{"meta":{"key":"s_sc--pass-02","task":"S_SC","title":"SSC South Carolina remaining-evidence investigation","parent_title":"South Carolina debt and debt relief law","edition":"pass-02","path":"/research/s_sc--pass-02/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-24","tables":7,"claims":14,"sources":4,"review_status":"revise","review_complete":true,"sha256":"e20a9c6bb8d88dcb7faf06a4f96cfcc3a50f6e91c6b65d20bdba6d35d15c7f5c","headings":["Bottom-line changes to PASS-01","1. DCA Administrative Interpretation 7.108-1003","1.1 Compensation source, not consumer billing label, controls the threshold","1.2 Education, budget analysis, and written contract come before compensated counseling services","1.3 Assignment from a compliant licensed assignor","1.4 Assignment from an unlicensed/noncompliant assignor","1.5 Assignment-law caveat","1.6 What 7.108-1003 does not resolve","2. DCA Administrative Interpretation 7.108-1001","Practical boundary","3. Status and later-history limitation of the interpretations","Actual issue recovered","Relevant-result check","Legal-effect conclusion","Additional PASS-01 claims materially clarified","Failed/recovered routes","Narrowed unresolved dependencies","Actually read in PASS-02","Not claimed"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Medium","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_SC/pass-02","facets":{"geography":["us","us-sc"],"debt_type":[],"stage":[],"subject":[]},"scope":"Only recover full DCA formal interpretations7.108-1003 and related relevant2010text (not index summaries) plus actual October23Register issue relevant changes. Use new usable public text route and preserve failures; no rerun broadstate/feeexamples/federaloverview.","pending_corrections":0},"markdown":"# S_SC PASS-02 — South Carolina remaining-evidence investigation\n\n**Baseline inherited:** October 22, 2026, Pacific.\n**Actual research/access date for this pass:** **October 24, 2026, Pacific.**\n\n**Scope actually completed:** only the two PASS-01 evidence gaps requested:\n\n1. Full South Carolina DCA Administrative Interpretation **7.108-1003**, plus the related 2010 **7.108-1001**, read from the actual page images rather than index summaries.\n2. The actual **October 23, 2026 South Carolina State Register, Volume 50, Issue 10**, checked for changes relevant to Chapter 7 / R.28-700 / credit counseling.\n\nI did **not** rerun the state overview, fee examples, federal baseline, provider lookup, or broader South Carolina dossier.\n\n## Bottom-line changes to PASS-01\n\nThree useful things are now established.\n\n**First, assignment does not let a credit-counseling provider bypass the pre-service requirements.** DCA's 7.108-1003 says that when credit-counseling services are provided for a fee, compensation, gain, or expectation thereof, the consumer education program, budget analysis, and compliant written-contract requirements must be satisfied before the provider begins covered credit-counseling services. A licensed assignee receiving compliant contracts from a properly licensed assignor does not need to duplicate those steps, but must ensure they were properly completed. If the assignor was not licensed, the assignee generally has to cure those prerequisites before providing covered services for compensation. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n**Second, “free to the consumer” is not enough.** The same interpretation expressly says “fee, compensation or gain” is not limited to money from the consumer; DCA identifies outside-source compensation such as fair-share contributions and grant funding. On the facts addressed, a noncompliant assignee could provide services before curing the Act's requirements only on a genuinely uncompensated basis—no money received or expected from any source for those services. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n**Third, the October 23 Register contains no relevant Department of Consumer Affairs, Chapter 28, §37-7, R.28-700, or credit-counseling amendment.** The issue is now actually accessible and is Volume 50, Issue 10, published October 23, 2026. Its table of contents has no DCA item, and targeted searches found no “Chapter 28,” “37-7,” or “counseling” occurrence. Thus PASS-01's October-register currentness hold is resolved **for this specific issue**. [South Carolina Legislature+4](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\n# A. Full interpretation findings\n\n## 1. DCA Administrative Interpretation 7.108-1003\n\n**Document:** Administrative Interpretation 7.108-1003\n**Issuer:** South Carolina Department of Consumer Affairs\n**Date:** June 29, 2010\n**Document length:** 3 pages\n**Status characterization:** agency administrative interpretation/informal interpretation response—not a regulation, statute, court holding, or adjudicatory final order.\n\nThe actual question presented was whether an organization could take assignment of South Carolina credit-counseling contracts and then perform services **before** providing a consumer education program, completing the budget analysis, or entering the required contract, when no fee was being charged to the consumer. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n### 1.1 Compensation source, not consumer billing label, controls the threshold\n\nDCA first restated that an organization providing or offering credit-counseling services for a **fee, compensation, gain, or expectation thereof** is a credit-counseling organization requiring the licensing framework. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nThe most important new passage appears on page 3. DCA says that the statutory concept of “fee, compensation or gain” is **not merely limited to money received from or on behalf of a consumer**. It can include money received from other sources, with DCA specifically giving examples including **fair-share contributions and grant funding**. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nThat materially narrows the PASS-01 “free service” uncertainty:\n\nA service is not outside the Act merely because the consumer is charged $0.\n\nFor the factual model presented in the interpretation, the relevant question becomes whether compensation, gain, or an expectation of it exists **from any source**.\n\n### 1.2 Education, budget analysis, and written contract come before compensated counseling services\n\nOn page 2 DCA relies on §§37-7-108, 37-7-110, and 37-7-113. It explains that the Act bars the organization, through its counselors, from engaging in covered counseling or DMP services unless the required credit-education program and budget analysis have been completed; and it separately identifies the written, dated contract requirement for services requiring payment, fee, or other consideration. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nDCA's stated conclusion is broader than merely “do these before billing”: when the provider is engaging in the service for fee, compensation, gain, or expectation thereof, it must satisfy the education, budget-analysis, and written-contract requirements **before providing the credit-counseling services**. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nThat resolves the assignment/bypass question. It does **not** authorize a provider to do compensated substantive counseling first and “paper the account” afterward.\n\n### 1.3 Assignment from a compliant licensed assignor\n\nDCA then applies the assignment principle that an assignee stands in the assignor's shoes.\n\nWhere the assignee is licensed and acquires South Carolina consumer contracts from an organization that:\n\n- was licensed when it entered into the contracts, and\n- maintained the required licenses while servicing them,\n\nthe assignee does **not** have to duplicate the consumer-education program, budget analysis, and contract process. Instead, it must ensure the assignor's prior actions complied with the Act. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nThis is a meaningful operational rule: lawful assignment can preserve completed statutory prerequisites, but it does not erase them.\n\n### 1.4 Assignment from an unlicensed/noncompliant assignor\n\nIf the assignee acquires contracts from an organization that failed to obtain the required licenses, DCA says the assignee must provide the consumer education program, budget analysis, and Act-compliant written contract before it provides covered credit-counseling services—unless the service is genuinely provided free of charge in the sense discussed above. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nDCA's conclusion is explicit: if the assignor-license conditions are not met, the assignee may perform services before curing the Act's requirements only on a **free-of-charge basis**, meaning no money will be received or expected **from any source** for those services. Once the assignee complies with the Act, fees, compensation, or gain may then be received. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n### 1.5 Assignment-law caveat\n\nDCA separately warns that assignment remains subject to other Code provisions. The interpretation specifically references:\n\n- §37-2-412 concerning notice of assignment; and\n- §37-2-404 concerning the claims and defenses a consumer may assert against an assignee.\n\nThose broader assignment consequences remain outside this pass. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n### 1.6 What 7.108-1003 does **not** resolve\n\nIt does **not** resolve PASS-01's narrower question about the interaction between:\n\n- §37-7-110(A)'s express exception for the §37-7-109(A) DMP setup fee; and\n- R.28-700(B)(5)'s fee-in-contract provision.\n\nThe interpretation discusses the general written-contract/prerequisite rule and assignment. It does not specifically analyze the statutory setup-fee exception or declare exactly when that setup fee may be documented/requested/received relative to contract execution.\n\nAccordingly, **P1-C029 stays partially held**, but the dependency is much narrower now.\n\n## 2. DCA Administrative Interpretation 7.108-1001\n\n**Document:** Administrative Interpretation 7.108-1001\n**Issuer:** South Carolina Department of Consumer Affairs\n**Date:** April 15, 2010\n**Document length:** 2 pages\n**Status:** agency administrative interpretation/informal interpretation response.\n\nThe presented question concerned whether **unlicensed counselors employed by a licensed counseling organization** could collect South Carolina consumer information—including date of birth and financial-account information—for entry into the statutory budget analysis. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf)\n\nDCA answered **no**.\n\nSection 37-7-108 requires the budget analysis before the organization engages in covered counseling, and DCA reasoned that because covered services may be provided only by a licensed organization through licensed counselors, the required budget analysis must likewise be performed and completed by licensed counselors. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf)\n\nDCA's concrete conclusion is that an employee/counselor may not collect the information required by §37-7-108(2)(a)–(m), including financial-account information, until the person has satisfied the licensing requirements and the Department has issued the counselor license. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf)\n\n### Practical boundary\n\nFor an operating model with intake representatives, call-center agents, or application/intake staff, the interpretation creates a meaningful line:\n\n**An unlicensed counselor cannot be used to collect the statutory budget-analysis information as a workaround while waiting for licensure.**\n\nThis pass does not attempt to decide every distinction between purely clerical website data collection and “credit counselor” conduct. The interpretation addressed employees/counselors gathering the statutorily required budget-analysis information.\n\n## 3. Status and later-history limitation of the interpretations\n\nDCA still currently lists both interpretations on its Chapter Seven Administrative Interpretations page:\n\n- 7.108-1001, issued April 15, 2010;\n- 7.108-1003, issued June 29, 2010.\n\nThe same current index expressly cautions users that law and interpretations may change and recommends confirming that a document has not been superseded before formal reliance. [Consumer Affairs](https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven)\n\nThe documents themselves also state that reliance on an administrative interpretation receives the statutory protection described there if the interpretation is later declared invalid by a court or rescinded. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nA focused search for these exact interpretation numbers did **not** locate a later rescission or superseding DCA interpretation. The current DCA index continues to publish both. That supports describing them as **currently posted agency interpretations**, but it is not equivalent to a formal DCA certification on October 24, 2026 that no later unpublished or differently numbered authority affects them. DCA's own disclaimer prevents that stronger claim. [Consumer Affairs+2](https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com)\n\n# B. October 23, 2026 State Register check\n\n## Actual issue recovered\n\n**South Carolina State Register, Volume 50, Issue No. 10**\n**Published:** October 23, 2026\n**Issuer:** Legislative Council of the South Carolina General Assembly\n**Length:** 56 PDF pages.\n\nThe issue states that it contains notices, proposed regulations, emergency regulations, final-form regulations, and other materials filed under the Administrative Procedures Act. It also states that final regulations generally take effect on publication unless otherwise specified. [South Carolina Legislature](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\n### Relevant-result check\n\nThe actual table of contents was read. It lists the agencies and regulation documents published in the issue. **Department of Consumer Affairs does not appear in the table of contents.** [South Carolina Legislature+1](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\nTargeted full-document searches also returned:\n\n- **“Chapter 28” — no match**\n- **“37-7” — no match**\n- **“counseling” — no match** [South Carolina Legislature+2](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\nA search for “Department of Consumer Affairs” did not locate a substantive DCA item; the returned context was the issue's table of contents and unrelated agencies. [South Carolina Legislature](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\n### Legal-effect conclusion\n\n**No October 23, 2026 State Register item changes the PASS-01 provider-access or consumer-fee findings for Chapter 7 / R.28-700.**\n\nThis is a bounded conclusion about **Volume 50, Issue 10 only**. It does not constitute a new review of every 2026 statute, court case, DCA bulletin, or non-Register source.\n\nPASS-01's specific currentness gap—“scheduled October 23 issue remains unverified”—is now closed.\n\n# C. PASS-02 source table\n\n| Source ID | Primary source / issuer | Direct literal URL | Exact material read | Status / access / limitation |\n| --- | --- | --- | --- | --- |\n| **S_SC-P2-S001** | Administrative Interpretation 7.108-1003 — South Carolina Department of Consumer Affairs | https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf | **All 3 pages**, including question presented, statutory reasoning, assignment analysis, outside-source compensation, conclusion, assignment caveat, and reliance paragraph. [Consumer Affairs+2](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | Issued **6/29/2010**. Agency administrative interpretation, not regulation/court holding/final adjudicatory order. Actual page images read **10/24/2026** after text extraction remained essentially empty. Current DCA index still lists it but warns of possible supersession. |\n| **S_SC-P2-S002** | Administrative Interpretation 7.108-1001 — South Carolina Department of Consumer Affairs | https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf | **Both pages**, including presented question and DCA conclusion concerning licensed counselors and budget-analysis information. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf) | Issued **4/15/2010**. Same status limitation as S001. Page images actually read **10/24/2026**. |\n| **S_SC-P2-S003** | Chapter Seven Administrative Interpretations index — South Carolina Department of Consumer Affairs | https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven | Lines 9–21: current listing of 1001 and 1003, issue dates, agency summaries, and supersession warning. [Consumer Affairs](https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven) | Current agency webpage checked **10/24/2026**. Index proves current posting, not substantive continuing-validity certification. |\n| **S_SC-P2-S004** | South Carolina State Register Vol.50 Issue 10 — Legislative Council | https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1 | Publication metadata; status explanations; full TOC; targeted complete-document searches for DCA/Chapter28/37-7/counseling. [South Carolina Legislature+5](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1) | **Published 10/23/2026.** Official state publication, but its own disclaimer says printed State Register is the official version. Web PDF actually accessible/read **10/24/2026**. No relevant DCA/Chapter7/R.28-700 item found. |\n| **S_SC-P2-S005** | Alternate current DCA-hosted route for 7.108-1003 | https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf | Search-discovered current hosted copy. [Consumer Affairs](https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com) | Discovery/corroboration only; substantive page reading came from S001. |\n| **S_SC-P2-S006** | Alternate current DCA-hosted route for 7.108-1001 | https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf | Search-discovered current hosted copy. [Consumer Affairs](https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com) | Discovery/corroboration only; substantive page reading came from S002. |\n\n# D. Material claim table\n\n| Claim ID | Precise assertion | Sources / pinpoint | Conditions / exceptions / confidence |\n| --- | --- | --- | --- |\n| **S_SC-P2-C001** | 7.108-1003 addresses assignment of SC credit-counseling contracts and whether services can begin before education, budget analysis and contract compliance where no consumer fee is charged. | S001 p.1. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High.** Directly stated question presented. |\n| **S_SC-P2-C002** | DCA interprets compensated credit counseling to require the education program, budget analysis and written-contract compliance before covered credit-counseling services are provided. | S001 p.2. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High as DCA's 2010 interpretation.** Not characterized as regulation or court holding. |\n| **S_SC-P2-C003** | A licensed assignee receiving contracts from an assignor that was properly licensed when contracting and remained licensed while servicing need not duplicate the prerequisites, but must ensure they were compliant. | S001 pp.2–3. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High as agency interpretation.** Actual assignor/assignee license facts must satisfy the stated conditions. |\n| **S_SC-P2-C004** | If the assignor was unlicensed, the licensed assignee must complete education, budget-analysis and written-contract prerequisites before compensated counseling services, subject to the genuinely uncompensated-service boundary. | S001 p.3. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High as agency interpretation.** |\n| **S_SC-P2-C005** | DCA interprets “fee, compensation or gain” as extending beyond money from/on behalf of the consumer and gives fair-share contributions and grant funding as examples of outside-source compensation. | S001 p.3. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High for DCA's interpretation.** Does not resolve every conceivable indirect economic benefit. |\n| **S_SC-P2-C006** | On the facts addressed, precompliance services may be provided only on a genuinely free basis—no money received or expected from any source for those services. | S001 p.3. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High as agency interpretation.** More specific than “consumer pays $0.” |\n| **S_SC-P2-C007** | 7.108-1003 does not specifically resolve the §109(A) setup-fee exception versus R.28-700(B)(5) contract-documentation sequencing question. | S001 all pages. [Consumer Affairs+2](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High negative-scope conclusion from complete reading.** P1-C029 remains partially held. |\n| **S_SC-P2-C008** | DCA's 7.108-1001 concludes that unlicensed counselors may not collect §37-7-108(2)(a)–(m) budget-analysis information, including financial-account information, until the counselor licensing process has resulted in issuance of a license. | S002 p.2. [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf) | **High as agency interpretation.** Narrowed to persons/functions addressed by the interpretation. |\n| **S_SC-P2-C009** | DCA currently posts both 2010 interpretations but expressly warns users to verify that they have not been superseded before formal reliance. | S003 lines 11–21. [Consumer Affairs](https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven) | **High.** Current posting is not a certification of unchanged legal validity. |\n| **S_SC-P2-C010** | Focused exact-ID searching found no later rescission/superseding interpretation; both documents remain current-hosted by DCA. | S003, S005, S006. [Consumer Affairs+2](https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com) | **Moderate.** Absence of a discovered rescission is not proof none exists; DCA's own disclaimer controls confidence. |\n| **S_SC-P2-C011** | State Register Vol.50 Issue 10 was actually published October 23, 2026. | S004 lines 19–24. [South Carolina Legislature](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1) | **High.** |\n| **S_SC-P2-C012** | The October23 issue contains no DCA item in its TOC and no detected Chapter28, §37-7 or credit-counseling material. | S004 TOC and targeted searches. [South Carolina Legislature+4](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1) | **High for this issue.** Does not establish absence of changes in other legal channels. |\n| **S_SC-P2-C013** | Consequently the specific PASS-01 October23-Register currentness hold can be closed without changing the PASS-01 Chapter7/R.28-700 fee conclusions. | S004. [South Carolina Legislature+1](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1) | **High and bounded.** No broader 2026 legal-currentness claim implied. |\n| **S_SC-P2-C014** | Neither recovered 2010 interpretation resolves installment-settled “remaining creditor” counting, partial-month proration, reinstatement/dishonor mechanics, or independent-vendor fee treatment. | S001–S002 complete readings. [Consumer Affairs+4](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) | **High negative-scope conclusion.** P1-C048 remains held. |\n\n# E. Original PASS-01 claim patch map\n\n| Existing claim ID | PASS-02 disposition | Revised/clarified treatment |\n| --- | --- | --- |\n| **S_SC-P1-C029** | **PARTIAL HOLD REMAINS — narrowed** | Full 7.108-1003 is now read. It establishes that assignment does not bypass education, budget-analysis and contract prerequisites for compensated counseling. But it does **not specifically analyze §109(A)'s setup-fee exception against R.28-700(B)(5)**. Do not convert the interpretation into a definitive setup-fee timing rule. Supporting new claims: **P2-C002, C003, C004, C007**. |\n| **S_SC-P1-C041** | **RESOLVED FOR OCT.23 REGISTER DEPENDENCY** | Replace “scheduled October23 issue remains unverified” with: “State Register Vol.50 Issue10, published October23, 2026, was actually read on October24; no DCA/Chapter28/§37-7/credit-counseling item relevant to PASS-01 was found.” Supporting: **P2-C011–C013**. |\n| **S_SC-P1-C042** | **UPGRADED / REPLACED** | No longer limited to index summaries. Full 7.108-1001 and 7.108-1003 page images were read. 1001 bars unlicensed counselors from collecting statutory budget-analysis data; 1003 provides the assignment/prerequisite/outside-source-compensation rules above. Supporting: **P2-C001–C010**. |\n| **S_SC-P1-C048** | **UNCHANGED HOLD** | Neither 2010 interpretation addresses installment-settled creditor counts, partial-month proration, reinstatement/dishonor mechanics, or independent-vendor fee mechanics. Supporting: **P2-C014**. |\n\n### Additional PASS-01 claims materially clarified\n\n| Existing claim ID | Patch |\n| --- | --- |\n| **S_SC-P1-C005** | **Strengthened.** The prior statement that compensation/gain is broader than a consumer invoice is now supported by the actual DCA interpretation. DCA specifically treats outside-source funds such as fair-share contributions and grants as potentially constituting “fee, compensation or gain.” **P2-C005–C006.** |\n| **S_SC-P1-C017** | **Strengthened at counselor-intake level.** 7.108-1001 specifically interprets the budget-analysis information collection itself as work requiring a licensed counselor in the addressed circumstances. **P2-C008.** |\n\nNo other PASS-01 claim is reopened by this focused pass.\n\n# F. Failed-route and dependency table\n\n## Failed/recovered routes\n\n| Evidence | Prior / current route result | PASS-02 treatment |\n| --- | --- | --- |\n| 7.108-1003 ordinary PDF text extraction | PDF exposed only the title, not body text. | **Recovered through materially different page-image rendering.** All three pages were read. [Consumer Affairs+3](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf) |\n| 7.108-1001 ordinary PDF text extraction | PDF exposed only the title, not body text. | **Recovered through page-image rendering.** Both pages were read. [Consumer Affairs+2](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf) |\n| October23 State Register | PASS-01 route was not yet retrievable. | **Recovered.** 56-page Issue10 read/searchable on October24. [South Carolina Legislature](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1) |\n| Formal confirmation interpretations have never been superseded | No such primary certification found in focused search. | **Still a dependency.** Current DCA index publishes them but expressly recommends confirmation before formal reliance. [Consumer Affairs](https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven) |\n\n## Narrowed unresolved dependencies\n\n| Dependency | Why it still matters | Exact next evidence/action |\n| --- | --- | --- |\n| §109(A) setup fee versus §110(A)/R.28-700(B)(5) sequencing | 7.108-1003 did not discuss the specific statutory setup-fee exception. | Locate a later DCA interpretation, order, enforcement decision, judicial decision, or operative regulation specifically addressing when the §109(A) setup fee may be contracted for/requested/received. Do not infer from 1003 alone. |\n| Formal present-day nonsupersession of 7.108-1001/1003 | DCA's current index contains an explicit supersession warning. | A future formal-use review should locate any later numbered interpretations/orders or a current authoritative confirmation. No contact was made in this pass. |\n| Clerical web intake versus “credit counselor” budget-analysis collection | 1001 addressed unlicensed counselors collecting §108(2) information, not every possible passive form or clerical workflow. | Investigate later DCA authority/cases if a proposed operating model relies on unlicensed intake or automated data capture. |\n| P1-C048 fee mechanics | Neither recovered interpretation touches them. | Separate targeted authority search for remaining-creditor counting, partial months, reinstatement/dishonor sequence, and direct/indirect vendor fees. |\n\n# G. Granular PASS-02 coverage\n\n| Assigned item | Status | Claim IDs | Remaining gap |\n| --- | --- | --- | --- |\n| Recover full 7.108-1003 | **Answered** | P2-C001–C007 | Only later supersession/current-formal-reliance check remains. |\n| Assignment from compliant licensed provider | **Answered** | P2-C003 | Provider-specific facts later. |\n| Assignment from unlicensed/noncompliant provider | **Answered** | P2-C004, C006 | Provider-specific facts later. |\n| Meaning of no consumer fee / outside-source compensation | **Answered materially** | P2-C005–C006 | Every exotic indirect-benefit model not adjudicated. |\n| Recover related 2010 text, 7.108-1001 | **Answered** | P2-C008 | Automated/clerical intake boundary later if operationally relevant. |\n| Determine whether those interpretations currently appear on DCA site | **Answered** | P2-C009–C010 | Formal nonsupersession certification not established. |\n| Resolve precise DMP setup-fee sequencing | **Still partial/unresolved** | P2-C007 | Specific authority absent. |\n| Recover actual October23 Register | **Answered** | P2-C011 | None for retrieval. |\n| Check October23 issue for relevant DCA/Chapter28/Chapter7 change | **Answered: none found** | P2-C012–C013 | Other legal channels not reopened. |\n| Resolve P1-C048 miscellaneous fee mechanics | **Not answered by assigned evidence** | P2-C014 | Separate later investigation required. |\n| Full agreements/funds/bond/remedies/cases/limitations/exemptions/secured/local/tribal/sector investigation | **Outside PASS-02 and remains open** | — | Later passes. |\n| Full South Carolina acceptance / A066 acceptance | **Not performed** | — | Remains open. |\n\n# H. Researcher self-check\n\nThis is **not independent review**.\n\n### Actually read in PASS-02\n\n- All three page images of Administrative Interpretation **7.108-1003**.\n- Both page images of Administrative Interpretation **7.108-1001**.\n- DCA's current Chapter Seven interpretations index and its supersession disclaimer.\n- The publication metadata and actual table of contents of **South Carolina State Register Vol.50 Issue10, October23, 2026**.\n- Targeted full-text searches within that issue for Chapter28, §37-7, counseling, and DCA references.\n- Focused exact-number searches for later rescission/supersession indicators.\n\n### Not claimed\n\n- No claim that DCA has affirmatively certified the 2010 interpretations as nonsuperseded as of October24, 2026.\n- No inference that an index listing has the force of statute or regulation.\n- No claim that the State Register check proves there were no relevant statutory, judicial, administrative, or unpublished changes outside that issue.\n- No fresh review of PASS-01's fee caps, federal TSR baseline, provider roster, licensing application, examples, or other state categories.\n- No local save, publication, application, contact, other chat, account change, API use, browser-permission change, or model/UI verification occurred.\n- No full-state or A066 completion/readiness claim is made.\n\n**END S_SC PASS-02**\n\n","tables":[{"headers":["Source ID","Primary source / issuer","Direct literal URL","Exact material read","Status / access / limitation"],"index":0,"links":[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+2"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs\n+1"},{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+5"},{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com","text":"Consumer Affairs"}],"row_links":[[],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+2"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs\n+1"}],[{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+5"}],[{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com","text":"Consumer Affairs"}]],"rows":[["Source ID","Primary source / issuer","Direct literal URL","Exact material read","Status / access / limitation"],["S_SC-P2-S001","Administrative Interpretation 7.108-1003 — South Carolina Department of Consumer Affairs","https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","All 3 pages, including question presented, statutory reasoning, assignment analysis, outside-source compensation, conclusion, assignment caveat, and reliance paragraph. \nConsumer Affairs\n+2","Issued 6/29/2010. Agency administrative interpretation, not regulation/court holding/final adjudicatory order. Actual page images read 10/24/2026 after text extraction remained essentially empty. Current DCA index still lists it but warns of possible supersession."],["S_SC-P2-S002","Administrative Interpretation 7.108-1001 — South Carolina Department of Consumer Affairs","https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","Both pages, including presented question and DCA conclusion concerning licensed counselors and budget-analysis information. \nConsumer Affairs\n+1","Issued 4/15/2010. Same status limitation as S001. Page images actually read 10/24/2026."],["S_SC-P2-S003","Chapter Seven Administrative Interpretations index — South Carolina Department of Consumer Affairs","https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","Lines 9–21: current listing of 1001 and 1003, issue dates, agency summaries, and supersession warning. \nConsumer Affairs","Current agency webpage checked 10/24/2026. Index proves current posting, not substantive continuing-validity certification."],["S_SC-P2-S004","South Carolina State Register Vol.50 Issue 10 — Legislative Council","https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","Publication metadata; status explanations; full TOC; targeted complete-document searches for DCA/Chapter28/37-7/counseling. \nSouth Carolina Legislature\n+5","Published 10/23/2026. Official state publication, but its own disclaimer says printed State Register is the official version. Web PDF actually accessible/read 10/24/2026. No relevant DCA/Chapter7/R.28-700 item found."],["S_SC-P2-S005","Alternate current DCA-hosted route for 7.108-1003","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","Search-discovered current hosted copy. \nConsumer Affairs","Discovery/corroboration only; substantive page reading came from S001."],["S_SC-P2-S006","Alternate current DCA-hosted route for 7.108-1001","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","Search-discovered current hosted copy. \nConsumer Affairs","Discovery/corroboration only; substantive page reading came from S002."]]},{"headers":["Claim ID","Precise assertion","Sources / pinpoint","Conditions / exceptions / confidence"],"index":1,"links":[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+1"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+2"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"},{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Consumer Affairs\n+2"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+4"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+1"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+4"}],"row_links":[[],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+1"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+2"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"}],[{"href":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Consumer Affairs\n+2"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+4"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature\n+1"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+4"}]],"rows":[["Claim ID","Precise assertion","Sources / pinpoint","Conditions / exceptions / confidence"],["S_SC-P2-C001","7.108-1003 addresses assignment of SC credit-counseling contracts and whether services can begin before education, budget analysis and contract compliance where no consumer fee is charged.","S001 p.1. \nConsumer Affairs","High. Directly stated question presented."],["S_SC-P2-C002","DCA interprets compensated credit counseling to require the education program, budget analysis and written-contract compliance before covered credit-counseling services are provided.","S001 p.2. \nConsumer Affairs","High as DCA's 2010 interpretation. Not characterized as regulation or court holding."],["S_SC-P2-C003","A licensed assignee receiving contracts from an assignor that was properly licensed when contracting and remained licensed while servicing need not duplicate the prerequisites, but must ensure they were compliant.","S001 pp.2–3. \nConsumer Affairs\n+1","High as agency interpretation. Actual assignor/assignee license facts must satisfy the stated conditions."],["S_SC-P2-C004","If the assignor was unlicensed, the licensed assignee must complete education, budget-analysis and written-contract prerequisites before compensated counseling services, subject to the genuinely uncompensated-service boundary.","S001 p.3. \nConsumer Affairs","High as agency interpretation."],["S_SC-P2-C005","DCA interprets “fee, compensation or gain” as extending beyond money from/on behalf of the consumer and gives fair-share contributions and grant funding as examples of outside-source compensation.","S001 p.3. \nConsumer Affairs","High for DCA's interpretation. Does not resolve every conceivable indirect economic benefit."],["S_SC-P2-C006","On the facts addressed, precompliance services may be provided only on a genuinely free basis—no money received or expected from any source for those services.","S001 p.3. \nConsumer Affairs","High as agency interpretation. More specific than “consumer pays $0.”"],["S_SC-P2-C007","7.108-1003 does not specifically resolve the §109(A) setup-fee exception versus R.28-700(B)(5) contract-documentation sequencing question.","S001 all pages. \nConsumer Affairs\n+2","High negative-scope conclusion from complete reading. P1-C029 remains partially held."],["S_SC-P2-C008","DCA's 7.108-1001 concludes that unlicensed counselors may not collect §37-7-108(2)(a)–(m) budget-analysis information, including financial-account information, until the counselor licensing process has resulted in issuance of a license.","S002 p.2. \nConsumer Affairs","High as agency interpretation. Narrowed to persons/functions addressed by the interpretation."],["S_SC-P2-C009","DCA currently posts both 2010 interpretations but expressly warns users to verify that they have not been superseded before formal reliance.","S003 lines 11–21. \nConsumer Affairs","High. Current posting is not a certification of unchanged legal validity."],["S_SC-P2-C010","Focused exact-ID searching found no later rescission/superseding interpretation; both documents remain current-hosted by DCA.","S003, S005, S006. \nConsumer Affairs\n+2","Moderate. Absence of a discovered rescission is not proof none exists; DCA's own disclaimer controls confidence."],["S_SC-P2-C011","State Register Vol.50 Issue 10 was actually published October 23, 2026.","S004 lines 19–24. \nSouth Carolina Legislature","High."],["S_SC-P2-C012","The October23 issue contains no DCA item in its TOC and no detected Chapter28, §37-7 or credit-counseling material.","S004 TOC and targeted searches. \nSouth Carolina Legislature\n+4","High for this issue. Does not establish absence of changes in other legal channels."],["S_SC-P2-C013","Consequently the specific PASS-01 October23-Register currentness hold can be closed without changing the PASS-01 Chapter7/R.28-700 fee conclusions.","S004. \nSouth Carolina Legislature\n+1","High and bounded. No broader 2026 legal-currentness claim implied."],["S_SC-P2-C014","Neither recovered 2010 interpretation resolves installment-settled “remaining creditor” counting, partial-month proration, reinstatement/dishonor mechanics, or independent-vendor fee treatment.","S001–S002 complete readings. \nConsumer Affairs\n+4","High negative-scope conclusion. P1-C048 remains held."]]},{"headers":["Existing claim ID","PASS-02 disposition","Revised/clarified treatment"],"index":2,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Existing claim ID","PASS-02 disposition","Revised/clarified treatment"],["S_SC-P1-C029","PARTIAL HOLD REMAINS — narrowed","Full 7.108-1003 is now read. It establishes that assignment does not bypass education, budget-analysis and contract prerequisites for compensated counseling. But it does not specifically analyze §109(A)'s setup-fee exception against R.28-700(B)(5). Do not convert the interpretation into a definitive setup-fee timing rule. Supporting new claims: P2-C002, C003, C004, C007."],["S_SC-P1-C041","RESOLVED FOR OCT.23 REGISTER DEPENDENCY","Replace “scheduled October23 issue remains unverified” with: “State Register Vol.50 Issue10, published October23, 2026, was actually read on October24; no DCA/Chapter28/§37-7/credit-counseling item relevant to PASS-01 was found.” Supporting: P2-C011–C013."],["S_SC-P1-C042","UPGRADED / REPLACED","No longer limited to index summaries. Full 7.108-1001 and 7.108-1003 page images were read. 1001 bars unlicensed counselors from collecting statutory budget-analysis data; 1003 provides the assignment/prerequisite/outside-source-compensation rules above. Supporting: P2-C001–C010."],["S_SC-P1-C048","UNCHANGED HOLD","Neither 2010 interpretation addresses installment-settled creditor counts, partial-month proration, reinstatement/dishonor mechanics, or independent-vendor fee mechanics. Supporting: P2-C014."]]},{"headers":["Existing claim ID","Patch"],"index":3,"links":[],"row_links":[[],[],[]],"rows":[["Existing claim ID","Patch"],["S_SC-P1-C005","Strengthened. The prior statement that compensation/gain is broader than a consumer invoice is now supported by the actual DCA interpretation. DCA specifically treats outside-source funds such as fair-share contributions and grants as potentially constituting “fee, compensation or gain.” P2-C005–C006."],["S_SC-P1-C017","Strengthened at counselor-intake level. 7.108-1001 specifically interprets the budget-analysis information collection itself as work requiring a licensed counselor in the addressed circumstances. P2-C008."]]},{"headers":["Evidence","Prior / current route result","PASS-02 treatment"],"index":4,"links":[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+3"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs\n+2"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature"},{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"}],"row_links":[[],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","text":"Consumer Affairs\n+3"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","text":"Consumer Affairs\n+2"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","text":"South Carolina Legislature"}],[{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","text":"Consumer Affairs"}]],"rows":[["Evidence","Prior / current route result","PASS-02 treatment"],["7.108-1003 ordinary PDF text extraction","PDF exposed only the title, not body text.","Recovered through materially different page-image rendering. All three pages were read. \nConsumer Affairs\n+3"],["7.108-1001 ordinary PDF text extraction","PDF exposed only the title, not body text.","Recovered through page-image rendering. Both pages were read. \nConsumer Affairs\n+2"],["October23 State Register","PASS-01 route was not yet retrievable.","Recovered. 56-page Issue10 read/searchable on October24. \nSouth Carolina Legislature"],["Formal confirmation interpretations have never been superseded","No such primary certification found in focused search.","Still a dependency. Current DCA index publishes them but expressly recommends confirmation before formal reliance. \nConsumer Affairs"]]},{"headers":["Dependency","Why it still matters","Exact next evidence/action"],"index":5,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Dependency","Why it still matters","Exact next evidence/action"],["§109(A) setup fee versus §110(A)/R.28-700(B)(5) sequencing","7.108-1003 did not discuss the specific statutory setup-fee exception.","Locate a later DCA interpretation, order, enforcement decision, judicial decision, or operative regulation specifically addressing when the §109(A) setup fee may be contracted for/requested/received. Do not infer from 1003 alone."],["Formal present-day nonsupersession of 7.108-1001/1003","DCA's current index contains an explicit supersession warning.","A future formal-use review should locate any later numbered interpretations/orders or a current authoritative confirmation. No contact was made in this pass."],["Clerical web intake versus “credit counselor” budget-analysis collection","1001 addressed unlicensed counselors collecting §108(2) information, not every possible passive form or clerical workflow.","Investigate later DCA authority/cases if a proposed operating model relies on unlicensed intake or automated data capture."],["P1-C048 fee mechanics","Neither recovered interpretation touches them.","Separate targeted authority search for remaining-creditor counting, partial months, reinstatement/dishonor sequence, and direct/indirect vendor fees."]]},{"headers":["Assigned item","Status","Claim IDs","Remaining gap"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned item","Status","Claim IDs","Remaining gap"],["Recover full 7.108-1003","Answered","P2-C001–C007","Only later supersession/current-formal-reliance check remains."],["Assignment from compliant licensed provider","Answered","P2-C003","Provider-specific facts later."],["Assignment from unlicensed/noncompliant provider","Answered","P2-C004, C006","Provider-specific facts later."],["Meaning of no consumer fee / outside-source compensation","Answered materially","P2-C005–C006","Every exotic indirect-benefit model not adjudicated."],["Recover related 2010 text, 7.108-1001","Answered","P2-C008","Automated/clerical intake boundary later if operationally relevant."],["Determine whether those interpretations currently appear on DCA site","Answered","P2-C009–C010","Formal nonsupersession certification not established."],["Resolve precise DMP setup-fee sequencing","Still partial/unresolved","P2-C007","Specific authority absent."],["Recover actual October23 Register","Answered","P2-C011","None for retrieval."],["Check October23 issue for relevant DCA/Chapter28/Chapter7 change","Answered: none found","P2-C012–C013","Other legal channels not reopened."],["Resolve P1-C048 miscellaneous fee mechanics","Not answered by assigned evidence","P2-C014","Separate later investigation required."],["Full agreements/funds/bond/remedies/cases/limitations/exemptions/secured/local/tribal/sector investigation","Outside PASS-02 and remains open","—","Later passes."],["Full South Carolina acceptance / A066 acceptance","Not performed","—","Remains open."]]}],"claims":[{"claim_id":"S_SC-P2-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C001","Precise assertion":"7.108-1003 addresses assignment of SC credit-counseling contracts and whether services can begin before education, budget analysis and contract compliance where no consumer fee is charged.","Sources / pinpoint":"S001 p.1. \nConsumer Affairs","Conditions / exceptions / confidence":"High. Directly stated question presented."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C002","Precise assertion":"DCA interprets compensated credit counseling to require the education program, budget analysis and written-contract compliance before covered credit-counseling services are provided.","Sources / pinpoint":"S001 p.2. \nConsumer Affairs","Conditions / exceptions / confidence":"High as DCA's 2010 interpretation. Not characterized as regulation or court holding."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C003","Precise assertion":"A licensed assignee receiving contracts from an assignor that was properly licensed when contracting and remained licensed while servicing need not duplicate the prerequisites, but must ensure they were compliant.","Sources / pinpoint":"S001 pp.2–3. \nConsumer Affairs\n+1","Conditions / exceptions / confidence":"High as agency interpretation. Actual assignor/assignee license facts must satisfy the stated conditions."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C004","Precise assertion":"If the assignor was unlicensed, the licensed assignee must complete education, budget-analysis and written-contract prerequisites before compensated counseling services, subject to the genuinely uncompensated-service boundary.","Sources / pinpoint":"S001 p.3. \nConsumer Affairs","Conditions / exceptions / confidence":"High as agency interpretation."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C005","Precise assertion":"DCA interprets “fee, compensation or gain” as extending beyond money from/on behalf of the consumer and gives fair-share contributions and grant funding as examples of outside-source compensation.","Sources / pinpoint":"S001 p.3. \nConsumer Affairs","Conditions / exceptions / confidence":"High for DCA's interpretation. Does not resolve every conceivable indirect economic benefit."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C006","Precise assertion":"On the facts addressed, precompliance services may be provided only on a genuinely free basis—no money received or expected from any source for those services.","Sources / pinpoint":"S001 p.3. \nConsumer Affairs","Conditions / exceptions / confidence":"High as agency interpretation. More specific than “consumer pays $0.”"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C007","Precise assertion":"7.108-1003 does not specifically resolve the §109(A) setup-fee exception versus R.28-700(B)(5) contract-documentation sequencing question.","Sources / pinpoint":"S001 all pages. \nConsumer Affairs\n+2","Conditions / exceptions / confidence":"High negative-scope conclusion from complete reading. P1-C029 remains partially held."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C008","Precise assertion":"DCA's 7.108-1001 concludes that unlicensed counselors may not collect §37-7-108(2)(a)–(m) budget-analysis information, including financial-account information, until the counselor licensing process has resulted in issuance of a license.","Sources / pinpoint":"S002 p.2. \nConsumer Affairs","Conditions / exceptions / confidence":"High as agency interpretation. Narrowed to persons/functions addressed by the interpretation."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C009","Precise assertion":"DCA currently posts both 2010 interpretations but expressly warns users to verify that they have not been superseded before formal reliance.","Sources / pinpoint":"S003 lines 11–21. \nConsumer Affairs","Conditions / exceptions / confidence":"High. Current posting is not a certification of unchanged legal validity."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C010","Precise assertion":"Focused exact-ID searching found no later rescission/superseding interpretation; both documents remain current-hosted by DCA.","Sources / pinpoint":"S003, S005, S006. \nConsumer Affairs\n+2","Conditions / exceptions / confidence":"Moderate. Absence of a discovered rescission is not proof none exists; DCA's own disclaimer controls confidence."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C011","Precise assertion":"State Register Vol.50 Issue 10 was actually published October 23, 2026.","Sources / pinpoint":"S004 lines 19–24. \nSouth Carolina Legislature","Conditions / exceptions / confidence":"High."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C012","Precise assertion":"The October23 issue contains no DCA item in its TOC and no detected Chapter28, §37-7 or credit-counseling material.","Sources / pinpoint":"S004 TOC and targeted searches. \nSouth Carolina Legislature\n+4","Conditions / exceptions / confidence":"High for this issue. Does not establish absence of changes in other legal channels."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C013","Precise assertion":"Consequently the specific PASS-01 October23-Register currentness hold can be closed without changing the PASS-01 Chapter7/R.28-700 fee conclusions.","Sources / pinpoint":"S004. \nSouth Carolina Legislature\n+1","Conditions / exceptions / confidence":"High and bounded. No broader 2026 legal-currentness claim implied."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_SC-P2-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P2-C014","Precise assertion":"Neither recovered 2010 interpretation resolves installment-settled “remaining creditor” counting, partial-month proration, reinstatement/dishonor mechanics, or independent-vendor fee treatment.","Sources / pinpoint":"S001–S002 complete readings. \nConsumer Affairs\n+4","Conditions / exceptions / confidence":"High negative-scope conclusion. P1-C048 remains held."},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"S_SC-P2-S001","urls":["https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P2-S001","Primary source / issuer":"Administrative Interpretation 7.108-1003 — South Carolina Department of Consumer Affairs","Direct literal URL":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","Exact material read":"All 3 pages, including question presented, statutory reasoning, assignment analysis, outside-source compensation, conclusion, assignment caveat, and reliance paragraph. \nConsumer Affairs\n+2","Status / access / limitation":"Issued 6/29/2010. Agency administrative interpretation, not regulation/court holding/final adjudicatory order. Actual page images read 10/24/2026 after text extraction remained essentially empty. Current DCA index still lists it but warns of possible supersession."},"coordinator_verification_status":"not_yet_checked","alias_source_ids":["S_SC-P2-S005"],"alias_researcher_records":[{"Source ID":"S_SC-P2-S005","Primary source / issuer":"Alternate current DCA-hosted route for 7.108-1003","Direct literal URL":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf","Exact material read":"Search-discovered current hosted copy. \nConsumer Affairs","Status / access / limitation":"Discovery/corroboration only; substantive page reading came from S001."}]},{"source_id":"S_SC-P2-S002","urls":["https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P2-S002","Primary source / issuer":"Administrative Interpretation 7.108-1001 — South Carolina Department of Consumer Affairs","Direct literal URL":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","Exact material read":"Both pages, including presented question and DCA conclusion concerning licensed counselors and budget-analysis information. \nConsumer Affairs\n+1","Status / access / limitation":"Issued 4/15/2010. Same status limitation as S001. Page images actually read 10/24/2026."},"coordinator_verification_status":"not_yet_checked","alias_source_ids":["S_SC-P2-S006"],"alias_researcher_records":[{"Source ID":"S_SC-P2-S006","Primary source / issuer":"Alternate current DCA-hosted route for 7.108-1001","Direct literal URL":"https://consumer.sc.gov/sites/default/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf","Exact material read":"Search-discovered current hosted copy. \nConsumer Affairs","Status / access / limitation":"Discovery/corroboration only; substantive page reading came from S002."}]},{"source_id":"S_SC-P2-S003","urls":["https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven"],"researcher_record":{"Source ID":"S_SC-P2-S003","Primary source / issuer":"Chapter Seven Administrative Interpretations index — South Carolina Department of Consumer Affairs","Direct literal URL":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven","Exact material read":"Lines 9–21: current listing of 1001 and 1003, issue dates, agency summaries, and supersession warning. \nConsumer Affairs","Status / access / limitation":"Current agency webpage checked 10/24/2026. Index proves current posting, not substantive continuing-validity certification."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_SC-P2-S004","urls":["https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1"],"researcher_record":{"Source ID":"S_SC-P2-S004","Primary source / issuer":"South Carolina State Register Vol.50 Issue 10 — Legislative Council","Direct literal URL":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1","Exact material read":"Publication metadata; status explanations; full TOC; targeted complete-document searches for DCA/Chapter28/37-7/counseling. \nSouth Carolina Legislature\n+5","Status / access / limitation":"Published 10/23/2026. Official state publication, but its own disclaimer says printed State Register is the official version. Web PDF actually accessible/read 10/24/2026. No relevant DCA/Chapter7/R.28-700 item found."},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"Recover full 7.108-1003","researcher_record":{"Assigned item":"Recover full 7.108-1003","Status":"Answered","Claim IDs":"P2-C001–C007","Remaining gap":"Only later supersession/current-formal-reliance check remains."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Assignment from compliant licensed provider","researcher_record":{"Assigned item":"Assignment from compliant licensed provider","Status":"Answered","Claim IDs":"P2-C003","Remaining gap":"Provider-specific facts later."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Assignment from unlicensed/noncompliant provider","researcher_record":{"Assigned item":"Assignment from unlicensed/noncompliant provider","Status":"Answered","Claim IDs":"P2-C004, C006","Remaining gap":"Provider-specific facts later."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Meaning of no consumer fee / outside-source compensation","researcher_record":{"Assigned item":"Meaning of no consumer fee / outside-source compensation","Status":"Answered materially","Claim IDs":"P2-C005–C006","Remaining gap":"Every exotic indirect-benefit model not adjudicated."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Recover related 2010 text, 7.108-1001","researcher_record":{"Assigned item":"Recover related 2010 text, 7.108-1001","Status":"Answered","Claim IDs":"P2-C008","Remaining gap":"Automated/clerical intake boundary later if operationally relevant."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Determine whether those interpretations currently appear on DCA site","researcher_record":{"Assigned item":"Determine whether those interpretations currently appear on DCA site","Status":"Answered","Claim IDs":"P2-C009–C010","Remaining gap":"Formal nonsupersession certification not established."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve precise DMP setup-fee sequencing","researcher_record":{"Assigned item":"Resolve precise DMP setup-fee sequencing","Status":"Still partial/unresolved","Claim IDs":"P2-C007","Remaining gap":"Specific authority absent."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Recover actual October23 Register","researcher_record":{"Assigned item":"Recover actual October23 Register","Status":"Answered","Claim IDs":"P2-C011","Remaining gap":"None for retrieval."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Check October23 issue for relevant DCA/Chapter28/Chapter7 change","researcher_record":{"Assigned item":"Check October23 issue for relevant DCA/Chapter28/Chapter7 change","Status":"Answered: none found","Claim IDs":"P2-C012–C013","Remaining gap":"Other legal channels not reopened."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve P1-C048 miscellaneous fee mechanics","researcher_record":{"Assigned item":"Resolve P1-C048 miscellaneous fee mechanics","Status":"Not answered by assigned evidence","Claim IDs":"P2-C014","Remaining gap":"Separate later investigation required."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Full agreements/funds/bond/remedies/cases/limitations/exemptions/secured/local/tribal/sector investigation","researcher_record":{"Assigned item":"Full agreements/funds/bond/remedies/cases/limitations/exemptions/secured/local/tribal/sector investigation","Status":"Outside PASS-02 and remains open","Claim IDs":"—","Remaining gap":"Later passes."},"coordinator_acceptance":"not_yet_reviewed"},{"topic":"Full South Carolina acceptance / A066 acceptance","researcher_record":{"Assigned item":"Full South Carolina acceptance / A066 acceptance","Status":"Not performed","Claim IDs":"—","Remaining gap":"Remains open."},"coordinator_acceptance":"not_yet_reviewed"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}