{"meta":{"key":"s_vt--pass-01","task":"S_VT","title":"SVT Vermont provider market access and consumer fees","parent_title":"Vermont debt and debt relief law","edition":"pass-01","path":"/research/s_vt--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-25","tables":4,"claims":38,"sources":17,"review_status":"revise","review_complete":true,"sha256":"9de72eaaae045c85c298c58c3c005364de18cb0e19d2333bcfce7cb75f14817f","headings":["Bottom-line determination","A1. Definitions and classification","1.1 Controlling definition","1.2 Principal reduction and noncustodial settlement","1.3 DMP and credit-counseling models","1.4 Consumer versus business-purpose debt","1.5 Resident and remote-provider nexus","A2. Prohibition, licensing path, and exemptions","2.1 Conditional market access—not categorical prohibition","2.2 Custodial requirements","2.3 Attorney exception","2.4 Nonprofit exception","2.5 Institutional and professional exceptions","2.6 Original-creditor or self-creditor activity","A3. Consumer fee structures and present limits","3.1 Verified statutory formula","3.2 No verified CPI or administrative adjustment","3.3 No additive menu of fee labels","3.4 Noncustodial debt-settlement fee problem","3.5 Creditor compensation","A4. When fees may be requested or received","4.1 Vermont state trigger","4.2 Three-business-day rescission","4.3 Later cancellation","4.4 Federal TSR overlay","4.5 State and federal rules are cumulative","A5. Regulator permission, application, and public lookup","5.1 Regulator and application route","5.2 State applicant fees, bond, and suitability","5.3 Renewal","5.4 NMLS fee reconciliation","5.5 Public lookup","5.6 Operative regulations","5.7 Historical fee materials","A6. Court-decision boundary","A7. Operational classification for SettleADebt.com","Verified conditional pathway","Not yet established","D1. Worked examples","Example 1 — Custodial DMP over 12 months","Example 2 — Lower payment and timely rescission","Example 3 — One debt settled in a multi-debt custodial program","Example 4 — Fully noncustodial percentage-of-savings model","Example 5 — Prior fees and an additional monthly payment","Example 6 — Cancellation after several months","D2. Component coverage and gap table","Highest-priority next investigations","Material actually read","Discovered but not substantively read","Not performed"],"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_VT/pass-01","facets":{"geography":["us","us-vt"],"debt_type":[],"stage":[],"subject":["fees-outcomes","provider-licensing"]},"scope":"Fresh Vermont provider-access/fees component; all broader state categories remain required","pending_corrections":0},"markdown":"# S_VT PASS-01 — Vermont provider market access and consumer fees\n\n**Registry:** S_VT\n**Component:** Provider market access and consumer fees only\n**Baseline supplied:** October 22, 2026, America/Los_Angeles\n**Actual public-source access date:** October 24, 2026, America/Los_Angeles\n**Actual model/mode:** GPT-5.6 Sol Pro in regular Chat; GPT-6 Pro was not available in this chat, so the authorized quality-first fallback applied. No Deep Research or Work mode was used.\n\n**Scope status:** This does **not** complete the Vermont dossier, approve a provider, establish publication readiness, or imply state-level or A066 acceptance. Agreement terms, handling of funds, bond claims, remedies, collection and litigation issues, limitations, the full exemption universe, secured debt, sector-specific laws, local/tribal issues, broader contract law, and comprehensive case law remain open except where narrowly necessary here.\n\n## Bottom-line determination\n\n| Business model | Vermont classification | Market-access result | Consumer-fee result established in this pass |\n| --- | --- | --- | --- |\n| Custodial debt-management plan or creditor-distribution program | Debt adjustment | Conditionally licensable through the Vermont Department of Financial Regulation; license, bond, fitness findings, and prior approval of the consumer contract are required | Verified statutory ceiling: one $50 initial setup fee plus 10% of payments the licensee receives from the debtor **for distribution to creditors** |\n| Noncustodial debt settlement or principal-reduction negotiation | Debt adjustment even if the provider does not hold or distribute the consumer’s funds | Conditionally licensable; noncustody does not itself avoid Chapter 83 | A percentage-of-enrolled-debt or percentage-of-savings pathway was **not established**. The literal statutory percentage base is money received for creditor distribution. Where that amount is zero, the percentage component is zero; whether DFR would approve any particular noncustodial contract, including even a $50-only model, remains held |\n| Credit counseling with a proposed payment plan, schedule, creditor concessions, or creditor intermediation | Debt adjustment | License required unless a specific exemption applies | Same Chapter 83 ceiling; labels such as “counseling” do not create another fee schedule |\n| General financial education with no proposed payment schedule, creditor negotiation, concession work, or distribution control | Probably outside the core definition, depending on actual conduct | Fact-specific; nonlicensees also face restrictions on using debt-adjuster and debt-reduction terminology in public materials | No Chapter 83 fee conclusion should be assigned without confirming the service stays outside the definition |\n| Attorney, nonprofit, bank, lender, creditor, or affiliate model | Depends on the exact statutory exception and actual activities | No blanket exception based merely on an attorney relationship, nonprofit tax status, or creditor affiliation | Exempt status must be proved before Chapter 83’s licensing and fee provisions are omitted |\n\nVermont’s definition covers both distribution-oriented plans and intermediary services seeking creditor concessions. It separately reaches programs containing a proposed or actual payment schedule used to pay debt. The operative license provision then prohibits engaging in the business without first obtaining a Commissioner-issued license. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\nThe central unresolved issue is therefore **not** whether ordinary noncustodial debt settlement is regulated—it is—but whether Vermont permits that licensee to charge the industry-standard percentage-of-enrolled-debt or percentage-of-savings fee. The currently posted statute supplies no such fee base, and no current rule, DFR interpretation, approved contract, or controlling Vermont appellate decision establishing it was retrieved in this pass. The business should not be marked launchable on standard noncustodial debt-settlement economics from the present evidence alone. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\n# A. Substantive answers\n\n## A1. Definitions and classification\n\n### 1.1 Controlling definition\n\nChapter 83 defines “debt adjustment” by the provider’s conduct, not its marketing name. It includes an agreement under which the provider distributes, supervises, coordinates, negotiates, or controls the distribution of money among one or more creditors in full or partial payment. It also includes acting as an intermediary between the debtor and creditors to obtain concessions. **S_VT-P1-C001.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\nThe definition then adds any program or strategy in which the provider furnishes services that include a proposed or actual payment, or payment schedule, used to pay the debtor’s debt. This second sentence independently reaches many programs that do not fit a traditional “send us one monthly payment” DMP. **S_VT-P1-C002.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\n### 1.2 Principal reduction and noncustodial settlement\n\nA provider that negotiates reductions, settlements, interest concessions, fee waivers, or altered payment terms is facially performing covered debt adjustment even when the consumer pays creditors or a separate account administrator directly. “Negotiates” and “obtaining concessions” do not require the provider to take custody of the money. A proposed settlement-payment schedule supplies an additional coverage route. **S_VT-P1-C003.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\nAccordingly, the following are not reliable exclusions:\n\n- calling the service “debt resolution,” “financial coaching,” or “legal support”;\n- using a third-party dedicated-account company;\n- waiting for the consumer to approve each settlement;\n- having the consumer or account administrator pay the creditor directly;\n- charging only after a settlement under the federal TSR.\n\nThose facts may affect other duties and fee timing, but they do not remove negotiation or concession work from Vermont’s definition.\n\n### 1.3 DMP and credit-counseling models\n\nA conventional DMP is plainly covered when the provider receives payments, coordinates distributions, or administers a creditor-payment schedule. Credit counseling is also covered when it includes creditor intermediation, concessions, or a proposed or actual schedule used to pay debt. **S_VT-P1-C004.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\nPure education or budgeting assistance may fall outside the definition where the provider does **not** negotiate with creditors, obtain concessions, propose or administer a debt-payment schedule, control payment distribution, or otherwise act as an intermediary. That is a bounded inference from the statutory elements, not a DFR safe harbor. In addition, a nonlicensee may not publicly use specified terms such as “debt adjuster,” “debt reduction,” “budget planner,” or “budget planning,” or similar words. **S_VT-P1-C005.** [Vermont Legislature](https://legislature.vermont.gov/statutes/fullchapter/08/083)\n\n### 1.4 Consumer versus business-purpose debt\n\nChapter 83 does not state a general “personal, family, or household purpose” limitation and does not contain an express generic business-debt exemption. Some territorial hooks refer specifically to an “individual” Vermont resident, but the core definition uses the broader terms “debtor,” “creditors,” and “obligations.” **S_VT-P1-C007.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\nTherefore:\n\n- An individual or sole proprietor should not assume that business-purpose debt escapes Vermont regulation.\n- A program serving a corporation or other entity debtor presents a less certain boundary, especially when neither the solicitation nor the provider is in Vermont.\n- The federal TSR’s business-to-business call exemption does not create a Vermont Chapter 83 exemption. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6)\n\nThe entity-debtor boundary requires a later Vermont-specific interpretation and case-law pass.\n\n### 1.5 Resident and remote-provider nexus\n\nVermont expressly treats the following as engaging in debt adjustment “in this State”:\n\n1. soliciting from within Vermont by mail, telephone, electronic means, or other means, even when the debtor is outside Vermont;\n2. soliciting an individual residing in Vermont;\n3. entering into or succeeding to a debt-adjustment contract with an individual residing in Vermont; and\n4. providing, offering, or agreeing to provide debt-adjustment services directly or through others.\n\nThus an out-of-state internet or telephone provider serving a Vermont resident is facially within the statute. The fourth hook is unusually broad; its outer constitutional reach was not adjudicated in this pass. **S_VT-P1-C006.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\n## A2. Prohibition, licensing path, and exemptions\n\n### 2.1 Conditional market access—not categorical prohibition\n\nVermont does not categorically prohibit covered commercial debt adjustment. It creates a conditional licensing path: no person may engage in the business except as authorized by Chapter 83 and without first obtaining a license from the Commissioner. **S_VT-P1-C008.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02752)\n\nA license is not the only condition. The application must disclose the proposed services, marketing, fee amounts or calculation methods, locations serving Vermont residents, other-state licensing history, and the intended consumer contract. Every contract’s terms and conditions are subject to the Commissioner’s prior approval. **S_VT-P1-C009.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02753)\n\nBefore taking any consumer fee, receiving direct or indirect compensation, or accepting any payment from the debtor, the licensee must execute the approved written contract and immediately provide a true copy. The contract must disclose the services, every debtor fee, suitability warning, creditor compensation where applicable, any secured-debt exclusion, and the covered debts and their interest rates. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759)\n\n### 2.2 Custodial requirements\n\nChapter 83 requires each licensee to maintain a separate federally insured bank account for debtor funds received for creditor benefit, provide distribution statements at least quarterly, preserve records for seven years, and remit to creditors at least once every 30 days under the contract. **S_VT-P1-C010.** [Vermont Legislature](https://legislature.vermont.gov/statutes/fullchapter/08/083)\n\nThe application separately asks for the name and address of the federally insured institution maintaining the separate account. The Commissioner may waive application-information requirements in §2753, but that waiver language does not expressly waive §2760’s substantive account provision. Exact DFR treatment of a provider that never touches consumer funds remains unresolved. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02753)\n\n### 2.3 Attorney exception\n\nThe attorney exception applies to an attorney admitted to practice in Vermont **when engaged in that practice**. It does not facially exempt:\n\n- a debt-settlement company merely because it employs or refers consumers to an attorney;\n- an out-of-state attorney not admitted in Vermont;\n- a company owned by an attorney;\n- nonlegal operations performed outside the practice of law.\n\n**S_VT-P1-C011.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02763)\n\n### 2.4 Nonprofit exception\n\nVermont does not exempt every nonprofit or every organization with federal tax-exempt status. The text is limited to a **bona fide nonprofit religious, fraternal, or cooperative organization** offering debt-adjustment services **exclusively for members**. Both the organizational category and members-only service condition matter. **S_VT-P1-C012.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02763)\n\nA generic nonprofit credit counselor, public charity, trade association, or nonprofit affiliate cannot be marked exempt from this wording alone.\n\n### 2.5 Institutional and professional exceptions\n\nOther express exceptions cover:\n\n- a “financial institution” under 8 V.S.A. §11101(32), or a Chapter 73 licensed lender, when debt adjustment is performed in the regular course of its principal business;\n- a person acting under Vermont or federal law or a court order;\n- an employee of a licensee acting in the regular course of employment; and\n- a Vermont-licensed CPA providing the service in the course of CPA practice.\n\n**S_VT-P1-C013.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02763)\n\nThe financial-institution definition cross-references Vermont, state, and national financial institutions. A complete determination for a credit union, cooperative, bank affiliate, fintech partner, or other institution requires following the full definitional chain and the “regular course of principal business” condition. That analysis remains held. **S_VT-P1-C014.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/201/11101)\n\n### 2.6 Original-creditor or self-creditor activity\n\nChapter 83 has no express general exemption for an original creditor adjusting its own debt. Direct bilateral restructuring may fall outside the first sentence’s intermediary feature in some circumstances, but the second sentence’s payment-program language is broader. No blanket self-creditor exclusion should be assigned without DFR authority or controlling case law. **S_VT-P1-C015.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\n## A3. Consumer fee structures and present limits\n\n### 3.1 Verified statutory formula\n\nThe current statutory consumer-fee ceiling is:\n\nMaximum retained fee=$50.00+10%×(payments received from debtor for distribution to creditors)\\text{Maximum retained fee}\n=\n\\$50.00\n+\n10\\% \\times\n\\left(\\text{payments received from debtor for distribution to creditors}\\right)Maximum retained fee=$50.00+10%×(payments received from debtor for distribution to creditors)The fee must be agreed upon in advance. **S_VT-P1-C016.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\nThe $50 component is described as an “initial set up fee,” singular. The statute does not create a separate setup fee for every debt, creditor, settlement, or month.\n\n### 3.2 No verified CPI or administrative adjustment\n\nThe current integrated statute still states exactly **$50.00** and **10 percent**. The section contains no CPI formula, annual indexing clause, or authority for an administrative dollar adjustment, and its history shows its last amendment in 2009. No official adjustment notice changing the consumer amounts was located. **S_VT-P1-C017.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\nThis is distinct from applicant and licensing fees, which have changed separately.\n\n### 3.3 No additive menu of fee labels\n\nSection 2762 caps the **fee retained**. It does not authorize separate additive buckets for:\n\n- monthly maintenance;\n- creditor or account administration;\n- settlement or success fees;\n- a fee for each debt;\n- percentage of enrolled debt;\n- percentage of savings;\n- consultation, legal-network, technology, or document charges; or\n- cancellation.\n\nRelabeling compensation does not avoid the aggregate ceiling, especially because §2759 reaches direct and indirect compensation and requires all fees to be disclosed in the approved contract. **S_VT-P1-C018.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759)\n\nA third-party charge may present separate factual and legal questions, but an affiliated or provider-required charge cannot safely be treated as outside the cap merely because another entity collects it.\n\n### 3.4 Noncustodial debt-settlement fee problem\n\nA fully noncustodial settlement provider may be covered and licensable, yet receive **zero dollars** from the debtor “for the purpose of distribution to creditors.” On the literal formula:\n\n10%×$0=$010\\% \\times \\$0 = \\$010%×$0=$0That leaves the statutory text’s $50 initial setup amount, but it does **not** establish that:\n\n- DFR will approve a $50-only noncustodial contract;\n- the setup fee may be requested before federal TSR conditions;\n- a savings-based fee is permissible;\n- an enrolled-debt fee is permissible; or\n- a separate account administrator’s creditor payments can automatically be attributed to the licensee as its statutory fee base.\n\nNo current rule, written DFR interpretation, approved form, or Vermont appellate holding resolving those questions was retrieved. Percentage-of-savings and percentage-of-enrolled-debt fees therefore remain **held, not approved**. **S_VT-P1-C019.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\n### 3.5 Creditor compensation\n\nThe contract must disclose creditor compensation where applicable, and Chapter 83 expressly allows creditor rebates to licensees notwithstanding its referral-compensation prohibition. The text reviewed does not conclusively state whether every form of creditor-paid compensation counts toward §2762’s debtor-fee ceiling or how it affects a noncustodial model. **S_VT-P1-C020.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759)\n\nThat issue requires current DFR interpretation and approved-contract evidence.\n\n## A4. When fees may be requested or received\n\n### 4.1 Vermont state trigger\n\nVermont’s express state prerequisite is an approved written contract. Before any fee, direct or indirect compensation, or debtor payment is taken, the licensee must execute the written contract in a form previously approved by the Commissioner and furnish a copy to the debtor. **S_VT-P1-C021.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759)\n\nThe Chapter 83 provisions read in this pass do not themselves state that a creditor must first accept a settlement, that a consumer must make a first settlement payment, or that a specified percentage of work must be completed before a fee becomes earned. That is an absence in the retrieved statutory text—not affirmative permission to charge an advance fee. Operative rules were not fully retrievable. **S_VT-P1-C022.** [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/083/02759)\n\n### 4.2 Three-business-day rescission\n\nThe debtor may rescind until midnight of the third business day after signing. The provider must supply the prescribed contract disclosure and detachable cancellation notice and orally explain the right. Until the disclosure obligations are satisfied, the three-business-day period does not begin. **S_VT-P1-C023.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759a)\n\nThe statutory form says payments will be returned within **10 business days after receipt of the cancellation notice**, while the operative restoration subsection says the licensee must tender all debtor payments within **10 days after cancellation**. The text contains a real internal mismatch. No controlling interpretation resolving it was located. For conservative operations, 10 calendar days after cancellation is the safer endpoint, but that is a risk-control choice rather than a judicial construction. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759a)\n\n### 4.3 Later cancellation\n\nA debtor may cancel the contract at any time without a cancellation premium or penalty. The sections reviewed do not fully state the treatment of every fee already earned or unearned after the initial rescission period. No additional cancellation fee may be imposed. **S_VT-P1-C024.** [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759b)\n\n### 4.4 Federal TSR overlay\n\nFor covered telemarketing, the TSR defines “debt relief service” broadly to include services represented as renegotiating, settling, or altering payment or other terms of unsecured debts, including reductions in balance, interest, or fees. **S_VT-P1-C025.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nThe federal rule prohibits requesting or receiving a debt-relief fee until:\n\n1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid agreement;\n2. the customer has made at least one payment under that agreement; and\n3. when debts are resolved individually, the fee is allocated either proportionally according to the enrolled debt amount or by a constant percentage of actual savings.\n\n**S_VT-P1-C026.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe ordinary inbound-response exemptions do not rescue debt-relief advertising calls: calls responding to advertisements or direct mail concerning debt-relief services are expressly carved out of those exemptions. Business-to-business calls have a separate federal exemption, but that does not alter Vermont’s state definition. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6)\n\nA dedicated account can be required under the TSR only if it satisfies the rule’s insured-institution, consumer-ownership, independence, no-referral-payment, and withdrawal/refund conditions. Money placed in such an account is not thereby an earned provider fee. **S_VT-P1-C027.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### 4.5 State and federal rules are cumulative\n\nWhen both laws apply:\n\n- federal law determines the earliest permissible success event for requesting or receiving the fee;\n- Vermont determines the permitted state fee amount and requires an approved contract and state license;\n- compliance with one does not replace the other; and\n- Vermont’s $50/10% ceiling is not advance-fee authorization.\n\nThe practical collectible amount is the lowest amount permitted after applying every applicable rule. **S_VT-P1-C028.**\n\n## A5. Regulator permission, application, and public lookup\n\n### 5.1 Regulator and application route\n\nThe issuing regulator is the Vermont Department of Financial Regulation, acting through the Commissioner. Chapter 72 requires specified applicant and control-person information to be furnished through NMLS. The official DFR Debt Adjuster page is search-indexed as directing all applications through NMLS, although direct retrieval of that DFR page returned HTTP 403 during this pass. **S_VT-P1-C029.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02102)\n\nThe current NMLS checklist compiler is publicly available and instructs applicants to select the relevant license and download its requirements, but its Vermont Debt Adjuster checklist content did not render through the available public reader. The legal licensing path is verified; the exact current operational checklist is not. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx)\n\n### 5.2 State applicant fees, bond, and suitability\n\nThe exact statutory Vermont initial fees are:\n\n- license fee: **$250**;\n- application and investigation fee: **$500**;\n- total state initial fee: **$750**.\n\nThe minimum bond is **$50,000**, with authority for the Commissioner to require a higher amount based on business circumstances, consumer complaints, financial condition, business plan, locations, and anticipated debtor payments and fees. **S_VT-P1-C030.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02102)\n\nThe applicant and relevant control persons must satisfy findings concerning financial responsibility, experience, competence, character, general fitness, honest and fair operation, and the public interest. The debt-adjuster bond requirement is incorporated into the approval criteria. **S_VT-P1-C031.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02103)\n\nFor a complete application, the statute calls for issuance within 60 days if the standards are met, or notice of denial within 60 days if they are not. An application incomplete for 120 days may be deemed abandoned or withdrawn. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/072/02103)\n\n### 5.3 Renewal\n\nThe state renewal fee is **$250**, due through the annual renewal process on or before December 1, with continued satisfaction of licensing standards and maintenance of the required bond. A license originally issued on or after November 1 is valid for the following year as well. **S_VT-P1-C032.** [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02109)\n\n### 5.4 NMLS fee reconciliation\n\nCurrent standard NMLS state-license processing fees are:\n\n- company initial setup: **$120 per agency/license**;\n- company annual processing: **$120 per agency/license**;\n- branch initial and annual processing: **$25**;\n- credit-card payment surcharge: **2.5%**;\n- ACH surcharge: **none**.\n\nPossible professional-standard charges include a $36.25 criminal-background check, a $10 print-card packet, and a $15 credit report, depending on the filing and individuals involved. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html)\n\nThe $120 company fees became effective March 1, 2025 and apply across NMLS industries. [CSBS](https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1)\n\nAccordingly:\n\n- **Expected initial base:** $750 Vermont statutory fees + $120 NMLS company fee = **$870**.\n- **Expected renewal base:** $250 Vermont fee + $120 NMLS company fee = **$370**.\n\nThose are computed base amounts, **not verified current checkout totals**, because the Vermont-specific checklist and transaction screen were not obtained and additional background, credit, branch, card, or other filing charges may apply. **S_VT-P1-C033.**\n\nThe indexed DFR Debt Adjuster page still states a $350 corporate renewal including a $100 NMLS fee and a $20 branch fee. Those NMLS components conflict with the current NMLS schedule and appear stale. The controlling Vermont state renewal component remains $250; the current NMLS schedule supplies $120 and $25. [Department of Financial Regulation+1](https://dfr.vermont.gov/banking/financial-services/debt-adjuster)\n\n### 5.5 Public lookup\n\nThe official DFR “Verify a License” page is search-indexed as directing users to NMLS Consumer Access, but the page itself returned HTTP 403 during direct retrieval. No named provider was searched or declared authorized in this pass. **S_VT-P1-C034.** [Department of Financial Regulation](https://dfr.vermont.gov/consumers/verify-license)\n\nA defensible provider-status verification must use the provider’s exact legal name or NMLS ID and confirm:\n\n- Vermont as the jurisdiction;\n- “Debt Adjuster” as the authority or license type;\n- current status;\n- effective and expiration dates;\n- legal and trade names;\n- branches if relevant; and\n- any public regulatory actions.\n\nA marketing statement, general NMLS registration, or license in another state is not Vermont debt-adjuster authority. A Vermont license also does not by itself prove that a particular fee contract has received the required prior approval.\n\n### 5.6 Operative regulations\n\nThe Vermont Secretary of State’s rules service was read and links to the current Code of Vermont Rules. The linked current CVR interface did not provide readable substantive rule text through the available public route. Searches did not produce a verified current fee-specific debt-adjuster rule or the rule governing contract-duration limits referenced in §2760b(j). **S_VT-P1-C035.** [Vermont Secure+1](https://secure.vermont.gov/SOS/rules/search.php)\n\nThis means:\n\n- the statutory $50/10% ceiling is verified;\n- the absence of an additional operative rule is **not** established;\n- exact contract-duration limits remain held; and\n- no negative conclusion should be drawn merely because the current CVR text was inaccessible.\n\n### 5.7 Historical fee materials\n\nA 2019 DFR alert is indexed as increasing the **application and investigation fee** from $250 to $500 effective July 1, 2019. That historical notice concerns provider licensing costs—not the consumer fee under §2762. **S_VT-P1-C036.** [Department of Financial Regulation](https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees)\n\nLikewise, the 2025 NMLS increase changed platform-processing fees; it did not amend Vermont’s consumer fee ceiling. [CSBS+1](https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1)\n\n## A6. Court-decision boundary\n\n*In re Sinnott*, 2004 VT 16, involved Vermont attorney-discipline rules and a $1,200 fee where the attorney performed no service of value toward the client’s debt-settlement objective. The Vermont Supreme Court approved full restitution because the fee was unreasonable under the professional-conduct rules. [Justia Law+1](https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html)\n\nThat decision does **not** interpret §2762, approve an ordinary licensee’s percentage-of-savings fee, or establish the earning rule for a nonattorney debt adjuster. The discussion of advance or success-based attorney fees appearing in the embedded hearing-panel material is not a Chapter 83 holding. **S_VT-P1-C037.** [Justia Law](https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html)\n\nTargeted searches did not locate a controlling Vermont appellate decision resolving §2762’s application to a fully noncustodial settlement provider. That is a search result and confidence limitation, not a representation that no such authority exists. **S_VT-P1-C038.**\n\n## A7. Operational classification for SettleADebt.com\n\n### Verified conditional pathway\n\nA custodial DMP or similar program has a recognizable Vermont pathway where the provider:\n\n1. obtains the Vermont Debt Adjuster license;\n2. maintains the required bond;\n3. receives prior DFR approval of the consumer contract;\n4. complies with account, distribution, statement, record, cancellation, and advertising requirements;\n5. limits retained consumer fees to the verified formula; and\n6. separately complies with the federal TSR when its telemarketing coverage applies.\n\n### Not yet established\n\nA standard noncustodial settlement model funded by:\n\n- 15–25% of enrolled debt;\n- a fixed percentage of savings;\n- a per-debt success fee;\n- a monthly platform fee; or\n- a separately labeled affiliated fee\n\ndoes **not** have a verified Vermont fee pathway in this pass. Licensing classification is clear; fee legality is not. The needed evidence is a current DFR interpretation, operative rule, approval record or form, administrative decision, or controlling court decision applying §2762 to the noncustodial structure.\n\n# B. Source table\n\n| Source ID | Title / issuer | Direct literal URL(s) | Exact pinpoint, version, and effective status | Actual access and limitations |\n| --- | --- | --- | --- | --- |\n| **S_VT-P1-S001** | Vermont Title 8, Chapter 83, Debt Adjusters — Vermont General Assembly | https://legislature.vermont.gov/statutes/fullchapter/08/083 https://legislature.vermont.gov/statutes/section/08/083/02751 https://legislature.vermont.gov/statutes/section/08/083/02752 https://legislature.vermont.gov/statutes/section/08/083/02753 https://legislature.vermont.gov/statutes/section/08/083/02755 https://legislature.vermont.gov/statutes/section/08/083/02759 https://legislature.vermont.gov/statutes/section/08/083/02759a https://legislature.vermont.gov/statutes/section/08/083/02759b https://legislature.vermont.gov/statutes/section/08/083/02762 https://legislature.vermont.gov/statutes/section/08/083/02763 | §§2751, 2752, 2753, 2755, 2759–2759c, 2760–2760c, 2762–2764. Online compilation says it includes actions of the 2026 session. §2759a last amended effective July 1, 2023; §2760b includes amendments effective May 12, 2021; §2762 history ends in 2009. | Freshly read October 24, 2026. General Assembly warns that its online statutes are an unofficial convenience copy. This source supplies the controlling statutory text used throughout. [Vermont Legislature+4](https://legislature.vermont.gov/statutes/section/08/083/02751) |\n| **S_VT-P1-S002** | Vermont Title 8, Chapter 72, general nonbank licensing — Vermont General Assembly | https://legislature.vermont.gov/statutes/section/08/072/02102 https://legislature.vermont.gov/statutes/section/08/072/02103 https://legislature.vermont.gov/statutes/section/08/072/02109 | §2102(b)(12), (c); §2103(a)–(c); §2109(a)(12), (b). Current §§2103 and 2109 reflect amendments effective July 1, 2026. | Freshly read October 24, 2026. Establishes state applicant fees, NMLS information, suitability, decision period, duration, and renewal. Same unofficial-online-copy limitation. [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/072/02102) |\n| **S_VT-P1-S003** | 8 V.S.A. §11101 definitions — Vermont General Assembly | https://legislature.vermont.gov/statutes/section/08/201/11101 | Subdivisions (18), (32), and related institutional definitions. | Freshly read October 24, 2026. Used only to begin the cross-reference required by §2763(2); the complete bank/credit-union classification chain remains open. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/201/11101) |\n| **S_VT-P1-S004** | Debt Adjuster industry page — Vermont Department of Financial Regulation | https://dfr.vermont.gov/banking/financial-services/debt-adjuster | Indexed material states the application is handled through NMLS and displays initial and renewal information. Indexed renewal still uses a $100 company and $20 branch NMLS fee. | Official page was discovered and search-indexed on October 24, 2026, but direct fetch returned HTTP 403. It is operational discovery, not controlling legal authority and not treated as fully read. Its NMLS amounts conflict with the current NMLS schedule. [Department of Financial Regulation](https://dfr.vermont.gov/banking/financial-services/debt-adjuster) |\n| **S_VT-P1-S005** | Verify a License — Vermont Department of Financial Regulation | https://dfr.vermont.gov/consumers/verify-license | Indexed page directs users to NMLS Consumer Access for relevant license searches. | Official page discovered October 24, 2026; direct fetch returned HTTP 403. No provider record was queried. [Department of Financial Regulation](https://dfr.vermont.gov/consumers/verify-license) |\n| **S_VT-P1-S006** | NMLS Processing Fees — NMLS/CSBS | https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html | State-licensure Table 1: company $120 initial/$120 annual; branch $25/$25. Professional standards Table 4: background and credit-report amounts. Credit-card and ACH provisions at lines 49–60. | Freshly read October 24, 2026. General platform schedule; exact Vermont-specific applicability must be reconciled with the Vermont checklist and transaction. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html) |\n| **S_VT-P1-S007** | Licensing Checklists, Requirements, and Fees — NMLS | https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx | Public checklist compiler instructs applicants to select licenses and download relevant requirements. | Page was reached October 24, 2026, but the Vermont Debt Adjuster checklist did not render in the public reader. Exact current filing checklist remains unresolved. [Nationwide Licensing System+1](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx) |\n| **S_VT-P1-S008** | Reminder—NMLS Processing Fee Increase Takes Effect March 1 — CSBS | https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1 | Published February 20, 2025; increase effective March 1, 2025; first increase since 2008 and applicable to all NMLS industries. | Freshly read October 24, 2026. Used to reconcile stale DFR-indexed platform fees. [CSBS](https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1) |\n| **S_VT-P1-S009** | Adjustment to Fees for Certain Non-Bank Licensees — Vermont DFR | https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees | Indexed historical notice: debt-adjuster application/investigation component increased to $500 effective July 1, 2019. | Official historical page discovered, but direct fetch returned HTTP 403. Used only to distinguish licensing fees from consumer fees. [Department of Financial Regulation](https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees) |\n| **S_VT-P1-S010** | Debt Adjusters — Vermont Attorney General, Consumer Assistance | https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters | Indexed guidance says companies offering debt settlement or adjustment to Vermont consumers must be licensed. | Official page discovered, but direct fetch returned HTTP 403. Guidance is consistent with §2752 but is not substituted for statutory permission. [Vermont Attorney General's Office](https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters) |\n| **S_VT-P1-S011** | Vermont Secretary of State Rules Service and Code of Vermont Rules link | https://secure.vermont.gov/SOS/rules/search.php https://advance.lexis.com/container?config=0147JAAzNTM4MTQxMS04MjI5LTQxN2QtODFjMy1hNWQ1OGExMjc3ZTUKAFBvZENhdGFsb2e0UpKanB5ifXeRwqlwuxNP | SOS page is the proposed-rule search and links to the current CVR. | SOS portal freshly read October 24, 2026. Linked current-rule interface produced no usable substantive debt-adjuster text. No conclusion that no rule exists. [Vermont Secure+1](https://secure.vermont.gov/SOS/rules/search.php) |\n| **S_VT-P1-S012** | Record Retention, Regulation B-2014-01 — Vermont DFR | https://dfr.vermont.gov/reg-bul-ord/record-retention | Indexed as effective July 1, 2014 and applicable to debt adjusters. | Search-indexed official material only; full text was not relied upon for a fee or access conclusion. Chapter 83’s seven-year record requirement was independently read. [Department of Financial Regulation+1](https://dfr.vermont.gov/reg-bul-ord/record-retention) |\n| **S_VT-P1-S013** | Privacy of Consumer Financial and Health Information, Regulation B-2018-01 — Vermont DFR | https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation | Indexed regulation dated February 15, 2018 and including debt adjusters. | Search-indexed official material only; privacy merits are outside this pass. [Department of Financial Regulation](https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation) |\n| **S_VT-P1-S014** | RAM Payment, LLC, DFR Docket 24-015-B — Vermont DFR | https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf | Search-indexed September 12, 2025 enforcement material referring to Vermont debt-adjuster licensing. | Direct PDF route returned HTTP 403; the PDF was not read or used for a substantive claim. It remains a next-pass enforcement source. [Department of Financial Regulation](https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf) |\n| **S_VT-P1-S015** | Telemarketing Sales Rule, 16 C.F.R. §§310.2, 310.4, 310.6 — eCFR | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6 | §310.2(o); §310.4(a)(5); §310.6(b)(5)–(7). eCFR displayed Title 16 as current through October 22, 2026 and last amended October 19, 2026. | Freshly read October 24, 2026. Federal common context only; not a Vermont fee source. eCFR is authoritative but unofficial. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_VT-P1-S016** | Debt Relief Services and the Telemarketing Sales Rule: A Guide for Business — Federal Trade Commission | https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business | FTC staff explanation of debt-relief coverage, fee triggers, allocation, and dedicated accounts. | Read as interpretive guidance; nonbinding and subordinate to S015. [Federal Trade Commission+2](https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business) |\n| **S_VT-P1-S017** | *In re Sinnott*, 2004 VT 16 — Vermont Supreme Court opinion reproduced by Justia | https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html | ¶¶12–13 and 20–21; embedded hearing-panel restitution material. | Opinion text freshly read October 24, 2026 through a nonofficial republisher. Used only to define its narrow attorney-discipline holding and prevent misapplication to §2762. [Justia Law+2](https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html) |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_VT-P1-C001** | Debt adjustment includes distributing, supervising, coordinating, negotiating, or controlling creditor payments and intermediary work obtaining concessions. | S001, §2751 first sentence. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751) | **High—direct statutory text.** Actual conduct controls. |\n| **S_VT-P1-C002** | A program or strategy furnishing services that include a proposed or actual payment or payment schedule used to pay debt is also debt adjustment. | S001, §2751 second sentence. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751) | **High—direct statutory text.** Broader than custody alone. |\n| **S_VT-P1-C003** | Noncustodial settlement and principal-reduction negotiation are covered when the provider negotiates or acts as an intermediary for concessions. | S001, §2751. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751) | **High** for ordinary settlement facts; edge cases depend on actual service. |\n| **S_VT-P1-C004** | DMP or credit-counseling activity is covered when it includes payment administration, a proposed schedule, creditor intermediation, or concessions. | S001, §§2751, 2759c, 2760–2760a. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751) | **High** for plans with those elements. Counseling label alone is not dispositive. |\n| **S_VT-P1-C005** | Pure education may be outside Chapter 83 if it contains none of the statutory elements, but nonlicensees cannot use specified debt-adjuster/debt-reduction terms publicly. | S001, §§2751, 2760b(c). [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751) | **Moderate—inference** as to education boundary; reserved-term restriction is direct. |\n| **S_VT-P1-C006** | Vermont reaches in-state solicitation, solicitation or contracting with Vermont-resident individuals, and provision or offers directly or through others. | S001, §2751(1)–(4). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751) | **High—direct text.** Outer constitutional reach not analyzed. |\n| **S_VT-P1-C007** | Chapter 83 has no express generic business-purpose-debt exclusion; entity-debtor boundaries remain uncertain. | S001, §2751. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02751) | **Moderate.** Textual negative verified; full case-law/legislative-history treatment open. |\n| **S_VT-P1-C008** | A covered nonexempt person must obtain a Commissioner-issued license before engaging in debt adjustment. | S001, §2752. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02752) | **High—direct statutory command.** |\n| **S_VT-P1-C009** | Market access is conditional on application disclosures and prior Commissioner approval of all consumer-contract terms. | S001, §2753(a)(1)–(8). [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02753) | **High.** Approval is contract-specific; license alone is not fee-form approval. |\n| **S_VT-P1-C010** | Custodial operations require a separate insured account, quarterly statements, records, and creditor remittance at least every 30 days. | S001, §§2759c, 2760, 2760a. [Vermont Legislature](https://legislature.vermont.gov/statutes/fullchapter/08/083) | **High.** Exact treatment of a zero-custody licensee remains open. |\n| **S_VT-P1-C011** | Attorney exception is limited to a Vermont-admitted attorney when engaged in law practice. | S001, §2763(1). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02763) | **High.** Mere ownership, employment, referral, or attorney affiliation is insufficient on the text. |\n| **S_VT-P1-C012** | Nonprofit exception is limited to bona fide nonprofit religious, fraternal, or cooperative organizations serving members exclusively. | S001, §2763(4). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02763) | **High.** Generic nonprofit or §501(c)(3) status is not the statutory test. |\n| **S_VT-P1-C013** | Express exemptions also cover qualifying financial institutions/Chapter 73 lenders, law or court-order actors, licensee employees, and Vermont CPAs. | S001, §2763(2), (3), (5), (6). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02763) | **High** as to listed text; activity conditions must be met. |\n| **S_VT-P1-C014** | A credit union, cooperative, affiliate, or fintech cannot be treated as exempt without completing §11101’s institutional chain and principal-business analysis. | S001 §2763(2); S003 §11101. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/201/11101) | **Held.** Full institutional analysis is outside this component. |\n| **S_VT-P1-C015** | No general self-creditor/original-creditor exception appears in §2763. | S001, §§2751, 2763. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02751) | **Held** for direct creditor restructuring because the definition’s application may depend on facts and interpretation. |\n| **S_VT-P1-C016** | Consumer fee retained may not exceed one $50 initial setup fee plus 10% of payments received from the debtor for creditor distribution. | S001, §2762. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02762) | **High—direct current text.** |\n| **S_VT-P1-C017** | The verified current amounts are $50 and 10%; §2762 contains no index or adjustment mechanism. | S001, §2762 and history. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02762) | **High** for statutory text; no official contrary adjustment notice located. |\n| **S_VT-P1-C018** | Setup, monthly, per-debt, settlement, savings, or other labels do not create additive amounts above the retained-fee ceiling. | S001, §§2759(a)–(b), 2762. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759) | **High as an aggregate-cap reading.** Third-party independence requires factual review. |\n| **S_VT-P1-C019** | For a provider receiving no money for creditor distribution, the statutory percentage base is facially zero; a savings/enrolled-debt fee pathway was not established. | S001, §§2753(a)(4), 2762. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02753) | **Moderate textual inference / material hold.** Needs DFR or controlling adjudicative authority. |\n| **S_VT-P1-C020** | Creditor rebates are allowed and creditor compensation must be disclosed where applicable, but their treatment under the consumer cap is unresolved. | S001, §§2759(b)(4), 2760b(k). [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759) | **High** for permission/disclosure; **held** for cap interaction. |\n| **S_VT-P1-C021** | Approved written contract must precede any fee, direct/indirect compensation, or debtor payment. | S001, §2759(a). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759) | **High—direct text.** |\n| **S_VT-P1-C022** | Retrieved Vermont statutory text has no express settlement-success or first-payment earning trigger. | S001, §§2759, 2762; S011. [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/083/02759) | **Moderate.** Operative rules were inaccessible; absence is not state advance-fee authorization. |\n| **S_VT-P1-C023** | Three-business-day rescission applies; disclosure noncompliance postpones commencement; all payments must be restored, with a 10-business-day/10-day text mismatch. | S001, §2759a(a)–(c). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759a) | **High** for the text; exact reconciliation unresolved. |\n| **S_VT-P1-C024** | Consumer may cancel at any time with no cancellation premium or penalty. | S001, §2759b. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02759b) | **High.** Post-rescission earned-fee refund detail remains open. |\n| **S_VT-P1-C025** | Federal TSR “debt relief service” includes represented renegotiation, settlement, or alteration of unsecured debt terms. | S015, 16 C.F.R. §310.2(o). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) | **High federal text.** TSR coverage must be established separately for each channel/model. |\n| **S_VT-P1-C026** | Covered TSR fees require one resolved debt, a valid agreement, and one consumer payment; individual-debt fees must use proportional or constant-savings allocation. | S015, §310.4(a)(5)(i). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High federal text.** Does not replace Vermont’s lower amount cap. |\n| **S_VT-P1-C027** | TSR-compliant dedicated accounts require insured custody, consumer ownership, independence, no referral consideration, and prompt withdrawal rights. | S015, §310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High.** Account deposits are not automatically earned fees. |\n| **S_VT-P1-C028** | When both apply, Vermont amount/contract restrictions and federal earning timing are cumulative. | S001 §§2759, 2762; S015 §310.4(a)(5). [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/083/02759) | **High general application principle;** exact TSR coverage remains fact-specific. |\n| **S_VT-P1-C029** | DFR is the regulator; the statutory application system uses NMLS, and DFR’s indexed operational page directs applications there. | S002 §2102(c); S004. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02102) | **High** for statutory NMLS data submission; DFR page itself was not fully retrievable. |\n| **S_VT-P1-C030** | Exact state initial fees are $750 and minimum bond is $50,000, subject to increase. | S002 §2102(b)(12); S001 §2755. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02102) | **High—current statutory amounts.** |\n| **S_VT-P1-C031** | Approval requires financial responsibility, experience, competence, character, fitness, public-interest findings, and the bond; complete applications receive issuance or denial action within 60 days. | S002 §2103(a)–(c). [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/072/02103) | **High.** A complete filing is prerequisite to the clock. |\n| **S_VT-P1-C032** | State annual renewal is $250, due by December 1, with continuing standards and bond. | S002 §2109(a)(12). [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/072/02109) | **High; current amendment effective July 1, 2026.** |\n| **S_VT-P1-C033** | Current standard NMLS company fee is $120 initial and annual; expected base totals are $870 initial and $370 renewal, but exact all-in Vermont totals remain unverified. | S006; S008; S002. [Nationwide Licensing System+3](https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html) | **High** for components; **computed/conditional** for totals because the VT checklist was unavailable. |\n| **S_VT-P1-C034** | DFR points users to NMLS Consumer Access, but no named provider’s Vermont Debt Adjuster status was checked. | S005. [Department of Financial Regulation](https://dfr.vermont.gov/consumers/verify-license) | **Procedure partially verified; provider authorization unresolved.** |\n| **S_VT-P1-C035** | No current operative fee or contract-duration rule was verified because the current CVR text was inaccessible. | S011; S001 §2760b(j). [Vermont Secure+1](https://secure.vermont.gov/SOS/rules/search.php) | **Evidence gap, not a negative legal finding.** |\n| **S_VT-P1-C036** | The 2019 DFR change concerns the applicant investigation fee, and the 2025 NMLS change concerns platform fees; neither alters §2762’s consumer ceiling. | S009; S008; S001 §2762. [Department of Financial Regulation+2](https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees) | **High** as reconciliation; S009 full page was inaccessible. |\n| **S_VT-P1-C037** | *Sinnott* is an attorney professional-conduct decision, not authority approving a Chapter 83 savings fee. | S017, ¶¶12–13, 20–21. [Justia Law+1](https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html) | **High** regarding the opinion’s holding; nonofficial reproduction used. |\n| **S_VT-P1-C038** | Current statutory text includes 2026-session actions, but no controlling Vermont appellate interpretation of §2762’s noncustodial application was located in targeted searches. | S001 currentness notice; S017 boundary. [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/083/02751) | **Moderate overall confidence.** Search negatives are not proof of absence; rules and agency interpretations remain gaps. |\n\n# D. Worked examples and component coverage\n\n## D1. Worked examples\n\nAll amounts are rounded to the nearest cent for presentation. No Vermont-specific rounding rule was verified.\n\n### Example 1 — Custodial DMP over 12 months\n\n**Inputs**\n\n- Initial setup fee: $50.00\n- Monthly payment received for distribution: $400.00\n- Number of payments: 12\n- Statutory percentage: 10%\n\n**Base**\n\n- Cumulative creditor-distribution payment base:$400.00 × 12 = **$4,800.00**\n\n**Operator**\n\n- 10% × $4,800.00\n\n**Intermediate result**\n\n- Percentage component: **$480.00**\n\n**Final state ceiling**\n\n- $50.00 + $480.00 = **$530.00**\n\n**Creditor funds under the assumed withholding method**\n\n- $4,800.00 − $480.00 = **$4,320.00**\n\nThis assumes the $400 payments are the gross payments received for creditor distribution and the contract permits the statutory fee to be retained from them. The provider still needs the license, bond, approved written contract, separate account, statements, and timely remittance. Federal TSR timing may independently prevent taking the $50 or percentage component at contract signing. [Vermont Legislature+3](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\n### Example 2 — Lower payment and timely rescission\n\n**Inputs**\n\n- Setup amount hypothetically paid: $50.00\n- One debtor payment for creditor distribution: $120.00\n- Cancellation during the three-business-day rescission period\n\n**Fee calculation before cancellation**\n\n- Percentage base: $120.00\n- 10% × $120.00 = **$12.00**\n- Numerical state ceiling: $50.00 + $12.00 = **$62.00**\n\n**Restoration calculation**\n\nIf the debtor had paid both the $50.00 and $120.00:\n\n- $50.00 + $120.00 = **$170.00 to be returned**\n\nThe statutory form says 10 business days after receipt of notice; the operative provision says 10 days after cancellation. Conservative execution would return the full $170.00 within 10 calendar days. If the TSR applies, the provider likely would not yet have satisfied the federal fee-earning conditions in this example. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759a)\n\n### Example 3 — One debt settled in a multi-debt custodial program\n\n**Inputs**\n\n- Total enrolled debt: $5,000.00\n- Debt A: $1,000.00\n- Total contractual fee for federal-allocation illustration: $1,000.00\n- Debt A is settled and the consumer makes the first required creditor payment\n- Provider receives $600.00 for creditor distribution at that stage\n- No previous percentage fee retained\n\n**Federal proportional allocation**\n\n- Debt A share: $1,000 ÷ $5,000 = **20%**\n- 20% × $1,000 total contractual fee = **$200.00 federal allocation ceiling**\n\n**Vermont amount ceiling**\n\n- 10% × $600.00 = **$60.00**\n- Plus one setup fee: $50.00\n- Cumulative Vermont ceiling at that point: **$110.00**\n\n**Result**\n\n- Federal allocation permits no more than $200.00 on these assumptions.\n- Vermont permits no more than $110.00.\n- **Collectible maximum under both: $110.00**, assuming all other conditions are satisfied.\n\nThe federal formula determines how much of the contractual fee has matured; it does not override Vermont’s lower state amount ceiling. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\n### Example 4 — Fully noncustodial percentage-of-savings model\n\n**Inputs**\n\n- Enrolled debt: $20,000.00\n- Settlement payments to creditors: $10,000.00\n- Claimed savings: $10,000.00\n- Money received by the provider for creditor distribution: $0.00\n- Proposed savings fee: 25%\n- Proposed enrolled-debt fee: 20%\n\n**Proposed industry formulas**\n\n- 25% × $10,000.00 savings = **$2,500.00**\n- 20% × $20,000.00 enrolled debt = **$4,000.00**\n\n**Vermont statutory percentage base**\n\n- 10% × $0.00 received for creditor distribution = **$0.00**\n\n**Result**\n\nThe presently verified statutory formula does not establish either the $2,500.00 or $4,000.00 charge. The only numerical amount visible apart from the zero percentage component is the $50.00 initial setup amount, but DFR approval and federal timing for even that structure have not been established.\n\n**Classification:** Covered/licensable service; **fee pathway held**. [Vermont Legislature+2](https://legislature.vermont.gov/statutes/section/08/083/02751)\n\n### Example 5 — Prior fees and an additional monthly payment\n\n**Inputs**\n\n- Prior cumulative payments for creditor distribution: $3,000.00\n- Prior maximum percentage component: 10% × $3,000.00 = $300.00\n- Setup fee: $50.00\n- Prior cumulative state ceiling: $350.00\n- Amount actually retained to date: $330.00\n- New payment received for creditor distribution: $400.00\n\n**New-payment calculation**\n\n- 10% × $400.00 = **$40.00**\n\n**Updated cumulative ceiling**\n\n- $50.00 + 10% × ($3,000.00 + $400.00)\n- $50.00 + $340.00 = **$390.00**\n\n**Result**\n\n- Maximum additional fee clearly supported by the new payment: **$40.00**\n- Updated total retained: $330.00 + $40.00 = **$370.00**\n- Remaining difference to the cumulative mathematical ceiling: **$20.00**\n\nNo verified Vermont authority permits using the new $400 payment to collect $60—$40 for the current payment plus $20 of previously unused capacity. Because §2762 ties the percentage to “any payment” received, the safer reading is not to exceed 10% of the current payment absent DFR authority. The catch-up issue remains held. [Vermont Legislature](https://legislature.vermont.gov/statutes/section/08/083/02762)\n\n### Example 6 — Cancellation after several months\n\n**Inputs**\n\n- Four monthly creditor-distribution payments of $400.00\n- Cumulative distribution base: $1,600.00\n- Setup fee retained: $50.00\n- Percentage fees retained: 10% × $1,600.00 = $160.00\n- Total retained: $210.00\n- Consumer then cancels\n\n**Result**\n\n- Cancellation premium or penalty: **$0.00**\n- No additional termination fee may be added.\n- Whether some or all of the already retained $210.00 must be returned after the initial three-business-day rescission period is not fully specified in §§2759a–2759b and was not resolved by a retrieved rule or interpretation.\n- If a TSR-compliant dedicated account contains unearned consumer funds, the federal rule requires return of the applicable account balance within seven business days of withdrawal, apart from fees properly earned under the TSR. [Vermont Legislature+1](https://legislature.vermont.gov/statutes/section/08/083/02759b)\n\n## D2. Component coverage and gap table\n\n| Topic | Status in PASS-01 | Supporting claims | Missing evidence / exact next action |\n| --- | --- | --- | --- |\n| Core “debt adjustment” definition | **Answered** | C001–C002 | No immediate gap for ordinary covered conduct. |\n| Noncustodial settlement/principal reduction classification | **Answered** | C003 | Later fact-pattern testing for lead generators, attorney hybrids, software-only models, and consumer self-service tools. |\n| DMP and credit-counseling classification | **Answered with boundary** | C004–C005 | Obtain DFR interpretation for education-only and nonprofit counseling edge cases. |\n| Resident and remote-provider nexus | **Answered; outer limit open** | C006 | Later constitutional nexus and entity-debtor case-law review. |\n| Consumer versus business-purpose debt | **Partial** | C007 | Search DFR orders, legislative history, and Vermont cases addressing entity debtors and sole-proprietor business debt. |\n| Basic licensing requirement | **Answered** | C008–C010 | Exact current application checklist still required. |\n| Attorney exemption | **Answered textually** | C011 | Later unauthorized-practice and attorney-affiliate pass; determine treatment of out-of-state counsel and nonlegal staff. |\n| Nonprofit exemption | **Answered textually** | C012 | Later organization-by-organization analysis of religious, fraternal, and cooperative status and members-only operation. |\n| Financial institution/lender/CPA/employee exceptions | **Partial** | C013–C014 | Complete §11101 and Chapter 73 cross-reference chain; confirm credit-union and affiliate treatment. |\n| Original-creditor/self-creditor model | **Unresolved** | C015 | Retrieve DFR interpretations and Vermont cases applying both sentences of §2751 to a creditor adjusting its own account. |\n| Custodial consumer-fee formula | **Answered** | C016–C018 | Confirm whether any current rule adds a lower limit or special calculation instruction. |\n| Current fee indexing/adjustment | **Answered at statutory level** | C017, C036 | Retrieve full current CVR and any DFR bulletin database to exclude additional overlays conclusively. |\n| Monthly, per-debt, savings, settlement, and affiliate fees | **Answered as no separate statutory buckets; fact-specific third-party issue remains** | C018 | Review affiliation, mandatory-service, indirect-compensation, and contract-approval evidence. |\n| Fully noncustodial fee model | **Materially unresolved** | C019–C020 | Obtain a current DFR interpretation, approved contract form, administrative order, or controlling decision addressing §2762 when the licensee never receives creditor-distribution funds. |\n| Creditor rebates and creditor-paid compensation | **Partial** | C020 | Determine whether and how DFR treats creditor compensation under §2762 and contract approval. |\n| State contract-before-fee trigger | **Answered** | C021–C022 | Full current rules still needed before concluding there is no additional state performance trigger. |\n| Initial rescission and payment restoration | **Answered with textual conflict** | C023 | Locate DFR interpretation or judicial construction reconciling “10 business days” with “10 days.” |\n| Later cancellation and fee refund | **Partial** | C024 | Retrieve current approved contract requirements, rules, and decisions defining earned/unearned fees after the rescission window. |\n| Federal TSR timing and allocation | **Answered as common context** | C025–C028 | Each acquisition channel and entity model requires its own federal coverage analysis. |\n| State initial fees and bond | **Answered** | C030 | Full bond form, surety, rider, claims, cancellation, and increase procedure belongs in later bond pass. |\n| Fitness and 60-day application decision | **Answered** | C031 | Current checklist needed to determine when Vermont considers the application complete. |\n| Renewal fee and deadline | **Answered** | C032–C033 | Confirm current NMLS renewal window and exact all-in transaction amount from the Vermont checklist. |\n| NMLS current processing fees | **Answered generally; Vermont checkout held** | C033 | Download current Vermont Debt Adjuster company and branch checklists; inspect the live fee chart without filing. |\n| Public provider lookup procedure | **Partial** | C034 | Search exact legal name/NMLS ID for any later named provider and record jurisdiction, authority, status, dates, branches, and actions. |\n| Named provider authorization | **Not investigated** | C034 | No provider name was supplied or searched; do not infer authorization. |\n| Full operative regulations | **Unresolved** | C035 | Retrieve the current CVR title/rule text, adoption orders, amendments, effective dates, and any DFR debt-adjuster bulletins. Particular priority: contract-duration limits referenced by §2760b(j). |\n| Enforcement interpretations | **Unresolved** | C035, C038 | Obtain and read the RAM Payment order and other DFR orders; classify holdings versus allegations and consent terms. |\n| Controlling case law on §2762 | **Unresolved after targeted search** | C037–C038 | Search official Vermont Judiciary databases, Westlaw/Lexis or other authorized reporter access, and administrative appeals for §§2751–2764. |\n| *Sinnott* attorney-fee relevance | **Answered narrowly** | C037 | Do not use as ordinary licensee fee authority. |\n| Agreement and disclosures beyond fee prerequisites | **Excluded/later pass** | C009, C021 only as needed | Full approved-form, e-signature, language, suitability, secured-debt, amendment, duration, and contract-enforcement analysis. |\n| Funds, account administration, statements, and remittance | **Partial only as needed** | C010, C027 | Full custodial/noncustodial funds pass, including account ownership, payment authorization, reconciliation, insolvency, and third-party administrator treatment. |\n| Bond claims and remedies | **Excluded/later pass** | C030 only as market-access prerequisite | Analyze bond beneficiaries, claim procedures, restitution, private action, Consumer Protection Act, penalties, and regulator powers. |\n| Collection, litigation, and limitations periods | **Open** | None | Separate collection/litigation/limitations investigation. |\n| Full exemption universe | **Open beyond listed Chapter 83 exceptions** | C011–C015 | Check sector laws, federal preemption, governmental programs, bankruptcy actors, court-supervised programs, and entity-specific provisions. |\n| Secured debts | **Open** | Contract disclosure only | Analyze mortgage, auto, tax, medical liens, and other secured obligations in later pass. |\n| Sector, local, tribal, and contract-law overlays | **Open** | None | Separate passes required. |\n| Full Vermont dossier / A066 acceptance | **Not satisfied** | All | Complete all remaining components and coordinator reconciliation before any acceptance decision. |\n\n### Highest-priority next investigations\n\n1. **Retrieve the current NMLS Vermont Debt Adjuster company and branch checklists** and verify every state and platform fee, bond form, financial-statement requirement, control-person requirement, branch rule, and filing artifact.\n2. **Retrieve the operative Code of Vermont Rules text and adoption history**, especially any rule governing contract duration, fee treatment, trust accounts, noncustodial programs, refund calculations, and third-party administrators.\n3. **Locate DFR-approved contract evidence or interpretive authority for noncustodial settlement.** The decisive question is whether Vermont has approved a fee base other than payments the licensee receives for creditor distribution.\n4. **Read current DFR enforcement orders**, including the inaccessible RAM Payment PDF, and distinguish allegations, consent provisions, interpretations, and generally applicable holdings.\n5. **Run the official case-law and administrative-appeal search** for §§2751, 2752, 2759, 2760, 2762, and 2763, including unpublished or docket-level dispositions where publicly accessible.\n6. **Perform named-provider verification only when an exact legal name or NMLS ID is supplied.** A search must identify the Vermont Debt Adjuster authority itself, not merely an NMLS account or another state’s license.\n\n# E. Researcher self-check\n\n## Material actually read\n\nThe research directly read:\n\n- the current Vermont General Assembly text of Chapter 83’s definition, licensing requirement, application contents, bond, contract requirements, rescission, cancellation, statements, accounts, remittance, prohibited conduct, fee cap, exemptions, and private-action provision;\n- the current Chapter 72 application-fee, applicant-information, suitability, 60-day decision, license-duration, and renewal provisions;\n- the §11101 financial-institution cross-reference;\n- current NMLS processing-fee tables;\n- the CSBS notice establishing the March 1, 2025 NMLS fee increase;\n- the Vermont Secretary of State rule-search page and its current-CVR route;\n- current eCFR text for the federal TSR definition, fee trigger, allocation, dedicated account, and relevant call exemptions; and\n- the reproduced *In re Sinnott* opinion text.\n\n## Discovered but not substantively read\n\nThe following official routes were discovered but were not treated as fully read primary evidence:\n\n- Vermont DFR Debt Adjuster page — HTTP 403;\n- Vermont DFR Verify a License page — HTTP 403;\n- Vermont DFR 2019 fee-adjustment alert — HTTP 403;\n- Vermont Attorney General Debt Adjusters page — HTTP 403;\n- RAM Payment DFR order PDF — HTTP 403;\n- substantive current CVR debt-adjuster rule text — current interface did not render;\n- the Vermont-specific NMLS Debt Adjuster checklist — checklist content did not render through the public reader.\n\nSearch-indexed text from those routes was used only for discovery, procedural corroboration, or identification of stale figures—not as a substitute for statutory legal permission.\n\n## Not performed\n\nNo application was filed. No regulator, provider, surety, consumer, attorney, creditor, or third-party administrator was contacted. No account or permission was changed. No CAPTCHA or access restriction was bypassed. No named provider was checked. No private borrower data was used. No local file was created or claimed. No website was altered or published.\n\nThis was not an independent legal review, a regulator opinion, a legal memorandum for reliance, or a complete Vermont state acceptance review. The most consequential remaining hold is the lawful fee structure for a licensed, fully noncustodial debt-settlement provider.\n\n**END S_VT PASS-01.**\n\n","tables":[{"headers":["Business model","Vermont classification","Market-access result","Consumer-fee result established in this pass"],"index":0,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Business model","Vermont classification","Market-access result","Consumer-fee result established in this pass"],["Custodial debt-management plan or creditor-distribution program","Debt adjustment","Conditionally licensable through the Vermont Department of Financial Regulation; license, bond, fitness findings, and prior approval of the consumer contract are required","Verified statutory ceiling: one $50 initial setup fee plus 10% of payments the licensee receives from the debtor for distribution to creditors"],["Noncustodial debt settlement or principal-reduction negotiation","Debt adjustment even if the provider does not hold or distribute the consumer’s funds","Conditionally licensable; noncustody does not itself avoid Chapter 83","A percentage-of-enrolled-debt or percentage-of-savings pathway was not established. The literal statutory percentage base is money received for creditor distribution. Where that amount is zero, the percentage component is zero; whether DFR would approve any particular noncustodial contract, including even a $50-only model, remains held"],["Credit counseling with a proposed payment plan, schedule, creditor concessions, or creditor intermediation","Debt adjustment","License required unless a specific exemption applies","Same Chapter 83 ceiling; labels such as “counseling” do not create another fee schedule"],["General financial education with no proposed payment schedule, creditor negotiation, concession work, or distribution control","Probably outside the core definition, depending on actual conduct","Fact-specific; nonlicensees also face restrictions on using debt-adjuster and debt-reduction terminology in public materials","No Chapter 83 fee conclusion should be assigned without confirming the service stays outside the definition"],["Attorney, nonprofit, bank, lender, creditor, or affiliate model","Depends on the exact statutory exception and actual activities","No blanket exception based merely on an attorney relationship, nonprofit tax status, or creditor affiliation","Exempt status must be proved before Chapter 83’s licensing and fee provisions are omitted"]]},{"headers":["Source ID","Title / issuer","Direct literal URL(s)","Exact pinpoint, version, and effective status","Actual access and limitations"],"index":1,"links":[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+4"},{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+2"},{"href":"https://legislature.vermont.gov/statutes/section/08/201/11101","text":"Vermont Legislature\n+1"},{"href":"https://dfr.vermont.gov/banking/financial-services/debt-adjuster","text":"Department of Financial Regulation"},{"href":"https://dfr.vermont.gov/consumers/verify-license","text":"Department of Financial Regulation"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","text":"Nationwide Licensing System\n+1"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System\n+1"},{"href":"https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1","text":"CSBS"},{"href":"https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","text":"Department of Financial Regulation"},{"href":"https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters","text":"Vermont Attorney General's Office"},{"href":"https://secure.vermont.gov/SOS/rules/search.php","text":"Vermont Secure\n+1"},{"href":"https://dfr.vermont.gov/reg-bul-ord/record-retention","text":"Department of Financial Regulation\n+1"},{"href":"https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation","text":"Department of Financial Regulation"},{"href":"https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf","text":"Department of Financial Regulation"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"},{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"},{"href":"https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","text":"Justia Law\n+2"}],"row_links":[[],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+4"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+2"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/201/11101","text":"Vermont Legislature\n+1"}],[{"href":"https://dfr.vermont.gov/banking/financial-services/debt-adjuster","text":"Department of Financial Regulation"}],[{"href":"https://dfr.vermont.gov/consumers/verify-license","text":"Department of Financial Regulation"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","text":"Nationwide Licensing System\n+1"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","text":"Nationwide Licensing System\n+1"}],[{"href":"https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1","text":"CSBS"}],[{"href":"https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","text":"Department of Financial Regulation"}],[{"href":"https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters","text":"Vermont Attorney General's Office"}],[{"href":"https://secure.vermont.gov/SOS/rules/search.php","text":"Vermont Secure\n+1"}],[{"href":"https://dfr.vermont.gov/reg-bul-ord/record-retention","text":"Department of Financial Regulation\n+1"}],[{"href":"https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation","text":"Department of Financial Regulation"}],[{"href":"https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf","text":"Department of Financial Regulation"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR\n+2"}],[{"href":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","text":"Federal Trade Commission\n+2"}],[{"href":"https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","text":"Justia Law\n+2"}]],"rows":[["Source ID","Title / issuer","Direct literal URL(s)","Exact pinpoint, version, and effective status","Actual access and limitations"],["S_VT-P1-S001","Vermont Title 8, Chapter 83, Debt Adjusters — Vermont General Assembly","https://legislature.vermont.gov/statutes/fullchapter/08/083\nhttps://legislature.vermont.gov/statutes/section/08/083/02751\nhttps://legislature.vermont.gov/statutes/section/08/083/02752\nhttps://legislature.vermont.gov/statutes/section/08/083/02753\nhttps://legislature.vermont.gov/statutes/section/08/083/02755\nhttps://legislature.vermont.gov/statutes/section/08/083/02759\nhttps://legislature.vermont.gov/statutes/section/08/083/02759a\nhttps://legislature.vermont.gov/statutes/section/08/083/02759b\nhttps://legislature.vermont.gov/statutes/section/08/083/02762\nhttps://legislature.vermont.gov/statutes/section/08/083/02763","§§2751, 2752, 2753, 2755, 2759–2759c, 2760–2760c, 2762–2764. Online compilation says it includes actions of the 2026 session. §2759a last amended effective July 1, 2023; §2760b includes amendments effective May 12, 2021; §2762 history ends in 2009.","Freshly read October 24, 2026. General Assembly warns that its online statutes are an unofficial convenience copy. This source supplies the controlling statutory text used throughout. \nVermont Legislature\n+4"],["S_VT-P1-S002","Vermont Title 8, Chapter 72, general nonbank licensing — Vermont General Assembly","https://legislature.vermont.gov/statutes/section/08/072/02102\nhttps://legislature.vermont.gov/statutes/section/08/072/02103\nhttps://legislature.vermont.gov/statutes/section/08/072/02109","§2102(b)(12), (c); §2103(a)–(c); §2109(a)(12), (b). Current §§2103 and 2109 reflect amendments effective July 1, 2026.","Freshly read October 24, 2026. Establishes state applicant fees, NMLS information, suitability, decision period, duration, and renewal. Same unofficial-online-copy limitation. \nVermont Legislature\n+2"],["S_VT-P1-S003","8 V.S.A. §11101 definitions — Vermont General Assembly","https://legislature.vermont.gov/statutes/section/08/201/11101","Subdivisions (18), (32), and related institutional definitions.","Freshly read October 24, 2026. Used only to begin the cross-reference required by §2763(2); the complete bank/credit-union classification chain remains open. \nVermont Legislature\n+1"],["S_VT-P1-S004","Debt Adjuster industry page — Vermont Department of Financial Regulation","https://dfr.vermont.gov/banking/financial-services/debt-adjuster","Indexed material states the application is handled through NMLS and displays initial and renewal information. Indexed renewal still uses a $100 company and $20 branch NMLS fee.","Official page was discovered and search-indexed on October 24, 2026, but direct fetch returned HTTP 403. It is operational discovery, not controlling legal authority and not treated as fully read. Its NMLS amounts conflict with the current NMLS schedule. \nDepartment of Financial Regulation"],["S_VT-P1-S005","Verify a License — Vermont Department of Financial Regulation","https://dfr.vermont.gov/consumers/verify-license","Indexed page directs users to NMLS Consumer Access for relevant license searches.","Official page discovered October 24, 2026; direct fetch returned HTTP 403. No provider record was queried. \nDepartment of Financial Regulation"],["S_VT-P1-S006","NMLS Processing Fees — NMLS/CSBS","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","State-licensure Table 1: company $120 initial/$120 annual; branch $25/$25. Professional standards Table 4: background and credit-report amounts. Credit-card and ACH provisions at lines 49–60.","Freshly read October 24, 2026. General platform schedule; exact Vermont-specific applicability must be reconciled with the Vermont checklist and transaction. \nNationwide Licensing System\n+1"],["S_VT-P1-S007","Licensing Checklists, Requirements, and Fees — NMLS","https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Public checklist compiler instructs applicants to select licenses and download relevant requirements.","Page was reached October 24, 2026, but the Vermont Debt Adjuster checklist did not render in the public reader. Exact current filing checklist remains unresolved. \nNationwide Licensing System\n+1"],["S_VT-P1-S008","Reminder—NMLS Processing Fee Increase Takes Effect March 1 — CSBS","https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1","Published February 20, 2025; increase effective March 1, 2025; first increase since 2008 and applicable to all NMLS industries.","Freshly read October 24, 2026. Used to reconcile stale DFR-indexed platform fees. \nCSBS"],["S_VT-P1-S009","Adjustment to Fees for Certain Non-Bank Licensees — Vermont DFR","https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","Indexed historical notice: debt-adjuster application/investigation component increased to $500 effective July 1, 2019.","Official historical page discovered, but direct fetch returned HTTP 403. Used only to distinguish licensing fees from consumer fees. \nDepartment of Financial Regulation"],["S_VT-P1-S010","Debt Adjusters — Vermont Attorney General, Consumer Assistance","https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters","Indexed guidance says companies offering debt settlement or adjustment to Vermont consumers must be licensed.","Official page discovered, but direct fetch returned HTTP 403. Guidance is consistent with §2752 but is not substituted for statutory permission. \nVermont Attorney General's Office"],["S_VT-P1-S011","Vermont Secretary of State Rules Service and Code of Vermont Rules link","https://secure.vermont.gov/SOS/rules/search.php\nhttps://advance.lexis.com/container?config=0147JAAzNTM4MTQxMS04MjI5LTQxN2QtODFjMy1hNWQ1OGExMjc3ZTUKAFBvZENhdGFsb2e0UpKanB5ifXeRwqlwuxNP","SOS page is the proposed-rule search and links to the current CVR.","SOS portal freshly read October 24, 2026. Linked current-rule interface produced no usable substantive debt-adjuster text. No conclusion that no rule exists. \nVermont Secure\n+1"],["S_VT-P1-S012","Record Retention, Regulation B-2014-01 — Vermont DFR","https://dfr.vermont.gov/reg-bul-ord/record-retention","Indexed as effective July 1, 2014 and applicable to debt adjusters.","Search-indexed official material only; full text was not relied upon for a fee or access conclusion. Chapter 83’s seven-year record requirement was independently read. \nDepartment of Financial Regulation\n+1"],["S_VT-P1-S013","Privacy of Consumer Financial and Health Information, Regulation B-2018-01 — Vermont DFR","https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation","Indexed regulation dated February 15, 2018 and including debt adjusters.","Search-indexed official material only; privacy merits are outside this pass. \nDepartment of Financial Regulation"],["S_VT-P1-S014","RAM Payment, LLC, DFR Docket 24-015-B — Vermont DFR","https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf","Search-indexed September 12, 2025 enforcement material referring to Vermont debt-adjuster licensing.","Direct PDF route returned HTTP 403; the PDF was not read or used for a substantive claim. It remains a next-pass enforcement source. \nDepartment of Financial Regulation"],["S_VT-P1-S015","Telemarketing Sales Rule, 16 C.F.R. §§310.2, 310.4, 310.6 — eCFR","https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","§310.2(o); §310.4(a)(5); §310.6(b)(5)–(7). eCFR displayed Title 16 as current through October 22, 2026 and last amended October 19, 2026.","Freshly read October 24, 2026. Federal common context only; not a Vermont fee source. eCFR is authoritative but unofficial. \neCFR\n+2"],["S_VT-P1-S016","Debt Relief Services and the Telemarketing Sales Rule: A Guide for Business — Federal Trade Commission","https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","FTC staff explanation of debt-relief coverage, fee triggers, allocation, and dedicated accounts.","Read as interpretive guidance; nonbinding and subordinate to S015. \nFederal Trade Commission\n+2"],["S_VT-P1-S017","In re Sinnott, 2004 VT 16 — Vermont Supreme Court opinion reproduced by Justia","https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","¶¶12–13 and 20–21; embedded hearing-panel restitution material.","Opinion text freshly read October 24, 2026 through a nonofficial republisher. Used only to define its narrow attorney-discipline holding and prevent misapplication to §2762. \nJustia Law\n+2"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, confidence"],"index":2,"links":[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02752","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02753","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/fullchapter/08/083","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/201/11101","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02762","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02762","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02753","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+2"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759a","text":"Vermont Legislature"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759b","text":"Vermont Legislature"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+2"},{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/072/02103","text":"Vermont Legislature\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/072/02109","text":"Vermont Legislature"},{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","text":"Nationwide Licensing System\n+3"},{"href":"https://dfr.vermont.gov/consumers/verify-license","text":"Department of Financial Regulation"},{"href":"https://secure.vermont.gov/SOS/rules/search.php","text":"Vermont Secure\n+1"},{"href":"https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","text":"Department of Financial Regulation\n+2"},{"href":"https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","text":"Justia Law\n+1"},{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+2"}],"row_links":[[],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02752","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02753","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/fullchapter/08/083","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02763","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/201/11101","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02762","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02762","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02753","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+2"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759a","text":"Vermont Legislature"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759b","text":"Vermont Legislature"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02759","text":"Vermont Legislature\n+2"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/072/02102","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/072/02103","text":"Vermont Legislature\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/072/02109","text":"Vermont Legislature"}],[{"href":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","text":"Nationwide Licensing System\n+3"}],[{"href":"https://dfr.vermont.gov/consumers/verify-license","text":"Department of Financial Regulation"}],[{"href":"https://secure.vermont.gov/SOS/rules/search.php","text":"Vermont Secure\n+1"}],[{"href":"https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","text":"Department of Financial Regulation\n+2"}],[{"href":"https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","text":"Justia Law\n+1"}],[{"href":"https://legislature.vermont.gov/statutes/section/08/083/02751","text":"Vermont Legislature\n+2"}]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, currentness, confidence"],["S_VT-P1-C001","Debt adjustment includes distributing, supervising, coordinating, negotiating, or controlling creditor payments and intermediary work obtaining concessions.","S001, §2751 first sentence. \nVermont Legislature","High—direct statutory text. Actual conduct controls."],["S_VT-P1-C002","A program or strategy furnishing services that include a proposed or actual payment or payment schedule used to pay debt is also debt adjustment.","S001, §2751 second sentence. \nVermont Legislature","High—direct statutory text. Broader than custody alone."],["S_VT-P1-C003","Noncustodial settlement and principal-reduction negotiation are covered when the provider negotiates or acts as an intermediary for concessions.","S001, §2751. \nVermont Legislature","High for ordinary settlement facts; edge cases depend on actual service."],["S_VT-P1-C004","DMP or credit-counseling activity is covered when it includes payment administration, a proposed schedule, creditor intermediation, or concessions.","S001, §§2751, 2759c, 2760–2760a. \nVermont Legislature\n+1","High for plans with those elements. Counseling label alone is not dispositive."],["S_VT-P1-C005","Pure education may be outside Chapter 83 if it contains none of the statutory elements, but nonlicensees cannot use specified debt-adjuster/debt-reduction terms publicly.","S001, §§2751, 2760b(c). \nVermont Legislature\n+1","Moderate—inference as to education boundary; reserved-term restriction is direct."],["S_VT-P1-C006","Vermont reaches in-state solicitation, solicitation or contracting with Vermont-resident individuals, and provision or offers directly or through others.","S001, §2751(1)–(4). \nVermont Legislature","High—direct text. Outer constitutional reach not analyzed."],["S_VT-P1-C007","Chapter 83 has no express generic business-purpose-debt exclusion; entity-debtor boundaries remain uncertain.","S001, §2751. \nVermont Legislature","Moderate. Textual negative verified; full case-law/legislative-history treatment open."],["S_VT-P1-C008","A covered nonexempt person must obtain a Commissioner-issued license before engaging in debt adjustment.","S001, §2752. \nVermont Legislature","High—direct statutory command."],["S_VT-P1-C009","Market access is conditional on application disclosures and prior Commissioner approval of all consumer-contract terms.","S001, §2753(a)(1)–(8). \nVermont Legislature\n+1","High. Approval is contract-specific; license alone is not fee-form approval."],["S_VT-P1-C010","Custodial operations require a separate insured account, quarterly statements, records, and creditor remittance at least every 30 days.","S001, §§2759c, 2760, 2760a. \nVermont Legislature","High. Exact treatment of a zero-custody licensee remains open."],["S_VT-P1-C011","Attorney exception is limited to a Vermont-admitted attorney when engaged in law practice.","S001, §2763(1). \nVermont Legislature","High. Mere ownership, employment, referral, or attorney affiliation is insufficient on the text."],["S_VT-P1-C012","Nonprofit exception is limited to bona fide nonprofit religious, fraternal, or cooperative organizations serving members exclusively.","S001, §2763(4). \nVermont Legislature","High. Generic nonprofit or §501(c)(3) status is not the statutory test."],["S_VT-P1-C013","Express exemptions also cover qualifying financial institutions/Chapter 73 lenders, law or court-order actors, licensee employees, and Vermont CPAs.","S001, §2763(2), (3), (5), (6). \nVermont Legislature","High as to listed text; activity conditions must be met."],["S_VT-P1-C014","A credit union, cooperative, affiliate, or fintech cannot be treated as exempt without completing §11101’s institutional chain and principal-business analysis.","S001 §2763(2); S003 §11101. \nVermont Legislature\n+1","Held. Full institutional analysis is outside this component."],["S_VT-P1-C015","No general self-creditor/original-creditor exception appears in §2763.","S001, §§2751, 2763. \nVermont Legislature\n+1","Held for direct creditor restructuring because the definition’s application may depend on facts and interpretation."],["S_VT-P1-C016","Consumer fee retained may not exceed one $50 initial setup fee plus 10% of payments received from the debtor for creditor distribution.","S001, §2762. \nVermont Legislature","High—direct current text."],["S_VT-P1-C017","The verified current amounts are $50 and 10%; §2762 contains no index or adjustment mechanism.","S001, §2762 and history. \nVermont Legislature","High for statutory text; no official contrary adjustment notice located."],["S_VT-P1-C018","Setup, monthly, per-debt, settlement, savings, or other labels do not create additive amounts above the retained-fee ceiling.","S001, §§2759(a)–(b), 2762. \nVermont Legislature\n+1","High as an aggregate-cap reading. Third-party independence requires factual review."],["S_VT-P1-C019","For a provider receiving no money for creditor distribution, the statutory percentage base is facially zero; a savings/enrolled-debt fee pathway was not established.","S001, §§2753(a)(4), 2762. \nVermont Legislature\n+1","Moderate textual inference / material hold. Needs DFR or controlling adjudicative authority."],["S_VT-P1-C020","Creditor rebates are allowed and creditor compensation must be disclosed where applicable, but their treatment under the consumer cap is unresolved.","S001, §§2759(b)(4), 2760b(k). \nVermont Legislature\n+1","High for permission/disclosure; held for cap interaction."],["S_VT-P1-C021","Approved written contract must precede any fee, direct/indirect compensation, or debtor payment.","S001, §2759(a). \nVermont Legislature","High—direct text."],["S_VT-P1-C022","Retrieved Vermont statutory text has no express settlement-success or first-payment earning trigger.","S001, §§2759, 2762; S011. \nVermont Legislature\n+2","Moderate. Operative rules were inaccessible; absence is not state advance-fee authorization."],["S_VT-P1-C023","Three-business-day rescission applies; disclosure noncompliance postpones commencement; all payments must be restored, with a 10-business-day/10-day text mismatch.","S001, §2759a(a)–(c). \nVermont Legislature","High for the text; exact reconciliation unresolved."],["S_VT-P1-C024","Consumer may cancel at any time with no cancellation premium or penalty.","S001, §2759b. \nVermont Legislature","High. Post-rescission earned-fee refund detail remains open."],["S_VT-P1-C025","Federal TSR “debt relief service” includes represented renegotiation, settlement, or alteration of unsecured debt terms.","S015, 16 C.F.R. §310.2(o). \neCFR","High federal text. TSR coverage must be established separately for each channel/model."],["S_VT-P1-C026","Covered TSR fees require one resolved debt, a valid agreement, and one consumer payment; individual-debt fees must use proportional or constant-savings allocation.","S015, §310.4(a)(5)(i). \neCFR","High federal text. Does not replace Vermont’s lower amount cap."],["S_VT-P1-C027","TSR-compliant dedicated accounts require insured custody, consumer ownership, independence, no referral consideration, and prompt withdrawal rights.","S015, §310.4(a)(5)(ii). \neCFR","High. Account deposits are not automatically earned fees."],["S_VT-P1-C028","When both apply, Vermont amount/contract restrictions and federal earning timing are cumulative.","S001 §§2759, 2762; S015 §310.4(a)(5). \nVermont Legislature\n+2","High general application principle; exact TSR coverage remains fact-specific."],["S_VT-P1-C029","DFR is the regulator; the statutory application system uses NMLS, and DFR’s indexed operational page directs applications there.","S002 §2102(c); S004. \nVermont Legislature\n+1","High for statutory NMLS data submission; DFR page itself was not fully retrievable."],["S_VT-P1-C030","Exact state initial fees are $750 and minimum bond is $50,000, subject to increase.","S002 §2102(b)(12); S001 §2755. \nVermont Legislature\n+1","High—current statutory amounts."],["S_VT-P1-C031","Approval requires financial responsibility, experience, competence, character, fitness, public-interest findings, and the bond; complete applications receive issuance or denial action within 60 days.","S002 §2103(a)–(c). \nVermont Legislature\n+1","High. A complete filing is prerequisite to the clock."],["S_VT-P1-C032","State annual renewal is $250, due by December 1, with continuing standards and bond.","S002 §2109(a)(12). \nVermont Legislature","High; current amendment effective July 1, 2026."],["S_VT-P1-C033","Current standard NMLS company fee is $120 initial and annual; expected base totals are $870 initial and $370 renewal, but exact all-in Vermont totals remain unverified.","S006; S008; S002. \nNationwide Licensing System\n+3","High for components; computed/conditional for totals because the VT checklist was unavailable."],["S_VT-P1-C034","DFR points users to NMLS Consumer Access, but no named provider’s Vermont Debt Adjuster status was checked.","S005. \nDepartment of Financial Regulation","Procedure partially verified; provider authorization unresolved."],["S_VT-P1-C035","No current operative fee or contract-duration rule was verified because the current CVR text was inaccessible.","S011; S001 §2760b(j). \nVermont Secure\n+1","Evidence gap, not a negative legal finding."],["S_VT-P1-C036","The 2019 DFR change concerns the applicant investigation fee, and the 2025 NMLS change concerns platform fees; neither alters §2762’s consumer ceiling.","S009; S008; S001 §2762. \nDepartment of Financial Regulation\n+2","High as reconciliation; S009 full page was inaccessible."],["S_VT-P1-C037","Sinnott is an attorney professional-conduct decision, not authority approving a Chapter 83 savings fee.","S017, ¶¶12–13, 20–21. \nJustia Law\n+1","High regarding the opinion’s holding; nonofficial reproduction used."],["S_VT-P1-C038","Current statutory text includes 2026-session actions, but no controlling Vermont appellate interpretation of §2762’s noncustodial application was located in targeted searches.","S001 currentness notice; S017 boundary. \nVermont Legislature\n+2","Moderate overall confidence. Search negatives are not proof of absence; rules and agency interpretations remain gaps."]]},{"headers":["Topic","Status in PASS-01","Supporting claims","Missing evidence / exact next action"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Topic","Status in PASS-01","Supporting claims","Missing evidence / exact next action"],["Core “debt adjustment” definition","Answered","C001–C002","No immediate gap for ordinary covered conduct."],["Noncustodial settlement/principal reduction classification","Answered","C003","Later fact-pattern testing for lead generators, attorney hybrids, software-only models, and consumer self-service tools."],["DMP and credit-counseling classification","Answered with boundary","C004–C005","Obtain DFR interpretation for education-only and nonprofit counseling edge cases."],["Resident and remote-provider nexus","Answered; outer limit open","C006","Later constitutional nexus and entity-debtor case-law review."],["Consumer versus business-purpose debt","Partial","C007","Search DFR orders, legislative history, and Vermont cases addressing entity debtors and sole-proprietor business debt."],["Basic licensing requirement","Answered","C008–C010","Exact current application checklist still required."],["Attorney exemption","Answered textually","C011","Later unauthorized-practice and attorney-affiliate pass; determine treatment of out-of-state counsel and nonlegal staff."],["Nonprofit exemption","Answered textually","C012","Later organization-by-organization analysis of religious, fraternal, and cooperative status and members-only operation."],["Financial institution/lender/CPA/employee exceptions","Partial","C013–C014","Complete §11101 and Chapter 73 cross-reference chain; confirm credit-union and affiliate treatment."],["Original-creditor/self-creditor model","Unresolved","C015","Retrieve DFR interpretations and Vermont cases applying both sentences of §2751 to a creditor adjusting its own account."],["Custodial consumer-fee formula","Answered","C016–C018","Confirm whether any current rule adds a lower limit or special calculation instruction."],["Current fee indexing/adjustment","Answered at statutory level","C017, C036","Retrieve full current CVR and any DFR bulletin database to exclude additional overlays conclusively."],["Monthly, per-debt, savings, settlement, and affiliate fees","Answered as no separate statutory buckets; fact-specific third-party issue remains","C018","Review affiliation, mandatory-service, indirect-compensation, and contract-approval evidence."],["Fully noncustodial fee model","Materially unresolved","C019–C020","Obtain a current DFR interpretation, approved contract form, administrative order, or controlling decision addressing §2762 when the licensee never receives creditor-distribution funds."],["Creditor rebates and creditor-paid compensation","Partial","C020","Determine whether and how DFR treats creditor compensation under §2762 and contract approval."],["State contract-before-fee trigger","Answered","C021–C022","Full current rules still needed before concluding there is no additional state performance trigger."],["Initial rescission and payment restoration","Answered with textual conflict","C023","Locate DFR interpretation or judicial construction reconciling “10 business days” with “10 days.”"],["Later cancellation and fee refund","Partial","C024","Retrieve current approved contract requirements, rules, and decisions defining earned/unearned fees after the rescission window."],["Federal TSR timing and allocation","Answered as common context","C025–C028","Each acquisition channel and entity model requires its own federal coverage analysis."],["State initial fees and bond","Answered","C030","Full bond form, surety, rider, claims, cancellation, and increase procedure belongs in later bond pass."],["Fitness and 60-day application decision","Answered","C031","Current checklist needed to determine when Vermont considers the application complete."],["Renewal fee and deadline","Answered","C032–C033","Confirm current NMLS renewal window and exact all-in transaction amount from the Vermont checklist."],["NMLS current processing fees","Answered generally; Vermont checkout held","C033","Download current Vermont Debt Adjuster company and branch checklists; inspect the live fee chart without filing."],["Public provider lookup procedure","Partial","C034","Search exact legal name/NMLS ID for any later named provider and record jurisdiction, authority, status, dates, branches, and actions."],["Named provider authorization","Not investigated","C034","No provider name was supplied or searched; do not infer authorization."],["Full operative regulations","Unresolved","C035","Retrieve the current CVR title/rule text, adoption orders, amendments, effective dates, and any DFR debt-adjuster bulletins. Particular priority: contract-duration limits referenced by §2760b(j)."],["Enforcement interpretations","Unresolved","C035, C038","Obtain and read the RAM Payment order and other DFR orders; classify holdings versus allegations and consent terms."],["Controlling case law on §2762","Unresolved after targeted search","C037–C038","Search official Vermont Judiciary databases, Westlaw/Lexis or other authorized reporter access, and administrative appeals for §§2751–2764."],["Sinnott attorney-fee relevance","Answered narrowly","C037","Do not use as ordinary licensee fee authority."],["Agreement and disclosures beyond fee prerequisites","Excluded/later pass","C009, C021 only as needed","Full approved-form, e-signature, language, suitability, secured-debt, amendment, duration, and contract-enforcement analysis."],["Funds, account administration, statements, and remittance","Partial only as needed","C010, C027","Full custodial/noncustodial funds pass, including account ownership, payment authorization, reconciliation, insolvency, and third-party administrator treatment."],["Bond claims and remedies","Excluded/later pass","C030 only as market-access prerequisite","Analyze bond beneficiaries, claim procedures, restitution, private action, Consumer Protection Act, penalties, and regulator powers."],["Collection, litigation, and limitations periods","Open","None","Separate collection/litigation/limitations investigation."],["Full exemption universe","Open beyond listed Chapter 83 exceptions","C011–C015","Check sector laws, federal preemption, governmental programs, bankruptcy actors, court-supervised programs, and entity-specific provisions."],["Secured debts","Open","Contract disclosure only","Analyze mortgage, auto, tax, medical liens, and other secured obligations in later pass."],["Sector, local, tribal, and contract-law overlays","Open","None","Separate passes required."],["Full Vermont dossier / A066 acceptance","Not satisfied","All","Complete all remaining components and coordinator reconciliation before any acceptance decision."]]}],"claims":[{"claim_id":"S_VT-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C001","Precise assertion":"Debt adjustment includes distributing, supervising, coordinating, negotiating, or controlling creditor payments and intermediary work obtaining concessions.","Sources and pinpoints":"S001, §2751 first sentence. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct statutory text. Actual conduct controls."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C002","Precise assertion":"A program or strategy furnishing services that include a proposed or actual payment or payment schedule used to pay debt is also debt adjustment.","Sources and pinpoints":"S001, §2751 second sentence. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct statutory text. Broader than custody alone."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C003","Precise assertion":"Noncustodial settlement and principal-reduction negotiation are covered when the provider negotiates or acts as an intermediary for concessions.","Sources and pinpoints":"S001, §2751. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High for ordinary settlement facts; edge cases depend on actual service."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C004","Precise assertion":"DMP or credit-counseling activity is covered when it includes payment administration, a proposed schedule, creditor intermediation, or concessions.","Sources and pinpoints":"S001, §§2751, 2759c, 2760–2760a. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High for plans with those elements. Counseling label alone is not dispositive."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C005","Precise assertion":"Pure education may be outside Chapter 83 if it contains none of the statutory elements, but nonlicensees cannot use specified debt-adjuster/debt-reduction terms publicly.","Sources and pinpoints":"S001, §§2751, 2760b(c). \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"Moderate—inference as to education boundary; reserved-term restriction is direct."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C006","Precise assertion":"Vermont reaches in-state solicitation, solicitation or contracting with Vermont-resident individuals, and provision or offers directly or through others.","Sources and pinpoints":"S001, §2751(1)–(4). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct text. Outer constitutional reach not analyzed."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C007","Precise assertion":"Chapter 83 has no express generic business-purpose-debt exclusion; entity-debtor boundaries remain uncertain.","Sources and pinpoints":"S001, §2751. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"Moderate. Textual negative verified; full case-law/legislative-history treatment open."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C008","Precise assertion":"A covered nonexempt person must obtain a Commissioner-issued license before engaging in debt adjustment.","Sources and pinpoints":"S001, §2752. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct statutory command."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C009","Precise assertion":"Market access is conditional on application disclosures and prior Commissioner approval of all consumer-contract terms.","Sources and pinpoints":"S001, §2753(a)(1)–(8). \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High. Approval is contract-specific; license alone is not fee-form approval."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C010","Precise assertion":"Custodial operations require a separate insured account, quarterly statements, records, and creditor remittance at least every 30 days.","Sources and pinpoints":"S001, §§2759c, 2760, 2760a. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High. Exact treatment of a zero-custody licensee remains open."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C011","Precise assertion":"Attorney exception is limited to a Vermont-admitted attorney when engaged in law practice.","Sources and pinpoints":"S001, §2763(1). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High. Mere ownership, employment, referral, or attorney affiliation is insufficient on the text."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C012","Precise assertion":"Nonprofit exception is limited to bona fide nonprofit religious, fraternal, or cooperative organizations serving members exclusively.","Sources and pinpoints":"S001, §2763(4). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High. Generic nonprofit or §501(c)(3) status is not the statutory test."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C013","Precise assertion":"Express exemptions also cover qualifying financial institutions/Chapter 73 lenders, law or court-order actors, licensee employees, and Vermont CPAs.","Sources and pinpoints":"S001, §2763(2), (3), (5), (6). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High as to listed text; activity conditions must be met."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C014","Precise assertion":"A credit union, cooperative, affiliate, or fintech cannot be treated as exempt without completing §11101’s institutional chain and principal-business analysis.","Sources and pinpoints":"S001 §2763(2); S003 §11101. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"Held. Full institutional analysis is outside this component."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C015","Precise assertion":"No general self-creditor/original-creditor exception appears in §2763.","Sources and pinpoints":"S001, §§2751, 2763. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"Held for direct creditor restructuring because the definition’s application may depend on facts and interpretation."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C016","Precise assertion":"Consumer fee retained may not exceed one $50 initial setup fee plus 10% of payments received from the debtor for creditor distribution.","Sources and pinpoints":"S001, §2762. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct current text."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C017","Precise assertion":"The verified current amounts are $50 and 10%; §2762 contains no index or adjustment mechanism.","Sources and pinpoints":"S001, §2762 and history. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High for statutory text; no official contrary adjustment notice located."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C018","Precise assertion":"Setup, monthly, per-debt, settlement, savings, or other labels do not create additive amounts above the retained-fee ceiling.","Sources and pinpoints":"S001, §§2759(a)–(b), 2762. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High as an aggregate-cap reading. Third-party independence requires factual review."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C019","Precise assertion":"For a provider receiving no money for creditor distribution, the statutory percentage base is facially zero; a savings/enrolled-debt fee pathway was not established.","Sources and pinpoints":"S001, §§2753(a)(4), 2762. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"Moderate textual inference / material hold. Needs DFR or controlling adjudicative authority."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C020","Precise assertion":"Creditor rebates are allowed and creditor compensation must be disclosed where applicable, but their treatment under the consumer cap is unresolved.","Sources and pinpoints":"S001, §§2759(b)(4), 2760b(k). \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High for permission/disclosure; held for cap interaction."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C021","Precise assertion":"Approved written contract must precede any fee, direct/indirect compensation, or debtor payment.","Sources and pinpoints":"S001, §2759(a). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High—direct text."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C022","Precise assertion":"Retrieved Vermont statutory text has no express settlement-success or first-payment earning trigger.","Sources and pinpoints":"S001, §§2759, 2762; S011. \nVermont Legislature\n+2","Conditions, exceptions, currentness, confidence":"Moderate. Operative rules were inaccessible; absence is not state advance-fee authorization."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C023","Precise assertion":"Three-business-day rescission applies; disclosure noncompliance postpones commencement; all payments must be restored, with a 10-business-day/10-day text mismatch.","Sources and pinpoints":"S001, §2759a(a)–(c). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High for the text; exact reconciliation unresolved."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C024","Precise assertion":"Consumer may cancel at any time with no cancellation premium or penalty.","Sources and pinpoints":"S001, §2759b. \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High. Post-rescission earned-fee refund detail remains open."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C025","Precise assertion":"Federal TSR “debt relief service” includes represented renegotiation, settlement, or alteration of unsecured debt terms.","Sources and pinpoints":"S015, 16 C.F.R. §310.2(o). \neCFR","Conditions, exceptions, currentness, confidence":"High federal text. TSR coverage must be established separately for each channel/model."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C026","Precise assertion":"Covered TSR fees require one resolved debt, a valid agreement, and one consumer payment; individual-debt fees must use proportional or constant-savings allocation.","Sources and pinpoints":"S015, §310.4(a)(5)(i). \neCFR","Conditions, exceptions, currentness, confidence":"High federal text. Does not replace Vermont’s lower amount cap."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C027","Precise assertion":"TSR-compliant dedicated accounts require insured custody, consumer ownership, independence, no referral consideration, and prompt withdrawal rights.","Sources and pinpoints":"S015, §310.4(a)(5)(ii). \neCFR","Conditions, exceptions, currentness, confidence":"High. Account deposits are not automatically earned fees."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C028","Precise assertion":"When both apply, Vermont amount/contract restrictions and federal earning timing are cumulative.","Sources and pinpoints":"S001 §§2759, 2762; S015 §310.4(a)(5). \nVermont Legislature\n+2","Conditions, exceptions, currentness, confidence":"High general application principle; exact TSR coverage remains fact-specific."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C029","Precise assertion":"DFR is the regulator; the statutory application system uses NMLS, and DFR’s indexed operational page directs applications there.","Sources and pinpoints":"S002 §2102(c); S004. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High for statutory NMLS data submission; DFR page itself was not fully retrievable."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C030","Precise assertion":"Exact state initial fees are $750 and minimum bond is $50,000, subject to increase.","Sources and pinpoints":"S002 §2102(b)(12); S001 §2755. \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High—current statutory amounts."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C031","Precise assertion":"Approval requires financial responsibility, experience, competence, character, fitness, public-interest findings, and the bond; complete applications receive issuance or denial action within 60 days.","Sources and pinpoints":"S002 §2103(a)–(c). \nVermont Legislature\n+1","Conditions, exceptions, currentness, confidence":"High. A complete filing is prerequisite to the clock."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C032","Precise assertion":"State annual renewal is $250, due by December 1, with continuing standards and bond.","Sources and pinpoints":"S002 §2109(a)(12). \nVermont Legislature","Conditions, exceptions, currentness, confidence":"High; current amendment effective July 1, 2026."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C033","Precise assertion":"Current standard NMLS company fee is $120 initial and annual; expected base totals are $870 initial and $370 renewal, but exact all-in Vermont totals remain unverified.","Sources and pinpoints":"S006; S008; S002. \nNationwide Licensing System\n+3","Conditions, exceptions, currentness, confidence":"High for components; computed/conditional for totals because the VT checklist was unavailable."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C034","Precise assertion":"DFR points users to NMLS Consumer Access, but no named provider’s Vermont Debt Adjuster status was checked.","Sources and pinpoints":"S005. \nDepartment of Financial Regulation","Conditions, exceptions, currentness, confidence":"Procedure partially verified; provider authorization unresolved."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C035","Precise assertion":"No current operative fee or contract-duration rule was verified because the current CVR text was inaccessible.","Sources and pinpoints":"S011; S001 §2760b(j). \nVermont Secure\n+1","Conditions, exceptions, currentness, confidence":"Evidence gap, not a negative legal finding."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C036","Precise assertion":"The 2019 DFR change concerns the applicant investigation fee, and the 2025 NMLS change concerns platform fees; neither alters §2762’s consumer ceiling.","Sources and pinpoints":"S009; S008; S001 §2762. \nDepartment of Financial Regulation\n+2","Conditions, exceptions, currentness, confidence":"High as reconciliation; S009 full page was inaccessible."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C037","Precise assertion":"Sinnott is an attorney professional-conduct decision, not authority approving a Chapter 83 savings fee.","Sources and pinpoints":"S017, ¶¶12–13, 20–21. \nJustia Law\n+1","Conditions, exceptions, currentness, confidence":"High regarding the opinion’s holding; nonofficial reproduction used."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_VT-P1-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_VT-P1-C038","Precise assertion":"Current statutory text includes 2026-session actions, but no controlling Vermont appellate interpretation of §2762’s noncustodial application was located in targeted searches.","Sources and pinpoints":"S001 currentness notice; S017 boundary. \nVermont Legislature\n+2","Conditions, exceptions, currentness, confidence":"Moderate overall confidence. Search negatives are not proof of absence; rules and agency interpretations remain gaps."},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"S_VT-P1-S001","urls":["https://legislature.vermont.gov/statutes/fullchapter/08/083","https://legislature.vermont.gov/statutes/section/08/083/02751","https://legislature.vermont.gov/statutes/section/08/083/02752","https://legislature.vermont.gov/statutes/section/08/083/02753","https://legislature.vermont.gov/statutes/section/08/083/02755","https://legislature.vermont.gov/statutes/section/08/083/02759","https://legislature.vermont.gov/statutes/section/08/083/02759a","https://legislature.vermont.gov/statutes/section/08/083/02759b","https://legislature.vermont.gov/statutes/section/08/083/02762","https://legislature.vermont.gov/statutes/section/08/083/02763"],"researcher_record":{"Source ID":"S_VT-P1-S001","Title / issuer":"Vermont Title 8, Chapter 83, Debt Adjusters — Vermont General Assembly","Direct literal URL(s)":"https://legislature.vermont.gov/statutes/fullchapter/08/083\nhttps://legislature.vermont.gov/statutes/section/08/083/02751\nhttps://legislature.vermont.gov/statutes/section/08/083/02752\nhttps://legislature.vermont.gov/statutes/section/08/083/02753\nhttps://legislature.vermont.gov/statutes/section/08/083/02755\nhttps://legislature.vermont.gov/statutes/section/08/083/02759\nhttps://legislature.vermont.gov/statutes/section/08/083/02759a\nhttps://legislature.vermont.gov/statutes/section/08/083/02759b\nhttps://legislature.vermont.gov/statutes/section/08/083/02762\nhttps://legislature.vermont.gov/statutes/section/08/083/02763","Exact pinpoint, version, and effective status":"§§2751, 2752, 2753, 2755, 2759–2759c, 2760–2760c, 2762–2764. Online compilation says it includes actions of the 2026 session. §2759a last amended effective July 1, 2023; §2760b includes amendments effective May 12, 2021; §2762 history ends in 2009.","Actual access and limitations":"Freshly read October 24, 2026. General Assembly warns that its online statutes are an unofficial convenience copy. This source supplies the controlling statutory text used throughout. \nVermont Legislature\n+4"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S002","urls":["https://legislature.vermont.gov/statutes/section/08/072/02102","https://legislature.vermont.gov/statutes/section/08/072/02103","https://legislature.vermont.gov/statutes/section/08/072/02109"],"researcher_record":{"Source ID":"S_VT-P1-S002","Title / issuer":"Vermont Title 8, Chapter 72, general nonbank licensing — Vermont General Assembly","Direct literal URL(s)":"https://legislature.vermont.gov/statutes/section/08/072/02102\nhttps://legislature.vermont.gov/statutes/section/08/072/02103\nhttps://legislature.vermont.gov/statutes/section/08/072/02109","Exact pinpoint, version, and effective status":"§2102(b)(12), (c); §2103(a)–(c); §2109(a)(12), (b). Current §§2103 and 2109 reflect amendments effective July 1, 2026.","Actual access and limitations":"Freshly read October 24, 2026. Establishes state applicant fees, NMLS information, suitability, decision period, duration, and renewal. Same unofficial-online-copy limitation. \nVermont Legislature\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S003","urls":["https://legislature.vermont.gov/statutes/section/08/201/11101"],"researcher_record":{"Source ID":"S_VT-P1-S003","Title / issuer":"8 V.S.A. §11101 definitions — Vermont General Assembly","Direct literal URL(s)":"https://legislature.vermont.gov/statutes/section/08/201/11101","Exact pinpoint, version, and effective status":"Subdivisions (18), (32), and related institutional definitions.","Actual access and limitations":"Freshly read October 24, 2026. Used only to begin the cross-reference required by §2763(2); the complete bank/credit-union classification chain remains open. \nVermont Legislature\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S004","urls":["https://dfr.vermont.gov/banking/financial-services/debt-adjuster"],"researcher_record":{"Source ID":"S_VT-P1-S004","Title / issuer":"Debt Adjuster industry page — Vermont Department of Financial Regulation","Direct literal URL(s)":"https://dfr.vermont.gov/banking/financial-services/debt-adjuster","Exact pinpoint, version, and effective status":"Indexed material states the application is handled through NMLS and displays initial and renewal information. Indexed renewal still uses a $100 company and $20 branch NMLS fee.","Actual access and limitations":"Official page was discovered and search-indexed on October 24, 2026, but direct fetch returned HTTP 403. It is operational discovery, not controlling legal authority and not treated as fully read. Its NMLS amounts conflict with the current NMLS schedule. \nDepartment of Financial Regulation"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S005","urls":["https://dfr.vermont.gov/consumers/verify-license"],"researcher_record":{"Source ID":"S_VT-P1-S005","Title / issuer":"Verify a License — Vermont Department of Financial Regulation","Direct literal URL(s)":"https://dfr.vermont.gov/consumers/verify-license","Exact pinpoint, version, and effective status":"Indexed page directs users to NMLS Consumer Access for relevant license searches.","Actual access and limitations":"Official page discovered October 24, 2026; direct fetch returned HTTP 403. No provider record was queried. \nDepartment of Financial Regulation"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S006","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html"],"researcher_record":{"Source ID":"S_VT-P1-S006","Title / issuer":"NMLS Processing Fees — NMLS/CSBS","Direct literal URL(s)":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_processingFees-1.html","Exact pinpoint, version, and effective status":"State-licensure Table 1: company $120 initial/$120 annual; branch $25/$25. Professional standards Table 4: background and credit-report amounts. Credit-card and ACH provisions at lines 49–60.","Actual access and limitations":"Freshly read October 24, 2026. General platform schedule; exact Vermont-specific applicability must be reconciled with the Vermont checklist and transaction. \nNationwide Licensing System\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S007","urls":["https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx"],"researcher_record":{"Source ID":"S_VT-P1-S007","Title / issuer":"Licensing Checklists, Requirements, and Fees — NMLS","Direct literal URL(s)":"https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx","Exact pinpoint, version, and effective status":"Public checklist compiler instructs applicants to select licenses and download relevant requirements.","Actual access and limitations":"Page was reached October 24, 2026, but the Vermont Debt Adjuster checklist did not render in the public reader. Exact current filing checklist remains unresolved. \nNationwide Licensing System\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S008","urls":["https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1"],"researcher_record":{"Source ID":"S_VT-P1-S008","Title / issuer":"Reminder—NMLS Processing Fee Increase Takes Effect March 1 — CSBS","Direct literal URL(s)":"https://www.csbs.org/newsroom/reminder-nmls-processing-fee-increase-takes-effect-march-1","Exact pinpoint, version, and effective status":"Published February 20, 2025; increase effective March 1, 2025; first increase since 2008 and applicable to all NMLS industries.","Actual access and limitations":"Freshly read October 24, 2026. Used to reconcile stale DFR-indexed platform fees. \nCSBS"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S009","urls":["https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees"],"researcher_record":{"Source ID":"S_VT-P1-S009","Title / issuer":"Adjustment to Fees for Certain Non-Bank Licensees — Vermont DFR","Direct literal URL(s)":"https://dfr.vermont.gov/industry-alert/adjustment-fees-certain-non-bank-licensees","Exact pinpoint, version, and effective status":"Indexed historical notice: debt-adjuster application/investigation component increased to $500 effective July 1, 2019.","Actual access and limitations":"Official historical page discovered, but direct fetch returned HTTP 403. Used only to distinguish licensing fees from consumer fees. \nDepartment of Financial Regulation"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S010","urls":["https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters"],"researcher_record":{"Source ID":"S_VT-P1-S010","Title / issuer":"Debt Adjusters — Vermont Attorney General, Consumer Assistance","Direct literal URL(s)":"https://ago.vermont.gov/divisions/consumer-protection/money-and-credit/debt-adjusters","Exact pinpoint, version, and effective status":"Indexed guidance says companies offering debt settlement or adjustment to Vermont consumers must be licensed.","Actual access and limitations":"Official page discovered, but direct fetch returned HTTP 403. Guidance is consistent with §2752 but is not substituted for statutory permission. \nVermont Attorney General's Office"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S011","urls":["https://secure.vermont.gov/SOS/rules/search.php","https://advance.lexis.com/container?config=0147JAAzNTM4MTQxMS04MjI5LTQxN2QtODFjMy1hNWQ1OGExMjc3ZTUKAFBvZENhdGFsb2e0UpKanB5ifXeRwqlwuxNP"],"researcher_record":{"Source ID":"S_VT-P1-S011","Title / issuer":"Vermont Secretary of State Rules Service and Code of Vermont Rules link","Direct literal URL(s)":"https://secure.vermont.gov/SOS/rules/search.php\nhttps://advance.lexis.com/container?config=0147JAAzNTM4MTQxMS04MjI5LTQxN2QtODFjMy1hNWQ1OGExMjc3ZTUKAFBvZENhdGFsb2e0UpKanB5ifXeRwqlwuxNP","Exact pinpoint, version, and effective status":"SOS page is the proposed-rule search and links to the current CVR.","Actual access and limitations":"SOS portal freshly read October 24, 2026. Linked current-rule interface produced no usable substantive debt-adjuster text. No conclusion that no rule exists. \nVermont Secure\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S012","urls":["https://dfr.vermont.gov/reg-bul-ord/record-retention"],"researcher_record":{"Source ID":"S_VT-P1-S012","Title / issuer":"Record Retention, Regulation B-2014-01 — Vermont DFR","Direct literal URL(s)":"https://dfr.vermont.gov/reg-bul-ord/record-retention","Exact pinpoint, version, and effective status":"Indexed as effective July 1, 2014 and applicable to debt adjusters.","Actual access and limitations":"Search-indexed official material only; full text was not relied upon for a fee or access conclusion. Chapter 83’s seven-year record requirement was independently read. \nDepartment of Financial Regulation\n+1"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S013","urls":["https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation"],"researcher_record":{"Source ID":"S_VT-P1-S013","Title / issuer":"Privacy of Consumer Financial and Health Information, Regulation B-2018-01 — Vermont DFR","Direct literal URL(s)":"https://dfr.vermont.gov/reg-bul-ord/privacy-consumer-financial-and-health-information-regulation","Exact pinpoint, version, and effective status":"Indexed regulation dated February 15, 2018 and including debt adjusters.","Actual access and limitations":"Search-indexed official material only; privacy merits are outside this pass. \nDepartment of Financial Regulation"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S014","urls":["https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf"],"researcher_record":{"Source ID":"S_VT-P1-S014","Title / issuer":"RAM Payment, LLC, DFR Docket 24-015-B — Vermont DFR","Direct literal URL(s)":"https://dfr.vermont.gov/sites/finreg/files/regbul/dfr-order-docket-24-015-b-ram-payment.pdf","Exact pinpoint, version, and effective status":"Search-indexed September 12, 2025 enforcement material referring to Vermont debt-adjuster licensing.","Actual access and limitations":"Direct PDF route returned HTTP 403; the PDF was not read or used for a substantive claim. It remains a next-pass enforcement source. \nDepartment of Financial Regulation"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S015","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/section-310.6"],"researcher_record":{"Source ID":"S_VT-P1-S015","Title / issuer":"Telemarketing Sales Rule, 16 C.F.R. §§310.2, 310.4, 310.6 — eCFR","Direct literal URL(s)":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4\nhttps://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Exact pinpoint, version, and effective status":"§310.2(o); §310.4(a)(5); §310.6(b)(5)–(7). eCFR displayed Title 16 as current through October 22, 2026 and last amended October 19, 2026.","Actual access and limitations":"Freshly read October 24, 2026. Federal common context only; not a Vermont fee source. eCFR is authoritative but unofficial. \neCFR\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S016","urls":["https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business"],"researcher_record":{"Source ID":"S_VT-P1-S016","Title / issuer":"Debt Relief Services and the Telemarketing Sales Rule: A Guide for Business — Federal Trade Commission","Direct literal URL(s)":"https://www.ftc.gov/business-guidance/resources/debt-relief-services-telemarketing-sales-rule-guide-business","Exact pinpoint, version, and effective status":"FTC staff explanation of debt-relief coverage, fee triggers, allocation, and dedicated accounts.","Actual access and limitations":"Read as interpretive guidance; nonbinding and subordinate to S015. \nFederal Trade Commission\n+2"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_VT-P1-S017","urls":["https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html"],"researcher_record":{"Source ID":"S_VT-P1-S017","Title / issuer":"In re Sinnott, 2004 VT 16 — Vermont Supreme Court opinion reproduced by Justia","Direct literal URL(s)":"https://law.justia.com/cases/vermont/supreme-court/2004/2003-170eo.html","Exact pinpoint, version, and effective status":"¶¶12–13 and 20–21; embedded hearing-panel restitution material.","Actual access and limitations":"Opinion text freshly read October 24, 2026 through a nonofficial republisher. Used only to define its narrow attorney-discipline holding and prevent misapplication to §2762. \nJustia Law\n+2"},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"Core “debt adjustment” definition","researcher_record":{"Topic":"Core “debt adjustment” definition","Status in PASS-01":"Answered","Supporting claims":"C001–C002","Missing evidence / exact next action":"No immediate gap for ordinary covered conduct."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial settlement/principal reduction classification","researcher_record":{"Topic":"Noncustodial settlement/principal reduction classification","Status in PASS-01":"Answered","Supporting claims":"C003","Missing evidence / exact next action":"Later fact-pattern testing for lead generators, attorney hybrids, software-only models, and consumer self-service tools."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"DMP and credit-counseling classification","researcher_record":{"Topic":"DMP and credit-counseling classification","Status in PASS-01":"Answered with boundary","Supporting claims":"C004–C005","Missing evidence / exact next action":"Obtain DFR interpretation for education-only and nonprofit counseling edge cases."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Resident and remote-provider nexus","researcher_record":{"Topic":"Resident and remote-provider nexus","Status in PASS-01":"Answered; outer limit open","Supporting claims":"C006","Missing evidence / exact next action":"Later constitutional nexus and entity-debtor case-law review."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Consumer versus business-purpose debt","researcher_record":{"Topic":"Consumer versus business-purpose debt","Status in PASS-01":"Partial","Supporting claims":"C007","Missing evidence / exact next action":"Search DFR orders, legislative history, and Vermont cases addressing entity debtors and sole-proprietor business debt."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Basic licensing requirement","researcher_record":{"Topic":"Basic licensing requirement","Status in PASS-01":"Answered","Supporting claims":"C008–C010","Missing evidence / exact next action":"Exact current application checklist still required."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exemption","researcher_record":{"Topic":"Attorney exemption","Status in PASS-01":"Answered textually","Supporting claims":"C011","Missing evidence / exact next action":"Later unauthorized-practice and attorney-affiliate pass; determine treatment of out-of-state counsel and nonlegal staff."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit exemption","researcher_record":{"Topic":"Nonprofit exemption","Status in PASS-01":"Answered textually","Supporting claims":"C012","Missing evidence / exact next action":"Later organization-by-organization analysis of religious, fraternal, and cooperative status and members-only operation."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Financial institution/lender/CPA/employee exceptions","researcher_record":{"Topic":"Financial institution/lender/CPA/employee exceptions","Status in PASS-01":"Partial","Supporting claims":"C013–C014","Missing evidence / exact next action":"Complete §11101 and Chapter 73 cross-reference chain; confirm credit-union and affiliate treatment."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Original-creditor/self-creditor model","researcher_record":{"Topic":"Original-creditor/self-creditor model","Status in PASS-01":"Unresolved","Supporting claims":"C015","Missing evidence / exact next action":"Retrieve DFR interpretations and Vermont cases applying both sentences of §2751 to a creditor adjusting its own account."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Custodial consumer-fee formula","researcher_record":{"Topic":"Custodial consumer-fee formula","Status in PASS-01":"Answered","Supporting claims":"C016–C018","Missing evidence / exact next action":"Confirm whether any current rule adds a lower limit or special calculation instruction."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Current fee indexing/adjustment","researcher_record":{"Topic":"Current fee indexing/adjustment","Status in PASS-01":"Answered at statutory level","Supporting claims":"C017, C036","Missing evidence / exact next action":"Retrieve full current CVR and any DFR bulletin database to exclude additional overlays conclusively."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Monthly, per-debt, savings, settlement, and affiliate fees","researcher_record":{"Topic":"Monthly, per-debt, savings, settlement, and affiliate fees","Status in PASS-01":"Answered as no separate statutory buckets; fact-specific third-party issue remains","Supporting claims":"C018","Missing evidence / exact next action":"Review affiliation, mandatory-service, indirect-compensation, and contract-approval evidence."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Fully noncustodial fee model","researcher_record":{"Topic":"Fully noncustodial fee model","Status in PASS-01":"Materially unresolved","Supporting claims":"C019–C020","Missing evidence / exact next action":"Obtain a current DFR interpretation, approved contract form, administrative order, or controlling decision addressing §2762 when the licensee never receives creditor-distribution funds."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Creditor rebates and creditor-paid compensation","researcher_record":{"Topic":"Creditor rebates and creditor-paid compensation","Status in PASS-01":"Partial","Supporting claims":"C020","Missing evidence / exact next action":"Determine whether and how DFR treats creditor compensation under §2762 and contract approval."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"State contract-before-fee trigger","researcher_record":{"Topic":"State contract-before-fee trigger","Status in PASS-01":"Answered","Supporting claims":"C021–C022","Missing evidence / exact next action":"Full current rules still needed before concluding there is no additional state performance trigger."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Initial rescission and payment restoration","researcher_record":{"Topic":"Initial rescission and payment restoration","Status in PASS-01":"Answered with textual conflict","Supporting claims":"C023","Missing evidence / exact next action":"Locate DFR interpretation or judicial construction reconciling “10 business days” with “10 days.”"},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Later cancellation and fee refund","researcher_record":{"Topic":"Later cancellation and fee refund","Status in PASS-01":"Partial","Supporting claims":"C024","Missing evidence / exact next action":"Retrieve current approved contract requirements, rules, and decisions defining earned/unearned fees after the rescission window."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Federal TSR timing and allocation","researcher_record":{"Topic":"Federal TSR timing and allocation","Status in PASS-01":"Answered as common context","Supporting claims":"C025–C028","Missing evidence / exact next action":"Each acquisition channel and entity model requires its own federal coverage analysis."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"State initial fees and bond","researcher_record":{"Topic":"State initial fees and bond","Status in PASS-01":"Answered","Supporting claims":"C030","Missing evidence / exact next action":"Full bond form, surety, rider, claims, cancellation, and increase procedure belongs in later bond pass."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Fitness and 60-day application decision","researcher_record":{"Topic":"Fitness and 60-day application decision","Status in PASS-01":"Answered","Supporting claims":"C031","Missing evidence / exact next action":"Current checklist needed to determine when Vermont considers the application complete."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Renewal fee and deadline","researcher_record":{"Topic":"Renewal fee and deadline","Status in PASS-01":"Answered","Supporting claims":"C032–C033","Missing evidence / exact next action":"Confirm current NMLS renewal window and exact all-in transaction amount from the Vermont checklist."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"NMLS current processing fees","researcher_record":{"Topic":"NMLS current processing fees","Status in PASS-01":"Answered generally; Vermont checkout held","Supporting claims":"C033","Missing evidence / exact next action":"Download current Vermont Debt Adjuster company and branch checklists; inspect the live fee chart without filing."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Public provider lookup procedure","researcher_record":{"Topic":"Public provider lookup procedure","Status in PASS-01":"Partial","Supporting claims":"C034","Missing evidence / exact next action":"Search exact legal name/NMLS ID for any later named provider and record jurisdiction, authority, status, dates, branches, and actions."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Named provider authorization","researcher_record":{"Topic":"Named provider authorization","Status in PASS-01":"Not investigated","Supporting claims":"C034","Missing evidence / exact next action":"No provider name was supplied or searched; do not infer authorization."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Full operative regulations","researcher_record":{"Topic":"Full operative regulations","Status in PASS-01":"Unresolved","Supporting claims":"C035","Missing evidence / exact next action":"Retrieve the current CVR title/rule text, adoption orders, amendments, effective dates, and any DFR debt-adjuster bulletins. Particular priority: contract-duration limits referenced by §2760b(j)."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Enforcement interpretations","researcher_record":{"Topic":"Enforcement interpretations","Status in PASS-01":"Unresolved","Supporting claims":"C035, C038","Missing evidence / exact next action":"Obtain and read the RAM Payment order and other DFR orders; classify holdings versus allegations and consent terms."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Controlling case law on §2762","researcher_record":{"Topic":"Controlling case law on §2762","Status in PASS-01":"Unresolved after targeted search","Supporting claims":"C037–C038","Missing evidence / exact next action":"Search official Vermont Judiciary databases, Westlaw/Lexis or other authorized reporter access, and administrative appeals for §§2751–2764."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Sinnott attorney-fee relevance","researcher_record":{"Topic":"Sinnott attorney-fee relevance","Status in PASS-01":"Answered narrowly","Supporting claims":"C037","Missing evidence / exact next action":"Do not use as ordinary licensee fee authority."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Agreement and disclosures beyond fee prerequisites","researcher_record":{"Topic":"Agreement and disclosures beyond fee prerequisites","Status in PASS-01":"Excluded/later pass","Supporting claims":"C009, C021 only as needed","Missing evidence / exact next action":"Full approved-form, e-signature, language, suitability, secured-debt, amendment, duration, and contract-enforcement analysis."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Funds, account administration, statements, and remittance","researcher_record":{"Topic":"Funds, account administration, statements, and remittance","Status in PASS-01":"Partial only as needed","Supporting claims":"C010, C027","Missing evidence / exact next action":"Full custodial/noncustodial funds pass, including account ownership, payment authorization, reconciliation, insolvency, and third-party administrator treatment."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Bond claims and remedies","researcher_record":{"Topic":"Bond claims and remedies","Status in PASS-01":"Excluded/later pass","Supporting claims":"C030 only as market-access prerequisite","Missing evidence / exact next action":"Analyze bond beneficiaries, claim procedures, restitution, private action, Consumer Protection Act, penalties, and regulator powers."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Collection, litigation, and limitations periods","researcher_record":{"Topic":"Collection, litigation, and limitations periods","Status in PASS-01":"Open","Supporting claims":"None","Missing evidence / exact next action":"Separate collection/litigation/limitations investigation."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Full exemption universe","researcher_record":{"Topic":"Full exemption universe","Status in PASS-01":"Open beyond listed Chapter 83 exceptions","Supporting claims":"C011–C015","Missing evidence / exact next action":"Check sector laws, federal preemption, governmental programs, bankruptcy actors, court-supervised programs, and entity-specific provisions."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Secured debts","researcher_record":{"Topic":"Secured debts","Status in PASS-01":"Open","Supporting claims":"Contract disclosure only","Missing evidence / exact next action":"Analyze mortgage, auto, tax, medical liens, and other secured obligations in later pass."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Sector, local, tribal, and contract-law overlays","researcher_record":{"Topic":"Sector, local, tribal, and contract-law overlays","Status in PASS-01":"Open","Supporting claims":"None","Missing evidence / exact next action":"Separate passes required."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"},{"topic":"Full Vermont dossier / A066 acceptance","researcher_record":{"Topic":"Full Vermont dossier / A066 acceptance","Status in PASS-01":"Not satisfied","Supporting claims":"All","Missing evidence / exact next action":"Complete all remaining components and coordinator reconciliation before any acceptance decision."},"coordinator_acceptance":"scoped_review_with_holds_not_component_or_state_acceptance","table_index":3,"coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}