees\n\n**Actual research/access date:** October 24, 2026, Pacific time\n**Mode/model actually used:** Regular Chat, GPT-5.6 Sol Pro—the available owner-authorized quality-first fallback. No Deep Research, Work, Chrome control, other chats, purchases, accounts, applications, contacts, or private borrower data.\n**Scope:** Provider classification, public market access, consumer fees, and fee timing only. This does **not** complete the Rhode Island dossier or imply state/A066 acceptance.\n\n## Executive determination\n\nRhode Island is **not a categorical-prohibition state** for debt management or debt settlement. It has a Department of Business Regulation, Division of Banking **registration regime** under the Uniform Debt-Management Services Act. A covered provider generally may serve a person it reasonably should know resides in Rhode Island only after obtaining a certificate of registration. Chapter 19-14 uses the generic phrase “license or registration,” but the activity-specific chapter repeatedly calls the authorization a **registration**. [S_RI-P1-C009, C016] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm)\n\nThe functional definition is broad. It reaches an intermediary seeking creditor “concessions,” including traditional debt-management plans, interest/fee concessions, principal-reduction settlement, one-time negotiation, and custodial or noncustodial models. A marketing label, attorney ownership, nonprofit status, use of a consumer-controlled account, or routing work through another entity does not itself remove coverage. [C002–C006, C011] [Rhode Island Legislature+3](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\nThe statute contains usable, exact **percentage rules**:\n\n- settlement-plan setup fee: no more than the lesser of the applicable adjusted absolute ceiling and **4% of debt in the plan at inception**;\n- settlement compensation: no more than **30% of realized principal savings on each debt**, reduced by previously collected setup and monthly fees not already credited;\n- later termination refund: **65% of the uncredited portion of a settlement setup fee**;\n- counseling-fee lookback: **90 days**;\n- ordinary cancellation period: **three business days**. [Rhode Island Legislature+3](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\nThe exact October 2026 **dollar ceilings are unresolved and held**. Section 19-14.8-32(f) commands DBR to replace the printed statutory dollar figures with inflation-adjusted figures by rule, to adjust them when the specified CPI threshold is reached, and to notify registrants and publish the changes. The current official Rhode Island Code of Regulations catalog and the current DBR rules, bulletins, and guidance indexes reviewed for this pass did not display a debt-management adjustment rule or notice. That negative result does not establish that DBR never issued one, and it does not justify either inventing a CPI calculation or assuming that the printed 2006 figures are the operative 2026 figures. [C019, C020, C024, C025, C035] [Rhode Island Legislature+5](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-32.htm)\n\nRhode Island’s signed-agreement rule is only a **state-law minimum timing condition**. It is not advance-fee authorization under the federal Telemarketing Sales Rule. For a TSR-covered debt-relief telemarketing transaction, no fee may be requested or received until at least one debt has actually been altered under a valid agreement, the consumer has made at least one payment under that creditor agreement, and the fee satisfies the federal proportional or uniform-savings-percentage allocation requirement. [C031–C032] [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n# A. Substantive findings\n\n## 1. Classification of debt adjustment, settlement, DMPs, counseling, and related conduct\n\n### 1.1 The governing functional test\n\nRhode Island defines “debt-management services” as services performed **as an intermediary between an individual and one or more creditors for the purpose of obtaining concessions**. “Concessions” means creditor assent to repayment terms more favorable than the original terms. A “provider” includes a person that provides, offers, or agrees to provide the services directly **or through others**. [C002] [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\nThe General Assembly expressly directed that the official comments to the Act represent legislative intent and be used as an interpretive guide. Those comments explain that concessions encompass reductions in interest, finance charges, late/default/delinquency fees, and principal. They also state that money need not flow through the provider and that one-time assistance negotiating with one or more creditors is covered even when the arrangement is not a statutory “plan.” [C003–C004] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm)\n\n| Business model or conduct | Rhode Island classification | Market-access consequence |\n| --- | --- | --- |\n| Traditional DMP obtaining reduced interest, finance charges, or delinquency fees | Debt-management services; if it contains a payment schedule, also a statutory “plan.” [C002] | Registration generally required for a known or reasonably known Rhode Island resident. |\n| Principal-reduction debt settlement | Debt-management services; a scheduled settlement program is a “plan.” “Settlement fee” specifically refers to a charge associated with a creditor accepting less than principal. [C002–C003] | Registration route exists; not categorically prohibited. |\n| One-time negotiation after the consumer has accumulated settlement funds | Covered debt-management services even though it may not be a “plan.” [C004] | Registration ordinarily required, but the affirmative consumer-fee pathway for a truly no-plan arrangement is unresolved. |\n| Consumer-controlled or third-party-controlled dedicated account | Noncustodial structure does not remove the service from coverage. [C004, C029] | Registration still required; state trust-account provisions depend separately on whether the provider or its designee receives funds for creditor distribution. |\n| Provider or its designee receives money to distribute to creditors | Covered custodial model. [C029] | Registration plus statutory trust-account duties. |\n| Education or budgeting **only**, without acting as intermediary to obtain creditor concessions | Outside the statutory definition of debt-management services. [C005] | Chapter 19-14.8 registration is not established solely from that conduct; other Rhode Island laws remain unresearched. |\n| Counseling supplied by an entity that is otherwise a covered provider | Fee treatment can still fall under §19-14.8-23 even when no agreement is ultimately signed. [C023] | Registration/coverage depends on the provider’s broader conduct and resident nexus. |\n| Creditor negotiating or compromising its own debt | Ordinarily not an intermediary and therefore not a debt-management provider under this definition. [C005] | No chapter 19-14.8 registration shown for the self-creditor activity itself. |\n| Third party negotiating between the consumer and a creditor or debt buyer | Covered intermediary activity. [C002, C005] | Registration ordinarily required. |\n| Natural person’s personally liable business or farming debt | Included under the official comments’ use of “individual,” rather than the narrower consumer-purpose formulation. [C007] | Registration may apply even though the debt had a business purpose. |\n| Debt owed only by an LLC, corporation, or other entity, without a natural-person obligor | Coverage under this chapter is not established: the statute distinguishes an “individual” from an “entity.” [C007] | **Hold** for other statutes, guaranty facts, and entity-debt law. |\n| Website or advertisement merely visible in Rhode Island, without Rhode Island agreements or service | Accessibility alone is not necessarily an “offer” to Rhode Island residents under the official comments. [C008] | Fact-sensitive; targeted availability or enrollment can change the result. |\n| Remote provider with no Rhode Island office | Physical presence is unnecessary when serving Rhode Island residents. [C008] | Registration ordinarily required. |\n\nThe statutory term “plan” is narrower than “debt-management services.” A plan requires a program or strategy with a schedule of payments used to pay the individual’s debts. The official comments explain that a plan can involve full or partial payment of some or all debts and can include deposits into the consumer’s own account. Thus, a program may be covered debt-management activity without being a plan, but many consumer-fee provisions are written specifically around an individual assenting to a plan. [C004, C030] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\n### 1.2 Custodial versus noncustodial models\n\nWhen money is paid to the provider for distribution to creditors, it is held in trust and generally must be deposited into a trust account within two business days. The provider must keep individual records, maintain a matching cash balance, reconcile monthly, and make required creditor disbursements. [C029] [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-22.htm)\n\nThe incorporated comments distinguish this from a consumer-controlled account: when the provider or its designee does not receive funds for distribution and leaves them under the individual’s control, the state trust-account section does not itself require a provider trust account. That distinction affects custody duties—not classification or registration. [C004, C029] [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\nFederal TSR dedicated-account requirements can independently apply to a consumer-owned account used in a covered telemarketing program. Those federal conditions include an insured institution, consumer ownership, independence of the account administrator, no referral compensation, and a withdrawal/refund right. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 1.3 Resident and remote-provider nexus\n\nThe Rhode Island chapter does not apply to an agreement when the provider has no reason to know the individual resides in Rhode Island at the time of the agreement. It likewise exempts the provider, to the relevant extent, when it has no reason to know of Rhode Island residence when agreeing to provide services. [C008, C010] [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm)\n\nThe interpretive comments add these boundaries:\n\n- no physical presence in Rhode Island is necessary;\n- knowledge possessed by an enrolling agent or independent contractor may be attributable to the provider;\n- temporary Rhode Island residents can be covered;\n- a nonresident’s visit to Rhode Island does not itself create coverage;\n- moving to Rhode Island after an out-of-state agreement ordinarily does not retroactively convert that agreement into a Rhode Island agreement;\n- passive ad or website accessibility alone is not necessarily an offer to residents. [Federal Trade Commission+1](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\nThe general licensing chapter independently says the debt-management licensing requirement applies without regard to incorporation or physical presence to persons initiating or servicing plans for Rhode Island residents. The more specific chapter 19-14.8 provision reaches covered services, not just plans. [C008, C016] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm)\n\n## 2. Prohibited, registered, authorized, and exempt business models\n\n### 2.1 Covered providers have a registration pathway\n\nA provider may not furnish covered services to someone it reasonably should know resides in Rhode Island unless registered under chapter 19-14.8. The director is required to maintain and publicize a list of registered providers. Employees and agents of a registered provider do not obtain separate registrations under §19-14.8-4(b), although the provider remains responsible and the agents remain subject to other substantive prohibitions. [C009] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm)\n\nThe director generally “shall” issue a certificate when the applicant complies with the application provisions, subject to enumerated discretionary and mandatory denial grounds. Initial action is due within 120 days after filing, with a possible extension of up to 60 days; registration lasts one year and must be renewed annually. A timely complete renewal remains effective while the renewal decision is pending. [C014] [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-9.htm)\n\n### 2.2 The law does not establish a nonprofit-only market\n\nThe definition of “person” includes corporations, partnerships, LLCs, associations, and other legal or commercial entities. The issuance section does not impose a general nonprofit prerequisite. Instead, nonprofit or tax-exempt applicants have additional proof and board-independence requirements. That structure confirms that “nonprofit” is neither a blanket exemption nor the sole lawful organizational form. [C011] [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\nThe current substitute-bond form also permits an applicant to be a corporation, LLC, association, partnership, or individual. That form is operational evidence rather than the source of statutory permission, but it is consistent with the enacted statute. [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf)\n\n### 2.3 An attorney connection is not enough\n\nThe exclusion applies to legal services furnished:\n\n1. by an attorney licensed or otherwise authorized to practice law in Rhode Island;\n2. in an attorney-client relationship; and\n3. as actual legal services.\n\nThe official comments expressly warn that attorney ownership of the provider is insufficient. If the intermediary service is not rendered in the course of genuine legal services within that professional relationship, the debt-management chapter applies. The Act also says it does not authorize anyone to practice law. [C006] [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\nA March 2025 Attorney General complaint alleged that a provider disguised its operation as a law firm, operated without registration, and charged 27.5% of enrolled debt rather than a lawful savings-based fee. Those are allegations, not an adjudicated holding, but they show the state’s present enforcement position against attorney-label evasion. [C034] [Rhode Island Attorney General's Office](https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees)\n\n### 2.4 Express exclusions and conditional exemptions\n\nThe following are excluded, but only within their stated conditions:\n\n| Person or condition | Treatment |\n| --- | --- |\n| Provider receiving no compensation from the individual, anyone acting on the individual’s behalf, **or the creditors** | Exempt to that extent. A creditor payment defeats this no-compensation route. [C010] |\n| Judicial officer, person acting under a court or administrative order, or assignee for benefit of creditors | Excluded when acting in the regular course of that role. |\n| Federally chartered bank or Rhode Island-chartered bank | Excluded in regular course. |\n| Regulated affiliate of such a bank | Excluded within the statutory affiliate and regulatory conditions. |\n| Title insurer, escrow company, or bill-paying provider | Excluded only when debt-management services are incidental to bill-paying services. |\n| Bank chartered in another state | Excluded only if the other state expressly authorizes the activity under conditions no more restrictive than Rhode Island’s, as determined by the director. It is not a blanket out-of-state-bank exclusion. |\n| Regulated affiliate of that qualifying out-of-state bank | Conditional exclusion. |\n| Employee or agent of a registered provider | No separate registration, but not a substantive exemption from conduct rules. |\n| Creditor acting for itself | Normally outside the intermediary definition rather than an express §3 exemption. |\n\n### 2.5 Access prerequisites\n\nAn applicant must use DBR’s prescribed form and provide, among other things:\n\n- the statutory fee;\n- bond or approved substitute;\n- identification of required trust accounts;\n- fraud/dishonesty insurance;\n- organizational and ownership details;\n- regulatory and litigation history;\n- audited financial statements for the preceding two years or period of existence;\n- evidence of independent accreditation;\n- evidence that counselors become certified within 12 months of employment;\n- educational-program information;\n- the financial-analysis and initial-budget process;\n- every Rhode Island consumer agreement form;\n- the Rhode Island fee schedule;\n- relevant criminal-record checks. [C013] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-5.htm)\n\nThe printed statute refers to $250,000 in insurance, a maximum $10,000 deductible, and a $50,000 bond, but those figures themselves are among the dollar amounts subject to §19-14.8-32(f). The director can also vary the bond according to financial condition, experience, history, and consumer risk. The exact current adjusted access amounts were not verified in this pass. [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-5.htm)\n\nThe current Schedule E form requires an accrediting organization to certify that the applicant achieved accreditation “as a Credit Counseling Organization.” That wording is an operational issue for a settlement-only applicant, but it is not sufficient to convert Rhode Island’s statutory settlement registration pathway into a prohibition. The statute requires independent accreditation but does not itself say that only nonprofits or traditional DMP agencies may register. [C041] [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf)\n\n## 3. Applicable fee structures and limits\n\n### 3.1 Critical current-dollar hold\n\nFor clarity, these symbols are used below:\n\n- A_DMP_SETUP = current DBR-adjusted DMP setup ceiling;\n- A_MONTH_CREDITOR = current adjusted per-creditor monthly amount;\n- A_MONTH_CAP = current adjusted overall monthly ceiling;\n- A_SETTLEMENT_SETUP = current adjusted absolute settlement setup ceiling;\n- A_COUNSELING = current adjusted no-agreement counseling ceiling;\n- A_DISHONORED = current adjusted dishonored-payment ceiling.\n\nRhode Island’s online statute still prints $50, $10/$50, $400, $100, and $25, respectively. Section 19-14.8-32(f), however, says the director **shall adopt replacement dollar amounts by rule**, select a base year, make threshold-triggered July 1 adjustments, round §23 amounts to the nearest dollar, notify registrants, and make the information public. Because no current adjustment rule or notice was verified, the symbols—not the printed amounts—are the defensible current-limit placeholders. [C025, C035] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### 3.2 Consumer-fee matrix\n\n| Fee or receipt | Statutory structure | Verified current rule | Current-dollar conclusion |\n| --- | --- | --- | --- |\n| Any debt-management charge generally | A provider may not directly or indirectly charge an individual or receive money from/on behalf of an individual except as permitted by §23. [C017] | Comprehensive anti-evasion rule. Separate analysis, budget, referral, or termination charges are not authorized merely by relabeling them. | Exact fee depends on an affirmative §23 pathway. |\n| DMP/concession-plan setup fee | For a plan contemplating reduced finance charges or late/default/delinquency fees: setup fee ≤ A_DMP_SETUP. | Printed figure: $50. | **Exact 2026 amount held.** |\n| DMP/concession-plan monthly fee | ≤ min(A_MONTH_CREDITOR × creditors remaining when assessed, A_MONTH_CAP). | Printed figures: $10 per remaining creditor, maximum $50/month. | **Exact 2026 amounts held.** Creditor count rule is verified. |\n| Settlement-plan setup fee | ≤ min(A_SETTLEMENT_SETUP, 4% × debt in plan at inception). [C020] | Printed absolute figure: $400. The 4% branch is not a dollar amount and remains exact. | Absolute branch held; exact result may therefore remain unresolved even for lower debt. |\n| Settlement-plan monthly fee | Same remaining-creditor structure as above. | Printed figures: $10/$50. | **Exact 2026 amounts held.** |\n| DMP and settlement fee schedules combined | Provider may not impose or receive both §23(d)(1) and §23(d)(2) fee sets. | In a mixed plan, comments instruct use of the predominant approach for setup and count all creditors for monthly-fee purposes. [C022] | No double setup/monthly recovery. |\n| Per-debt settlement compensation | For each debt: no more than 30% × (principal at agreement − amount paid creditor under plan), less setup and aggregate monthly charges not already credited against an earlier settlement fee. [C021] | 30% of actual principal savings; per debt, not enrolled balance. | Exact percentage formula verified. |\n| Aggregate settlement compensation | Sum of lawful per-debt amounts after carrying forward uncredited setup/monthly advances. | No separate percentage of total enrolled debt was found. | Aggregate is derived from each debt, not a flat enrolled-debt percentage. |\n| Educational/counseling fee after agreement | Ordinarily prohibited. Director may authorize a fee based on nature and extent of additional services; government-sponsored-program education is separately excepted. | No generally applicable public amount or approval schedule located. | **Conditional authorization/amount held.** |\n| Education/counseling when no agreement is signed | ≤ A_COUNSELING, unless director approves a larger amount based on nature and extent. [C023] | Printed figure: $100. | Exact ordinary 2026 ceiling held; larger fee requires actual director approval. |\n| Counseling-fee refund | If the individual enters an agreement within 90 days after counseling ends, provider must refund the counseling fee. | 90-day condition verified. | Full refund of that fee. |\n| Dishonored-payment charge | Reasonable charge ≤ lesser of A_DISHONORED and amount permitted by other law. [C024] | Printed figure: $25. | Exact 2026 chapter amount held; other-law ceiling also required. |\n| Voluntary contribution | Provider may not solicit it. Until 30 days after completion or termination, aggregate receipts from/on behalf of the individual may not exceed §23’s lawful total. [C026] | “Voluntary” labeling cannot evade the limits. | No separate extra-fee pathway. |\n| Rhode Island provider registration fee | $200 for each debt-management registration under §19-14-4(a)(7). | This is a provider-to-state charge, not a consumer fee. [C040] | $200 verified in current chapter 14 text; NMLS processing fees not verified. |\n\n### 3.3 Fee bases and credits\n\n**DMP monthly count.** The count is the number of creditors **remaining in the plan at the time the fee is assessed**, not the original enrollment count. The comments reject adding a creditor that is not expected to make concessions merely to increase the fee. [C039] [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n**Settlement setup base.** The percentage branch uses debt in the plan **at inception**. The absolute branch is the adjusted replacement of the printed $400 figure. [C020] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n**Settlement-performance base.** “Principal amount” is a snapshot at the time of the agreement. The fee is based on the difference between that amount and what is paid to the creditor—not on total enrolled debt, the balance when negotiations finish, or future interest avoided. [C021] [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm)\n\n**Credits.** Settlement setup and monthly charges are advances against later settlement compensation. They must be credited rather than added on top. The official comments characterize the settlement fee as the provider’s real compensation and the preliminary charges as cash-flow advances. [C022, C037] [Federal Trade Commission+1](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n**Hybrid programs.** A provider performing both DMP and settlement work may not collect both setup structures. The comments direct the provider to determine whether the plan is predominantly full-payment/concession or principal-reduction settlement, while monthly creditor counting aggregates creditors across both components. [C022] [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n### 3.4 Refund and termination conditions\n\nAn agreement must allow the consumer to terminate at any time without penalty or further obligation. On termination:\n\n- unexpended money received for debt reduction or satisfaction must be returned;\n- for a settlement agreement, 65% of any portion of the setup fee not yet credited against settlement fees must be refunded;\n- powers of attorney terminate. [C028] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm)\n\nThe official comments say monthly fees should be credited against generated settlement fees first, maximizing the uncredited setup amount to which the 65% refund applies. They do not create a general later-termination refund of all monthly fees. [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\nAn individual may cancel before midnight of the third business day after assent. The mandatory cancellation notice says all money already paid must be refunded when cancellation occurs within that period. If the agreement fails to comply with the cancellation, agreement-content, or prohibited-practices provisions, the cancellation window extends to 30 days. [C027] [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-20.htm)\n\nThis pass does not attempt a full remedies analysis. Section 19-14.8-35 separately permits recovery when §20 cancellation rights are violated, and §19-14.8-25 makes unauthorized-fee and unregistered-provider agreements voidable; those provisions are reserved for the remedies pass except for this limited fee-boundary statement. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-25.htm)\n\n## 4. When fees may be requested or received\n\n### 4.1 Rhode Island state-law timing\n\nSection 19-14.8-23(b) says a provider may not impose charges or receive payment until both parties have signed an agreement complying with §§19-14.8-19 and 19-14.8-28. Before services are supplied, a registered provider also must give an itemized fee/service list and, through a certified counselor, provide financial education and prepare a financial analysis. If there will be regular periodic payments, it must prepare and assess the suitability of the plan and reasonably believe participating creditors will accept it. [C018] [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\nThe agreement itself must identify all services and itemize the amount or method for determining every fee. It must be delivered immediately on formation. [C018] [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm)\n\nThe state text therefore establishes:\n\n1. **No pre-agreement collection.**\n2. A signed agreement is not enough unless the agreement and underlying process comply with the chapter.\n3. The state statute does not contain a separate sentence matching the federal “one debt altered and one consumer payment” trigger for every setup or monthly charge.\n4. A final settlement-fee ceiling cannot be determined from enrollment alone because it depends on actual principal savings and the amount paid to the creditor.\n5. The settlement report must disclose the settlement terms and calculation when a creditor agrees to take less than principal. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\nA creditor’s assent is part of the statutory definition of a settlement fee. The statute nevertheless does not clearly establish in a standalone timing clause whether a state settlement fee may be collected immediately at creditor assent, only when payment is fixed, or only after payment. That precise state-only collection moment remains a narrower interpretive hold; in a covered telemarketing transaction, the federal rule supplies a clearer and later minimum. [C021, C031]\n\n### 4.2 Federal TSR timing must be applied separately\n\nThe current eCFR defines a debt-relief service as a represented program or service that renegotiates, settles, or otherwise alters payment terms with one or more **unsecured** creditors or debt collectors. Title 16 was displayed as current through October 22, 2026, with the title last amended October 19, 2026. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nFor a covered telemarketing transaction, 16 C.F.R. §310.4(a)(5) prohibits requesting or receiving a fee until:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid executed agreement;\n2. the customer has made at least one payment under that creditor agreement; and\n3. the fee either has the required proportional relationship to enrolled debt or uses the same savings percentage from debt to debt. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nConsumer inbound calls responding to debt-relief advertisements do not receive the ordinary advertisement-response exemption, and debt-relief direct-mail response calls likewise remain carved out of the relevant exemption. The rule also contains a general business-to-business call exemption, so business-purpose and caller/callee facts must be separately evaluated. [C031] [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310)\n\n### 4.3 Combined operational rule\n\nFor a transaction subject to both regimes:\n\n- Rhode Island determines whether the provider must be registered, what the maximum state fee is, and which state credits/refunds apply.\n- The TSR determines the federal earliest collection point and federal allocation conditions.\n- Compliance requires satisfying **both**, effectively applying the stricter combination.\n- A Rhode Island fee ceiling is not permission to collect that fee in advance.\n- TSR noncoverage does not create a Rhode Island exemption. [C032]\n\n## 5. Actual regulator procedure, lookup, and current market access\n\n### 5.1 Current public application channel\n\nDBR’s “All Other Licensees” page expressly lists **Debt Management Services Registration** among the authorizations that applicants must submit through NMLS. The same page links the Rhode Island accreditation form, substitute-bond form, and 2026 annual-report materials. [C012, C015] [Department of Business Regulation](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees)\n\nThe DBR license-lookup page directs banking license/registration searches to **NMLS Consumer Access**. That page was updated August 7, 2026. [C012, C033] [Department of Business Regulation](https://dbr.ri.gov/about-dbr/lookup-license)\n\nThe current public routes are therefore:\n\n- application/instructions: DBR page → NMLS Rhode Island requirements;\n- status lookup: DBR lookup page → NMLS Consumer Access;\n- state forms: DBR accreditation and bond forms;\n- continuing-status evidence: annual renewal and annual reporting.\n\n### 5.2 Evidence that the program is active\n\nDBR’s January 14, 2026 notice requires Rhode Island debt-management companies to file a report for calendar year 2025 by March 31, 2026, using license and NMLS identifiers and uploading financial statements to NMLS. The companion checklist requires all current licensees to report and asks for Rhode Island plan counts and dollar amounts. This is strong current operational evidence that registration remains active rather than being a dormant statutory program. [C015] [Department of Business Regulation+1](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf)\n\nThe notice contains an apparent internal typo referring once to a March 31, 2025 penalty date, while the rest of the notice and checklist consistently state March 31, 2026. That defect does not erase the overall evidence of a current 2026 reporting process, but the incorrect date should not be repeated as an operative deadline. [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf)\n\n### 5.3 Inaccessible or unverified procedural material\n\nThe linked NMLS Rhode Island requirements page and public checklist compiler returned no extractable substantive text through the public research route. Therefore this pass does **not** claim:\n\n- the complete current NMLS checklist;\n- current NMLS processing charges;\n- every MU1/MU2 filing item;\n- exact electronic-bond steps;\n- a named company’s active status. [C033] [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=RI)\n\nNo application was filed, no regulator was contacted, and no named-provider status was inferred from a company website or marketing statement.\n\n### 5.4 No current DMS-specific rule or adjustment notice located\n\nThe official Title 230 RICR catalog lists DBR’s Banking chapter and its financial-institution, lending, mutual-holding-company, money-servicer, and debt-collector subchapters. The displayed Money Servicers subchapter contains record-retention and check-casher parts, not a DMS fee-adjustment part. DBR’s current rules index, current banking bulletins, licensee-guidance page, and amended/revoked bulletin PDF likewise did not display a debt-management CPI adjustment notice. [C035] [Rules of Rhode Island+6](https://rules.sos.ri.gov/Organizations/Title/230)\n\nThis is a bounded catalog finding. It does **not** prove that no adjustment was ever issued through a register notice, registrant communication, individual order, archived webpage, or document not indexed in those locations.\n\n## 6. Worked fee and boundary examples\n\nThe examples below are illustrations of the verified formulas, not quotations of current adjusted dollar caps. They assume a properly registered provider, a compliant agreement, satisfaction of Rhode Island prerequisites, and—when the TSR applies—completion of the federal performance and payment triggers.\n\n### Example 1 — DMP with four creditors\n\n**Inputs**\n\n- Remaining creditors when monthly fee is assessed: 4\n- Current adjusted per-creditor amount: A_MONTH_CREDITOR\n- Current adjusted monthly maximum: A_MONTH_CAP\n\n**Operator**\n\nMonthly maximum = min(4 × A_MONTH_CREDITOR, A_MONTH_CAP)\n\n**Printed-statute-only illustration**\n\nUsing the unadjusted printed figures:\n\nmin(4 × $10, $50) = min($40, $50) = $40\n\n**Result**\n\n- Formula result: min(4 × A_MONTH_CREDITOR, A_MONTH_CAP)\n- Units: dollars per month\n- The $40 figure is **not represented as the verified October 2026 ceiling**.\n- Inflation-adjusted §23 amounts are rounded by DBR to the nearest dollar; no public current replacement was verified. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 2 — Monthly count decreases as creditors leave\n\n**Inputs**\n\n- Original creditors: 5\n- Creditors remaining when current month is assessed: 2\n\n**Operator**\n\nMonthly maximum = min(2 × A_MONTH_CREDITOR, A_MONTH_CAP)\n\n**Printed-statute-only illustration**\n\nmin(2 × $10, $50) = $20\n\n**Result**\n\nThe two remaining creditors—not the five originally enrolled—control the calculation. The exact current dollar result remains held. [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n### Example 3 — Lower-debt settlement setup fee\n\n**Inputs**\n\n- Debt in plan at inception: $6,000\n- Exact percentage: 4%\n- Current adjusted absolute ceiling: A_SETTLEMENT_SETUP\n\n**Intermediate calculation**\n\n4% × $6,000 = $240\n\n**Operator**\n\nMaximum setup fee = min(A_SETTLEMENT_SETUP, $240)\n\n**Result**\n\nThe exact ceiling is min(A_SETTLEMENT_SETUP, $240). It is not safe to declare $240 without verifying that the current adjusted absolute ceiling is at least that amount. Units are dollars; the 4% arithmetic produces $240.00. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 4 — Per-debt settlement compensation with prior fees\n\n**Inputs**\n\n- Principal at agreement: $10,000\n- Amount paid creditor in full settlement: $6,000\n- Setup/monthly amounts already collected and still uncredited: $500\n\n**Intermediate calculations**\n\nRealized principal savings = $10,000 − $6,000 = $4,000\n\nGross state settlement-fee ceiling = 30% × $4,000 = $1,200\n\nAdditional settlement fee = $1,200 − $500 = $700\n\n**Result**\n\n- Maximum additional fee: $700\n- Total provider compensation attributable to this debt, including the prior $500 advances: $1,200\n- This is a state maximum, not a conclusion that the fee was timely collected under the TSR.\n- The agreement must disclose the method. No separate Rhode Island transactional-cent rounding rule was located; the example uses exact dollar arithmetic. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 5 — Small settlement savings and prior-fee credit\n\n**Inputs**\n\n- Principal at agreement: $8,000\n- Amount paid creditor: $7,600\n- Uncredited setup/monthly advances: $180\n\n**Intermediate calculations**\n\nSavings = $8,000 − $7,600 = $400\n\nGross ceiling = 30% × $400 = $120\n\nAdditional fee = max($0, $120 − $180) = $0\n\n**Credit tracking**\n\n- $120 of the prior advances is credited against this debt’s gross ceiling.\n- $60 remains uncredited and must remain available to reduce a later settlement fee or enter the termination-refund calculation.\n- The provider does not obtain a negative fee and cannot charge an additional amount on this debt. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 6 — Two debts and aggregate compensation\n\n**Inputs**\n\n- Debt A: principal $10,000, paid $6,000\n- Debt B: principal $5,000, paid $4,000\n- Uncredited setup/monthly advances before Debt A: $500\n- Assumption: Debt A is completed first\n\n**Debt A**\n\nSavings = $4,000\n\nGross ceiling = 30% × $4,000 = $1,200\n\nAdditional fee = $1,200 − $500 = $700\n\n**Debt B**\n\nSavings = $1,000\n\nGross ceiling = 30% × $1,000 = $300\n\nPrior advances remaining uncredited = $0\n\nAdditional fee = $300\n\n**Aggregate**\n\nPrior advances $500 + additional A $700 + additional B $300 = $1,500\n\nThat equals the sum of the two per-debt gross ceilings. It is not 30% of the total enrolled balance. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 7 — Later termination and 65% setup refund\n\n**Inputs**\n\n- Settlement setup fee previously paid: $300\n- Monthly fees paid: $120\n- Settlement-fee entitlement generated before termination: $200\n\nThe official comments direct monthly fees to be credited first.\n\n**Intermediate calculations**\n\nMonthly credit applied = $120\n\nRemaining generated settlement fee = $200 − $120 = $80\n\nSetup fee credited = $80\n\nUncredited setup fee = $300 − $80 = $220\n\nRefund = 65% × $220 = $143\n\n**Result**\n\n- Setup-fee refund: $143\n- Any consumer money still held for creditors must also be returned, subject to lawfully payable fees.\n- Assumes all original fees were themselves lawful under the adjusted ceilings and any applicable TSR timing rule. [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm)\n\n### Example 8 — Ordinary three-business-day cancellation\n\n**Inputs**\n\n- Setup paid: $300\n- Monthly amount paid: $50\n- Cancellation properly delivered within the ordinary statutory period\n\n**Calculation**\n\nRefund = $300 + $50 = $350\n\n**Result**\n\nThe mandatory notice requires refund of all money already paid during the three-business-day cancellation period; the 65% later-termination calculation does not replace that full-cancellation refund. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-20.htm)\n\n### Example 9 — Counseling without an agreement\n\n**Inputs**\n\n- Consumer pays lawful counseling fee F\n- Consumer later enters a debt-management agreement 45 days after counseling ends\n\n**Condition**\n\n45 days ≤ 90 days\n\n**Result**\n\nRefund = 100% × F\n\nThe exact ordinary ceiling for F remains held because the printed $100 amount is subject to §32(f). A director-approved larger fee would require actual approval and would still be subject to the 90-day refund rule. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm)\n\n### Example 10 — One-time negotiation with no payment schedule\n\n**Facts**\n\n- Provider negotiates one debt for a Rhode Island resident.\n- Consumer has already accumulated funds.\n- No payment schedule or other statutory “plan” is formed.\n\n**Classification**\n\nThe activity is covered debt-management services under the official comments.\n\n**Fee result**\n\n- Registration: ordinarily required.\n- Positive consumer-fee authorization: **HOLD**.\n- The setup, monthly, and savings-based provisions are framed around a consumer assenting to a plan.\n- A provider cannot rely on the comprehensive fee prohibition and simply invent a “negotiation fee.”\n- If the transaction is lawfully structured as a plan with a scheduled payment, the plan provisions may apply; that is a different fact pattern. [Federal Trade Commission+2](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n### Example 11 — Natural-person business debt versus entity-only debt\n\n**Case A:** A sole proprietor is personally liable on a business credit card and hires an intermediary to obtain a concession.\n\n- “Individual” coverage is supported by the official comments.\n- Registration and fee rules may apply.\n\n**Case B:** An LLC alone owes a trade debt, with no natural-person guaranty or personal liability.\n\n- Chapter 19-14.8 coverage is not established on the present evidence.\n- No Rhode Island consumer-fee calculation should be imposed by analogy.\n- Other commercial-debt, collection, licensing, and contract law remains open. [Federal Trade Commission+2](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf)\n\n## 7. Immediate implementation implications for SettleADebt.com\n\nFor a Rhode Island launch decision, the defensible present conclusions are:\n\n1. **Do not launch compensated Rhode Island settlement or DMP enrollment without confirming an active DBR debt-management registration.**\n2. **Do not rely on nonprofit status, attorney ownership, out-of-state location, a consumer-controlled account, or a one-debt model as an exemption.**\n3. **Do not use a percentage of enrolled debt as the Rhode Island consumer settlement fee.**\n4. **Track principal at agreement, creditor payment amount, realized savings, setup fees, monthly fees, and the sequence in which credits are applied for every debt.**\n5. **Do not place the printed $50/$10/$50/$400/$100/$25 figures into production until the current §32(f) adjustment history is resolved.**\n6. **Apply federal TSR timing separately to covered phone-originated or phone-closed business; a state formula is not authorization to collect before federal performance.**\n7. **Treat a truly no-plan, one-time negotiation fee as unresolved rather than assuming the plan fee schedule applies.**\n\n# B. Source table\n\nAll web and PDF sources below were actually opened on October 24, 2026. PDF sources used substantively were also visually inspected through page screenshots.\n\n| Source ID | Title / issuer / status | Direct literal URL and pinpoint | Actual check and limitations |\n| --- | --- | --- | --- |\n| **S_RI-P1-S001** | 2026 Rhode Island General Laws portal and chapter index; Rhode Island General Assembly. Current online compilation is expressly provisional. | https://webserver.rilegislature.gov/statutes/Statutes.html — portal notice and “Search the 2026 General Laws.”  https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/INDEX.htm — complete chapter index. | Freshly opened/read 2026-10-24. Portal warns that printed official publication controls legal rights. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/statutes/Statutes.html) |\n| **S_RI-P1-S002** | R.I. Gen. Laws ch. 19-14.8, Uniform Debt-Management Services Act; operative statutory authority. | Key section URLs: https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm — definitions, especially (7), (9), (10), (12)–(17), (20). .../19-14.8-3.htm — resident, compensation, and institutional exclusions. .../19-14.8-4.htm — registration. .../19-14.8-5.htm and .../19-14.8-6.htm — application. .../19-14.8-9.htm, .../19-14.8-10.htm, .../19-14.8-11.htm — issuance, timing, renewal. .../19-14.8-13.htm, .../19-14.8-14.htm — bond/substitute. .../19-14.8-17.htm — prerequisites. .../19-14.8-19.htm, .../19-14.8-20.htm — agreement and cancellation. .../19-14.8-22.htm through .../19-14.8-28.htm — trust, fees, contributions, voidability, termination, reports, prohibited acts. .../19-14.8-32.htm — director powers/indexing. .../19-14.8-43.htm — official comments. | Relevant operative sections freshly opened and read. Current online text remains subject to S001’s provisional-publication warning. [Rhode Island Legislature+10](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm) |\n| **S_RI-P1-S003** | R.I. Gen. Laws ch. 19-14, Licensed Activities. | https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm — license/registration requirement and remote-plan nexus. https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm — $200 debt-management registration fee and late charge. | Freshly read. Chapter 14 uses generic licensing terminology; ch. 14.8 specifically uses registration. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm) |\n| **S_RI-P1-S004** | Uniform Debt-Management Services Act final text and official comments; Uniform Law Commission document hosted by FTC. Rhode Island §19-14.8-43 gives the official comments interpretive-guide status. | https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf Relevant PDF pages: 9; 15–20; 22; 58; 63; 66–70. | PDF parsed and relevant pages visually inspected. It is the national final model-act/comment document, not a Rhode Island codifier PDF. It was used only where enacted Rhode Island text aligns and because §43 directs use of official comments. [Rhode Island Legislature+7](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm) |\n| **S_RI-P1-S005** | “All Other Licensees — Applications, Forms & Other Information”; Rhode Island DBR. Current procedural page. | https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees Debt Management Services Registration/NMLS at page lines 119–146; 2026 annual reports at 157–163. | Freshly read. Page itself says last updated May 21, 2025, but links current 2026 annual-report files. Procedure evidence, not a substitute for statutory authority. [Department of Business Regulation](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees) |\n| **S_RI-P1-S006** | “Lookup a License or Registration”; Rhode Island DBR. | https://dbr.ri.gov/about-dbr/lookup-license Banking lookup through NMLS Consumer Access at lines 116–120. | Freshly read; page updated August 7, 2026. No named-provider search was completed. [Department of Business Regulation](https://dbr.ri.gov/about-dbr/lookup-license) |\n| **S_RI-P1-S007** | Official Rhode Island Code of Regulations catalog, Title 230/Chapter 40. | https://rules.sos.ri.gov/Organizations/Title/230 https://rules.sos.ri.gov/Organizations/Chapter/230-40 https://rules.sos.ri.gov/Organizations/SubChapter/230-40-20 Also checked displayed Financial Institutions and Lending subchapters. | Freshly read as current catalog evidence. No DMS-specific part appeared in the displayed catalog. This is a bounded negative result, not proof against unpublished or archived material. [Rules of Rhode Island+2](https://rules.sos.ri.gov/Organizations/Title/230) |\n| **S_RI-P1-S008** | Current DBR rules, bulletins, and guidance indexes. | https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions https://dbr.ri.gov/insurance-banking-securities-and-charitable-organizations/banking/credit-unions-financial-0 | Indexes freshly read. No DMS CPI/fee-adjustment item appeared. Catalog absence is not conclusive proof no separate notice exists. [Department of Business Regulation+2](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules) |\n| **S_RI-P1-S009** | Schedule E — Debt Management Services Evidence of Accreditation; Rhode Island DBR. | https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20(fillable).pdf PDF p.1, form lines 7–15. | PDF opened and visually inspected. File location is current, but footer says form dated June 27, 2007. It uses “Credit Counseling Organization” wording. [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf) |\n| **S_RI-P1-S010** | Uniform Debt-Management Services Act Substitute Bond Form; Rhode Island DBR. | https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf PDF pp.1–2, especially lines 7–15, 38–42, 70–78. | PDF opened and visually inspected. URL/file label suggests 2025 revision, while form footer contains older/inconsistent revision text; statute controls. [Department of Business Regulation+1](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf) |\n| **S_RI-P1-S011** | 2026 Debt Management Services annual-report notice and checklist; Rhode Island DBR. | https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_checklist_1-20-26rls.pdf | PDFs opened and visually inspected. Notice contains one apparent 2025 typo; checklist and remaining text specify 2026. Used as operational-currentness evidence only. [Department of Business Regulation+1](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf) |\n| **S_RI-P1-S012** | NMLS Rhode Island requirements and checklist compiler. | https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx?StateID=RI https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx | Actual public routes opened but returned zero extractable lines. Exact current checklist, system fees, and filing fields remain unresolved. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=RI) |\n| **S_RI-P1-S013** | Telemarketing Sales Rule, 16 C.F.R. pt. 310; eCFR. | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 — debt-relief definition. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 — advance-fee rule. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310 — exemptions. | Freshly read. eCFR displayed Title 16 through October 22, 2026 and notes eCFR is authoritative but unofficial. [eCFR+3](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_RI-P1-S014** | March 19, 2025 Palisade debt-management complaint announcement; Rhode Island Attorney General. | https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees Registration allegations at lines 94–103; fee allegations at 108–110. | Freshly read. Complaint allegations are not a final adjudication or controlling decision. [Rhode Island Attorney General's Office](https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees) |\n| **S_RI-P1-S015** | DBR Banking Enforcement Actions roster and Golden Financial consent agreement. | https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions https://dbr.ri.gov/documents/decisions/BK_Consent_Agreement-Golden_Financial_Services.pdf | Roster read; consent-order PDF opened and visually inspected. Consent resolution is operational/enforcement evidence, not a controlling appellate interpretation. [Department of Business Regulation+1](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions) |\n| **S_RI-P1-S016** | Amended and Revoked Banking Bulletins; Rhode Island DBR. | https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf | PDF opened and visually inspected. The displayed historical list concerned mortgage-related matters and did not supply a DMS fee adjustment. Updated May 10, 2016. [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf) |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Source IDs and exact pinpoints | Conditions, currentness, and confidence limits |\n| --- | --- | --- | --- |\n| **S_RI-P1-C001** | The current online 2026 Rhode Island General Laws contain chapter 19-14.8, the Uniform Debt-Management Services Act. | S001 portal; S001 chapter index. | High confidence in current online text; portal is expressly provisional and printed official publication controls. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/statutes/Statutes.html) |\n| **C002** | DMS means acting as an intermediary between an individual and one or more creditors to obtain more favorable repayment terms. | S002 §19-14.8-2(7), (9), (15). | Functional rather than label-based. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm) |\n| **C003** | Concessions include reductions of interest/finance charges, delinquency/default fees, and principal. | S002 §2(7); S004 PDF p.15 lines 459–465. | Official-comment interpretation given force by §43. High confidence. [Federal Trade Commission+1](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf) |\n| **C004** | One-time negotiation and noncustodial programs can be covered; no statutory plan or provider control of funds is required for classification. | S004 PDF p.15 lines 466–478; S002 §2(13). | Registration can apply even where fee provisions framed around a plan do not clearly fit. High confidence on classification. [Federal Trade Commission](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf) |\n| **C005** | Pure education without creditor intermediation is outside DMS; a creditor compromising its own claim is not an intermediary. | S004 PDF p.15 lines 479–487. | Other Rhode Island laws remain open. High confidence under chapter 14.8. [Federal Trade Commission+1](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf) |\n| **C006** | Attorney/CPA/planner exclusions require actual qualifying professional services in the relevant client relationship; ownership or affiliation is insufficient. | S002 §2(9)(a)–(c); S004 PDF p.16 lines 493–503. | Attorney must be licensed/otherwise authorized in Rhode Island. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm) |\n| **C007** | Natural-person business/farming debt can be covered; entity-only obligations are not shown covered under “individual.” | S004 PDF p.9 lines 286–295 and p.22 lines 701–706; S002 §2(10), (12). | Entity-debt and guaranty issues remain open. Moderate-high confidence. [Federal Trade Commission+2](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf) |\n| **C008** | Rhode Island resident nexus applies without physical presence; knowledge can arise through agents; later relocation and passive website accessibility have narrower boundaries. | S002 §3(a)–(b); S003 §19-14-2(a); S004 pp.19–20. | Agreement-time facts control. High confidence. [Rhode Island Legislature+3](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm) |\n| **C009** | Covered compensated providers must register; employees/agents of a registered provider need no separate registration; public list required. | S002 §4(a)–(c). | Other conduct obligations still apply to agents. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm) |\n| **C010** | Exemptions include zero compensation from every side and specified institutional actors under stated conditions. | S002 §3(b)–(c). | Out-of-state-bank and incidental-bill-pay exclusions are conditional. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm) |\n| **C011** | Nonprofit status is not a general exemption or exclusive eligibility rule; for-profit applicants are contemplated. | S002 §2(12), §5(b)(6), §9(a), (c); S010 form. | Schedule E wording creates an operational issue but not a statutory nonprofit-only rule. High confidence. [Rhode Island Legislature+3](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm) |\n| **C012** | Current DBR procedure sends DMS-registration applicants through NMLS and banking lookups through NMLS Consumer Access. | S005 lines 119–146; S006 lines 116–120. | Exact NMLS checklist was not extractable. High confidence on the route. [Department of Business Regulation+1](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees) |\n| **C013** | Application requires fee, bond/security, insurance, accreditation, certified counselors, financial and organizational disclosures, agreement forms, and fee schedule. | S002 §§5–6. | Several access-dollar figures are themselves subject to §32(f). High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-5.htm) |\n| **C014** | Director generally shall issue to a compliant applicant, subject to denial grounds; initial decision 120 days plus possible 60-day extension; annual renewal required. | S002 §§9–11. | Registration does not arise merely by filing. High confidence. [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-9.htm) |\n| **C015** | Rhode Island’s DMS registration program was operational in 2026. | S005 annual-report links; S011 notice/checklist. | Operational evidence, not proof that any particular company was active. High confidence. [Department of Business Regulation+2](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees) |\n| **C016** | Specific legal authorization is a registration even though chapter 14 and agency forms sometimes use “license/licensee.” | S002 §§4, 9–11; S003 §19-14-2(a). | Terminology should not be used to convert registration into a different licensing regime. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm) |\n| **C017** | Section 23’s fee prohibition is comprehensive and reaches indirect/relabelled charges. | S002 §23(a); S004 PDF pp.66–67 lines 2145–2164. | No extra analysis, budget, referral, or termination fee unless affirmatively authorized. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C018** | Rhode Island prohibits charges before a compliant signed agreement and requires pre-service itemization, education, and analysis. | S002 §23(b), §17(a)–(c), §19(a). | This is a state floor, not TSR compliance. High confidence. [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C019** | DMP setup and monthly limits use adjusted dollar amounts; printed figures are $50 and $10 per creditor/$50 monthly. | S002 §23(d)(1), §32(f)–(g). | Exact current adjusted dollars unresolved. High confidence on formula/base-text distinction. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C020** | Settlement setup fee is the lesser of the adjusted absolute ceiling and 4% of plan debt at inception; monthly formula uses adjusted amounts. | S002 §23(d)(2). | 4% exact; absolute and monthly dollars held. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C021** | Settlement compensation is capped per debt at 30% of principal savings less uncredited setup/monthly advances. | S002 §23(f); S014 fee allegation consistent with formula. | State maximum; timing and federal law separately apply. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C022** | Provider cannot charge both DMP and settlement setup/monthly schedules; mixed plans use predominant approach and aggregate remaining creditors. | S002 §23(d)(3); S004 PDF pp.68–69 lines 2226–2236. | Official-comment interpretation. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C023** | No-agreement counseling has an adjusted ceiling or director-approved higher amount and must be refunded if an agreement follows within 90 days. | S002 §23(c)–(e). | Exact adjusted ordinary dollar amount and any specific approvals not located. High confidence on structure. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C024** | Dishonored-payment fee is the lesser of the adjusted chapter amount and other-law amount. | S002 §23(g). | Printed $25 is not verified current amount; other-law inquiry remains open. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C025** | DBR must replace specified statutory dollars by rule, use a base year, make threshold-triggered July 1 adjustments, round §23 figures to nearest dollar, notify registrants, and publish. | S002 §32(f)–(g). | Mandatory statutory mechanism; actual adjustment document unresolved. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-32.htm) |\n| **C026** | Voluntary contributions cannot be solicited or used to exceed the lawful aggregate. | S002 §24; S004 PDF p.70. | Applies to all providers; voluntary label does not control. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-24.htm) |\n| **C027** | Consumer has a three-business-day cancellation right with full refund of money already paid; noncompliance can extend cancellation to 30 days. | S002 §20(a)–(b). | Full remedies consequences of extended-window cases remain later-pass work. High confidence on text. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-20.htm) |\n| **C028** | Later settlement termination requires return of trust funds and 65% of uncredited setup fee; monthly fees are credited first for the setup-refund computation. | S002 §19(d), §26; S004 p.58 lines 1875–1887. | No general later refund of all monthly fees established. High confidence. [Rhode Island Legislature+2](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm) |\n| **C029** | State trust duties apply when provider/designee receives money for creditor distribution, but not merely because the provider can advise a consumer controlling their own funds. | S002 §22; S004 p.63 lines 2027–2039. | TSR dedicated-account rules may independently apply. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-22.htm) |\n| **C030** | A truly no-plan one-time negotiation is covered DMS, but no affirmative consumer-fee pathway was established because §23’s operative settlement structures are plan-based. | S004 p.15 lines 473–478; S002 §23(a), (d), (f). | Fee authorization held; not a conclusion that registration is unavailable or that lawful fee must be zero. Moderate-high confidence. [Federal Trade Commission+1](https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf) |\n| **C031** | For covered TSR telemarketing, fee collection requires at least one altered debt, one consumer payment, and federal allocation compliance. | S013 §§310.2(o), 310.4(a)(5), 310.6. | TSR scope requires separate call, debt, and exemption analysis. High confidence. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **C032** | State fee permission and federal fee timing are independent; the stricter combination governs when both apply. | S002 §23; S013 §310.4(a)(5). | Legal synthesis; high confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C033** | Public application/lookup procedures were verified, but no named provider’s current status was checked. | S005, S006, S012. | NMLS substantive page extraction failed; no marketing statement was treated as authorization. High confidence on research boundary. [Department of Business Regulation+2](https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees) |\n| **C034** | Rhode Island has publicly enforced registration against purported settlement offerings; current AG allegations challenge attorney-label and enrolled-debt fee structures. | S014; S015 Golden consent. | Administrative consent and pending allegations are not controlling judicial holdings. High confidence as enforcement evidence only. [Rhode Island Attorney General's Office+1](https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees) |\n| **C035** | No DMS adjustment rule or notice appeared in the official current RICR/DBR catalogs reviewed. | S007, S008, S016. | Bounded negative finding; exact adjusted amounts remain held rather than assumed. Moderate confidence regarding public catalog visibility, not historical nonexistence. [Rules of Rhode Island+4](https://rules.sos.ri.gov/Organizations/Title/230) |\n| **C036** | Compensation from creditors defeats the zero-compensation exemption and must be disclosed where applicable. | S002 §3(b)(2), §17(d)(5). | This pass does not establish a cap on creditor-paid compensation. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm) |\n| **C037** | Settlement setup/monthly charges are advances against the later settlement fee rather than additional compensation. | S002 §23(f)(2); S004 p.70 lines 2260–2265. | Credits must be tracked across debts. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C038** | No separate flat aggregate percentage of enrolled debt was established; aggregate consumer settlement compensation is derived debt by debt. | S002 §23(f). | Other contract/remedy questions about allocation remain later work. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C039** | Monthly count uses creditors remaining at assessment, not original enrollment count. | S002 §23(d)(1)(B), (2)(B); S004 p.68. | Exact dollar multipliers held. High confidence. [Rhode Island Legislature+1](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm) |\n| **C040** | Current statute sets a $200 annual state fee for each DMS registration. | S003 §19-14-4(a)(7). | Does not include unverified NMLS system fees. High confidence. [Rhode Island Legislature](https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm) |\n| **C041** | Current Schedule E uses “Credit Counseling Organization” accreditation wording, creating a settlement-only applicant evidence issue. | S009 p.1 lines 7–15. | Form wording is operational evidence, not an independent statutory prohibition. High confidence on form text; legal effect beyond §6(8) unresolved. [Department of Business Regulation](https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf) |\n| **C042** | No reported Rhode Island controlling appellate or federal decision construing the central registration/fee provisions was located in the bounded public searches. | Targeted exact-statute and site-restricted public searches; S014/S015 are noncontrolling enforcement sources. | Not a comprehensive docket search or conclusion that no case exists. Full case-law pass remains open. |\n\n# D. Component coverage and gap table\n\n| Pass component | Status | Supporting claims | Missing evidence / exact next investigation |\n| --- | --- | --- | --- |\n| Functional DMS definition | **Answered** | C002–C005 | Later test unusual creditor/affiliate and lead-generator models against specific facts. |\n| DMP versus principal-reduction settlement | **Answered** | C002–C004 | No material gap for basic classification. |\n| One-time negotiation | **Partial** | C004, C030 | Locate Rhode Island order, declaratory ruling, or controlling case addressing §23 fees when covered services do not constitute a plan. |\n| Custodial/noncustodial distinction | **Answered for access boundary** | C004, C029 | Full trust-account operations, independent-account providers, electronic-access powers, and bank-location rules remain later-pass work. |\n| Consumer versus business purpose | **Answered for natural persons; partial otherwise** | C007 | Analyze guarantors, jointly liable owners, entity-only debt, and commercial-debt statutes. |\n| Rhode Island resident/remote nexus | **Answered** | C008 | Apply to actual enrollment scripts, IP/address facts, agent knowledge, and servicing transfers. |\n| General market access | **Answered** | C009, C012, C014–C016 | Registration required; exact company status requires NMLS lookup by legal name/NMLS ID. |\n| Attorney exclusion | **Answered at statutory level** | C006, C034 | Full unauthorized-practice, law-firm ownership, fee-sharing, and case-law analysis remains open. |\n| Nonprofit treatment | **Answered** | C011 | Review applicant-specific corporate and tax status only if relying on those representations. |\n| Institutional and no-compensation exclusions | **Answered at text level** | C010, C036 | Test any bank affiliate, incidental bill-pay, or other-state bank against actual facts and director determinations. |\n| Application requirements | **Answered in statute; procedural details partial** | C012–C015, C041 | Retrieve current public NMLS Rhode Island DMS checklist, MU filing instructions, and current system charges without using an account. |\n| Public lookup route | **Answered** | C012, C033 | Perform named-provider lookup when legal name/NMLS ID is supplied; no status inferred here. |\n| Current operation of registration program | **Answered** | C015 | Recheck future annual-report cycle in later currentness pass. |\n| Current DMP dollar fees | **Unresolved** | C019, C025, C035 | Locate §32(f) base-year rule, every July 1 adjustment, registrant notice, state-register filing, adoption order, or archived DBR schedule. |\n| Current settlement absolute setup ceiling | **Unresolved** | C020, C025, C035 | Same adjustment-document investigation. Do not calculate CPI independently. |\n| Current monthly dollar multiplier/cap | **Unresolved** | C019–C020, C025 | Same adjustment-document investigation. |\n| Current no-agreement counseling dollar cap | **Unresolved** | C023, C025 | Same adjustment-document investigation; also locate any director-approved higher-fee orders. |\n| Current dishonored-payment chapter cap | **Unresolved** | C024–C025 | Locate adjusted amount and separately research other Rhode Island dishonored-payment law. |\n| Exact percentage formulas | **Answered** | C020–C022, C037–C039 | Apply to actual contract and debt-level data only after dollar adjustments and timing are resolved. |\n| Setup/monthly credit mechanics | **Answered** | C022, C028, C037 | Contract-specific posting and overcollection remediation remain later-pass issues. |\n| Aggregate cap | **Answered within §23** | C038 | No flat enrolled-debt fee established; later verify no applicable special-sector law changes result. |\n| State fee timing | **Answered with narrow hold** | C018, C021 | Exact state-only moment for requesting final settlement fee after creditor assent but before payment remains an interpretive issue. |\n| Federal TSR timing | **Answered as common context** | C031–C032 | Apply to actual call flow, ad source, debt type, seller/telemarketer roles, and exemptions. |\n| Cancellation and fee refunds | **Answered within fee scope** | C023, C027–C028 | Full private remedies, class remedies, voidability, limitations, and restitution remain later-pass work. |\n| Provider bond/insurance | **Boundary only** | C013 | Exact adjusted bond/insurance dollars, claims, substitutes, duration, and recovery reserved for bond/remedies pass. |\n| Accreditation | **Partial** | C013, C041 | Determine current DBR-approved accreditors and how settlement-only applicants satisfy the “Credit Counseling Organization” form wording. |\n| Regulations/adoption orders | **Partial** | C025, C035 | Search Rhode Island State Register archives, DBR rulemaking dockets, superseded regulations, and notices to registrants. |\n| Controlling decisions | **Partial/negative search result** | C042 | Comprehensive Rhode Island Judiciary, Superior Court, federal district, First Circuit, and citator search. |\n| Enforcement posture | **Answered only as examples** | C034 | Obtain and analyze underlying Palisade complaint, docket status, later orders, and other DMS enforcement files. |\n| Creditor-paid compensation | **Boundary only** | C036 | Analyze fee caps, conflicts, disclosure, and creditor fair-share arrangements in a later pass. |\n| Agreements/e-signatures | **Excluded except timing/content needed here** | C018, C027 | Full formation, delivery, E-SIGN/UETA, choice-of-law, forum, POA, and severability pass. |\n| Full funds/trust analysis | **Excluded except custody boundary** | C029 | Full accounting, disbursement, insolvency, account administrator, reconciliation, and dedicated-account pass. |\n| Remedies, collection, litigation, limitations | **Excluded except refund boundary** | C027–C028 | Dedicated later passes required. |\n| Exemptions beyond access classification | **Open** | C010 | Sector, creditor, professional, bankruptcy, court-supervised, and institutional edge cases. |\n| Secured debt | **Open** | — | Analyze mortgage, auto, tax, utility, student-loan, medical, and other secured/special debt interactions. |\n| Local, tribal, sector, and contract law | **Open** | — | Separate Rhode Island/local/federal/tribal and contract investigations required. |\n| Proposed/future-effective rules | **Open** | C035 | Search active Rhode Island rulemaking notices and future-effective enactments; none is claimed absent. |\n| Named SettleADebt.com authorization | **Not established** | C033 | Registration must be independently confirmed before Rhode Island service. |\n| Full Rhode Island or A066 acceptance | **Expressly not performed** | All | Completion requires all remaining state components and coordinator review. |\n\n# E. Researcher self-check\n\n### Actually read\n\n- The current online 2026 Rhode Island General Laws portal, chapter index, and the operative chapter 19-14.8 provisions listed in S_RI-P1-S002.\n- Chapter 19-14’s general authorization and annual-fee provisions.\n- The relevant Uniform Act comments on classification, residence, professional exclusions, custody, fee limits, fee credits, and termination refunds.\n- DBR’s current application page and lookup page.\n- DBR’s accreditation form, substitute-bond form, and 2026 annual-report notice/checklist.\n- The official current RICR Title 230 and Banking catalogs.\n- DBR’s current rules, bulletins, guidance, and amended/revoked-bulletin indexes.\n- The current eCFR debt-relief definition, advance-fee provision, and relevant telemarketing exemptions.\n- The Golden consent agreement and current Rhode Island Attorney General enforcement announcement.\n\nAll substantively used PDFs were also inspected visually by page, not treated as title-only or snippet evidence.\n\n### Not read or not established\n\n- No authenticated NMLS backend, complete current NMLS checklist, or NMLS fee computation.\n- No named-provider status.\n- No nonpublic registrant notice, agency correspondence, or individual fee approval.\n- No complete Rhode Island State Register archive or historical rulemaking file for §19-14.8-32(f).\n- No comprehensive docket/citator search establishing the absence of controlling cases.\n- No underlying Palisade complaint or subsequent docket orders.\n- No private borrower records, contracts, trust-account data, applications, or regulator communications.\n- No independent legal review, state approval, publication readiness, or local save.\n\nThe calculations above were recomputed directly from the displayed assumptions and statutory operators. The unresolved adjusted dollar figures were deliberately preserved as variables rather than estimated from CPI.\n\n**PASS-01 conclusion:** Rhode Island has a presently active registration pathway for both DMP and principal-reduction settlement providers, with broad functional and remote-provider coverage. The savings-based 30% per-debt rule, 4% setup branch, credit mechanics, and 65% refund rule are supported. The critical unresolved issue for production is the complete, current §19-14.8-32(f) adjustment schedule for every statutory dollar amount, followed by named-provider registration verification and actual NMLS checklist retrieval.\n\nEND S_RI PASS-01.\n\n","tables":[{"headers":["Business model or conduct","Rhode Island classification","Market-access consequence"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model or conduct","Rhode Island classification","Market-access consequence"],["Traditional DMP obtaining reduced interest, finance charges, or delinquency fees","Debt-management services; if it contains a payment schedule, also a statutory “plan.” [C002]","Registration generally required for a known or reasonably known Rhode Island resident."],["Principal-reduction debt settlement","Debt-management services; a scheduled settlement program is a “plan.” “Settlement fee” specifically refers to a charge associated with a creditor accepting less than principal. [C002–C003]","Registration route exists; not categorically prohibited."],["One-time negotiation after the consumer has accumulated settlement funds","Covered debt-management services even though it may not be a “plan.” [C004]","Registration ordinarily required, but the affirmative consumer-fee pathway for a truly no-plan arrangement is unresolved."],["Consumer-controlled or third-party-controlled dedicated account","Noncustodial structure does not remove the service from coverage. [C004, C029]","Registration still required; state trust-account provisions depend separately on whether the provider or its designee receives funds for creditor distribution."],["Provider or its designee receives money to distribute to creditors","Covered custodial model. [C029]","Registration plus statutory trust-account duties."],["Education or budgeting only, without acting as intermediary to obtain creditor concessions","Outside the statutory definition of debt-management services. [C005]","Chapter 19-14.8 registration is not established solely from that conduct; other Rhode Island laws remain unresearched."],["Counseling supplied by an entity that is otherwise a covered provider","Fee treatment can still fall under §19-14.8-23 even when no agreement is ultimately signed. [C023]","Registration/coverage depends on the provider’s broader conduct and resident nexus."],["Creditor negotiating or compromising its own debt","Ordinarily not an intermediary and therefore not a debt-management provider under this definition. [C005]","No chapter 19-14.8 registration shown for the self-creditor activity itself."],["Third party negotiating between the consumer and a creditor or debt buyer","Covered intermediary activity. [C002, C005]","Registration ordinarily required."],["Natural person’s personally liable business or farming debt","Included under the official comments’ use of “individual,” rather than the narrower consumer-purpose formulation. [C007]","Registration may apply even though the debt had a business purpose."],["Debt owed only by an LLC, corporation, or other entity, without a natural-person obligor","Coverage under this chapter is not established: the statute distinguishes an “individual” from an “entity.” [C007]","Hold for other statutes, guaranty facts, and entity-debt law."],["Website or advertisement merely visible in Rhode Island, without Rhode Island agreements or service","Accessibility alone is not necessarily an “offer” to Rhode Island residents under the official comments. [C008]","Fact-sensitive; targeted availability or enrollment can change the result."],["Remote provider with no Rhode Island office","Physical presence is unnecessary when serving Rhode Island residents. [C008]","Registration ordinarily required."]]},{"headers":["Person or condition","Treatment"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Person or condition","Treatment"],["Provider receiving no compensation from the individual, anyone acting on the individual’s behalf, or the creditors","Exempt to that extent. A creditor payment defeats this no-compensation route. [C010]"],["Judicial officer, person acting under a court or administrative order, or assignee for benefit of creditors","Excluded when acting in the regular course of that role."],["Federally chartered bank or Rhode Island-chartered bank","Excluded in regular course."],["Regulated affiliate of such a bank","Excluded within the statutory affiliate and regulatory conditions."],["Title insurer, escrow company, or bill-paying provider","Excluded only when debt-management services are incidental to bill-paying services."],["Bank chartered in another state","Excluded only if the other state expressly authorizes the activity under conditions no more restrictive than Rhode Island’s, as determined by the director. It is not a blanket out-of-state-bank exclusion."],["Regulated affiliate of that qualifying out-of-state bank","Conditional exclusion."],["Employee or agent of a registered provider","No separate registration, but not a substantive exemption from conduct rules."],["Creditor acting for itself","Normally outside the intermediary definition rather than an express §3 exemption."]]},{"headers":["Fee or receipt","Statutory structure","Verified current rule","Current-dollar conclusion"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Fee or receipt","Statutory structure","Verified current rule","Current-dollar conclusion"],["Any debt-management charge generally","A provider may not directly or indirectly charge an individual or receive money from/on behalf of an individual except as permitted by §23. [C017]","Comprehensive anti-evasion rule. Separate analysis, budget, referral, or termination charges are not authorized merely by relabeling them.","Exact fee depends on an affirmative §23 pathway."],["DMP/concession-plan setup fee","For a plan contemplating reduced finance charges or late/default/delinquency fees: setup fee ≤ A_DMP_SETUP.","Printed figure: $50.","Exact 2026 amount held."],["DMP/concession-plan monthly fee","≤ min(A_MONTH_CREDITOR × creditors remaining when assessed, A_MONTH_CAP).","Printed figures: $10 per remaining creditor, maximum $50/month.","Exact 2026 amounts held. Creditor count rule is verified."],["Settlement-plan setup fee","≤ min(A_SETTLEMENT_SETUP, 4% × debt in plan at inception). [C020]","Printed absolute figure: $400. The 4% branch is not a dollar amount and remains exact.","Absolute branch held; exact result may therefore remain unresolved even for lower debt."],["Settlement-plan monthly fee","Same remaining-creditor structure as above.","Printed figures: $10/$50.","Exact 2026 amounts held."],["DMP and settlement fee schedules combined","Provider may not impose or receive both §23(d)(1) and §23(d)(2) fee sets.","In a mixed plan, comments instruct use of the predominant approach for setup and count all creditors for monthly-fee purposes. [C022]","No double setup/monthly recovery."],["Per-debt settlement compensation","For each debt: no more than 30% × (principal at agreement − amount paid creditor under plan), less setup and aggregate monthly charges not already credited against an earlier settlement fee. [C021]","30% of actual principal savings; per debt, not enrolled balance.","Exact percentage formula verified."],["Aggregate settlement compensation","Sum of lawful per-debt amounts after carrying forward uncredited setup/monthly advances.","No separate percentage of total enrolled debt was found.","Aggregate is derived from each debt, not a flat enrolled-debt percentage."],["Educational/counseling fee after agreement","Ordinarily prohibited. Director may authorize a fee based on nature and extent of additional services; government-sponsored-program education is separately excepted.","No generally applicable public amount or approval schedule located.","Conditional authorization/amount held."],["Education/counseling when no agreement is signed","≤ A_COUNSELING, unless director approves a larger amount based on nature and extent. [C023]","Printed figure: $100.","Exact ordinary 2026 ceiling held; larger fee requires actual director approval."],["Counseling-fee refund","If the individual enters an agreement within 90 days after counseling ends, provider must refund the counseling fee.","90-day condition verified.","Full refund of that fee."],["Dishonored-payment charge","Reasonable charge ≤ lesser of A_DISHONORED and amount permitted by other law. [C024]","Printed figure: $25.","Exact 2026 chapter amount held; other-law ceiling also required."],["Voluntary contribution","Provider may not solicit it. Until 30 days after completion or termination, aggregate receipts from/on behalf of the individual may not exceed §23’s lawful total. [C026]","“Voluntary” labeling cannot evade the limits.","No separate extra-fee pathway."],["Rhode Island provider registration fee","$200 for each debt-management registration under §19-14-4(a)(7).","This is a provider-to-state charge, not a consumer fee. [C040]","$200 verified in current chapter 14 text; NMLS processing fees not verified."]]},{"headers":["Source ID","Title / issuer / status","Direct literal URL and pinpoint","Actual check and limitations"],"index":3,"links":[{"href":"https://webserver.rilegislature.gov/statutes/Statutes.html","text":"Rhode Island Legislature\n+1"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+10"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm","text":"Rhode Island Legislature\n+1"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm","text":"Rhode Island Legislature\n+7"},{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business Regulation"},{"href":"https://dbr.ri.gov/about-dbr/lookup-license","text":"Department of Business Regulation"},{"href":"https://rules.sos.ri.gov/Organizations/Title/230","text":"Rules of Rhode Island\n+2"},{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules","text":"Department of Business Regulation\n+2"},{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf","text":"Department of Business Regulation"},{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf","text":"Department of Business Regulation\n+1"},{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf","text":"Department of Business Regulation\n+1"},{"href":"https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=RI","text":"Nationwide Licensing System\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+3"},{"href":"https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees","text":"Rhode Island Attorney General's Office"},{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions","text":"Department of Business Regulation\n+1"},{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf","text":"Department of Business Regulation"}],"row_links":[[],[{"href":"https://webserver.rilegislature.gov/statutes/Statutes.html","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+10"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm","text":"Rhode Island Legislature\n+7"}],[{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business Regulation"}],[{"href":"https://dbr.ri.gov/about-dbr/lookup-license","text":"Department of Business Regulation"}],[{"href":"https://rules.sos.ri.gov/Organizations/Title/230","text":"Rules of Rhode Island\n+2"}],[{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules","text":"Department of Business Regulation\n+2"}],[{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf","text":"Department of Business Regulation"}],[{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf","text":"Department of Business Regulation\n+1"}],[{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf","text":"Department of Business Regulation\n+1"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=RI","text":"Nationwide Licensing System\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+3"}],[{"href":"https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees","text":"Rhode Island Attorney General's Office"}],[{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions","text":"Department of Business Regulation\n+1"}],[{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf","text":"Department of Business Regulation"}]],"rows":[["Source ID","Title / issuer / status","Direct literal URL and pinpoint","Actual check and limitations"],["S_RI-P1-S001","2026 Rhode Island General Laws portal and chapter index; Rhode Island General Assembly. Current online compilation is expressly provisional.","https://webserver.rilegislature.gov/statutes/Statutes.html — portal notice and “Search the 2026 General Laws.”\n\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/INDEX.htm — complete chapter index.","Freshly opened/read 2026-10-24. Portal warns that printed official publication controls legal rights. \nRhode Island Legislature\n+1"],["S_RI-P1-S002","R.I. Gen. Laws ch. 19-14.8, Uniform Debt-Management Services Act; operative statutory authority.","Key section URLs:\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm — definitions, especially (7), (9), (10), (12)–(17), (20).\n.../19-14.8-3.htm — resident, compensation, and institutional exclusions.\n.../19-14.8-4.htm — registration.\n.../19-14.8-5.htm and .../19-14.8-6.htm — application.\n.../19-14.8-9.htm, .../19-14.8-10.htm, .../19-14.8-11.htm — issuance, timing, renewal.\n.../19-14.8-13.htm, .../19-14.8-14.htm — bond/substitute.\n.../19-14.8-17.htm — prerequisites.\n.../19-14.8-19.htm, .../19-14.8-20.htm — agreement and cancellation.\n.../19-14.8-22.htm through .../19-14.8-28.htm — trust, fees, contributions, voidability, termination, reports, prohibited acts.\n.../19-14.8-32.htm — director powers/indexing.\n.../19-14.8-43.htm — official comments.","Relevant operative sections freshly opened and read. Current online text remains subject to S001’s provisional-publication warning. \nRhode Island Legislature\n+10"],["S_RI-P1-S003","R.I. Gen. Laws ch. 19-14, Licensed Activities.","https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm — license/registration requirement and remote-plan nexus.\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm — $200 debt-management registration fee and late charge.","Freshly read. Chapter 14 uses generic licensing terminology; ch. 14.8 specifically uses registration. \nRhode Island Legislature\n+1"],["S_RI-P1-S004","Uniform Debt-Management Services Act final text and official comments; Uniform Law Commission document hosted by FTC. Rhode Island §19-14.8-43 gives the official comments interpretive-guide status.","https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf\nRelevant PDF pages: 9; 15–20; 22; 58; 63; 66–70.","PDF parsed and relevant pages visually inspected. It is the national final model-act/comment document, not a Rhode Island codifier PDF. It was used only where enacted Rhode Island text aligns and because §43 directs use of official comments. \nRhode Island Legislature\n+7"],["S_RI-P1-S005","“All Other Licensees — Applications, Forms & Other Information”; Rhode Island DBR. Current procedural page.","https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees\nDebt Management Services Registration/NMLS at page lines 119–146; 2026 annual reports at 157–163.","Freshly read. Page itself says last updated May 21, 2025, but links current 2026 annual-report files. Procedure evidence, not a substitute for statutory authority. \nDepartment of Business Regulation"],["S_RI-P1-S006","“Lookup a License or Registration”; Rhode Island DBR.","https://dbr.ri.gov/about-dbr/lookup-license\nBanking lookup through NMLS Consumer Access at lines 116–120.","Freshly read; page updated August 7, 2026. No named-provider search was completed. \nDepartment of Business Regulation"],["S_RI-P1-S007","Official Rhode Island Code of Regulations catalog, Title 230/Chapter 40.","https://rules.sos.ri.gov/Organizations/Title/230\nhttps://rules.sos.ri.gov/Organizations/Chapter/230-40\nhttps://rules.sos.ri.gov/Organizations/SubChapter/230-40-20\nAlso checked displayed Financial Institutions and Lending subchapters.","Freshly read as current catalog evidence. No DMS-specific part appeared in the displayed catalog. This is a bounded negative result, not proof against unpublished or archived material. \nRules of Rhode Island\n+2"],["S_RI-P1-S008","Current DBR rules, bulletins, and guidance indexes.","https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules\nhttps://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions\nhttps://dbr.ri.gov/insurance-banking-securities-and-charitable-organizations/banking/credit-unions-financial-0","Indexes freshly read. No DMS CPI/fee-adjustment item appeared. Catalog absence is not conclusive proof no separate notice exists. \nDepartment of Business Regulation\n+2"],["S_RI-P1-S009","Schedule E — Debt Management Services Evidence of Accreditation; Rhode Island DBR.","https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20(fillable).pdf\nPDF p.1, form lines 7–15.","PDF opened and visually inspected. File location is current, but footer says form dated June 27, 2007. It uses “Credit Counseling Organization” wording. \nDepartment of Business Regulation"],["S_RI-P1-S010","Uniform Debt-Management Services Act Substitute Bond Form; Rhode Island DBR.","https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf\nPDF pp.1–2, especially lines 7–15, 38–42, 70–78.","PDF opened and visually inspected. URL/file label suggests 2025 revision, while form footer contains older/inconsistent revision text; statute controls. \nDepartment of Business Regulation\n+1"],["S_RI-P1-S011","2026 Debt Management Services annual-report notice and checklist; Rhode Island DBR.","https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf\nhttps://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_checklist_1-20-26rls.pdf","PDFs opened and visually inspected. Notice contains one apparent 2025 typo; checklist and remaining text specify 2026. Used as operational-currentness evidence only. \nDepartment of Business Regulation\n+1"],["S_RI-P1-S012","NMLS Rhode Island requirements and checklist compiler.","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx?StateID=RI\nhttps://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Actual public routes opened but returned zero extractable lines. Exact current checklist, system fees, and filing fields remain unresolved. \nNationwide Licensing System\n+1"],["S_RI-P1-S013","Telemarketing Sales Rule, 16 C.F.R. pt. 310; eCFR.","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 — debt-relief definition.\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 — advance-fee rule.\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310 — exemptions.","Freshly read. eCFR displayed Title 16 through October 22, 2026 and notes eCFR is authoritative but unofficial. \neCFR\n+3"],["S_RI-P1-S014","March 19, 2025 Palisade debt-management complaint announcement; Rhode Island Attorney General.","https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees\nRegistration allegations at lines 94–103; fee allegations at 108–110.","Freshly read. Complaint allegations are not a final adjudication or controlling decision. \nRhode Island Attorney General's Office"],["S_RI-P1-S015","DBR Banking Enforcement Actions roster and Golden Financial consent agreement.","https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions\nhttps://dbr.ri.gov/documents/decisions/BK_Consent_Agreement-Golden_Financial_Services.pdf","Roster read; consent-order PDF opened and visually inspected. Consent resolution is operational/enforcement evidence, not a controlling appellate interpretation. \nDepartment of Business Regulation\n+1"],["S_RI-P1-S016","Amended and Revoked Banking Bulletins; Rhode Island DBR.","https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf","PDF opened and visually inspected. The displayed historical list concerned mortgage-related matters and did not supply a DMS fee adjustment. Updated May 10, 2016. \nDepartment of Business Regulation"]]},{"headers":["Claim ID","Precise assertion","Source IDs and exact pinpoints","Conditions, currentness, and confidence limits"],"index":4,"links":[{"href":"https://webserver.rilegislature.gov/statutes/Statutes.html","text":"Rhode Island Legislature\n+1"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature"},{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"},{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission"},{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+1"},{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+2"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm","text":"Rhode Island Legislature\n+3"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm","text":"Rhode Island Legislature"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm","text":"Rhode Island Legislature"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+3"},{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business 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Legislature"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm","text":"Rhode Island Legislature\n+2"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-22.htm","text":"Rhode Island Legislature\n+1"},{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+2"},{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm","text":"Rhode Island Legislature\n+1"},{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business Regulation\n+2"},{"href":"https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees","text":"Rhode Island Attorney General's 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Regulation"}],"row_links":[[],[{"href":"https://webserver.rilegislature.gov/statutes/Statutes.html","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+2"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm","text":"Rhode Island Legislature\n+3"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm","text":"Rhode Island Legislature"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm","text":"Rhode Island Legislature"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm","text":"Rhode Island Legislature\n+3"}],[{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business Regulation\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-5.htm","text":"Rhode Island 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Legislature\n+2"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-22.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","text":"Federal Trade Commission\n+1"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR\n+2"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees","text":"Department of Business Regulation\n+2"}],[{"href":"https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees","text":"Rhode Island Attorney General's Office\n+1"}],[{"href":"https://rules.sos.ri.gov/Organizations/Title/230","text":"Rules of Rhode Island\n+4"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm","text":"Rhode Island Legislature"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm","text":"Rhode Island Legislature\n+1"}],[{"href":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm","text":"Rhode Island Legislature"}],[{"href":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf","text":"Department of Business Regulation"}],[]],"rows":[["Claim ID","Precise assertion","Source IDs and exact pinpoints","Conditions, currentness, and confidence limits"],["S_RI-P1-C001","The current online 2026 Rhode Island General Laws contain chapter 19-14.8, the Uniform Debt-Management Services Act.","S001 portal; S001 chapter index.","High confidence in current online text; portal is expressly provisional and printed official publication controls. \nRhode Island Legislature\n+1"],["C002","DMS means acting as an intermediary between an individual and one or more creditors to obtain more favorable repayment terms.","S002 §19-14.8-2(7), (9), (15).","Functional rather than label-based. High confidence. \nRhode Island Legislature"],["C003","Concessions include reductions of interest/finance charges, delinquency/default fees, and principal.","S002 §2(7); S004 PDF p.15 lines 459–465.","Official-comment interpretation given force by §43. High confidence. \nFederal Trade Commission\n+1"],["C004","One-time negotiation and noncustodial programs can be covered; no statutory plan or provider control of funds is required for classification.","S004 PDF p.15 lines 466–478; S002 §2(13).","Registration can apply even where fee provisions framed around a plan do not clearly fit. High confidence on classification. \nFederal Trade Commission"],["C005","Pure education without creditor intermediation is outside DMS; a creditor compromising its own claim is not an intermediary.","S004 PDF p.15 lines 479–487.","Other Rhode Island laws remain open. High confidence under chapter 14.8. \nFederal Trade Commission\n+1"],["C006","Attorney/CPA/planner exclusions require actual qualifying professional services in the relevant client relationship; ownership or affiliation is insufficient.","S002 §2(9)(a)–(c); S004 PDF p.16 lines 493–503.","Attorney must be licensed/otherwise authorized in Rhode Island. High confidence. \nRhode Island Legislature\n+1"],["C007","Natural-person business/farming debt can be covered; entity-only obligations are not shown covered under “individual.”","S004 PDF p.9 lines 286–295 and p.22 lines 701–706; S002 §2(10), (12).","Entity-debt and guaranty issues remain open. Moderate-high confidence. \nFederal Trade Commission\n+2"],["C008","Rhode Island resident nexus applies without physical presence; knowledge can arise through agents; later relocation and passive website accessibility have narrower boundaries.","S002 §3(a)–(b); S003 §19-14-2(a); S004 pp.19–20.","Agreement-time facts control. High confidence. \nRhode Island Legislature\n+3"],["C009","Covered compensated providers must register; employees/agents of a registered provider need no separate registration; public list required.","S002 §4(a)–(c).","Other conduct obligations still apply to agents. High confidence. \nRhode Island Legislature"],["C010","Exemptions include zero compensation from every side and specified institutional actors under stated conditions.","S002 §3(b)–(c).","Out-of-state-bank and incidental-bill-pay exclusions are conditional. High confidence. \nRhode Island Legislature"],["C011","Nonprofit status is not a general exemption or exclusive eligibility rule; for-profit applicants are contemplated.","S002 §2(12), §5(b)(6), §9(a), (c); S010 form.","Schedule E wording creates an operational issue but not a statutory nonprofit-only rule. High confidence. \nRhode Island Legislature\n+3"],["C012","Current DBR procedure sends DMS-registration applicants through NMLS and banking lookups through NMLS Consumer Access.","S005 lines 119–146; S006 lines 116–120.","Exact NMLS checklist was not extractable. High confidence on the route. \nDepartment of Business Regulation\n+1"],["C013","Application requires fee, bond/security, insurance, accreditation, certified counselors, financial and organizational disclosures, agreement forms, and fee schedule.","S002 §§5–6.","Several access-dollar figures are themselves subject to §32(f). High confidence. \nRhode Island Legislature\n+1"],["C014","Director generally shall issue to a compliant applicant, subject to denial grounds; initial decision 120 days plus possible 60-day extension; annual renewal required.","S002 §§9–11.","Registration does not arise merely by filing. High confidence. \nRhode Island Legislature\n+2"],["C015","Rhode Island’s DMS registration program was operational in 2026.","S005 annual-report links; S011 notice/checklist.","Operational evidence, not proof that any particular company was active. High confidence. \nDepartment of Business Regulation\n+2"],["C016","Specific legal authorization is a registration even though chapter 14 and agency forms sometimes use “license/licensee.”","S002 §§4, 9–11; S003 §19-14-2(a).","Terminology should not be used to convert registration into a different licensing regime. High confidence. \nRhode Island Legislature\n+1"],["C017","Section 23’s fee prohibition is comprehensive and reaches indirect/relabelled charges.","S002 §23(a); S004 PDF pp.66–67 lines 2145–2164.","No extra analysis, budget, referral, or termination fee unless affirmatively authorized. High confidence. \nRhode Island Legislature\n+1"],["C018","Rhode Island prohibits charges before a compliant signed agreement and requires pre-service itemization, education, and analysis.","S002 §23(b), §17(a)–(c), §19(a).","This is a state floor, not TSR compliance. High confidence. \nRhode Island Legislature\n+2"],["C019","DMP setup and monthly limits use adjusted dollar amounts; printed figures are $50 and $10 per creditor/$50 monthly.","S002 §23(d)(1), §32(f)–(g).","Exact current adjusted dollars unresolved. High confidence on formula/base-text distinction. \nRhode Island Legislature\n+1"],["C020","Settlement setup fee is the lesser of the adjusted absolute ceiling and 4% of plan debt at inception; monthly formula uses adjusted amounts.","S002 §23(d)(2).","4% exact; absolute and monthly dollars held. High confidence. \nRhode Island Legislature"],["C021","Settlement compensation is capped per debt at 30% of principal savings less uncredited setup/monthly advances.","S002 §23(f); S014 fee allegation consistent with formula.","State maximum; timing and federal law separately apply. High confidence. \nRhode Island Legislature\n+1"],["C022","Provider cannot charge both DMP and settlement setup/monthly schedules; mixed plans use predominant approach and aggregate remaining creditors.","S002 §23(d)(3); S004 PDF pp.68–69 lines 2226–2236.","Official-comment interpretation. High confidence. \nRhode Island Legislature\n+1"],["C023","No-agreement counseling has an adjusted ceiling or director-approved higher amount and must be refunded if an agreement follows within 90 days.","S002 §23(c)–(e).","Exact adjusted ordinary dollar amount and any specific approvals not located. High confidence on structure. \nRhode Island Legislature"],["C024","Dishonored-payment fee is the lesser of the adjusted chapter amount and other-law amount.","S002 §23(g).","Printed $25 is not verified current amount; other-law inquiry remains open. High confidence. \nRhode Island Legislature"],["C025","DBR must replace specified statutory dollars by rule, use a base year, make threshold-triggered July 1 adjustments, round §23 figures to nearest dollar, notify registrants, and publish.","S002 §32(f)–(g).","Mandatory statutory mechanism; actual adjustment document unresolved. High confidence. \nRhode Island Legislature"],["C026","Voluntary contributions cannot be solicited or used to exceed the lawful aggregate.","S002 §24; S004 PDF p.70.","Applies to all providers; voluntary label does not control. High confidence. \nRhode Island Legislature\n+1"],["C027","Consumer has a three-business-day cancellation right with full refund of money already paid; noncompliance can extend cancellation to 30 days.","S002 §20(a)–(b).","Full remedies consequences of extended-window cases remain later-pass work. High confidence on text. \nRhode Island Legislature"],["C028","Later settlement termination requires return of trust funds and 65% of uncredited setup fee; monthly fees are credited first for the setup-refund computation.","S002 §19(d), §26; S004 p.58 lines 1875–1887.","No general later refund of all monthly fees established. High confidence. \nRhode Island Legislature\n+2"],["C029","State trust duties apply when provider/designee receives money for creditor distribution, but not merely because the provider can advise a consumer controlling their own funds.","S002 §22; S004 p.63 lines 2027–2039.","TSR dedicated-account rules may independently apply. High confidence. \nRhode Island Legislature\n+1"],["C030","A truly no-plan one-time negotiation is covered DMS, but no affirmative consumer-fee pathway was established because §23’s operative settlement structures are plan-based.","S004 p.15 lines 473–478; S002 §23(a), (d), (f).","Fee authorization held; not a conclusion that registration is unavailable or that lawful fee must be zero. Moderate-high confidence. \nFederal Trade Commission\n+1"],["C031","For covered TSR telemarketing, fee collection requires at least one altered debt, one consumer payment, and federal allocation compliance.","S013 §§310.2(o), 310.4(a)(5), 310.6.","TSR scope requires separate call, debt, and exemption analysis. High confidence. \neCFR\n+2"],["C032","State fee permission and federal fee timing are independent; the stricter combination governs when both apply.","S002 §23; S013 §310.4(a)(5).","Legal synthesis; high confidence. \nRhode Island Legislature\n+1"],["C033","Public application/lookup procedures were verified, but no named provider’s current status was checked.","S005, S006, S012.","NMLS substantive page extraction failed; no marketing statement was treated as authorization. High confidence on research boundary. \nDepartment of Business Regulation\n+2"],["C034","Rhode Island has publicly enforced registration against purported settlement offerings; current AG allegations challenge attorney-label and enrolled-debt fee structures.","S014; S015 Golden consent.","Administrative consent and pending allegations are not controlling judicial holdings. High confidence as enforcement evidence only. \nRhode Island Attorney General's Office\n+1"],["C035","No DMS adjustment rule or notice appeared in the official current RICR/DBR catalogs reviewed.","S007, S008, S016.","Bounded negative finding; exact adjusted amounts remain held rather than assumed. Moderate confidence regarding public catalog visibility, not historical nonexistence. \nRules of Rhode Island\n+4"],["C036","Compensation from creditors defeats the zero-compensation exemption and must be disclosed where applicable.","S002 §3(b)(2), §17(d)(5).","This pass does not establish a cap on creditor-paid compensation. High confidence. \nRhode Island Legislature\n+1"],["C037","Settlement setup/monthly charges are advances against the later settlement fee rather than additional compensation.","S002 §23(f)(2); S004 p.70 lines 2260–2265.","Credits must be tracked across debts. High confidence. \nRhode Island Legislature\n+1"],["C038","No separate flat aggregate percentage of enrolled debt was established; aggregate consumer settlement compensation is derived debt by debt.","S002 §23(f).","Other contract/remedy questions about allocation remain later work. High confidence. \nRhode Island Legislature"],["C039","Monthly count uses creditors remaining at assessment, not original enrollment count.","S002 §23(d)(1)(B), (2)(B); S004 p.68.","Exact dollar multipliers held. High confidence. \nRhode Island Legislature\n+1"],["C040","Current statute sets a $200 annual state fee for each DMS registration.","S003 §19-14-4(a)(7).","Does not include unverified NMLS system fees. High confidence. \nRhode Island Legislature"],["C041","Current Schedule E uses “Credit Counseling Organization” accreditation wording, creating a settlement-only applicant evidence issue.","S009 p.1 lines 7–15.","Form wording is operational evidence, not an independent statutory prohibition. High confidence on form text; legal effect beyond §6(8) unresolved. \nDepartment of Business Regulation"],["C042","No reported Rhode Island controlling appellate or federal decision construing the central registration/fee provisions was located in the bounded public searches.","Targeted exact-statute and site-restricted public searches; S014/S015 are noncontrolling enforcement sources.","Not a comprehensive docket search or conclusion that no case exists. Full case-law pass remains open."]]},{"headers":["Pass component","Status","Supporting claims","Missing evidence / exact next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Pass component","Status","Supporting claims","Missing evidence / exact next investigation"],["Functional DMS definition","Answered","C002–C005","Later test unusual creditor/affiliate and lead-generator models against specific facts."],["DMP versus principal-reduction settlement","Answered","C002–C004","No material gap for basic classification."],["One-time negotiation","Partial","C004, C030","Locate Rhode Island order, declaratory ruling, or controlling case addressing §23 fees when covered services do not constitute a plan."],["Custodial/noncustodial distinction","Answered for access boundary","C004, C029","Full trust-account operations, independent-account providers, electronic-access powers, and bank-location rules remain later-pass work."],["Consumer versus business purpose","Answered for natural persons; partial otherwise","C007","Analyze guarantors, jointly liable owners, entity-only debt, and commercial-debt statutes."],["Rhode Island resident/remote nexus","Answered","C008","Apply to actual enrollment scripts, IP/address facts, agent knowledge, and servicing transfers."],["General market access","Answered","C009, C012, C014–C016","Registration required; exact company status requires NMLS lookup by legal name/NMLS ID."],["Attorney exclusion","Answered at statutory level","C006, C034","Full unauthorized-practice, law-firm ownership, fee-sharing, and case-law analysis remains open."],["Nonprofit treatment","Answered","C011","Review applicant-specific corporate and tax status only if relying on those representations."],["Institutional and no-compensation exclusions","Answered at text level","C010, C036","Test any bank affiliate, incidental bill-pay, or other-state bank against actual facts and director determinations."],["Application requirements","Answered in statute; procedural details partial","C012–C015, C041","Retrieve current public NMLS Rhode Island DMS checklist, MU filing instructions, and current system charges without using an account."],["Public lookup route","Answered","C012, C033","Perform named-provider lookup when legal name/NMLS ID is supplied; no status inferred here."],["Current operation of registration program","Answered","C015","Recheck future annual-report cycle in later currentness pass."],["Current DMP dollar fees","Unresolved","C019, C025, C035","Locate §32(f) base-year rule, every July 1 adjustment, registrant notice, state-register filing, adoption order, or archived DBR schedule."],["Current settlement absolute setup ceiling","Unresolved","C020, C025, C035","Same adjustment-document investigation. Do not calculate CPI independently."],["Current monthly dollar multiplier/cap","Unresolved","C019–C020, C025","Same adjustment-document investigation."],["Current no-agreement counseling dollar cap","Unresolved","C023, C025","Same adjustment-document investigation; also locate any director-approved higher-fee orders."],["Current dishonored-payment chapter cap","Unresolved","C024–C025","Locate adjusted amount and separately research other Rhode Island dishonored-payment law."],["Exact percentage formulas","Answered","C020–C022, C037–C039","Apply to actual contract and debt-level data only after dollar adjustments and timing are resolved."],["Setup/monthly credit mechanics","Answered","C022, C028, C037","Contract-specific posting and overcollection remediation remain later-pass issues."],["Aggregate cap","Answered within §23","C038","No flat enrolled-debt fee established; later verify no applicable special-sector law changes result."],["State fee timing","Answered with narrow hold","C018, C021","Exact state-only moment for requesting final settlement fee after creditor assent but before payment remains an interpretive issue."],["Federal TSR timing","Answered as common context","C031–C032","Apply to actual call flow, ad source, debt type, seller/telemarketer roles, and exemptions."],["Cancellation and fee refunds","Answered within fee scope","C023, C027–C028","Full private remedies, class remedies, voidability, limitations, and restitution remain later-pass work."],["Provider bond/insurance","Boundary only","C013","Exact adjusted bond/insurance dollars, claims, substitutes, duration, and recovery reserved for bond/remedies pass."],["Accreditation","Partial","C013, C041","Determine current DBR-approved accreditors and how settlement-only applicants satisfy the “Credit Counseling Organization” form wording."],["Regulations/adoption orders","Partial","C025, C035","Search Rhode Island State Register archives, DBR rulemaking dockets, superseded regulations, and notices to registrants."],["Controlling decisions","Partial/negative search result","C042","Comprehensive Rhode Island Judiciary, Superior Court, federal district, First Circuit, and citator search."],["Enforcement posture","Answered only as examples","C034","Obtain and analyze underlying Palisade complaint, docket status, later orders, and other DMS enforcement files."],["Creditor-paid compensation","Boundary only","C036","Analyze fee caps, conflicts, disclosure, and creditor fair-share arrangements in a later pass."],["Agreements/e-signatures","Excluded except timing/content needed here","C018, C027","Full formation, delivery, E-SIGN/UETA, choice-of-law, forum, POA, and severability pass."],["Full funds/trust analysis","Excluded except custody boundary","C029","Full accounting, disbursement, insolvency, account administrator, reconciliation, and dedicated-account pass."],["Remedies, collection, litigation, limitations","Excluded except refund boundary","C027–C028","Dedicated later passes required."],["Exemptions beyond access classification","Open","C010","Sector, creditor, professional, bankruptcy, court-supervised, and institutional edge cases."],["Secured debt","Open","—","Analyze mortgage, auto, tax, utility, student-loan, medical, and other secured/special debt interactions."],["Local, tribal, sector, and contract law","Open","—","Separate Rhode Island/local/federal/tribal and contract investigations required."],["Proposed/future-effective rules","Open","C035","Search active Rhode Island rulemaking notices and future-effective enactments; none is claimed absent."],["Named SettleADebt.com authorization","Not established","C033","Registration must be independently confirmed before Rhode Island service."],["Full Rhode Island or A066 acceptance","Expressly not performed","All","Completion requires all remaining state components and coordinator review."]]}],"claims":[{"claim_id":"S_RI-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_RI-P1-C001","Precise assertion":"The current online 2026 Rhode Island General Laws contain chapter 19-14.8, the Uniform Debt-Management Services Act.","Source IDs and exact pinpoints":"S001 portal; S001 chapter index.","Conditions, currentness, and confidence limits":"High confidence in current online text; portal is expressly provisional and printed official publication controls. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"DMS means acting as an intermediary between an individual and one or more creditors to obtain more favorable repayment terms.","Source IDs and exact pinpoints":"S002 §19-14.8-2(7), (9), (15).","Conditions, currentness, and confidence limits":"Functional rather than label-based. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"Concessions include reductions of interest/finance charges, delinquency/default fees, and principal.","Source IDs and exact pinpoints":"S002 §2(7); S004 PDF p.15 lines 459–465.","Conditions, currentness, and confidence limits":"Official-comment interpretation given force by §43. High confidence. \nFederal Trade Commission\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"One-time negotiation and noncustodial programs can be covered; no statutory plan or provider control of funds is required for classification.","Source IDs and exact pinpoints":"S004 PDF p.15 lines 466–478; S002 §2(13).","Conditions, currentness, and confidence limits":"Registration can apply even where fee provisions framed around a plan do not clearly fit. High confidence on classification. \nFederal Trade Commission"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"Pure education without creditor intermediation is outside DMS; a creditor compromising its own claim is not an intermediary.","Source IDs and exact pinpoints":"S004 PDF p.15 lines 479–487.","Conditions, currentness, and confidence limits":"Other Rhode Island laws remain open. High confidence under chapter 14.8. \nFederal Trade Commission\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Attorney/CPA/planner exclusions require actual qualifying professional services in the relevant client relationship; ownership or affiliation is insufficient.","Source IDs and exact pinpoints":"S002 §2(9)(a)–(c); S004 PDF p.16 lines 493–503.","Conditions, currentness, and confidence limits":"Attorney must be licensed/otherwise authorized in Rhode Island. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"Natural-person business/farming debt can be covered; entity-only obligations are not shown covered under “individual.”","Source IDs and exact pinpoints":"S004 PDF p.9 lines 286–295 and p.22 lines 701–706; S002 §2(10), (12).","Conditions, currentness, and confidence limits":"Entity-debt and guaranty issues remain open. Moderate-high confidence. \nFederal Trade Commission\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"Rhode Island resident nexus applies without physical presence; knowledge can arise through agents; later relocation and passive website accessibility have narrower boundaries.","Source IDs and exact pinpoints":"S002 §3(a)–(b); S003 §19-14-2(a); S004 pp.19–20.","Conditions, currentness, and confidence limits":"Agreement-time facts control. High confidence. \nRhode Island Legislature\n+3"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"Covered compensated providers must register; employees/agents of a registered provider need no separate registration; public list required.","Source IDs and exact pinpoints":"S002 §4(a)–(c).","Conditions, currentness, and confidence limits":"Other conduct obligations still apply to agents. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"Exemptions include zero compensation from every side and specified institutional actors under stated conditions.","Source IDs and exact pinpoints":"S002 §3(b)–(c).","Conditions, currentness, and confidence limits":"Out-of-state-bank and incidental-bill-pay exclusions are conditional. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"Nonprofit status is not a general exemption or exclusive eligibility rule; for-profit applicants are contemplated.","Source IDs and exact pinpoints":"S002 §2(12), §5(b)(6), §9(a), (c); S010 form.","Conditions, currentness, and confidence limits":"Schedule E wording creates an operational issue but not a statutory nonprofit-only rule. High confidence. \nRhode Island Legislature\n+3"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"Current DBR procedure sends DMS-registration applicants through NMLS and banking lookups through NMLS Consumer Access.","Source IDs and exact pinpoints":"S005 lines 119–146; S006 lines 116–120.","Conditions, currentness, and confidence limits":"Exact NMLS checklist was not extractable. High confidence on the route. \nDepartment of Business Regulation\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"Application requires fee, bond/security, insurance, accreditation, certified counselors, financial and organizational disclosures, agreement forms, and fee schedule.","Source IDs and exact pinpoints":"S002 §§5–6.","Conditions, currentness, and confidence limits":"Several access-dollar figures are themselves subject to §32(f). High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"Director generally shall issue to a compliant applicant, subject to denial grounds; initial decision 120 days plus possible 60-day extension; annual renewal required.","Source IDs and exact pinpoints":"S002 §§9–11.","Conditions, currentness, and confidence limits":"Registration does not arise merely by filing. High confidence. \nRhode Island Legislature\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Rhode Island’s DMS registration program was operational in 2026.","Source IDs and exact pinpoints":"S005 annual-report links; S011 notice/checklist.","Conditions, currentness, and confidence limits":"Operational evidence, not proof that any particular company was active. High confidence. \nDepartment of Business Regulation\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"Specific legal authorization is a registration even though chapter 14 and agency forms sometimes use “license/licensee.”","Source IDs and exact pinpoints":"S002 §§4, 9–11; S003 §19-14-2(a).","Conditions, currentness, and confidence limits":"Terminology should not be used to convert registration into a different licensing regime. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"Section 23’s fee prohibition is comprehensive and reaches indirect/relabelled charges.","Source IDs and exact pinpoints":"S002 §23(a); S004 PDF pp.66–67 lines 2145–2164.","Conditions, currentness, and confidence limits":"No extra analysis, budget, referral, or termination fee unless affirmatively authorized. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"Rhode Island prohibits charges before a compliant signed agreement and requires pre-service itemization, education, and analysis.","Source IDs and exact pinpoints":"S002 §23(b), §17(a)–(c), §19(a).","Conditions, currentness, and confidence limits":"This is a state floor, not TSR compliance. High confidence. \nRhode Island Legislature\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"DMP setup and monthly limits use adjusted dollar amounts; printed figures are $50 and $10 per creditor/$50 monthly.","Source IDs and exact pinpoints":"S002 §23(d)(1), §32(f)–(g).","Conditions, currentness, and confidence limits":"Exact current adjusted dollars unresolved. High confidence on formula/base-text distinction. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"Settlement setup fee is the lesser of the adjusted absolute ceiling and 4% of plan debt at inception; monthly formula uses adjusted amounts.","Source IDs and exact pinpoints":"S002 §23(d)(2).","Conditions, currentness, and confidence limits":"4% exact; absolute and monthly dollars held. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"Settlement compensation is capped per debt at 30% of principal savings less uncredited setup/monthly advances.","Source IDs and exact pinpoints":"S002 §23(f); S014 fee allegation consistent with formula.","Conditions, currentness, and confidence limits":"State maximum; timing and federal law separately apply. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"Provider cannot charge both DMP and settlement setup/monthly schedules; mixed plans use predominant approach and aggregate remaining creditors.","Source IDs and exact pinpoints":"S002 §23(d)(3); S004 PDF pp.68–69 lines 2226–2236.","Conditions, currentness, and confidence limits":"Official-comment interpretation. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"No-agreement counseling has an adjusted ceiling or director-approved higher amount and must be refunded if an agreement follows within 90 days.","Source IDs and exact pinpoints":"S002 §23(c)–(e).","Conditions, currentness, and confidence limits":"Exact adjusted ordinary dollar amount and any specific approvals not located. High confidence on structure. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"Dishonored-payment fee is the lesser of the adjusted chapter amount and other-law amount.","Source IDs and exact pinpoints":"S002 §23(g).","Conditions, currentness, and confidence limits":"Printed $25 is not verified current amount; other-law inquiry remains open. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"DBR must replace specified statutory dollars by rule, use a base year, make threshold-triggered July 1 adjustments, round §23 figures to nearest dollar, notify registrants, and publish.","Source IDs and exact pinpoints":"S002 §32(f)–(g).","Conditions, currentness, and confidence limits":"Mandatory statutory mechanism; actual adjustment document unresolved. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise assertion":"Voluntary contributions cannot be solicited or used to exceed the lawful aggregate.","Source IDs and exact pinpoints":"S002 §24; S004 PDF p.70.","Conditions, currentness, and confidence limits":"Applies to all providers; voluntary label does not control. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise assertion":"Consumer has a three-business-day cancellation right with full refund of money already paid; noncompliance can extend cancellation to 30 days.","Source IDs and exact pinpoints":"S002 §20(a)–(b).","Conditions, currentness, and confidence limits":"Full remedies consequences of extended-window cases remain later-pass work. High confidence on text. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise assertion":"Later settlement termination requires return of trust funds and 65% of uncredited setup fee; monthly fees are credited first for the setup-refund computation.","Source IDs and exact pinpoints":"S002 §19(d), §26; S004 p.58 lines 1875–1887.","Conditions, currentness, and confidence limits":"No general later refund of all monthly fees established. High confidence. \nRhode Island Legislature\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise assertion":"State trust duties apply when provider/designee receives money for creditor distribution, but not merely because the provider can advise a consumer controlling their own funds.","Source IDs and exact pinpoints":"S002 §22; S004 p.63 lines 2027–2039.","Conditions, currentness, and confidence limits":"TSR dedicated-account rules may independently apply. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise assertion":"A truly no-plan one-time negotiation is covered DMS, but no affirmative consumer-fee pathway was established because §23’s operative settlement structures are plan-based.","Source IDs and exact pinpoints":"S004 p.15 lines 473–478; S002 §23(a), (d), (f).","Conditions, currentness, and confidence limits":"Fee authorization held; not a conclusion that registration is unavailable or that lawful fee must be zero. Moderate-high confidence. \nFederal Trade Commission\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C031","Precise assertion":"For covered TSR telemarketing, fee collection requires at least one altered debt, one consumer payment, and federal allocation compliance.","Source IDs and exact pinpoints":"S013 §§310.2(o), 310.4(a)(5), 310.6.","Conditions, currentness, and confidence limits":"TSR scope requires separate call, debt, and exemption analysis. High confidence. \neCFR\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C032","Precise assertion":"State fee permission and federal fee timing are independent; the stricter combination governs when both apply.","Source IDs and exact pinpoints":"S002 §23; S013 §310.4(a)(5).","Conditions, currentness, and confidence limits":"Legal synthesis; high confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C033","Precise assertion":"Public application/lookup procedures were verified, but no named provider’s current status was checked.","Source IDs and exact pinpoints":"S005, S006, S012.","Conditions, currentness, and confidence limits":"NMLS substantive page extraction failed; no marketing statement was treated as authorization. High confidence on research boundary. \nDepartment of Business Regulation\n+2"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C034","Precise assertion":"Rhode Island has publicly enforced registration against purported settlement offerings; current AG allegations challenge attorney-label and enrolled-debt fee structures.","Source IDs and exact pinpoints":"S014; S015 Golden consent.","Conditions, currentness, and confidence limits":"Administrative consent and pending allegations are not controlling judicial holdings. High confidence as enforcement evidence only. \nRhode Island Attorney General's Office\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C035","Precise assertion":"No DMS adjustment rule or notice appeared in the official current RICR/DBR catalogs reviewed.","Source IDs and exact pinpoints":"S007, S008, S016.","Conditions, currentness, and confidence limits":"Bounded negative finding; exact adjusted amounts remain held rather than assumed. Moderate confidence regarding public catalog visibility, not historical nonexistence. \nRules of Rhode Island\n+4"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C036","Precise assertion":"Compensation from creditors defeats the zero-compensation exemption and must be disclosed where applicable.","Source IDs and exact pinpoints":"S002 §3(b)(2), §17(d)(5).","Conditions, currentness, and confidence limits":"This pass does not establish a cap on creditor-paid compensation. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C037","Precise assertion":"Settlement setup/monthly charges are advances against the later settlement fee rather than additional compensation.","Source IDs and exact pinpoints":"S002 §23(f)(2); S004 p.70 lines 2260–2265.","Conditions, currentness, and confidence limits":"Credits must be tracked across debts. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C038","Precise assertion":"No separate flat aggregate percentage of enrolled debt was established; aggregate consumer settlement compensation is derived debt by debt.","Source IDs and exact pinpoints":"S002 §23(f).","Conditions, currentness, and confidence limits":"Other contract/remedy questions about allocation remain later work. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C039","Precise assertion":"Monthly count uses creditors remaining at assessment, not original enrollment count.","Source IDs and exact pinpoints":"S002 §23(d)(1)(B), (2)(B); S004 p.68.","Conditions, currentness, and confidence limits":"Exact dollar multipliers held. High confidence. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C040","Precise assertion":"Current statute sets a $200 annual state fee for each DMS registration.","Source IDs and exact pinpoints":"S003 §19-14-4(a)(7).","Conditions, currentness, and confidence limits":"Does not include unverified NMLS system fees. High confidence. \nRhode Island Legislature"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C041","Precise assertion":"Current Schedule E uses “Credit Counseling Organization” accreditation wording, creating a settlement-only applicant evidence issue.","Source IDs and exact pinpoints":"S009 p.1 lines 7–15.","Conditions, currentness, and confidence limits":"Form wording is operational evidence, not an independent statutory prohibition. High confidence on form text; legal effect beyond §6(8) unresolved. \nDepartment of Business Regulation"},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"claim_id":"S_RI-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C042","Precise assertion":"No reported Rhode Island controlling appellate or federal decision construing the central registration/fee provisions was located in the bounded public searches.","Source IDs and exact pinpoints":"Targeted exact-statute and site-restricted public searches; S014/S015 are noncontrolling enforcement sources.","Conditions, currentness, and confidence limits":"Not a comprehensive docket search or conclusion that no case exists. Full case-law pass remains open."},"coordinator_verification_status":"not_yet_checked","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_RI-P1-S001","urls":["https://webserver.rilegislature.gov/statutes/Statutes.html","https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/INDEX.htm"],"researcher_record":{"Source ID":"S_RI-P1-S001","Title / issuer / status":"2026 Rhode Island General Laws portal and chapter index; Rhode Island General Assembly. Current online compilation is expressly provisional.","Direct literal URL and pinpoint":"https://webserver.rilegislature.gov/statutes/Statutes.html — portal notice and “Search the 2026 General Laws.”\n\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/INDEX.htm — complete chapter index.","Actual check and limitations":"Freshly opened/read 2026-10-24. Portal warns that printed official publication controls legal rights. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S002","urls":["https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm"],"researcher_record":{"Source ID":"S_RI-P1-S002","Title / issuer / status":"R.I. Gen. Laws ch. 19-14.8, Uniform Debt-Management Services Act; operative statutory authority.","Direct literal URL and pinpoint":"Key section URLs:\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm — definitions, especially (7), (9), (10), (12)–(17), (20).\n.../19-14.8-3.htm — resident, compensation, and institutional exclusions.\n.../19-14.8-4.htm — registration.\n.../19-14.8-5.htm and .../19-14.8-6.htm — application.\n.../19-14.8-9.htm, .../19-14.8-10.htm, .../19-14.8-11.htm — issuance, timing, renewal.\n.../19-14.8-13.htm, .../19-14.8-14.htm — bond/substitute.\n.../19-14.8-17.htm — prerequisites.\n.../19-14.8-19.htm, .../19-14.8-20.htm — agreement and cancellation.\n.../19-14.8-22.htm through .../19-14.8-28.htm — trust, fees, contributions, voidability, termination, reports, prohibited acts.\n.../19-14.8-32.htm — director powers/indexing.\n.../19-14.8-43.htm — official comments.","Actual check and limitations":"Relevant operative sections freshly opened and read. Current online text remains subject to S001’s provisional-publication warning. \nRhode Island Legislature\n+10"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S003","urls":["https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm","https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm"],"researcher_record":{"Source ID":"S_RI-P1-S003","Title / issuer / status":"R.I. Gen. Laws ch. 19-14, Licensed Activities.","Direct literal URL and pinpoint":"https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-2.htm — license/registration requirement and remote-plan nexus.\nhttps://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm — $200 debt-management registration fee and late charge.","Actual check and limitations":"Freshly read. Chapter 14 uses generic licensing terminology; ch. 14.8 specifically uses registration. \nRhode Island Legislature\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S004","urls":["https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf","https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm"],"researcher_record":{"Source ID":"S_RI-P1-S004","Title / issuer / status":"Uniform Debt-Management Services Act final text and official comments; Uniform Law Commission document hosted by FTC. Rhode Island §19-14.8-43 gives the official comments interpretive-guide status.","Direct literal URL and pinpoint":"https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf\nRelevant PDF pages: 9; 15–20; 22; 58; 63; 66–70.","Actual check and limitations":"PDF parsed and relevant pages visually inspected. It is the national final model-act/comment document, not a Rhode Island codifier PDF. It was used only where enacted Rhode Island text aligns and because §43 directs use of official comments. \nRhode Island Legislature\n+7"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S005","urls":["https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees"],"researcher_record":{"Source ID":"S_RI-P1-S005","Title / issuer / status":"“All Other Licensees — Applications, Forms & Other Information”; Rhode Island DBR. Current procedural page.","Direct literal URL and pinpoint":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/all-other-licensees\nDebt Management Services Registration/NMLS at page lines 119–146; 2026 annual reports at 157–163.","Actual check and limitations":"Freshly read. Page itself says last updated May 21, 2025, but links current 2026 annual-report files. Procedure evidence, not a substitute for statutory authority. \nDepartment of Business Regulation"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S006","urls":["https://dbr.ri.gov/about-dbr/lookup-license"],"researcher_record":{"Source ID":"S_RI-P1-S006","Title / issuer / status":"“Lookup a License or Registration”; Rhode Island DBR.","Direct literal URL and pinpoint":"https://dbr.ri.gov/about-dbr/lookup-license\nBanking lookup through NMLS Consumer Access at lines 116–120.","Actual check and limitations":"Freshly read; page updated August 7, 2026. No named-provider search was completed. \nDepartment of Business Regulation"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S007","urls":["https://rules.sos.ri.gov/Organizations/Title/230","https://rules.sos.ri.gov/Organizations/Chapter/230-40","https://rules.sos.ri.gov/Organizations/SubChapter/230-40-20"],"researcher_record":{"Source ID":"S_RI-P1-S007","Title / issuer / status":"Official Rhode Island Code of Regulations catalog, Title 230/Chapter 40.","Direct literal URL and pinpoint":"https://rules.sos.ri.gov/Organizations/Title/230\nhttps://rules.sos.ri.gov/Organizations/Chapter/230-40\nhttps://rules.sos.ri.gov/Organizations/SubChapter/230-40-20\nAlso checked displayed Financial Institutions and Lending subchapters.","Actual check and limitations":"Freshly read as current catalog evidence. No DMS-specific part appeared in the displayed catalog. This is a bounded negative result, not proof against unpublished or archived material. \nRules of Rhode Island\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S008","urls":["https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules","https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions","https://dbr.ri.gov/insurance-banking-securities-and-charitable-organizations/banking/credit-unions-financial-0"],"researcher_record":{"Source ID":"S_RI-P1-S008","Title / issuer / status":"Current DBR rules, bulletins, and guidance indexes.","Direct literal URL and pinpoint":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions/rules\nhttps://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/credit-unions-financial-institutions\nhttps://dbr.ri.gov/insurance-banking-securities-and-charitable-organizations/banking/credit-unions-financial-0","Actual check and limitations":"Indexes freshly read. No DMS CPI/fee-adjustment item appeared. Catalog absence is not conclusive proof no separate notice exists. \nDepartment of Business Regulation\n+2"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S009","urls":["https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20(fillable).pdf","https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20%28fillable%29.pdf"],"researcher_record":{"Source ID":"S_RI-P1-S009","Title / issuer / status":"Schedule E — Debt Management Services Evidence of Accreditation; Rhode Island DBR.","Direct literal URL and pinpoint":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Schedule%20E%20-%20Debt%20Management%20Services%20Evidence%20of%20Accreditation%20Form%20%20(fillable).pdf\nPDF p.1, form lines 7–15.","Actual check and limitations":"PDF opened and visually inspected. File location is current, but footer says form dated June 27, 2007. It uses “Credit Counseling Organization” wording. \nDepartment of Business Regulation"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S010","urls":["https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf"],"researcher_record":{"Source ID":"S_RI-P1-S010","Title / issuer / status":"Uniform Debt-Management Services Act Substitute Bond Form; Rhode Island DBR.","Direct literal URL and pinpoint":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2025-05/Uniform%20Debt-Managrment%20Services%20Act%20Substitute%20Bond%20Form%20%20rev.%205-20-2025%20fillable.pdf\nPDF pp.1–2, especially lines 7–15, 38–42, 70–78.","Actual check and limitations":"PDF opened and visually inspected. URL/file label suggests 2025 revision, while form footer contains older/inconsistent revision text; statute controls. \nDepartment of Business Regulation\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S011","urls":["https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf","https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_checklist_1-20-26rls.pdf"],"researcher_record":{"Source ID":"S_RI-P1-S011","Title / issuer / status":"2026 Debt Management Services annual-report notice and checklist; Rhode Island DBR.","Direct literal URL and pinpoint":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_filing_notice_1-14-26.pdf\nhttps://dbr.ri.gov/sites/g/files/xkgbur696/files/2026-01/2026_annual_report_dm_checklist_1-20-26rls.pdf","Actual check and limitations":"PDFs opened and visually inspected. Notice contains one apparent 2025 typo; checklist and remaining text specify 2026. Used as operational-currentness evidence only. \nDepartment of Business Regulation\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S012","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx?StateID=RI","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=RI"],"researcher_record":{"Source ID":"S_RI-P1-S012","Title / issuer / status":"NMLS Rhode Island requirements and checklist compiler.","Direct literal URL and pinpoint":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx?StateID=RI\nhttps://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Actual check and limitations":"Actual public routes opened but returned zero extractable lines. Exact current checklist, system fees, and filing fields remain unresolved. \nNationwide Licensing System\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S013","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","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310"],"researcher_record":{"Source ID":"S_RI-P1-S013","Title / issuer / status":"Telemarketing Sales Rule, 16 C.F.R. pt. 310; eCFR.","Direct literal URL and pinpoint":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 — debt-relief definition.\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 — advance-fee rule.\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310 — exemptions.","Actual check and limitations":"Freshly read. eCFR displayed Title 16 through October 22, 2026 and notes eCFR is authoritative but unofficial. \neCFR\n+3"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S014","urls":["https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees"],"researcher_record":{"Source ID":"S_RI-P1-S014","Title / issuer / status":"March 19, 2025 Palisade debt-management complaint announcement; Rhode Island Attorney General.","Direct literal URL and pinpoint":"https://riag.ri.gov/press-releases/attorney-general-neronha-sues-debt-management-group-charging-illegal-excessive-fees\nRegistration allegations at lines 94–103; fee allegations at 108–110.","Actual check and limitations":"Freshly read. Complaint allegations are not a final adjudication or controlling decision. \nRhode Island Attorney General's Office"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S015","urls":["https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions","https://dbr.ri.gov/documents/decisions/BK_Consent_Agreement-Golden_Financial_Services.pdf"],"researcher_record":{"Source ID":"S_RI-P1-S015","Title / issuer / status":"DBR Banking Enforcement Actions roster and Golden Financial consent agreement.","Direct literal URL and pinpoint":"https://dbr.ri.gov/banking-securities-and-charitable-organizations/banking/consumers/banking-enforcement-actions\nhttps://dbr.ri.gov/documents/decisions/BK_Consent_Agreement-Golden_Financial_Services.pdf","Actual check and limitations":"Roster read; consent-order PDF opened and visually inspected. Consent resolution is operational/enforcement evidence, not a controlling appellate interpretation. \nDepartment of Business Regulation\n+1"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"source_id":"S_RI-P1-S016","urls":["https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf"],"researcher_record":{"Source ID":"S_RI-P1-S016","Title / issuer / status":"Amended and Revoked Banking Bulletins; Rhode Island DBR.","Direct literal URL and pinpoint":"https://dbr.ri.gov/sites/g/files/xkgbur696/files/documents/news/banking/Amended_and_Revoked_Bulletins_Banking.pdf","Actual check and limitations":"PDF opened and visually inspected. The displayed historical list concerned mortgage-related matters and did not supply a DMS fee adjustment. Updated May 10, 2016. \nDepartment of Business Regulation"},"coordinator_verification_status":"not_yet_checked","coordinator_review":"[internal evidence reference]","coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"coverage":[{"topic":"Functional DMS definition","researcher_record":{"Pass component":"Functional DMS definition","Status":"Answered","Supporting claims":"C002–C005","Missing evidence / exact next investigation":"Later test unusual creditor/affiliate and lead-generator models against specific facts."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"DMP versus principal-reduction settlement","researcher_record":{"Pass component":"DMP versus principal-reduction settlement","Status":"Answered","Supporting claims":"C002–C004","Missing evidence / exact next investigation":"No material gap for basic classification."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"One-time negotiation","researcher_record":{"Pass component":"One-time negotiation","Status":"Partial","Supporting claims":"C004, C030","Missing evidence / exact next investigation":"Locate Rhode Island order, declaratory ruling, or controlling case addressing §23 fees when covered services do not constitute a plan."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Custodial/noncustodial distinction","researcher_record":{"Pass component":"Custodial/noncustodial distinction","Status":"Answered for access boundary","Supporting claims":"C004, C029","Missing evidence / exact next investigation":"Full trust-account operations, independent-account providers, electronic-access powers, and bank-location rules remain later-pass work."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Consumer versus business purpose","researcher_record":{"Pass component":"Consumer versus business purpose","Status":"Answered for natural persons; partial otherwise","Supporting claims":"C007","Missing evidence / exact next investigation":"Analyze guarantors, jointly liable owners, entity-only debt, and commercial-debt statutes."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Rhode Island resident/remote nexus","researcher_record":{"Pass component":"Rhode Island resident/remote nexus","Status":"Answered","Supporting claims":"C008","Missing evidence / exact next investigation":"Apply to actual enrollment scripts, IP/address facts, agent knowledge, and servicing transfers."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"General market access","researcher_record":{"Pass component":"General market access","Status":"Answered","Supporting claims":"C009, C012, C014–C016","Missing evidence / exact next investigation":"Registration required; exact company status requires NMLS lookup by legal name/NMLS ID."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Attorney exclusion","researcher_record":{"Pass component":"Attorney exclusion","Status":"Answered at statutory level","Supporting claims":"C006, C034","Missing evidence / exact next investigation":"Full unauthorized-practice, law-firm ownership, fee-sharing, and case-law analysis remains open."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Nonprofit treatment","researcher_record":{"Pass component":"Nonprofit treatment","Status":"Answered","Supporting claims":"C011","Missing evidence / exact next investigation":"Review applicant-specific corporate and tax status only if relying on those representations."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Institutional and no-compensation exclusions","researcher_record":{"Pass component":"Institutional and no-compensation exclusions","Status":"Answered at text level","Supporting claims":"C010, C036","Missing evidence / exact next investigation":"Test any bank affiliate, incidental bill-pay, or other-state bank against actual facts and director determinations."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Application requirements","researcher_record":{"Pass component":"Application requirements","Status":"Answered in statute; procedural details partial","Supporting claims":"C012–C015, C041","Missing evidence / exact next investigation":"Retrieve current public NMLS Rhode Island DMS checklist, MU filing instructions, and current system charges without using an account."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Public lookup route","researcher_record":{"Pass component":"Public lookup route","Status":"Answered","Supporting claims":"C012, C033","Missing evidence / exact next investigation":"Perform named-provider lookup when legal name/NMLS ID is supplied; no status inferred here."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current operation of registration program","researcher_record":{"Pass component":"Current operation of registration program","Status":"Answered","Supporting claims":"C015","Missing evidence / exact next investigation":"Recheck future annual-report cycle in later currentness pass."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current DMP dollar fees","researcher_record":{"Pass component":"Current DMP dollar fees","Status":"Unresolved","Supporting claims":"C019, C025, C035","Missing evidence / exact next investigation":"Locate §32(f) base-year rule, every July 1 adjustment, registrant notice, state-register filing, adoption order, or archived DBR schedule."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current settlement absolute setup ceiling","researcher_record":{"Pass component":"Current settlement absolute setup ceiling","Status":"Unresolved","Supporting claims":"C020, C025, C035","Missing evidence / exact next investigation":"Same adjustment-document investigation. Do not calculate CPI independently."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current monthly dollar multiplier/cap","researcher_record":{"Pass component":"Current monthly dollar multiplier/cap","Status":"Unresolved","Supporting claims":"C019–C020, C025","Missing evidence / exact next investigation":"Same adjustment-document investigation."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current no-agreement counseling dollar cap","researcher_record":{"Pass component":"Current no-agreement counseling dollar cap","Status":"Unresolved","Supporting claims":"C023, C025","Missing evidence / exact next investigation":"Same adjustment-document investigation; also locate any director-approved higher-fee orders."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Current dishonored-payment chapter cap","researcher_record":{"Pass component":"Current dishonored-payment chapter cap","Status":"Unresolved","Supporting claims":"C024–C025","Missing evidence / exact next investigation":"Locate adjusted amount and separately research other Rhode Island dishonored-payment law."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Exact percentage formulas","researcher_record":{"Pass component":"Exact percentage formulas","Status":"Answered","Supporting claims":"C020–C022, C037–C039","Missing evidence / exact next investigation":"Apply to actual contract and debt-level data only after dollar adjustments and timing are resolved."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Setup/monthly credit mechanics","researcher_record":{"Pass component":"Setup/monthly credit mechanics","Status":"Answered","Supporting claims":"C022, C028, C037","Missing evidence / exact next investigation":"Contract-specific posting and overcollection remediation remain later-pass issues."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Aggregate cap","researcher_record":{"Pass component":"Aggregate cap","Status":"Answered within §23","Supporting claims":"C038","Missing evidence / exact next investigation":"No flat enrolled-debt fee established; later verify no applicable special-sector law changes result."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"State fee timing","researcher_record":{"Pass component":"State fee timing","Status":"Answered with narrow hold","Supporting claims":"C018, C021","Missing evidence / exact next investigation":"Exact state-only moment for requesting final settlement fee after creditor assent but before payment remains an interpretive issue."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Federal TSR timing","researcher_record":{"Pass component":"Federal TSR timing","Status":"Answered as common context","Supporting claims":"C031–C032","Missing evidence / exact next investigation":"Apply to actual call flow, ad source, debt type, seller/telemarketer roles, and exemptions."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Cancellation and fee refunds","researcher_record":{"Pass component":"Cancellation and fee refunds","Status":"Answered within fee scope","Supporting claims":"C023, C027–C028","Missing evidence / exact next investigation":"Full private remedies, class remedies, voidability, limitations, and restitution remain later-pass work."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Provider bond/insurance","researcher_record":{"Pass component":"Provider bond/insurance","Status":"Boundary only","Supporting claims":"C013","Missing evidence / exact next investigation":"Exact adjusted bond/insurance dollars, claims, substitutes, duration, and recovery reserved for bond/remedies pass."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Accreditation","researcher_record":{"Pass component":"Accreditation","Status":"Partial","Supporting claims":"C013, C041","Missing evidence / exact next investigation":"Determine current DBR-approved accreditors and how settlement-only applicants satisfy the “Credit Counseling Organization” form wording."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Regulations/adoption orders","researcher_record":{"Pass component":"Regulations/adoption orders","Status":"Partial","Supporting claims":"C025, C035","Missing evidence / exact next investigation":"Search Rhode Island State Register archives, DBR rulemaking dockets, superseded regulations, and notices to registrants."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Controlling decisions","researcher_record":{"Pass component":"Controlling decisions","Status":"Partial/negative search result","Supporting claims":"C042","Missing evidence / exact next investigation":"Comprehensive Rhode Island Judiciary, Superior Court, federal district, First Circuit, and citator search."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Enforcement posture","researcher_record":{"Pass component":"Enforcement posture","Status":"Answered only as examples","Supporting claims":"C034","Missing evidence / exact next investigation":"Obtain and analyze underlying Palisade complaint, docket status, later orders, and other DMS enforcement files."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Creditor-paid compensation","researcher_record":{"Pass component":"Creditor-paid compensation","Status":"Boundary only","Supporting claims":"C036","Missing evidence / exact next investigation":"Analyze fee caps, conflicts, disclosure, and creditor fair-share arrangements in a later pass."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Agreements/e-signatures","researcher_record":{"Pass component":"Agreements/e-signatures","Status":"Excluded except timing/content needed here","Supporting claims":"C018, C027","Missing evidence / exact next investigation":"Full formation, delivery, E-SIGN/UETA, choice-of-law, forum, POA, and severability pass."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Full funds/trust analysis","researcher_record":{"Pass component":"Full funds/trust analysis","Status":"Excluded except custody boundary","Supporting claims":"C029","Missing evidence / exact next investigation":"Full accounting, disbursement, insolvency, account administrator, reconciliation, and dedicated-account pass."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Remedies, collection, litigation, limitations","researcher_record":{"Pass component":"Remedies, collection, litigation, limitations","Status":"Excluded except refund boundary","Supporting claims":"C027–C028","Missing evidence / exact next investigation":"Dedicated later passes required."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Exemptions beyond access classification","researcher_record":{"Pass component":"Exemptions beyond access classification","Status":"Open","Supporting claims":"C010","Missing evidence / exact next investigation":"Sector, creditor, professional, bankruptcy, court-supervised, and institutional edge cases."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Secured debt","researcher_record":{"Pass component":"Secured debt","Status":"Open","Supporting claims":"—","Missing evidence / exact next investigation":"Analyze mortgage, auto, tax, utility, student-loan, medical, and other secured/special debt interactions."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Local, tribal, sector, and contract law","researcher_record":{"Pass component":"Local, tribal, sector, and contract law","Status":"Open","Supporting claims":"—","Missing evidence / exact next investigation":"Separate Rhode Island/local/federal/tribal and contract investigations required."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Proposed/future-effective rules","researcher_record":{"Pass component":"Proposed/future-effective rules","Status":"Open","Supporting claims":"C035","Missing evidence / exact next investigation":"Search active Rhode Island rulemaking notices and future-effective enactments; none is claimed absent."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Named SettleADebt.com authorization","researcher_record":{"Pass component":"Named SettleADebt.com authorization","Status":"Not established","Supporting claims":"C033","Missing evidence / exact next investigation":"Registration must be independently confirmed before Rhode Island service."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"},{"topic":"Full Rhode Island or A066 acceptance","researcher_record":{"Pass component":"Full Rhode Island or A066 acceptance","Status":"Expressly not performed","Supporting claims":"All","Missing evidence / exact next investigation":"Completion requires all remaining state components and coordinator review."},"coordinator_acceptance":"scoped_review_with_material_corrections_and_remaining_holds","coordinator_review":"[internal evidence reference]","coordinator_review_limit":"Actual checks listed separately; original researcher_record remains verbatim. This is not complete independent authority/currentness verification.","subsequent_scoped_correction":"[internal evidence reference]","subsequent_correction_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}