{"meta":{"key":"s_wy--pass-01","task":"S_WY","title":"SWY Wyoming provider market access and consumer fees","parent_title":"Wyoming debt and debt relief law","edition":"pass-01","path":"/research/s_wy--pass-01/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":6,"claims":30,"sources":20,"review_status":"scoped_review_complete_with_limits","review_complete":true,"sha256":"c15d3b9f0da51a3b9ec965006407782178e46a78810a06ff83d986569acde98c","headings":["Bottom-line determination","Executive classification matrix","1. Definition and classification of covered conduct","1.1 Operative definition","1.2 Principal reduction versus concession and distribution services","1.3 The fee-clause grammar is not perfectly resolved","1.4 Consumer versus business-purpose debt","1.5 Resident and remote-provider nexus","1.6 Self-creditor and institutional conduct","2. Prohibited, licensed, authorized, and conditionally excluded models","2.1 Nonexcluded debt-adjusting business: prohibited","2.2 Conditional nonprofit exclusion","2.3 Attorney and legal-practice exclusions","2.4 Banks, lenders, collection agencies, and other licenses","2.5 Financial technology sandbox","3. Applicable fee structures, limits, indexing, and refunds","3.1 Covered nonexcluded provider","3.2 Conditional nonprofit service","3.3 Attorney fees","4. When fees may be requested or received","4.1 Wyoming state timing","4.2 Federal TSR debt-relief timing—independent common context","4.3 Separate TSR credit-improvement timing","4.4 Conditional CROA overlap","5. Actual regulator permission, lookup, and application evidence","5.1 No Chapter 14 issuing regulator or application","5.2 Condition-specific verification tools","6. Worked fee and boundary examples","Example E1 — Noncustodial commercial settlement fee","Example E2 — Custodial DMP with setup and monthly fees","Example E3 — Lower-debt case","Example E4 — Conditional nonprofit fixed fees","Example E5 — Attorney advance and cancellation","Example E6 — Federal proportional method with prior earned fees","Example E7 — Dedicated-account cancellation without double deduction","Actually read","Searched but not established","Not read or not done"],"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_WY/pass-01","facets":{"geography":["us","us-wy"],"debt_type":["unknown"],"stage":[],"subject":["definitions-classification","fees-outcomes","provider-licensing"]},"scope":"First extensive Wyoming provider market access/consumer-fees component only; all broader state dimensions remain required.","pending_corrections":0},"markdown":"# S_WY PASS-01 — Wyoming provider market access and consumer fees\n\n**Coordinator reference date:** October 25, 2026, Pacific.\n**Actual fresh source-access date:** **October 25, 2026, Pacific.**\n**Mode/model actually used:** regular Chat, GPT-5.6 Sol Pro fallback; public web research; no Deep Research, Chrome control, other chats, private data, contacts, applications, or account changes.\n\n**Component boundary:** This is the Wyoming provider-market-access and consumer-fees component only. It does not constitute acceptance of the full Wyoming dossier or A066, and it leaves the other parent-state dimensions expressly open.\n\n## Bottom-line determination\n\nWyoming’s current Chapter 14 is an **outright prohibition**, not a licensing statute. A nonexcluded person may not engage in fee-based debt adjusting. The operative definition expressly reaches both:\n\n1. noncustodial efforts to adjust, compromise, or discharge debt; and  \n2. custodial debt-management or debt-pooling arrangements that receive debtor funds and disburse them to creditors.\n\nChapter 14 creates **no debt-adjuster license, registration, regulator, application procedure, fee schedule, percentage ceiling, indexed amount, performance trigger, or state refund formula**. It is therefore incorrect to describe Wyoming as allowing ordinary commercial debt settlement subject to a fee cap. It is also imprecise to call the state cap “zero”: the covered business itself is prohibited rather than licensed at a zero-dollar ceiling. W.S. 33-14-102(a) makes the business unlawful, and §33-14-103 supplies a misdemeanor penalty for each violation. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nThe principal Chapter 14 carve-outs are conditional: a “tax exempt nonprofit consumer credit counseling service”; an individual admitted to the Wyoming bar; an all-Wyoming-bar copartnership or professional corporation; and, separately, situations in which debt adjusting is incurred in the practice of law in Wyoming. A nonprofit label, a bankruptcy-counseling listing, an attorney referral, a collection-agency license, an NMLS credential, or a fintech-sandbox application does not by itself establish authority to operate a commercial Wyoming debt-settlement program. [Wyoming Legislative Services Office+2](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### Executive classification matrix\n\n| Business model | Wyoming Chapter 14 result | Consumer-fee result |\n| --- | --- | --- |\n| Nonexcluded commercial principal-reduction or debt-settlement provider charging the debtor | **Prohibited**, not licensable under Chapter 14 | No Wyoming-authorized settlement, savings, per-debt, enrollment, setup, or monthly fee |\n| Nonexcluded custodial DMP/debt-pooling provider receiving and distributing debtor funds | **Prohibited**, not licensable under Chapter 14 | No Wyoming-authorized setup, monthly, remittance, or aggregate fee |\n| Noncustodial concession service negotiating interest, fees, or payment terms for debtor compensation | Strongly within “adjustment”/“debt management”; **prohibited** | No Chapter 14 fee pathway |\n| Pure financial education with no debt adjustment, no fund handling, and no fee contract to perform §101(a)(ii)(A) or (B) conduct | Potentially outside; facts control | Not affirmatively licensed or approved by Chapter 14 |\n| Creditor adjusting its own debt, with no separate debtor-paid adjustment service | Likely outside on statutory elements, not an express institutional exemption | Separate fees and affiliate structures require fact-specific analysis |\n| Tax-exempt nonprofit consumer credit counseling service | Excluded from Chapter 14’s definition of “person” only if all status and functional conditions are real | No Wyoming numeric cap; federal tax-exemption conditions may restrict fee methods |\n| Wyoming-admitted lawyer / qualifying all-lawyer entity | Textual exclusion; actual legal-practice situations also separately outside the act | No Chapter 14 numeric cap; professional-conduct and applicable federal timing rules remain |\n| Attorney-affiliated nonlawyer company | **Not automatically excluded** | Attorney participation cannot be used as a wrapper for otherwise prohibited nonlawyer activity |\n| Collection agency, lender, creditor, bank, credit union, or NMLS licensee providing third-party debtor-side adjustment | Other credential does **not** substitute for Chapter 14 authority | Separate credential does not create a debt-adjustment fee right |\n| Wyoming fintech-sandbox participant | Sandbox cannot waive Title 33, Chapter 14 and does not immunize criminal conduct | $500 sandbox application fee is a government charge, not a consumer debt-adjustment fee |\n| Remote provider serving Wyoming debtors | No express territorial clause; likely substantial Wyoming nexus, but exact reach is unresolved | Do not treat remote location or choice-of-law wording as a safe harbor |\n| Business-purpose debt service | No consumer-purpose limitation appears in Chapter 14; potentially covered | Business debt is not safely outside merely because the TSR may be inapplicable |\n\n# A. Substantive answers to the numbered scope questions\n\n## 1. Definition and classification of covered conduct\n\n### 1.1 Operative definition\n\nW.S. 33-14-101(a)(ii) defines “debt adjusting” through a combination of named business categories—debt adjustment, budget counseling, debt management, and debt pooling—and conduct involving services to debtors in managing debt. It then identifies two operative fee-based functions:\n\n- effecting an adjustment, compromise, or discharge of an account, note, or other indebtedness; or\n- receiving value from the debtor and disbursing it to creditors.\n\nThe provision is functional. Calling a program “financial wellness,” “resolution,” “legal support,” “hardship advocacy,” “debt consulting,” or “credit counseling” does not alter the analysis if the actual contracted service and fee fall within §33-14-101(a)(ii)(A) or (B). **Claims S_WY-P1-C001–C004.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 1.2 Principal reduction versus concession and distribution services\n\n**Principal reduction / settlement / negotiation.** Contracting for compensation to obtain a compromise, reduced balance, discharge, or other alteration of indebtedness falls squarely within §33-14-101(a)(ii)(A). The statute does not require the provider to possess the consumer’s money. A conventional noncustodial settlement model is therefore covered even if all consumer funds remain in a consumer-owned bank account. **S_WY-P1-C002.** [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n**Interest-rate, late-fee, and payment-term concessions.** Those are not separately itemized, but “adjustment” and “debt management” naturally encompass altering repayment terms. Federal law is not controlling on the state definition, but the federal tax-code definition of DMP services confirms that ordinary industry usage includes negotiating lower interest rates and fee waivers. No Wyoming appellate construction was located, so the precise outer boundary is moderate-confidence rather than adjudicated. **S_WY-P1-C004.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n**Custodial DMP or debt pooling.** Receiving funds or another thing of value from the debtor and disbursing it to creditors is expressly covered by §33-14-101(a)(ii)(B). Custody is therefore an independent coverage route; it is not required for settlement coverage under subparagraph (A). **S_WY-P1-C003.** [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 1.3 The fee-clause grammar is not perfectly resolved\n\nThe sentence can be parsed in two ways:\n\n1. the “contracting with a debtor for a fee” language modifies all named debt-adjusting business; or  \n2. it modifies only the “holding oneself out” branch immediately preceding it.\n\nNo controlling Wyoming opinion or official interpretation resolving that grammar was located. The high-confidence core is narrower and sufficient for the commercial models at issue: **an actual contract with a debtor for a fee to perform subparagraph (A) or (B) is covered.**\n\nAccordingly:\n\n- a fee-based commercial settlement or DMP program is not a close case;\n- purely gratuitous education or counseling with no adjustment contract is not safely classified as prohibited on the present evidence;\n- a creditor-funded “fair-share” model with no debtor-paid or debtor-imposed fee remains a held boundary question;\n- an indirectly imposed or affiliate-routed charge should not be assumed outside merely because the invoice uses another label.\n\n**S_WY-P1-C005.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 1.4 Consumer versus business-purpose debt\n\nUnlike Wyoming’s collection-agency chapter, Chapter 14 contains no definition limiting “debtor” or “indebtedness” to personal, family, or household obligations. It speaks of “any account, note, or other indebtedness.” The literal text therefore does not create a business-debt exclusion. At the same time, §33-14-103 is penal, and no Wyoming decision was located applying Chapter 14 to a business debtor. A business-debt negotiation program should be treated as **potentially covered**, not conclusively outside. **S_WY-P1-C006.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nThe separate collection-agency act is instructively different: it expressly defines business debt and expressly addresses interstate collection communications. Those collection provisions cannot be imported into Chapter 14, but their specificity underscores that Chapter 14 itself supplies neither a consumer-purpose limitation nor a detailed remote-provider rule. [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 1.5 Resident and remote-provider nexus\n\nChapter 14 does not say:\n\n- that the debtor must reside in Wyoming;\n- that the provider must maintain a Wyoming office;\n- that contracting, solicitation, performance, or payment in Wyoming is sufficient;\n- whether a contractual choice-of-law clause controls; or\n- how the prohibition applies to a remote provider operating entirely from another state.\n\nServing and contracting with a Wyoming debtor, negotiating that debtor’s obligations, and collecting fees from that debtor creates an evident practical Wyoming connection, but the precise territorial test remains unresolved without controlling case law or an official Attorney General interpretation. Remote location is therefore **not a verified safe harbor**, but this pass does not claim unlimited extraterritorial reach. **S_WY-P1-C007.**\n\n### 1.6 Self-creditor and institutional conduct\n\nChapter 14 contains no express blanket exclusion for banks, credit unions, licensed lenders, collection agencies, original creditors, government entities, or their affiliates. Nevertheless, an original creditor merely modifying its own receivable—without selling the debtor a separate debt-management service or charging a distinct adjustment fee—may fail the statutory service-and-fee elements. That is an outside-the-definition analysis, not a statutory exemption.\n\nA creditor affiliate, lead generator, service company, or third party charging the debtor for negotiation cannot automatically inherit the creditor’s position. **S_WY-P1-C029.**\n\n## 2. Prohibited, licensed, authorized, and conditionally excluded models\n\n### 2.1 Nonexcluded debt-adjusting business: prohibited\n\nW.S. 33-14-102(a) states that engaging in the business of debt adjusting is unlawful. Chapter 14 contains no application, license, registration, certificate, bond, commissioner, board, renewal, fee table, reciprocity provision, or waiver authority. This is a prohibition model, not a regulator-administered market-access model. **S_WY-P1-C008.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nSection 33-14-103 makes a violating individual—or an officer, director, or employee of an entity—guilty of a misdemeanor upon conviction, with a maximum $100 fine, up to six months in county jail, or both, **for each violation**. This pass does not determine additional civil, consumer-protection, restitution, contract, or common-law consequences. **S_WY-P1-C009.** [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 2.2 Conditional nonprofit exclusion\n\nThe definition of “person” excludes a **tax-exempt nonprofit consumer credit counseling service**. All descriptors matter:\n\n- tax exempt;\n- nonprofit; and\n- actually a consumer credit counseling service.\n\n“Nonprofit” in a company name, state incorporation as a nonprofit, U.S. Trustee approval for bankruptcy counseling, or a general educational mission does not by itself prove the complete exclusion. Wyoming does not define “tax exempt,” identify the relevant tax system, prescribe documentary evidence, or create a state recognition process. **S_WY-P1-C010.** [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nThe exclusion wording was enacted in 1989 Senate File 0133A, Enrolled Act 40, Chapter 92, effective June 8, 1989. That act amended the “person” definition; it did not enact a nonprofit licensing or fee schedule. [Knowvation+1](https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e)\n\nFor an organization relying on federal income-tax exemption where credit counseling is a substantial purpose, 26 U.S.C. §501(q) requires, among other things, tailored counseling, no refusal based on inability to pay or unwillingness to enroll in a DMP, reasonable fees, and a waiver policy for inability to pay. It generally prohibits debt-, payment-, or savings-percentage fees except to the extent state law allows them. Wyoming’s entity exclusion does not expressly say that a particular percentage fee is “allowed by State law,” and no controlling interpretation was located. An exact percentage-based nonprofit fee is therefore **held**, not affirmatively validated. **S_WY-P1-C016.** [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t26/s501/)\n\n### 2.3 Attorney and legal-practice exclusions\n\nThere are overlapping attorney provisions:\n\n1. §33-14-101(a)(i) omits an individual admitted to the Wyoming bar and an all-Wyoming-bar copartnership or professional corporation from the definition of “person”; and  \n2. §33-14-102(b) separately says the act does not apply to debt-adjusting situations incurred in the practice of law in Wyoming.\n\nThe interaction between the status-based and situation-based clauses has no located Wyoming appellate construction. An individual Wyoming-bar member is textually excluded, but a nonlawyer provider does not become excluded merely by retaining, referring to, employing, or sharing revenue with a lawyer. **S_WY-P1-C011.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nWyoming’s authorized-practice rules recognize Wyoming Bar members, limited pro hac vice practice, specified clinical practice, and qualifying Rule 5.5(d) activity. They define legal practice through actual legal services, advice, or representative work in a client relationship. An out-of-state lawyer cannot simply establish a systematic Wyoming legal presence or hold out as admitted without authorization. [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf)\n\nThe statute’s entity language still names only copartnerships and professional corporations, while current Rule 10 permits lawyers to practice through sole proprietorships, partnerships, LLPs, professional corporations, nonprofit corporations, and LLCs. For a modern law-firm form not enumerated in §33-14-101(a)(i), the safer Chapter 14 basis is the actual-practice-of-law situation in §33-14-102(b), coupled with full compliance with the current court rules—not the mere presence of a lawyer’s name. Rule 10 became effective January 26, 2026. [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf)\n\nRule 5.4 limits fee sharing, nonlawyer ownership, nonlawyer partnerships involving legal practice, and outside control of professional judgment. Rule 5.5 restricts unauthorized and systematic out-of-state practice. Those rules defeat the premise that an attorney connection automatically shelters a nonlawyer debt-settlement platform. **S_WY-P1-C019.** [Wyoming Judicial Branch+2](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf)\n\n### 2.4 Banks, lenders, collection agencies, and other licenses\n\nWyoming’s current Division of Banking page identifies non-lender creditor registration and licenses for consumer lenders, sales finance companies, post-dated check cashers, and pawnbrokers. It directs those categories to NMLS. It does not identify a debt-adjuster or debt-settlement license. More importantly, none of those operational categories overrides §33-14-102. **S_WY-P1-C013.** [Wyoming Banking Division+1](https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration)\n\nThe Collection Agency Board provides a licensee list and collection-agency application process, but collection agencies are separately defined as businesses collecting debts for creditors or debts owed another. A collection-agency license is creditor-side authority and is not a debtor-side debt-adjustment license. **S_WY-P1-C012.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\n### 2.5 Financial technology sandbox\n\nThe sandbox’s waiver statute lists specified provisions in Titles 13, 17, and 40. Title 33, Chapter 14 is not on that list. Participants also remain subject to criminal and consumer-protection laws. Thus, a sandbox authorization cannot waive the Chapter 14 debt-adjuster prohibition. **S_WY-P1-C014.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title40.pdf)\n\nThe sandbox application requires a $500 governmental application fee, but that is neither a consumer charge nor a debt-adjuster licensing fee, and it does not create a Chapter 14 route. **S_WY-P1-C030.** [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title40.pdf)\n\n## 3. Applicable fee structures, limits, indexing, and refunds\n\n### 3.1 Covered nonexcluded provider\n\nNo fee structure is lawfully established under Chapter 14 for a nonexcluded provider. The chapter contains no:\n\n- setup or enrollment allowance;\n- monthly maintenance allowance;\n- settlement or savings percentage;\n- per-account amount;\n- creditor remittance fee;\n- aggregate cap;\n- lower-debt exception;\n- CPI or other adjustment mechanism;\n- annual regulator notice;\n- earned-fee credit formula;\n- cancellation refund schedule; or\n- partial-settlement allocation method.\n\nThe reason is not an omitted fee table inside a licensing scheme; the business is prohibited. **S_WY-P1-C015.** [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nNo current Wyoming debt-adjuster fee bulletin or administrative adjustment notice was located. A private multistate chart or dated industry table cannot supply permission or a ceiling absent operative Wyoming authority.\n\n### 3.2 Conditional nonprofit service\n\nChapter 14 itself places no numeric fee ceiling on a qualifying excluded nonprofit because the entity is removed from the definition of covered “person.” That exclusion is not an affirmative declaration that every fee formula is lawful.\n\nFor a federally tax-exempt credit-counseling organization within §501(q):\n\n- consumer fees must be reasonable;\n- the organization must allow waiver where the consumer cannot pay; and\n- percentage-of-debt, percentage-of-DMP-payment, and percentage-of-savings formulas are generally prohibited unless state law allows them.\n\nWyoming has not been verified to affirmatively allow a particular percentage. Fixed setup or monthly fees are not numerically capped by Chapter 14, but remain subject to the federal reasonableness and waiver conditions where §501(q) applies. **S_WY-P1-C016.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t26/s501/)\n\n### 3.3 Attorney fees\n\nChapter 14 contains no attorney fee ceiling. Wyoming Rule of Professional Conduct 1.5 instead prohibits unreasonable fees, lists reasonableness factors, and requires communication of the representation’s scope and fee basis or rate. A contingent arrangement must be written and state its calculation method. **S_WY-P1-C017.** [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf)\n\nPaid but unearned legal fees and anticipated but unincurred expenses must be deposited in client trust and withdrawn only when earned or incurred. Upon termination, an attorney must refund any unearned advance payment. **S_WY-P1-C018.** [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf)\n\nThese professional rules do not negate independently applicable TSR or CROA timing. A lawyer cannot treat Rule 1.5 reasonableness or a state-law exclusion as federal advance-fee authorization.\n\n## 4. When fees may be requested or received\n\n### 4.1 Wyoming state timing\n\nFor a nonexcluded covered provider, Wyoming supplies no performance trigger because it supplies no lawful operating route. Completing negotiations, obtaining a creditor offer, receiving the consumer’s first deposit, or making a creditor payment does not convert the prohibited business into an authorized one. **S_WY-P1-C015.**\n\nFor a qualifying nonprofit, Chapter 14 supplies no state earned-fee trigger; federal tax-exemption requirements and other applicable law must be examined.\n\nFor a qualifying attorney, the state professional rule is an earned/incurred standard: an advance may be collected but must remain in trust until earned, and any unearned balance must be returned. [Wyoming Judicial Branch+2](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf)\n\n### 4.2 Federal TSR debt-relief timing—independent common context\n\nWhere the Telemarketing Sales Rule applies, “debt relief service” includes a represented service to renegotiate, settle, or otherwise alter an unsecured debt’s payment terms, balance, interest, or fees. **S_WY-P1-C020.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2)\n\nUnder 16 C.F.R. §310.4(a)(5), a covered seller or telemarketer may not request or receive a debt-relief fee until:\n\n1. at least one debt has actually been altered under a valid agreement executed by the customer;  \n2. the customer has made at least one payment pursuant to that agreement; and  \n3. an individually adjusted debt fee uses one of the rule’s permitted allocation methods. **S_WY-P1-C021.** [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe two allocation methods are:\n\n- the same proportional relationship between the individual enrolled debt and the total enrolled debt; or\n- the same percentage of actual savings for each individually resolved debt.\n\nA provider may not switch methods debt by debt or count a prior fee against a different enrolled balance.\n\nA qualifying dedicated account must be at an insured financial institution, owned by the customer, administered independently without referral compensation, and structured so the customer may withdraw from the **debt-relief service** without penalty. Within seven business days of the request, the customer must receive all account funds other than fees already earned under the federal trigger and allocation rules. **S_WY-P1-C022.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThe TSR does not cover every interaction. Truly unsolicited customer calls can fall within an exemption, but calls responding to debt-relief advertising or direct mail do not obtain the ordinary inbound-call exemption. Business-to-business calls are generally exempt, subject to the rule’s specified exceptions. **S_WY-P1-C023.** [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6)\n\nMost importantly, the TSR is a federal restriction, not Wyoming permission. Satisfaction of §310.4(a)(5) cannot legalize a model that Wyoming independently prohibits.\n\n### 4.3 Separate TSR credit-improvement timing\n\nWhere the seller represents that services will remove derogatory information or improve a credit record, history, or rating, §310.4(a)(2) is a separate rule. It bars payment until the represented timeframe for all services has expired **and** the seller has furnished a consumer report demonstrating the promised results, issued more than six months after those results were achieved. The provision also preserves the FCRA permissible-purpose requirement. **S_WY-P1-C024.** [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4)\n\nThis is separate from the TSR debt-relief trigger. A program making both settlement and credit-improvement representations may require analysis under both provisions.\n\n### 4.4 Conditional CROA overlap\n\nCROA applies only when its elements are met, including a paid service offered through interstate commerce or the mails for an express or implied credit-improvement purpose. It defines “consumer credit transaction” through personal, family, or household purposes and excludes specified §501(c)(3) nonprofits, creditors restructuring their own debt, and depository institutions or credit unions and certain affiliates. Debt settlement is not universally a credit-repair service. **S_WY-P1-C025.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679a/)\n\nWhere CROA applies:\n\n- no fee may be charged or received before the agreed service is fully performed; and\n- the consumer may cancel before midnight of the third business day without penalty.\n\nCROA preserves noninconsistent state law; it does not displace Wyoming’s stricter prohibition. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1679b/)\n\n## 5. Actual regulator permission, lookup, and application evidence\n\n### 5.1 No Chapter 14 issuing regulator or application\n\nChapter 14 names no licensing authority and contains no application procedure. The Division of Banking’s current licensing page does not list debt adjustment or debt settlement among its license categories. The Collection Agency Board’s application and licensee list concern collection agencies, not debtor-side adjustment. **S_WY-P1-C008, C012, C013.** [Wyoming Legislative Services Office+2](https://wyoleg.gov/statutes/compress/title33.pdf)\n\nTherefore, there is no verified state debt-adjuster application or Wyoming debt-adjuster registry to consult. The absence of a webpage is not the primary legal reasoning—the statutory prohibition is.\n\n### 5.2 Condition-specific verification tools\n\n| Claimed pathway | Public verification available | What it proves—and does not prove |\n| --- | --- | --- |\n| Wyoming lawyer | Wyoming State Bar member directory | Verifies Wyoming lawyer licensure; does not prove that a particular debt-relief transaction is genuine legal practice or federally compliant. [Wyoming State Bar](https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/) |\n| Federal tax exemption | IRS Tax Exempt Organization Search | Can support federal exemption status; does not prove the entity is functionally a consumer credit counseling service or satisfies every Wyoming exclusion condition. [IRS](https://apps.irs.gov/app/eos) |\n| Bankruptcy credit counseling | U.S. Trustee Wyoming list | Shows approval under 11 U.S.C. §111 for bankruptcy counseling; it is not a Wyoming debt-adjuster license. [Department of Justice](https://www.justice.gov/ust/credit-counseling-by-state/Wyoming) |\n| Collection agency | Wyoming Collection Agency Board licensee list | Verifies collection-agency status only; not debtor-side settlement authority. [Wyoming Collection Agency Board](https://wyomingcollectionagencyboard.wyo.gov/) |\n| Consumer lender or other UCCC license | Wyoming Division of Banking/NMLS process | Verifies the separate listed financial activity; does not repeal Chapter 14. [Wyoming Banking Division](https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration) |\n| Fintech sandbox | Sandbox application process | Cannot waive Chapter 14 and leaves criminal law applicable. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title40.pdf) |\n\nNo named provider was tested, and no provider authorization is inferred from advertising, a directory entry, a bankruptcy list, or an unrelated license. **S_WY-P1-C026.**\n\n## 6. Worked fee and boundary examples\n\nThe calculations below show classification and timing. A mathematically correct fee is not necessarily legally collectible.\n\n### Example E1 — Noncustodial commercial settlement fee\n\n**Inputs**\n\n- Enrolled debt: $8,000.00  \n- Contracted settlement fee: 18%  \n- Provider does not hold consumer funds\n\n**Operator**\n\n$8,000.00 × 0.18 = $1,440.00\n\n**Numeric result**\n\n$1,440.00\n\n**Legal result**\n\nThe model contracts with a debtor for compensation to compromise or discharge indebtedness under §33-14-101(a)(ii)(A). For a nonexcluded provider, §33-14-102 prohibits the business. The $1,440.00 is therefore **not a Wyoming-authorized fee**. It is not converted into a lawful fee merely because a creditor later accepts an offer or because the federal TSR trigger is satisfied. **C002, C008, C015, C021.**\n\n**Units/rounding:** dollars; rounded to cents.\n\n### Example E2 — Custodial DMP with setup and monthly fees\n\n**Inputs**\n\n- Setup fee: $50.00  \n- Monthly fee: $35.00  \n- Months: 12  \n- Consumer’s creditor payments: $600.00 per month\n\n**Operator**\n\n$50.00 + ($35.00 × 12) = $470.00\n\n**Numeric result**\n\n$470.00 in provider fees.\n\n**Legal result**\n\nReceiving debtor funds and disbursing them to creditors is expressly covered by §33-14-101(a)(ii)(B). A nonexcluded provider cannot make the arrangement lawful by reducing the fee, waiting until the first creditor payment, or describing the charge as administration. **C003, C008, C015.**\n\n### Example E3 — Lower-debt case\n\n**Inputs**\n\n- Debt: $600.00  \n- Proposed fee: 20%\n\n**Operator**\n\n$600.00 × 0.20 = $120.00\n\n**Legal result**\n\nNo de minimis debt or fee exception was found in Chapter 14. The low balance does not create an ordinary commercial pathway. **C002, C008, C015.**\n\n### Example E4 — Conditional nonprofit fixed fees\n\n**Inputs**\n\n- Fixed setup fee: $25.00  \n- Monthly fee: $20.00  \n- Six months\n\n**Operator**\n\n$25.00 + ($20.00 × 6) = $145.00\n\n**Numeric result**\n\n$145.00\n\n**Legal result**\n\nThe arithmetic does not establish legality. The organization must first be an actual tax-exempt nonprofit consumer credit counseling service. Chapter 14 neither caps nor expressly approves the $145.00. If §501(q) applies, the fees must be reasonable and waivable for inability to pay. If the consumer cannot pay, the implemented policy may require waiver, potentially reducing the consumer charge to $0.00. **C010, C016.**\n\nA percentage-of-debt or savings formula is not used in this example because Wyoming has not been verified to affirmatively allow one for purposes of §501(q)(1)(C)(iii).\n\n### Example E5 — Attorney advance and cancellation\n\n**Inputs**\n\n- Advance legal fee deposited: $1,000.00  \n- Amount actually earned under a valid, reasonable engagement before termination: $300.00\n\n**Operator**\n\n$1,000.00 − $300.00 = $700.00\n\n**Result**\n\n- Earned amount: $300.00  \n- Unearned amount to refund: $700.00\n\n**Conditions**\n\nThe unearned advance must have remained in client trust, and the $300.00 must genuinely have been earned under the engagement rather than declared earned merely by contract label. If the TSR or CROA applies, the federal rule may impose a later or stricter collection point. **C017, C018, C021, C025.**\n\n### Example E6 — Federal proportional method with prior earned fees\n\nThis is federal allocation arithmetic only for an independently lawful provider. It does **not** create a lawful commercial Wyoming provider.\n\n**Same enrolled balances throughout**\n\n| Debt | Enrollment balance |\n| --- | --- |\n| A | $2,000.00 |\n| B | $3,000.00 |\n| C | $5,000.00 |\n| **Total** | **$10,000.00** |\n\n**Contracted total fee**\n\n20% × $10,000.00 = $2,000.00\n\nThe provider uses the proportional-enrolled-balance method for every debt.\n\n**Debt A**\n\nAfter a valid executed agreement and the consumer’s first payment:\n\n($2,000 ÷ $10,000) × $2,000 = $400.00\n\n**Debt B**\n\nAfter its own valid executed agreement and first payment:\n\n($3,000 ÷ $10,000) × $2,000 = $600.00\n\n**Reconciliation**\n\n- Previously earned on A: $400.00  \n- Newly earned on B: $600.00  \n- Cumulative earned: $1,000.00  \n- Debt C, no trigger: $0.00 earned  \n- Remaining unearned contracted fee: $1,000.00\n\nNo balance or method changed between debts, and the prior $400.00 is not deducted a second time.\n\n**Failure case:** If B has only an informal creditor offer, no executed agreement, or no first consumer payment under that agreement, the fee for B is $0.00 at that point—not $600.00.\n\n### Example E7 — Dedicated-account cancellation without double deduction\n\nAssume the E6 provider is independently lawful and the consumer withdraws from the debt-relief service.\n\n**Case 1: Current account balance is $1,300.00 and includes the $1,000.00 properly earned but not yet paid to the provider.**\n\n$1,300.00 − $1,000.00 = $300.00 returned within seven business days.\n\n**Case 2: Current account balance is $1,300.00 after the $1,000.00 earned fees were already removed.**\n\nReturn: $1,300.00.\n\nThe provider may not subtract the same earned fee twice. The seven-business-day rule concerns funds currently in the account and excludes only fees actually earned under the prescribed trigger and allocation rules. **C021, C022.**\n\n# B. Source table\n\nAll sources below were accessed or checked on **October 25, 2026, Pacific**, unless a different source-current date is stated.\n\n| Source ID | Title / issuer and direct literal URL | Exact pinpoint, version, and legal status | Actual use and limitations |\n| --- | --- | --- | --- |\n| **S_WY-P1-S001** | Wyoming Statutes, Title 33 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title33.pdf | pp. 110–111, W.S. 33-14-101 through -103; pp. 85–88, W.S. 33-11-101 through -102. Official 2026 compilation; retrieved PDF does not print a precise compilation-through date. | **Freshly read controlling text.** Primary authority for definition, exclusions, prohibition, penalty, and collection boundary. [Wyoming Legislative Services Office+3](https://wyoleg.gov/statutes/compress/title33.pdf) |\n| **S_WY-P1-S002** | 1989 Original Senate File 0133A, Enrolled Act 40, Chapter 92 — Wyoming Legislature scan. https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e | Scan p. 1, §§1–2: amended W.S. 33-14-101(a)(i); effective June 8, 1989; approved February 22, 1989. | **Freshly read historical primary act and page image.** Establishes origin/effective date of current exclusion language. Does not itself establish currentness after 1989. [Knowvation+1](https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e) |\n| **S_WY-P1-S003** | Division of Banking — License and Registration. https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration | Registration/licensing categories and NMLS instructions; page states updated April 27, 2026. | **Freshly read operational material.** Supports current procedure for other financial categories, not legal permission for debt adjusting. [Wyoming Banking Division+1](https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration) |\n| **S_WY-P1-S004** | Wyoming Collection Agency Board. https://wyomingcollectionagencyboard.wyo.gov/ | Licensee list, statutes/regulations, and application-process links. | **Freshly read operational material.** Separate collection-agency procedure only. [Wyoming Collection Agency Board](https://wyomingcollectionagencyboard.wyo.gov/) |\n| **S_WY-P1-S005** | Wyoming Statutes, Title 40 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title40.pdf | pp. 382–385, W.S. 40-29-103 and -104. Official 2026 compilation; precise compilation-through date not printed. | **Freshly read controlling text.** Sandbox waiver list, retained criminal-law applicability, and $500 application fee. [Wyoming Legislative Services Office+2](https://wyoleg.gov/statutes/compress/title40.pdf) |\n| **S_WY-P1-S006** | Wyoming Rules of Professional Conduct, effective-rule compilation. https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf | Rule 1.5, pp. 18–20; current Rule 1.15, p. 68, effective Sept. 21, 2026; Rule 1.16(d), p. 74; Rules 5.4–5.5, pp. 109–111. | **Freshly read controlling court rules.** Used only for attorney pathway; not a nonlawyer debt-adjuster authorization. [Wyoming Judicial Branch+5](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf) |\n| **S_WY-P1-S007** | Rules Governing the Wyoming State Bar and Authorized Practice of Law, consolidated November 2021 file. https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf | Rule 7, pp. 1–2. | **Freshly read for Rule 7 only.** Its old Rule 10 is not used because S008 supplies the later amendment. [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf) |\n| **S_WY-P1-S008** | Order Amending Rule 10 — Wyoming Supreme Court. https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf | Order p. 1 and amended Rule 10; effective January 26, 2026. | **Freshly read controlling amendment order.** Establishes current authorized law-firm forms and lawyer-only practice/fee-sharing conditions. [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf) |\n| **S_WY-P1-S009** | Wyoming State Bar Lawyer Directory. https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/ | Member Directory Search for all lawyers licensed in Wyoming. | **Freshly read lookup instruction.** Verifies licensure only, not transaction-level Chapter 14 or federal compliance. [Wyoming State Bar](https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/) |\n| **S_WY-P1-S010** | 26 U.S.C. §501 — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t26/s501/ | §501(q)(1)(A)–(C), lines corresponding to tailored services, access, reasonable/waivable fees, and percentage-fee restriction; §501(q)(4) definitions. Text through Pub. L. 119-124, Oct. 15, 2026. | **Freshly read federal primary text.** Applies to qualifying federal tax-exempt credit-counseling organizations; does not define Wyoming’s entire exclusion. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t26/s501/) |\n| **S_WY-P1-S011** | IRS Tax Exempt Organization Search. https://apps.irs.gov/app/eos | Search by EIN/name/location. | **Freshly read lookup page.** JavaScript results for no named provider were requested or run. Federal status only. [IRS](https://apps.irs.gov/app/eos) |\n| **S_WY-P1-S012** | U.S. Trustee Program, Credit Counseling Agencies — Wyoming. https://www.justice.gov/ust/credit-counseling-by-state/Wyoming | List of agencies approved pursuant to 11 U.S.C. §111. | **Freshly read operational list.** Bankruptcy approval only; not state debt-adjuster permission. [Department of Justice](https://www.justice.gov/ust/credit-counseling-by-state/Wyoming) |\n| **S_WY-P1-S013** | 16 C.F.R. §310.2 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2 | §310.2(o), debt-relief-service definition. | **Freshly read federal rule.** Federal telemarketing scope only. [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) |\n| **S_WY-P1-S014** | 16 C.F.R. §310.4 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | §310.4(a)(2), credit-improvement timing; §310.4(a)(5)(i)–(ii), debt-relief fee timing, allocation, and dedicated accounts. Title 16 displayed current through Oct. 22, 2026. | **Freshly read federal rule.** Independent restriction, not state permission. [eCFR+2](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) |\n| **S_WY-P1-S015** | 16 C.F.R. §310.6 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6 | §310.6(b)(4)–(7), inbound-advertising, direct-mail, and B2B exemptions. Title 16 displayed current through Oct. 22, 2026. | **Freshly read federal rule.** Used to keep TSR application conditional. [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6) |\n| **S_WY-P1-S016** | 15 U.S.C. §1679a — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679a/ | CROA definitions and exclusions. Text through Pub. L. 119-124, Oct. 15, 2026. | **Freshly read federal primary text.** Conditional credit-improvement overlap only. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679a/) |\n| **S_WY-P1-S017** | 15 U.S.C. §1679b — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679b/ | §1679b(b), advance-payment prohibition. Text through Pub. L. 119-124, Oct. 15, 2026. | **Freshly read federal primary text.** Applies only where CROA’s definition is met. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679b/) |\n| **S_WY-P1-S018** | 15 U.S.C. §1679e — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679e/ | Third-business-day cancellation and document-copy requirements. Text through Pub. L. 119-124, Oct. 15, 2026. | **Freshly read federal primary text.** Conditional CROA application only. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679e/) |\n| **S_WY-P1-S019** | 15 U.S.C. §1679j — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679j/ | State-law savings clause. Text through Pub. L. 119-124, Oct. 15, 2026. | **Freshly read federal primary text.** Confirms no general displacement of noninconsistent Wyoming law. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1679j/) |\n| **S_WY-P1-S020** | Wyoming 2026 statutes portal and legislation landing. https://statutes.wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm and https://www.wyoleg.gov/Legislation/2026 | Official current-statute and 2026 session access routes. | **Discovery/currentness route only.** Operative language was taken from S001/S005, not reconstructed from a title or search snippet. [Wyoming Legislative Services Office+1](https://wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm) |\n\n# C. Claim table\n\n| Claim ID | Precise assertion | Sources and pinpoints | Conditions, exceptions, and confidence |\n| --- | --- | --- | --- |\n| **S_WY-P1-C001** | Chapter 14 defines “person” broadly but excludes a tax-exempt nonprofit consumer credit counseling service, a Wyoming-bar-admitted individual, and an all-Wyoming-bar copartnership or professional corporation. | S001, §33-14-101(a)(i), pp. 110–111; S002, §1. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** “Tax exempt” is not further defined. |\n| **C002** | A debtor-fee contract to adjust, compromise, or discharge debt is covered even without provider custody of funds. | S001, §33-14-101(a)(ii)(A). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **High** for actual fee-based settlement; outer “adjustment” boundary lacks case law. |\n| **C003** | Receiving debtor funds or value and disbursing it to creditors is expressly covered. | S001, §33-14-101(a)(ii)(B). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** |\n| **C004** | Budget counseling, debt management, and debt pooling are named categories; service function controls over marketing label. | S001, §33-14-101(a)(ii). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **High** for listed conduct; pure education remains fact dependent. |\n| **C005** | The reach of the debtor-fee phrase across the entire definition is grammatically unresolved; creditor-paid and wholly free models should be held rather than categorically classified. | S001, §33-14-101(a)(ii). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **Moderate/held.** No Wyoming construction located. |\n| **C006** | Chapter 14 contains no personal/family/household limitation and is potentially applicable to business indebtedness. | S001, §§33-14-101 to -103. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **Moderate.** Penal-statute and no-case limits preserved. |\n| **C007** | Chapter 14 has no express resident, remote-provider, transaction-location, or choice-of-law test. | S001, complete Chapter 14. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **Held** as to exact extraterritorial reach. |\n| **C008** | A nonexcluded person’s debt-adjusting business is prohibited; Chapter 14 creates no license or registration. | S001, §33-14-102(a), complete chapter. [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** |\n| **C009** | Violation is a misdemeanor with up to $100, six months’ county jail, or both, for each violation. | S001, §33-14-103. [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** Other remedies are outside this pass. |\n| **C010** | The nonprofit exclusion is conditional on tax-exempt nonprofit status and actual consumer-credit-counseling function; no state recognition process is supplied. | S001, §33-14-101(a)(i); S002. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **High** on text; meaning of “tax exempt” unresolved. |\n| **C011** | Attorney status and actual practice-of-law clauses overlap; attorney affiliation does not automatically exempt a separate nonlawyer provider. | S001, §§33-14-101(a)(i), -102(b); S007–S008. [Wyoming Legislative Services Office+3](https://wyoleg.gov/statutes/compress/title33.pdf) | **High** as to text; exact overlap lacks a controlling case. |\n| **C012** | A collection-agency license is separate creditor-side authority, not a Chapter 14 debt-adjuster license. | S001, §§33-11-101, -102; S004. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** |\n| **C013** | Current Division of Banking categories do not include debt adjustment; another UCCC/NMLS credential does not override §33-14-102. | S003; S001 §33-14-102. [Wyoming Banking Division+1](https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration) | **High** on listed procedure; separate incidental UCCC obligations remain open. |\n| **C014** | The fintech sandbox cannot waive Title 33, Chapter 14 and leaves criminal law applicable. | S005, §§40-29-103(a)–(b). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title40.pdf) | **High.** |\n| **C015** | Chapter 14 supplies no lawful commercial fee menu, numeric ceiling, indexing, state performance trigger, or refund formula. | S001, complete Chapter 14. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **High.** Do not restate this as a “0% cap.” |\n| **C016** | A federally tax-exempt credit-counseling organization subject to §501(q) needs reasonable fees, inability-to-pay waivers, and generally no percentage formula absent state allowance. | S010, §501(q)(1)(B)–(C). [U.S. Code](https://uscode.house.gov/us/usc/119-124/t26/s501/) | **High** federally; whether Wyoming’s exclusion constitutes state “allowance” is held. |\n| **C017** | Wyoming lawyer fees must be reasonable and the basis/rate communicated; contingent methods require a compliant writing. | S006, Rule 1.5(a)–(c). [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf) | **High.** No Chapter 14 numeric lawyer cap. |\n| **C018** | Paid but unearned legal fees remain in trust until earned; termination requires refund of the unearned advance. | S006, Rules 1.15(d), 1.16(d). [Wyoming Judicial Branch+1](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf) | **High.** Exact earning depends on engagement and applicable law. |\n| **C019** | Nonlawyer fee sharing, ownership, partnership, and professional control are restricted; an attorney shell is not a safe harbor. | S006, Rules 5.4–5.5; S008, Rule 10. [Wyoming Judicial Branch+2](https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf) | **High.** |\n| **C020** | The TSR’s debt-relief definition includes represented alterations of unsecured debt balance, interest, fees, or payment terms. | S013, §310.2(o). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2) | **High**, but federal telemarketing scope must exist. |\n| **C021** | TSR debt-relief fees require an executed debt alteration, first payment, and permitted proportional or same-savings-percentage allocation. | S014, §310.4(a)(5)(i). [eCFR+1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High.** Does not authorize Wyoming-prohibited conduct. |\n| **C022** | A qualifying dedicated account must meet ownership, independence, and withdrawal conditions; qualifying funds must be returned within seven business days. | S014, §310.4(a)(5)(ii). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High.** Withdrawal is from the service, not an invented unconditional bank-account rule. |\n| **C023** | Calls responding to debt-relief advertising/direct mail do not receive ordinary inbound-call exemption; B2B calls are generally exempt. | S015, §310.6(b)(4)–(7). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6) | **High** federally; transaction facts still control. |\n| **C024** | TSR credit-improvement timing is separate and requires expiration of the represented timeframe plus a qualifying later consumer report. | S014, §310.4(a)(2). [eCFR](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4) | **High**, conditional on credit-improvement representations. |\n| **C025** | CROA is conditional, prohibits advance payment before full performance, permits third-business-day cancellation, and preserves noninconsistent state law. | S016–S019. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1679a/) | **High** on federal text; no universal debt-settlement classification asserted. |\n| **C026** | Bar, IRS, UST, collection, and NMLS lookups verify only their respective statuses, not general Wyoming debt-settlement authorization. | S003–S004, S009, S011–S012. [Wyoming Banking Division+4](https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration) | **High.** No named provider checked. |\n| **C027** | No responsive Wyoming administrative rule, controlling public appellate decision, or official AG interpretation was located in the public routes searched. | Research log below. | **Unresolved, not an assertion that none exists.** |\n| **C028** | Current exclusion wording was enacted effective June 8, 1989 and remains in the official 2026 Title 33 compilation. | S001–S002. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **High** for those documents; original 1957 act remains unread. |\n| **C029** | Self-creditor modification may fall outside on elements, but no blanket bank, lender, credit-union, creditor, or government exemption appears in Chapter 14. | S001, complete Chapter 14. [Wyoming Legislative Services Office+1](https://wyoleg.gov/statutes/compress/title33.pdf) | **Moderate/fact dependent.** |\n| **C030** | The sandbox’s $500 application fee is a government application charge, not a consumer debt-adjustment fee or Chapter 14 permission. | S005, §40-29-104(e). [Wyoming Legislative Services Office](https://wyoleg.gov/statutes/compress/title40.pdf) | **High.** |\n\n# D. Scope coverage and gap table\n\n| Component issue | Status | Findings / claim IDs | Exact missing evidence and next investigation |\n| --- | --- | --- | --- |\n| Current operative Chapter 14 text | **Answered** | Prohibition, definitions, exclusions, penalty. C001–C009, C015. | Recheck after any later 2026 special-session or 2027 amendment before publication. |\n| Principal-reduction settlement | **Answered** | Fee-based compromise/discharge covered and prohibited for nonexcluded provider. C002, C008. | Case-law pass for unusual indirect-fee or creditor-funded structures. |\n| Custodial DMP/debt pooling | **Answered** | Expressly covered and prohibited for nonexcluded provider. C003, C008. | Later funds/trust-account and contract pass for excluded entities. |\n| Noncustodial concession management | **Answered with boundary limit** | “Adjustment” and “debt management” support coverage. C004. | Locate Wyoming construction of interest/fee-waiver-only services. |\n| Fee-clause grammar / no-fee model | **Partial** | High-confidence debtor-fee core; wholly free and creditor-paid models held. C005. | Shepardize/KeyCite §§33-14-101 and -102; inspect AG opinions and legislative history. |\n| Consumer versus business debt | **Partial** | No express consumer limitation; business debt potentially covered. C006. | Locate criminal or civil application to business-purpose obligations. |\n| Resident / remote-provider nexus | **Unresolved** | No express territorial clause. C007. | Controlling conflict-of-laws, criminal-jurisdiction, AG, or enforcement authority interpreting Chapter 14. |\n| Nonprofit exclusion | **Partial** | Conditional exclusion established. C010, C016. | Define “tax exempt”; determine whether Wyoming exclusion is sufficient state “allowance” under §501(q)(1)(C)(iii). |\n| Attorney exclusion / legal-practice route | **Answered with interpretive limit** | Status and practice clauses; current bar and business-entity rules. C011, C017–C019. | Controlling interpretation of overlap between §101(a)(i) and §102(b), especially nonlegal lawyer-owned business. |\n| Banks, lenders, credit unions, original creditors | **Partial** | No express institutional exclusion; self-creditor model may fail elements. C029. | Entity-specific enabling statutes and affiliate/fee facts in later sector pass. |\n| Collection-agency license substitution | **Answered** | Separate regime; no substitution. C012. | Full collection-law compliance remains outside this pass. |\n| NMLS/UCCC license substitution | **Answered for substitution** | Current categories do not include debt adjustment. C013. | Later review whether installment financing of an otherwise excluded provider’s fees triggers separate UCCC duties. |\n| Fintech sandbox | **Answered** | Cannot waive Chapter 14. C014, C030. | None for this component unless statute changes. |\n| Commercial state fee limits/indexing | **Answered** | No lawful fee schedule because model is prohibited. C015. | Historical private tables need no reconciliation unless an authority is produced. |\n| Nonprofit fees | **Partial** | No Wyoming number; federal reasonable/waivable policy and percentage restriction. C016. | IRS/state interpretation of “allowed by State law”; entity-specific exemption documents. |\n| Attorney fees/refunds | **Answered at rule level** | Reasonableness, communication, trust, earned withdrawal, refund. C017–C018. | Engagement-specific earning clauses and any applicable contingent-fee rules in a later contract pass. |\n| State performance trigger | **Answered** | None for prohibited commercial model; attorney earned standard. C015, C018. | No further action unless another state-authorized category is identified. |\n| TSR debt-relief timing | **Answered as conditional federal context** | Trigger, allocation, dedicated account, scope exceptions. C020–C023. | Entity, sales-channel, and FTC-jurisdiction facts for a named model. |\n| TSR credit-improvement overlap | **Answered conditionally** | Separate six-month-report rule. C024. | Actual marketing representations and consumer-report process. |\n| CROA overlap | **Answered conditionally** | Definition, advance-fee prohibition, cancellation, state savings. C025. | Actual credit-improvement purpose and statutory exclusions for a named provider. |\n| State regulator/application | **Answered** | No Chapter 14 issuing regulator or application. C008, C013. | Recheck agency materials after statutory amendment only. |\n| Public lookups | **Answered with limits** | Bar, TEOS, UST, collection and NMLS tools classified. C026. | Named-provider verification requires exact legal entity, EIN/license identity, and business model. |\n| Administrative regulations/adoption orders | **Unresolved negative search** | No responsive Chapter 14 rule located. C027. | Manual agency-by-agency Wyoming Rules review; inspect historical/repealed rules and state register. |\n| Controlling cases | **Unresolved** | No responsive official public opinion located. C027. | Paid citator or complete reporter search for §§33-14-101 through -103 and predecessor citations. |\n| Attorney General interpretations | **Unresolved** | No responsive official opinion located. C027. | Inspect complete AG opinion index, older bound opinions, and unindexed formal opinions. |\n| Original 1957 enactment | **Unresolved** | Current text and 1989 amendment read; original act not recovered. C028. | Obtain and read 1957 Wyoming Session Laws, Chapter 159, §§1–4, including effective-date language. |\n| Agreement contents and cancellation | **Excluded/later pass** | Only fee-timing rules needed for this component addressed. | Full Chapter 14, contract, UCCC, federal, and common-law agreement analysis. |\n| Trust accounts, bonds, financial assurance | **Excluded/later pass** | Federal dedicated-account condition addressed only as fee timing. | State/federal funds-control and bond pass for any excluded business model. |\n| Civil remedies, UDAP, restitution, contract enforceability | **Excluded/later pass** | Current misdemeanor noted only because it establishes prohibition. | Dedicated remedies/enforcement pass. |\n| Collections, litigation, statutes of limitation, garnishment | **Excluded/later pass** | Collection license discussed only to prevent category substitution. | Full Wyoming collection/litigation pass. |\n| Secured debt, mortgage, tax, student, medical and other sectors | **Excluded/later pass** | No sector acceptance by implication. | Sector-specific statutory passes. |\n| Local and tribal law | **Excluded/later pass** | No local/tribal conclusion. | Municipality, county, reservation, tribal-code, and jurisdiction research. |\n| Provider contracts and case-specific status | **Excluded/later pass** | No named-provider authorization. | Obtain public contract/form/status evidence in a separately authorized investigation. |\n\n# E. Researcher self-check\n\n## Actually read\n\nI freshly read:\n\n- the complete operative Wyoming Chapter 14 text in the official 2026 Title 33 compilation;\n- the relevant collection-agency definition and licensing boundary in the same title;\n- the scanned 1989 enrolled act and its visible effective date;\n- the Title 40 sandbox waiver list, criminal-law preservation clause, application provisions, and $500 governmental fee;\n- the current Division of Banking licensing page and Collection Agency Board page;\n- current Wyoming attorney fee, trust-account, termination, fee-sharing, unauthorized-practice, authorized-practice, and business-entity provisions;\n- the Wyoming lawyer-directory instruction;\n- 26 U.S.C. §501(q);\n- the IRS TEOS lookup page and U.S. Trustee Wyoming list;\n- current eCFR §§310.2, 310.4, and 310.6; and\n- CROA §§1679a, 1679b, 1679e, and 1679j.\n\nFor PDFs materially analyzed, page images were inspected in addition to parsed text, including the current statute pages, sandbox pages, attorney-rule pages, Rule 10 order, and 1989 enrolled act.\n\n## Searched but not established\n\nPublic official-domain searches were run for:\n\n- Wyoming administrative rules mentioning debt adjusters or debt adjusting;\n- Wyoming Judicial Branch opinions citing Chapter 14;\n- Wyoming Attorney General materials citing Chapter 14;\n- 2026 legislation amending §§33-14-101 through -103; and\n- the original 1957 session act.\n\nThose routes did not yield a responsive rule, controlling decision, AG opinion, 2026 amendment, or readable 1957 act during this pass. That is a qualified research result, not proof that no unindexed or commercial-database authority exists.\n\n## Not read or not done\n\nI did not:\n\n- recover or read 1957 Wyoming Session Laws, Chapter 159;\n- use a paid citator, Lexis, Westlaw, Bloomberg, or purchased historical source;\n- perform a complete unindexed trial-court docket search;\n- determine a named provider’s status;\n- run an IRS TEOS query for a named EIN;\n- submit an application, contact an agency, or ask for an interpretive opinion;\n- inspect private contracts or borrower information;\n- complete the parent-state agreement, funds, bond, remedies, collection, litigation, limitations, sector, local, tribal, or case-law passes;\n- create local files or claim publication readiness; or\n- conduct an independent review of this response.\n\n**Pass conclusion:** Wyoming currently presents a prohibition-based market-access rule for nonexcluded fee-based debt adjustment. No ordinary commercial licensing or fee-cap pathway was established. The conditional nonprofit and legal-practice routes require proof of their actual elements and remain subject to their own fee, professional, and federal constraints.\n\nEND S_WY PASS-01.\n\n","tables":[{"headers":["Business model","Wyoming Chapter 14 result","Consumer-fee result"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Business model","Wyoming Chapter 14 result","Consumer-fee result"],["Nonexcluded commercial principal-reduction or debt-settlement provider charging the debtor","Prohibited, not licensable under Chapter 14","No Wyoming-authorized settlement, savings, per-debt, enrollment, setup, or monthly fee"],["Nonexcluded custodial DMP/debt-pooling provider receiving and distributing debtor funds","Prohibited, not licensable under Chapter 14","No Wyoming-authorized setup, monthly, remittance, or aggregate fee"],["Noncustodial concession service negotiating interest, fees, or payment terms for debtor compensation","Strongly within “adjustment”/“debt management”; prohibited","No Chapter 14 fee pathway"],["Pure financial education with no debt adjustment, no fund handling, and no fee contract to perform §101(a)(ii)(A) or (B) conduct","Potentially outside; facts control","Not affirmatively licensed or approved by Chapter 14"],["Creditor adjusting its own debt, with no separate debtor-paid adjustment service","Likely outside on statutory elements, not an express institutional exemption","Separate fees and affiliate structures require fact-specific analysis"],["Tax-exempt nonprofit consumer credit counseling service","Excluded from Chapter 14’s definition of “person” only if all status and functional conditions are real","No Wyoming numeric cap; federal tax-exemption conditions may restrict fee methods"],["Wyoming-admitted lawyer / qualifying all-lawyer entity","Textual exclusion; actual legal-practice situations also separately outside the act","No Chapter 14 numeric cap; professional-conduct and applicable federal timing rules remain"],["Attorney-affiliated nonlawyer company","Not automatically excluded","Attorney participation cannot be used as a wrapper for otherwise prohibited nonlawyer activity"],["Collection agency, lender, creditor, bank, credit union, or NMLS licensee providing third-party debtor-side adjustment","Other credential does not substitute for Chapter 14 authority","Separate credential does not create a debt-adjustment fee right"],["Wyoming fintech-sandbox participant","Sandbox cannot waive Title 33, Chapter 14 and does not immunize criminal conduct","$500 sandbox application fee is a government charge, not a consumer debt-adjustment fee"],["Remote provider serving Wyoming debtors","No express territorial clause; likely substantial Wyoming nexus, but exact reach is unresolved","Do not treat remote location or choice-of-law wording as a safe harbor"],["Business-purpose debt service","No consumer-purpose limitation appears in Chapter 14; potentially covered","Business debt is not safely outside merely because the TSR may be inapplicable"]]},{"headers":["Claimed pathway","Public verification available","What it proves—and does not prove"],"index":1,"links":[{"href":"https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","text":"Wyoming State Bar"},{"href":"https://apps.irs.gov/app/eos","text":"IRS"},{"href":"https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","text":"Department of Justice"},{"href":"https://wyomingcollectionagencyboard.wyo.gov/","text":"Wyoming Collection Agency Board"},{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division"},{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office\n+1"}],"row_links":[[],[{"href":"https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","text":"Wyoming State Bar"}],[{"href":"https://apps.irs.gov/app/eos","text":"IRS"}],[{"href":"https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","text":"Department of Justice"}],[{"href":"https://wyomingcollectionagencyboard.wyo.gov/","text":"Wyoming Collection Agency Board"}],[{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division"}],[{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office\n+1"}]],"rows":[["Claimed pathway","Public verification available","What it proves—and does not prove"],["Wyoming lawyer","Wyoming State Bar member directory","Verifies Wyoming lawyer licensure; does not prove that a particular debt-relief transaction is genuine legal practice or federally compliant. \nWyoming State Bar"],["Federal tax exemption","IRS Tax Exempt Organization Search","Can support federal exemption status; does not prove the entity is functionally a consumer credit counseling service or satisfies every Wyoming exclusion condition. \nIRS"],["Bankruptcy credit counseling","U.S. Trustee Wyoming list","Shows approval under 11 U.S.C. §111 for bankruptcy counseling; it is not a Wyoming debt-adjuster license. \nDepartment of Justice"],["Collection agency","Wyoming Collection Agency Board licensee list","Verifies collection-agency status only; not debtor-side settlement authority. \nWyoming Collection Agency Board"],["Consumer lender or other UCCC license","Wyoming Division of Banking/NMLS process","Verifies the separate listed financial activity; does not repeal Chapter 14. \nWyoming Banking Division"],["Fintech sandbox","Sandbox application process","Cannot waive Chapter 14 and leaves criminal law applicable. \nWyoming Legislative Services Office\n+1"]]},{"headers":["Debt","Enrollment balance"],"index":2,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Debt","Enrollment balance"],["A","$2,000.00"],["B","$3,000.00"],["C","$5,000.00"],["Total","$10,000.00"]]},{"headers":["Source ID","Title / issuer and direct literal URL","Exact pinpoint, version, and legal status","Actual use and limitations"],"index":3,"links":[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+3"},{"href":"https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e","text":"Knowvation\n+1"},{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+1"},{"href":"https://wyomingcollectionagencyboard.wyo.gov/","text":"Wyoming Collection Agency Board"},{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office\n+2"},{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+5"},{"href":"https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf","text":"Wyoming Judicial Branch\n+1"},{"href":"https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf","text":"Wyoming Judicial Branch\n+1"},{"href":"https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","text":"Wyoming State Bar"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s501/","text":"U.S. Code\n+3"},{"href":"https://apps.irs.gov/app/eos","text":"IRS"},{"href":"https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","text":"Department of Justice"},{"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\n+2"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679b/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679e/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679j/","text":"U.S. Code"},{"href":"https://wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm","text":"Wyoming Legislative Services Office\n+1"}],"row_links":[[],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+3"}],[{"href":"https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e","text":"Knowvation\n+1"}],[{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+1"}],[{"href":"https://wyomingcollectionagencyboard.wyo.gov/","text":"Wyoming Collection Agency Board"}],[{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office\n+2"}],[{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+5"}],[{"href":"https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf","text":"Wyoming Judicial Branch\n+1"}],[{"href":"https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf","text":"Wyoming Judicial Branch\n+1"}],[{"href":"https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","text":"Wyoming State Bar"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s501/","text":"U.S. Code\n+3"}],[{"href":"https://apps.irs.gov/app/eos","text":"IRS"}],[{"href":"https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","text":"Department of Justice"}],[{"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\n+2"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","text":"eCFR\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679b/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679e/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679j/","text":"U.S. Code"}],[{"href":"https://wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm","text":"Wyoming Legislative Services Office\n+1"}]],"rows":[["Source ID","Title / issuer and direct literal URL","Exact pinpoint, version, and legal status","Actual use and limitations"],["S_WY-P1-S001","Wyoming Statutes, Title 33 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title33.pdf","pp. 110–111, W.S. 33-14-101 through -103; pp. 85–88, W.S. 33-11-101 through -102. Official 2026 compilation; retrieved PDF does not print a precise compilation-through date.","Freshly read controlling text. Primary authority for definition, exclusions, prohibition, penalty, and collection boundary. \nWyoming Legislative Services Office\n+3"],["S_WY-P1-S002","1989 Original Senate File 0133A, Enrolled Act 40, Chapter 92 — Wyoming Legislature scan. https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e","Scan p. 1, §§1–2: amended W.S. 33-14-101(a)(i); effective June 8, 1989; approved February 22, 1989.","Freshly read historical primary act and page image. Establishes origin/effective date of current exclusion language. Does not itself establish currentness after 1989. \nKnowvation\n+1"],["S_WY-P1-S003","Division of Banking — License and Registration. https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","Registration/licensing categories and NMLS instructions; page states updated April 27, 2026.","Freshly read operational material. Supports current procedure for other financial categories, not legal permission for debt adjusting. \nWyoming Banking Division\n+1"],["S_WY-P1-S004","Wyoming Collection Agency Board. https://wyomingcollectionagencyboard.wyo.gov/","Licensee list, statutes/regulations, and application-process links.","Freshly read operational material. Separate collection-agency procedure only. \nWyoming Collection Agency Board"],["S_WY-P1-S005","Wyoming Statutes, Title 40 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title40.pdf","pp. 382–385, W.S. 40-29-103 and -104. Official 2026 compilation; precise compilation-through date not printed.","Freshly read controlling text. Sandbox waiver list, retained criminal-law applicability, and $500 application fee. \nWyoming Legislative Services Office\n+2"],["S_WY-P1-S006","Wyoming Rules of Professional Conduct, effective-rule compilation. https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","Rule 1.5, pp. 18–20; current Rule 1.15, p. 68, effective Sept. 21, 2026; Rule 1.16(d), p. 74; Rules 5.4–5.5, pp. 109–111.","Freshly read controlling court rules. Used only for attorney pathway; not a nonlawyer debt-adjuster authorization. \nWyoming Judicial Branch\n+5"],["S_WY-P1-S007","Rules Governing the Wyoming State Bar and Authorized Practice of Law, consolidated November 2021 file. https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf","Rule 7, pp. 1–2.","Freshly read for Rule 7 only. Its old Rule 10 is not used because S008 supplies the later amendment. \nWyoming Judicial Branch\n+1"],["S_WY-P1-S008","Order Amending Rule 10 — Wyoming Supreme Court. https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf","Order p. 1 and amended Rule 10; effective January 26, 2026.","Freshly read controlling amendment order. Establishes current authorized law-firm forms and lawyer-only practice/fee-sharing conditions. \nWyoming Judicial Branch\n+1"],["S_WY-P1-S009","Wyoming State Bar Lawyer Directory. https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","Member Directory Search for all lawyers licensed in Wyoming.","Freshly read lookup instruction. Verifies licensure only, not transaction-level Chapter 14 or federal compliance. \nWyoming State Bar"],["S_WY-P1-S010","26 U.S.C. §501 — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t26/s501/","§501(q)(1)(A)–(C), lines corresponding to tailored services, access, reasonable/waivable fees, and percentage-fee restriction; §501(q)(4) definitions. Text through Pub. L. 119-124, Oct. 15, 2026.","Freshly read federal primary text. Applies to qualifying federal tax-exempt credit-counseling organizations; does not define Wyoming’s entire exclusion. \nU.S. Code\n+3"],["S_WY-P1-S011","IRS Tax Exempt Organization Search. https://apps.irs.gov/app/eos","Search by EIN/name/location.","Freshly read lookup page. JavaScript results for no named provider were requested or run. Federal status only. \nIRS"],["S_WY-P1-S012","U.S. Trustee Program, Credit Counseling Agencies — Wyoming. https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","List of agencies approved pursuant to 11 U.S.C. §111.","Freshly read operational list. Bankruptcy approval only; not state debt-adjuster permission. \nDepartment of Justice"],["S_WY-P1-S013","16 C.F.R. §310.2 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","§310.2(o), debt-relief-service definition.","Freshly read federal rule. Federal telemarketing scope only. \neCFR"],["S_WY-P1-S014","16 C.F.R. §310.4 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","§310.4(a)(2), credit-improvement timing; §310.4(a)(5)(i)–(ii), debt-relief fee timing, allocation, and dedicated accounts. Title 16 displayed current through Oct. 22, 2026.","Freshly read federal rule. Independent restriction, not state permission. \neCFR\n+2"],["S_WY-P1-S015","16 C.F.R. §310.6 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","§310.6(b)(4)–(7), inbound-advertising, direct-mail, and B2B exemptions. Title 16 displayed current through Oct. 22, 2026.","Freshly read federal rule. Used to keep TSR application conditional. \neCFR\n+1"],["S_WY-P1-S016","15 U.S.C. §1679a — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679a/","CROA definitions and exclusions. Text through Pub. L. 119-124, Oct. 15, 2026.","Freshly read federal primary text. Conditional credit-improvement overlap only. \nU.S. Code"],["S_WY-P1-S017","15 U.S.C. §1679b — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679b/","§1679b(b), advance-payment prohibition. Text through Pub. L. 119-124, Oct. 15, 2026.","Freshly read federal primary text. Applies only where CROA’s definition is met. \nU.S. Code"],["S_WY-P1-S018","15 U.S.C. §1679e — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679e/","Third-business-day cancellation and document-copy requirements. Text through Pub. L. 119-124, Oct. 15, 2026.","Freshly read federal primary text. Conditional CROA application only. \nU.S. Code"],["S_WY-P1-S019","15 U.S.C. §1679j — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679j/","State-law savings clause. Text through Pub. L. 119-124, Oct. 15, 2026.","Freshly read federal primary text. Confirms no general displacement of noninconsistent Wyoming law. \nU.S. Code"],["S_WY-P1-S020","Wyoming 2026 statutes portal and legislation landing. https://statutes.wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm and https://www.wyoleg.gov/Legislation/2026","Official current-statute and 2026 session access routes.","Discovery/currentness route only. Operative language was taken from S001/S005, not reconstructed from a title or search snippet. \nWyoming Legislative Services Office\n+1"]]},{"headers":["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, and confidence"],"index":4,"links":[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+3"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s501/","text":"U.S. Code"},{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+1"},{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+1"},{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+2"},{"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\n+1"},{"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-310.6","text":"eCFR"},{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"},{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+4"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"},{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office"}],"row_links":[[],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+3"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s501/","text":"U.S. Code"}],[{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+1"}],[{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+1"}],[{"href":"https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","text":"Wyoming Judicial Branch\n+2"}],[{"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\n+1"}],[{"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-310.6","text":"eCFR"}],[{"href":"https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","text":"eCFR"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1679a/","text":"U.S. Code\n+3"}],[{"href":"https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","text":"Wyoming Banking Division\n+4"}],[],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title33.pdf","text":"Wyoming Legislative Services Office\n+1"}],[{"href":"https://wyoleg.gov/statutes/compress/title40.pdf","text":"Wyoming Legislative Services Office"}]],"rows":[["Claim ID","Precise assertion","Sources and pinpoints","Conditions, exceptions, and confidence"],["S_WY-P1-C001","Chapter 14 defines “person” broadly but excludes a tax-exempt nonprofit consumer credit counseling service, a Wyoming-bar-admitted individual, and an all-Wyoming-bar copartnership or professional corporation.","S001, §33-14-101(a)(i), pp. 110–111; S002, §1. \nWyoming Legislative Services Office\n+1","High. “Tax exempt” is not further defined."],["C002","A debtor-fee contract to adjust, compromise, or discharge debt is covered even without provider custody of funds.","S001, §33-14-101(a)(ii)(A). \nWyoming Legislative Services Office","High for actual fee-based settlement; outer “adjustment” boundary lacks case law."],["C003","Receiving debtor funds or value and disbursing it to creditors is expressly covered.","S001, §33-14-101(a)(ii)(B). \nWyoming Legislative Services Office","High."],["C004","Budget counseling, debt management, and debt pooling are named categories; service function controls over marketing label.","S001, §33-14-101(a)(ii). \nWyoming Legislative Services Office","High for listed conduct; pure education remains fact dependent."],["C005","The reach of the debtor-fee phrase across the entire definition is grammatically unresolved; creditor-paid and wholly free models should be held rather than categorically classified.","S001, §33-14-101(a)(ii). \nWyoming Legislative Services Office","Moderate/held. No Wyoming construction located."],["C006","Chapter 14 contains no personal/family/household limitation and is potentially applicable to business indebtedness.","S001, §§33-14-101 to -103. \nWyoming Legislative Services Office\n+1","Moderate. Penal-statute and no-case limits preserved."],["C007","Chapter 14 has no express resident, remote-provider, transaction-location, or choice-of-law test.","S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","Held as to exact extraterritorial reach."],["C008","A nonexcluded person’s debt-adjusting business is prohibited; Chapter 14 creates no license or registration.","S001, §33-14-102(a), complete chapter. \nWyoming Legislative Services Office","High."],["C009","Violation is a misdemeanor with up to $100, six months’ county jail, or both, for each violation.","S001, §33-14-103. \nWyoming Legislative Services Office","High. Other remedies are outside this pass."],["C010","The nonprofit exclusion is conditional on tax-exempt nonprofit status and actual consumer-credit-counseling function; no state recognition process is supplied.","S001, §33-14-101(a)(i); S002. \nWyoming Legislative Services Office\n+1","High on text; meaning of “tax exempt” unresolved."],["C011","Attorney status and actual practice-of-law clauses overlap; attorney affiliation does not automatically exempt a separate nonlawyer provider.","S001, §§33-14-101(a)(i), -102(b); S007–S008. \nWyoming Legislative Services Office\n+3","High as to text; exact overlap lacks a controlling case."],["C012","A collection-agency license is separate creditor-side authority, not a Chapter 14 debt-adjuster license.","S001, §§33-11-101, -102; S004. \nWyoming Legislative Services Office\n+1","High."],["C013","Current Division of Banking categories do not include debt adjustment; another UCCC/NMLS credential does not override §33-14-102.","S003; S001 §33-14-102. \nWyoming Banking Division\n+1","High on listed procedure; separate incidental UCCC obligations remain open."],["C014","The fintech sandbox cannot waive Title 33, Chapter 14 and leaves criminal law applicable.","S005, §§40-29-103(a)–(b). \nWyoming Legislative Services Office","High."],["C015","Chapter 14 supplies no lawful commercial fee menu, numeric ceiling, indexing, state performance trigger, or refund formula.","S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","High. Do not restate this as a “0% cap.”"],["C016","A federally tax-exempt credit-counseling organization subject to §501(q) needs reasonable fees, inability-to-pay waivers, and generally no percentage formula absent state allowance.","S010, §501(q)(1)(B)–(C). \nU.S. Code","High federally; whether Wyoming’s exclusion constitutes state “allowance” is held."],["C017","Wyoming lawyer fees must be reasonable and the basis/rate communicated; contingent methods require a compliant writing.","S006, Rule 1.5(a)–(c). \nWyoming Judicial Branch\n+1","High. No Chapter 14 numeric lawyer cap."],["C018","Paid but unearned legal fees remain in trust until earned; termination requires refund of the unearned advance.","S006, Rules 1.15(d), 1.16(d). \nWyoming Judicial Branch\n+1","High. Exact earning depends on engagement and applicable law."],["C019","Nonlawyer fee sharing, ownership, partnership, and professional control are restricted; an attorney shell is not a safe harbor.","S006, Rules 5.4–5.5; S008, Rule 10. \nWyoming Judicial Branch\n+2","High."],["C020","The TSR’s debt-relief definition includes represented alterations of unsecured debt balance, interest, fees, or payment terms.","S013, §310.2(o). \neCFR","High, but federal telemarketing scope must exist."],["C021","TSR debt-relief fees require an executed debt alteration, first payment, and permitted proportional or same-savings-percentage allocation.","S014, §310.4(a)(5)(i). \neCFR\n+1","High. Does not authorize Wyoming-prohibited conduct."],["C022","A qualifying dedicated account must meet ownership, independence, and withdrawal conditions; qualifying funds must be returned within seven business days.","S014, §310.4(a)(5)(ii). \neCFR","High. Withdrawal is from the service, not an invented unconditional bank-account rule."],["C023","Calls responding to debt-relief advertising/direct mail do not receive ordinary inbound-call exemption; B2B calls are generally exempt.","S015, §310.6(b)(4)–(7). \neCFR","High federally; transaction facts still control."],["C024","TSR credit-improvement timing is separate and requires expiration of the represented timeframe plus a qualifying later consumer report.","S014, §310.4(a)(2). \neCFR","High, conditional on credit-improvement representations."],["C025","CROA is conditional, prohibits advance payment before full performance, permits third-business-day cancellation, and preserves noninconsistent state law.","S016–S019. \nU.S. Code\n+3","High on federal text; no universal debt-settlement classification asserted."],["C026","Bar, IRS, UST, collection, and NMLS lookups verify only their respective statuses, not general Wyoming debt-settlement authorization.","S003–S004, S009, S011–S012. \nWyoming Banking Division\n+4","High. No named provider checked."],["C027","No responsive Wyoming administrative rule, controlling public appellate decision, or official AG interpretation was located in the public routes searched.","Research log below.","Unresolved, not an assertion that none exists."],["C028","Current exclusion wording was enacted effective June 8, 1989 and remains in the official 2026 Title 33 compilation.","S001–S002. \nWyoming Legislative Services Office\n+1","High for those documents; original 1957 act remains unread."],["C029","Self-creditor modification may fall outside on elements, but no blanket bank, lender, credit-union, creditor, or government exemption appears in Chapter 14.","S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","Moderate/fact dependent."],["C030","The sandbox’s $500 application fee is a government application charge, not a consumer debt-adjustment fee or Chapter 14 permission.","S005, §40-29-104(e). \nWyoming Legislative Services Office","High."]]},{"headers":["Component issue","Status","Findings / claim IDs","Exact missing evidence and next investigation"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Component issue","Status","Findings / claim IDs","Exact missing evidence and next investigation"],["Current operative Chapter 14 text","Answered","Prohibition, definitions, exclusions, penalty. C001–C009, C015.","Recheck after any later 2026 special-session or 2027 amendment before publication."],["Principal-reduction settlement","Answered","Fee-based compromise/discharge covered and prohibited for nonexcluded provider. C002, C008.","Case-law pass for unusual indirect-fee or creditor-funded structures."],["Custodial DMP/debt pooling","Answered","Expressly covered and prohibited for nonexcluded provider. C003, C008.","Later funds/trust-account and contract pass for excluded entities."],["Noncustodial concession management","Answered with boundary limit","“Adjustment” and “debt management” support coverage. C004.","Locate Wyoming construction of interest/fee-waiver-only services."],["Fee-clause grammar / no-fee model","Partial","High-confidence debtor-fee core; wholly free and creditor-paid models held. C005.","Shepardize/KeyCite §§33-14-101 and -102; inspect AG opinions and legislative history."],["Consumer versus business debt","Partial","No express consumer limitation; business debt potentially covered. C006.","Locate criminal or civil application to business-purpose obligations."],["Resident / remote-provider nexus","Unresolved","No express territorial clause. C007.","Controlling conflict-of-laws, criminal-jurisdiction, AG, or enforcement authority interpreting Chapter 14."],["Nonprofit exclusion","Partial","Conditional exclusion established. C010, C016.","Define “tax exempt”; determine whether Wyoming exclusion is sufficient state “allowance” under §501(q)(1)(C)(iii)."],["Attorney exclusion / legal-practice route","Answered with interpretive limit","Status and practice clauses; current bar and business-entity rules. C011, C017–C019.","Controlling interpretation of overlap between §101(a)(i) and §102(b), especially nonlegal lawyer-owned business."],["Banks, lenders, credit unions, original creditors","Partial","No express institutional exclusion; self-creditor model may fail elements. C029.","Entity-specific enabling statutes and affiliate/fee facts in later sector pass."],["Collection-agency license substitution","Answered","Separate regime; no substitution. C012.","Full collection-law compliance remains outside this pass."],["NMLS/UCCC license substitution","Answered for substitution","Current categories do not include debt adjustment. C013.","Later review whether installment financing of an otherwise excluded provider’s fees triggers separate UCCC duties."],["Fintech sandbox","Answered","Cannot waive Chapter 14. C014, C030.","None for this component unless statute changes."],["Commercial state fee limits/indexing","Answered","No lawful fee schedule because model is prohibited. C015.","Historical private tables need no reconciliation unless an authority is produced."],["Nonprofit fees","Partial","No Wyoming number; federal reasonable/waivable policy and percentage restriction. C016.","IRS/state interpretation of “allowed by State law”; entity-specific exemption documents."],["Attorney fees/refunds","Answered at rule level","Reasonableness, communication, trust, earned withdrawal, refund. C017–C018.","Engagement-specific earning clauses and any applicable contingent-fee rules in a later contract pass."],["State performance trigger","Answered","None for prohibited commercial model; attorney earned standard. C015, C018.","No further action unless another state-authorized category is identified."],["TSR debt-relief timing","Answered as conditional federal context","Trigger, allocation, dedicated account, scope exceptions. C020–C023.","Entity, sales-channel, and FTC-jurisdiction facts for a named model."],["TSR credit-improvement overlap","Answered conditionally","Separate six-month-report rule. C024.","Actual marketing representations and consumer-report process."],["CROA overlap","Answered conditionally","Definition, advance-fee prohibition, cancellation, state savings. C025.","Actual credit-improvement purpose and statutory exclusions for a named provider."],["State regulator/application","Answered","No Chapter 14 issuing regulator or application. C008, C013.","Recheck agency materials after statutory amendment only."],["Public lookups","Answered with limits","Bar, TEOS, UST, collection and NMLS tools classified. C026.","Named-provider verification requires exact legal entity, EIN/license identity, and business model."],["Administrative regulations/adoption orders","Unresolved negative search","No responsive Chapter 14 rule located. C027.","Manual agency-by-agency Wyoming Rules review; inspect historical/repealed rules and state register."],["Controlling cases","Unresolved","No responsive official public opinion located. C027.","Paid citator or complete reporter search for §§33-14-101 through -103 and predecessor citations."],["Attorney General interpretations","Unresolved","No responsive official opinion located. C027.","Inspect complete AG opinion index, older bound opinions, and unindexed formal opinions."],["Original 1957 enactment","Unresolved","Current text and 1989 amendment read; original act not recovered. C028.","Obtain and read 1957 Wyoming Session Laws, Chapter 159, §§1–4, including effective-date language."],["Agreement contents and cancellation","Excluded/later pass","Only fee-timing rules needed for this component addressed.","Full Chapter 14, contract, UCCC, federal, and common-law agreement analysis."],["Trust accounts, bonds, financial assurance","Excluded/later pass","Federal dedicated-account condition addressed only as fee timing.","State/federal funds-control and bond pass for any excluded business model."],["Civil remedies, UDAP, restitution, contract enforceability","Excluded/later pass","Current misdemeanor noted only because it establishes prohibition.","Dedicated remedies/enforcement pass."],["Collections, litigation, statutes of limitation, garnishment","Excluded/later pass","Collection license discussed only to prevent category substitution.","Full Wyoming collection/litigation pass."],["Secured debt, mortgage, tax, student, medical and other sectors","Excluded/later pass","No sector acceptance by implication.","Sector-specific statutory passes."],["Local and tribal law","Excluded/later pass","No local/tribal conclusion.","Municipality, county, reservation, tribal-code, and jurisdiction research."],["Provider contracts and case-specific status","Excluded/later pass","No named-provider authorization.","Obtain public contract/form/status evidence in a separately authorized investigation."]]}],"claims":[{"claim_id":"S_WY-P1-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_WY-P1-C001","Precise assertion":"Chapter 14 defines “person” broadly but excludes a tax-exempt nonprofit consumer credit counseling service, a Wyoming-bar-admitted individual, and an all-Wyoming-bar copartnership or professional corporation.","Sources and pinpoints":"S001, §33-14-101(a)(i), pp. 110–111; S002, §1. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"High. “Tax exempt” is not further defined."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","Precise assertion":"A debtor-fee contract to adjust, compromise, or discharge debt is covered even without provider custody of funds.","Sources and pinpoints":"S001, §33-14-101(a)(ii)(A). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High for actual fee-based settlement; outer “adjustment” boundary lacks case law."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","Precise assertion":"Receiving debtor funds or value and disbursing it to creditors is expressly covered.","Sources and pinpoints":"S001, §33-14-101(a)(ii)(B). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","Precise assertion":"Budget counseling, debt management, and debt pooling are named categories; service function controls over marketing label.","Sources and pinpoints":"S001, §33-14-101(a)(ii). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High for listed conduct; pure education remains fact dependent."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","Precise assertion":"The reach of the debtor-fee phrase across the entire definition is grammatically unresolved; creditor-paid and wholly free models should be held rather than categorically classified.","Sources and pinpoints":"S001, §33-14-101(a)(ii). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"Moderate/held. No Wyoming construction located."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","Precise assertion":"Chapter 14 contains no personal/family/household limitation and is potentially applicable to business indebtedness.","Sources and pinpoints":"S001, §§33-14-101 to -103. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"Moderate. Penal-statute and no-case limits preserved."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","Precise assertion":"Chapter 14 has no express resident, remote-provider, transaction-location, or choice-of-law test.","Sources and pinpoints":"S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"Held as to exact extraterritorial reach."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","Precise assertion":"A nonexcluded person’s debt-adjusting business is prohibited; Chapter 14 creates no license or registration.","Sources and pinpoints":"S001, §33-14-102(a), complete chapter. \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","Precise assertion":"Violation is a misdemeanor with up to $100, six months’ county jail, or both, for each violation.","Sources and pinpoints":"S001, §33-14-103. \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High. Other remedies are outside this pass."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","Precise assertion":"The nonprofit exclusion is conditional on tax-exempt nonprofit status and actual consumer-credit-counseling function; no state recognition process is supplied.","Sources and pinpoints":"S001, §33-14-101(a)(i); S002. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"High on text; meaning of “tax exempt” unresolved."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","Precise assertion":"Attorney status and actual practice-of-law clauses overlap; attorney affiliation does not automatically exempt a separate nonlawyer provider.","Sources and pinpoints":"S001, §§33-14-101(a)(i), -102(b); S007–S008. \nWyoming Legislative Services Office\n+3","Conditions, exceptions, and confidence":"High as to text; exact overlap lacks a controlling case."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C012","Precise assertion":"A collection-agency license is separate creditor-side authority, not a Chapter 14 debt-adjuster license.","Sources and pinpoints":"S001, §§33-11-101, -102; S004. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C013","Precise assertion":"Current Division of Banking categories do not include debt adjustment; another UCCC/NMLS credential does not override §33-14-102.","Sources and pinpoints":"S003; S001 §33-14-102. \nWyoming Banking Division\n+1","Conditions, exceptions, and confidence":"High on listed procedure; separate incidental UCCC obligations remain open."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C014","Precise assertion":"The fintech sandbox cannot waive Title 33, Chapter 14 and leaves criminal law applicable.","Sources and pinpoints":"S005, §§40-29-103(a)–(b). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C015","Precise assertion":"Chapter 14 supplies no lawful commercial fee menu, numeric ceiling, indexing, state performance trigger, or refund formula.","Sources and pinpoints":"S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"High. Do not restate this as a “0% cap.”"},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C016","Precise assertion":"A federally tax-exempt credit-counseling organization subject to §501(q) needs reasonable fees, inability-to-pay waivers, and generally no percentage formula absent state allowance.","Sources and pinpoints":"S010, §501(q)(1)(B)–(C). \nU.S. Code","Conditions, exceptions, and confidence":"High federally; whether Wyoming’s exclusion constitutes state “allowance” is held."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C017","Precise assertion":"Wyoming lawyer fees must be reasonable and the basis/rate communicated; contingent methods require a compliant writing.","Sources and pinpoints":"S006, Rule 1.5(a)–(c). \nWyoming Judicial Branch\n+1","Conditions, exceptions, and confidence":"High. No Chapter 14 numeric lawyer cap."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C018","Precise assertion":"Paid but unearned legal fees remain in trust until earned; termination requires refund of the unearned advance.","Sources and pinpoints":"S006, Rules 1.15(d), 1.16(d). \nWyoming Judicial Branch\n+1","Conditions, exceptions, and confidence":"High. Exact earning depends on engagement and applicable law."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C019","Precise assertion":"Nonlawyer fee sharing, ownership, partnership, and professional control are restricted; an attorney shell is not a safe harbor.","Sources and pinpoints":"S006, Rules 5.4–5.5; S008, Rule 10. \nWyoming Judicial Branch\n+2","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C020","Precise assertion":"The TSR’s debt-relief definition includes represented alterations of unsecured debt balance, interest, fees, or payment terms.","Sources and pinpoints":"S013, §310.2(o). \neCFR","Conditions, exceptions, and confidence":"High, but federal telemarketing scope must exist."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C021","Precise assertion":"TSR debt-relief fees require an executed debt alteration, first payment, and permitted proportional or same-savings-percentage allocation.","Sources and pinpoints":"S014, §310.4(a)(5)(i). \neCFR\n+1","Conditions, exceptions, and confidence":"High. Does not authorize Wyoming-prohibited conduct."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C022","Precise assertion":"A qualifying dedicated account must meet ownership, independence, and withdrawal conditions; qualifying funds must be returned within seven business days.","Sources and pinpoints":"S014, §310.4(a)(5)(ii). \neCFR","Conditions, exceptions, and confidence":"High. Withdrawal is from the service, not an invented unconditional bank-account rule."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C023","Precise assertion":"Calls responding to debt-relief advertising/direct mail do not receive ordinary inbound-call exemption; B2B calls are generally exempt.","Sources and pinpoints":"S015, §310.6(b)(4)–(7). \neCFR","Conditions, exceptions, and confidence":"High federally; transaction facts still control."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C024","Precise assertion":"TSR credit-improvement timing is separate and requires expiration of the represented timeframe plus a qualifying later consumer report.","Sources and pinpoints":"S014, §310.4(a)(2). \neCFR","Conditions, exceptions, and confidence":"High, conditional on credit-improvement representations."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C025","Precise assertion":"CROA is conditional, prohibits advance payment before full performance, permits third-business-day cancellation, and preserves noninconsistent state law.","Sources and pinpoints":"S016–S019. \nU.S. Code\n+3","Conditions, exceptions, and confidence":"High on federal text; no universal debt-settlement classification asserted."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C026","Precise assertion":"Bar, IRS, UST, collection, and NMLS lookups verify only their respective statuses, not general Wyoming debt-settlement authorization.","Sources and pinpoints":"S003–S004, S009, S011–S012. \nWyoming Banking Division\n+4","Conditions, exceptions, and confidence":"High. No named provider checked."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C027","Precise assertion":"No responsive Wyoming administrative rule, controlling public appellate decision, or official AG interpretation was located in the public routes searched.","Sources and pinpoints":"Research log below.","Conditions, exceptions, and confidence":"Unresolved, not an assertion that none exists."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C028","Precise assertion":"Current exclusion wording was enacted effective June 8, 1989 and remains in the official 2026 Title 33 compilation.","Sources and pinpoints":"S001–S002. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"High for those documents; original 1957 act remains unread."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C029","Precise assertion":"Self-creditor modification may fall outside on elements, but no blanket bank, lender, credit-union, creditor, or government exemption appears in Chapter 14.","Sources and pinpoints":"S001, complete Chapter 14. \nWyoming Legislative Services Office\n+1","Conditions, exceptions, and confidence":"Moderate/fact dependent."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_WY-P1-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C030","Precise assertion":"The sandbox’s $500 application fee is a government application charge, not a consumer debt-adjustment fee or Chapter 14 permission.","Sources and pinpoints":"S005, §40-29-104(e). \nWyoming Legislative Services Office","Conditions, exceptions, and confidence":"High."},"coordinator_verification_status":"scoped_checked_with_explicit_remaining_holds","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_WY-P1-S001","urls":["https://wyoleg.gov/statutes/compress/title33.pdf"],"researcher_record":{"Source ID":"S_WY-P1-S001","Title / issuer and direct literal URL":"Wyoming Statutes, Title 33 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title33.pdf","Exact pinpoint, version, and legal status":"pp. 110–111, W.S. 33-14-101 through -103; pp. 85–88, W.S. 33-11-101 through -102. Official 2026 compilation; retrieved PDF does not print a precise compilation-through date.","Actual use and limitations":"Freshly read controlling text. Primary authority for definition, exclusions, prohibition, penalty, and collection boundary. \nWyoming Legislative Services Office\n+3"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S002","urls":["https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e"],"researcher_record":{"Source ID":"S_WY-P1-S002","Title / issuer and direct literal URL":"1989 Original Senate File 0133A, Enrolled Act 40, Chapter 92 — Wyoming Legislature scan. https://wyomingdigitalcollections.ptfs.com/aw-server/rest/product/purl/WSL/s/0f787d1d-f469-4376-b2c1-77b01712939e","Exact pinpoint, version, and legal status":"Scan p. 1, §§1–2: amended W.S. 33-14-101(a)(i); effective June 8, 1989; approved February 22, 1989.","Actual use and limitations":"Freshly read historical primary act and page image. Establishes origin/effective date of current exclusion language. Does not itself establish currentness after 1989. \nKnowvation\n+1"},"coordinator_verification_status":"fresh_historical_body_partial_dates_unverified","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S003","urls":["https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration"],"researcher_record":{"Source ID":"S_WY-P1-S003","Title / issuer and direct literal URL":"Division of Banking — License and Registration. https://wyomingbankingdivision.wyo.gov/consumer-lending/license-and-registration","Exact pinpoint, version, and legal status":"Registration/licensing categories and NMLS instructions; page states updated April 27, 2026.","Actual use and limitations":"Freshly read operational material. Supports current procedure for other financial categories, not legal permission for debt adjusting. \nWyoming Banking Division\n+1"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S004","urls":["https://wyomingcollectionagencyboard.wyo.gov/"],"researcher_record":{"Source ID":"S_WY-P1-S004","Title / issuer and direct literal URL":"Wyoming Collection Agency Board. https://wyomingcollectionagencyboard.wyo.gov/","Exact pinpoint, version, and legal status":"Licensee list, statutes/regulations, and application-process links.","Actual use and limitations":"Freshly read operational material. Separate collection-agency procedure only. \nWyoming Collection Agency Board"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S005","urls":["https://wyoleg.gov/statutes/compress/title40.pdf"],"researcher_record":{"Source ID":"S_WY-P1-S005","Title / issuer and direct literal URL":"Wyoming Statutes, Title 40 — Wyoming Legislature / LSO. https://wyoleg.gov/statutes/compress/title40.pdf","Exact pinpoint, version, and legal status":"pp. 382–385, W.S. 40-29-103 and -104. Official 2026 compilation; precise compilation-through date not printed.","Actual use and limitations":"Freshly read controlling text. Sandbox waiver list, retained criminal-law applicability, and $500 application fee. \nWyoming Legislative Services Office\n+2"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S006","urls":["https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf"],"researcher_record":{"Source ID":"S_WY-P1-S006","Title / issuer and direct literal URL":"Wyoming Rules of Professional Conduct, effective-rule compilation. https://www.wyocourts.gov/app/uploads/2026/06/WY-Rules-Prof-Conduct-Eff.-9-21-26.pdf","Exact pinpoint, version, and legal status":"Rule 1.5, pp. 18–20; current Rule 1.15, p. 68, effective Sept. 21, 2026; Rule 1.16(d), p. 74; Rules 5.4–5.5, pp. 109–111.","Actual use and limitations":"Freshly read controlling court rules. Used only for attorney pathway; not a nonlawyer debt-adjuster authorization. \nWyoming Judicial Branch\n+5"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S007","urls":["https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf"],"researcher_record":{"Source ID":"S_WY-P1-S007","Title / issuer and direct literal URL":"Rules Governing the Wyoming State Bar and Authorized Practice of Law, consolidated November 2021 file. https://www.wyocourts.gov/app/uploads/2025/01/RULES-GOVERNING-THE-WYOMING-STATE-BAR-AND-THE-AUTHORIZED-PRACTICE-OF-LAW-Nov-2021-1.pdf","Exact pinpoint, version, and legal status":"Rule 7, pp. 1–2.","Actual use and limitations":"Freshly read for Rule 7 only. Its old Rule 10 is not used because S008 supplies the later amendment. \nWyoming Judicial Branch\n+1"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S008","urls":["https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf"],"researcher_record":{"Source ID":"S_WY-P1-S008","Title / issuer and direct literal URL":"Order Amending Rule 10 — Wyoming Supreme Court. https://www.wyocourts.gov/app/uploads/2025/11/Order-Amending-Rule-10-for-the-Authorized-Practice-of-Law-Effective-Jan-2026.pdf","Exact pinpoint, version, and legal status":"Order p. 1 and amended Rule 10; effective January 26, 2026.","Actual use and limitations":"Freshly read controlling amendment order. Establishes current authorized law-firm forms and lawyer-only practice/fee-sharing conditions. \nWyoming Judicial Branch\n+1"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S009","urls":["https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/"],"researcher_record":{"Source ID":"S_WY-P1-S009","Title / issuer and direct literal URL":"Wyoming State Bar Lawyer Directory. https://www.wyomingbar.org/for-the-public/hire-a-lawyer/lawyer-search/","Exact pinpoint, version, and legal status":"Member Directory Search for all lawyers licensed in Wyoming.","Actual use and limitations":"Freshly read lookup instruction. Verifies licensure only, not transaction-level Chapter 14 or federal compliance. \nWyoming State Bar"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S010","urls":["https://uscode.house.gov/us/usc/119-124/t26/s501/"],"researcher_record":{"Source ID":"S_WY-P1-S010","Title / issuer and direct literal URL":"26 U.S.C. §501 — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t26/s501/","Exact pinpoint, version, and legal status":"§501(q)(1)(A)–(C), lines corresponding to tailored services, access, reasonable/waivable fees, and percentage-fee restriction; §501(q)(4) definitions. Text through Pub. L. 119-124, Oct. 15, 2026.","Actual use and limitations":"Freshly read federal primary text. Applies to qualifying federal tax-exempt credit-counseling organizations; does not define Wyoming’s entire exclusion. \nU.S. Code\n+3"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S011","urls":["https://apps.irs.gov/app/eos"],"researcher_record":{"Source ID":"S_WY-P1-S011","Title / issuer and direct literal URL":"IRS Tax Exempt Organization Search. https://apps.irs.gov/app/eos","Exact pinpoint, version, and legal status":"Search by EIN/name/location.","Actual use and limitations":"Freshly read lookup page. JavaScript results for no named provider were requested or run. Federal status only. \nIRS"},"coordinator_verification_status":"fresh_generic_page_javascript_limited_no_status_check","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S012","urls":["https://www.justice.gov/ust/credit-counseling-by-state/Wyoming"],"researcher_record":{"Source ID":"S_WY-P1-S012","Title / issuer and direct literal URL":"U.S. Trustee Program, Credit Counseling Agencies — Wyoming. https://www.justice.gov/ust/credit-counseling-by-state/Wyoming","Exact pinpoint, version, and legal status":"List of agencies approved pursuant to 11 U.S.C. §111.","Actual use and limitations":"Freshly read operational list. Bankruptcy approval only; not state debt-adjuster permission. \nDepartment of Justice"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S013","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2"],"researcher_record":{"Source ID":"S_WY-P1-S013","Title / issuer and direct literal URL":"16 C.F.R. §310.2 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.2","Exact pinpoint, version, and legal status":"§310.2(o), debt-relief-service definition.","Actual use and limitations":"Freshly read federal rule. Federal telemarketing scope only. \neCFR"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S014","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4"],"researcher_record":{"Source ID":"S_WY-P1-S014","Title / issuer and direct literal URL":"16 C.F.R. §310.4 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4","Exact pinpoint, version, and legal status":"§310.4(a)(2), credit-improvement timing; §310.4(a)(5)(i)–(ii), debt-relief fee timing, allocation, and dedicated accounts. Title 16 displayed current through Oct. 22, 2026.","Actual use and limitations":"Freshly read federal rule. Independent restriction, not state permission. \neCFR\n+2"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S015","urls":["https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6"],"researcher_record":{"Source ID":"S_WY-P1-S015","Title / issuer and direct literal URL":"16 C.F.R. §310.6 — eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.6","Exact pinpoint, version, and legal status":"§310.6(b)(4)–(7), inbound-advertising, direct-mail, and B2B exemptions. Title 16 displayed current through Oct. 22, 2026.","Actual use and limitations":"Freshly read federal rule. Used to keep TSR application conditional. \neCFR\n+1"},"coordinator_verification_status":"fresh_selected_body_checked_with_limits","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S016","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679a/"],"researcher_record":{"Source ID":"S_WY-P1-S016","Title / issuer and direct literal URL":"15 U.S.C. §1679a — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679a/","Exact pinpoint, version, and legal status":"CROA definitions and exclusions. Text through Pub. L. 119-124, Oct. 15, 2026.","Actual use and limitations":"Freshly read federal primary text. Conditional credit-improvement overlap only. \nU.S. Code"},"coordinator_verification_status":"fresh_routes_failed_explicit_dated_same_coordinator_body_reuse_PL119120","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S017","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679b/"],"researcher_record":{"Source ID":"S_WY-P1-S017","Title / issuer and direct literal URL":"15 U.S.C. §1679b — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679b/","Exact pinpoint, version, and legal status":"§1679b(b), advance-payment prohibition. Text through Pub. L. 119-124, Oct. 15, 2026.","Actual use and limitations":"Freshly read federal primary text. Applies only where CROA’s definition is met. \nU.S. Code"},"coordinator_verification_status":"fresh_routes_failed_explicit_dated_same_coordinator_body_reuse_PL119120","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S018","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679e/"],"researcher_record":{"Source ID":"S_WY-P1-S018","Title / issuer and direct literal URL":"15 U.S.C. §1679e — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679e/","Exact pinpoint, version, and legal status":"Third-business-day cancellation and document-copy requirements. Text through Pub. L. 119-124, Oct. 15, 2026.","Actual use and limitations":"Freshly read federal primary text. Conditional CROA application only. \nU.S. Code"},"coordinator_verification_status":"fresh_routes_failed_explicit_dated_same_coordinator_body_reuse_PL119120","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S019","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1679j/"],"researcher_record":{"Source ID":"S_WY-P1-S019","Title / issuer and direct literal URL":"15 U.S.C. §1679j — U.S. House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1679j/","Exact pinpoint, version, and legal status":"State-law savings clause. Text through Pub. L. 119-124, Oct. 15, 2026.","Actual use and limitations":"Freshly read federal primary text. Confirms no general displacement of noninconsistent Wyoming law. \nU.S. Code"},"coordinator_verification_status":"fresh_routes_failed_explicit_dated_same_coordinator_body_reuse_PL119120","coordinator_review":"[internal evidence reference]"},{"source_id":"S_WY-P1-S020","urls":["https://statutes.wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm","https://www.wyoleg.gov/Legislation/2026","https://wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm"],"researcher_record":{"Source ID":"S_WY-P1-S020","Title / issuer and direct literal URL":"Wyoming 2026 statutes portal and legislation landing. https://statutes.wyoleg.gov/NXT/gateway.dll?f=templates&fn=default.htm and https://www.wyoleg.gov/Legislation/2026","Exact pinpoint, version, and legal status":"Official current-statute and 2026 session access routes.","Actual use and limitations":"Discovery/currentness route only. Operative language was taken from S001/S005, not reconstructed from a title or search snippet. \nWyoming Legislative Services Office\n+1"},"coordinator_verification_status":"researcher_attributed_discovery_not_freshly_reopened","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"Current operative Chapter 14 text","researcher_record":{"Component issue":"Current operative Chapter 14 text","Status":"Answered","Findings / claim IDs":"Prohibition, definitions, exclusions, penalty. C001–C009, C015.","Exact missing evidence and next investigation":"Recheck after any later 2026 special-session or 2027 amendment before publication."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Principal-reduction settlement","researcher_record":{"Component issue":"Principal-reduction settlement","Status":"Answered","Findings / claim IDs":"Fee-based compromise/discharge covered and prohibited for nonexcluded provider. C002, C008.","Exact missing evidence and next investigation":"Case-law pass for unusual indirect-fee or creditor-funded structures."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Custodial DMP/debt pooling","researcher_record":{"Component issue":"Custodial DMP/debt pooling","Status":"Answered","Findings / claim IDs":"Expressly covered and prohibited for nonexcluded provider. C003, C008.","Exact missing evidence and next investigation":"Later funds/trust-account and contract pass for excluded entities."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Noncustodial concession management","researcher_record":{"Component issue":"Noncustodial concession management","Status":"Answered with boundary limit","Findings / claim IDs":"“Adjustment” and “debt management” support coverage. C004.","Exact missing evidence and next investigation":"Locate Wyoming construction of interest/fee-waiver-only services."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Fee-clause grammar / no-fee model","researcher_record":{"Component issue":"Fee-clause grammar / no-fee model","Status":"Partial","Findings / claim IDs":"High-confidence debtor-fee core; wholly free and creditor-paid models held. C005.","Exact missing evidence and next investigation":"Shepardize/KeyCite §§33-14-101 and -102; inspect AG opinions and legislative history."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer versus business debt","researcher_record":{"Component issue":"Consumer versus business debt","Status":"Partial","Findings / claim IDs":"No express consumer limitation; business debt potentially covered. C006.","Exact missing evidence and next investigation":"Locate criminal or civil application to business-purpose obligations."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Resident / remote-provider nexus","researcher_record":{"Component issue":"Resident / remote-provider nexus","Status":"Unresolved","Findings / claim IDs":"No express territorial clause. C007.","Exact missing evidence and next investigation":"Controlling conflict-of-laws, criminal-jurisdiction, AG, or enforcement authority interpreting Chapter 14."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit exclusion","researcher_record":{"Component issue":"Nonprofit exclusion","Status":"Partial","Findings / claim IDs":"Conditional exclusion established. C010, C016.","Exact missing evidence and next investigation":"Define “tax exempt”; determine whether Wyoming exclusion is sufficient state “allowance” under §501(q)(1)(C)(iii)."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney exclusion / legal-practice route","researcher_record":{"Component issue":"Attorney exclusion / legal-practice route","Status":"Answered with interpretive limit","Findings / claim IDs":"Status and practice clauses; current bar and business-entity rules. C011, C017–C019.","Exact missing evidence and next investigation":"Controlling interpretation of overlap between §101(a)(i) and §102(b), especially nonlegal lawyer-owned business."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Banks, lenders, credit unions, original creditors","researcher_record":{"Component issue":"Banks, lenders, credit unions, original creditors","Status":"Partial","Findings / claim IDs":"No express institutional exclusion; self-creditor model may fail elements. C029.","Exact missing evidence and next investigation":"Entity-specific enabling statutes and affiliate/fee facts in later sector pass."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Collection-agency license substitution","researcher_record":{"Component issue":"Collection-agency license substitution","Status":"Answered","Findings / claim IDs":"Separate regime; no substitution. C012.","Exact missing evidence and next investigation":"Full collection-law compliance remains outside this pass."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"NMLS/UCCC license substitution","researcher_record":{"Component issue":"NMLS/UCCC license substitution","Status":"Answered for substitution","Findings / claim IDs":"Current categories do not include debt adjustment. C013.","Exact missing evidence and next investigation":"Later review whether installment financing of an otherwise excluded provider’s fees triggers separate UCCC duties."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Fintech sandbox","researcher_record":{"Component issue":"Fintech sandbox","Status":"Answered","Findings / claim IDs":"Cannot waive Chapter 14. C014, C030.","Exact missing evidence and next investigation":"None for this component unless statute changes."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Commercial state fee limits/indexing","researcher_record":{"Component issue":"Commercial state fee limits/indexing","Status":"Answered","Findings / claim IDs":"No lawful fee schedule because model is prohibited. C015.","Exact missing evidence and next investigation":"Historical private tables need no reconciliation unless an authority is produced."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Nonprofit fees","researcher_record":{"Component issue":"Nonprofit fees","Status":"Partial","Findings / claim IDs":"No Wyoming number; federal reasonable/waivable policy and percentage restriction. C016.","Exact missing evidence and next investigation":"IRS/state interpretation of “allowed by State law”; entity-specific exemption documents."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney fees/refunds","researcher_record":{"Component issue":"Attorney fees/refunds","Status":"Answered at rule level","Findings / claim IDs":"Reasonableness, communication, trust, earned withdrawal, refund. C017–C018.","Exact missing evidence and next investigation":"Engagement-specific earning clauses and any applicable contingent-fee rules in a later contract pass."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State performance trigger","researcher_record":{"Component issue":"State performance trigger","Status":"Answered","Findings / claim IDs":"None for prohibited commercial model; attorney earned standard. C015, C018.","Exact missing evidence and next investigation":"No further action unless another state-authorized category is identified."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"TSR debt-relief timing","researcher_record":{"Component issue":"TSR debt-relief timing","Status":"Answered as conditional federal context","Findings / claim IDs":"Trigger, allocation, dedicated account, scope exceptions. C020–C023.","Exact missing evidence and next investigation":"Entity, sales-channel, and FTC-jurisdiction facts for a named model."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"TSR credit-improvement overlap","researcher_record":{"Component issue":"TSR credit-improvement overlap","Status":"Answered conditionally","Findings / claim IDs":"Separate six-month-report rule. C024.","Exact missing evidence and next investigation":"Actual marketing representations and consumer-report process."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"CROA overlap","researcher_record":{"Component issue":"CROA overlap","Status":"Answered conditionally","Findings / claim IDs":"Definition, advance-fee prohibition, cancellation, state savings. C025.","Exact missing evidence and next investigation":"Actual credit-improvement purpose and statutory exclusions for a named provider."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State regulator/application","researcher_record":{"Component issue":"State regulator/application","Status":"Answered","Findings / claim IDs":"No Chapter 14 issuing regulator or application. C008, C013.","Exact missing evidence and next investigation":"Recheck agency materials after statutory amendment only."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Public lookups","researcher_record":{"Component issue":"Public lookups","Status":"Answered with limits","Findings / claim IDs":"Bar, TEOS, UST, collection and NMLS tools classified. C026.","Exact missing evidence and next investigation":"Named-provider verification requires exact legal entity, EIN/license identity, and business model."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Administrative regulations/adoption orders","researcher_record":{"Component issue":"Administrative regulations/adoption orders","Status":"Unresolved negative search","Findings / claim IDs":"No responsive Chapter 14 rule located. C027.","Exact missing evidence and next investigation":"Manual agency-by-agency Wyoming Rules review; inspect historical/repealed rules and state register."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Controlling cases","researcher_record":{"Component issue":"Controlling cases","Status":"Unresolved","Findings / claim IDs":"No responsive official public opinion located. C027.","Exact missing evidence and next investigation":"Paid citator or complete reporter search for §§33-14-101 through -103 and predecessor citations."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Attorney General interpretations","researcher_record":{"Component issue":"Attorney General interpretations","Status":"Unresolved","Findings / claim IDs":"No responsive official opinion located. C027.","Exact missing evidence and next investigation":"Inspect complete AG opinion index, older bound opinions, and unindexed formal opinions."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Original 1957 enactment","researcher_record":{"Component issue":"Original 1957 enactment","Status":"Unresolved","Findings / claim IDs":"Current text and 1989 amendment read; original act not recovered. C028.","Exact missing evidence and next investigation":"Obtain and read 1957 Wyoming Session Laws, Chapter 159, §§1–4, including effective-date language."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Agreement contents and cancellation","researcher_record":{"Component issue":"Agreement contents and cancellation","Status":"Excluded/later pass","Findings / claim IDs":"Only fee-timing rules needed for this component addressed.","Exact missing evidence and next investigation":"Full Chapter 14, contract, UCCC, federal, and common-law agreement analysis."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Trust accounts, bonds, financial assurance","researcher_record":{"Component issue":"Trust accounts, bonds, financial assurance","Status":"Excluded/later pass","Findings / claim IDs":"Federal dedicated-account condition addressed only as fee timing.","Exact missing evidence and next investigation":"State/federal funds-control and bond pass for any excluded business model."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Civil remedies, UDAP, restitution, contract enforceability","researcher_record":{"Component issue":"Civil remedies, UDAP, restitution, contract enforceability","Status":"Excluded/later pass","Findings / claim IDs":"Current misdemeanor noted only because it establishes prohibition.","Exact missing evidence and next investigation":"Dedicated remedies/enforcement pass."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Collections, litigation, statutes of limitation, garnishment","researcher_record":{"Component issue":"Collections, litigation, statutes of limitation, garnishment","Status":"Excluded/later pass","Findings / claim IDs":"Collection license discussed only to prevent category substitution.","Exact missing evidence and next investigation":"Full Wyoming collection/litigation pass."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Secured debt, mortgage, tax, student, medical and other sectors","researcher_record":{"Component issue":"Secured debt, mortgage, tax, student, medical and other sectors","Status":"Excluded/later pass","Findings / claim IDs":"No sector acceptance by implication.","Exact missing evidence and next investigation":"Sector-specific statutory passes."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Local and tribal law","researcher_record":{"Component issue":"Local and tribal law","Status":"Excluded/later pass","Findings / claim IDs":"No local/tribal conclusion.","Exact missing evidence and next investigation":"Municipality, county, reservation, tribal-code, and jurisdiction research."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Provider contracts and case-specific status","researcher_record":{"Component issue":"Provider contracts and case-specific status","Status":"Excluded/later pass","Findings / claim IDs":"No named-provider authorization.","Exact missing evidence and next investigation":"Obtain public contract/form/status evidence in a separately authorized investigation."},"coordinator_acceptance":"scoped_checked_with_explicit_remaining_holds","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T18:09:41.030569+00:00","status":"scoped_review_complete_with_limits","review":"[internal evidence reference]","raw_originals_unchanged":true,"historical_C028_exact_dates":"researcherattributed_freshunverified_OCRinsufficient_noPDFpixels","CROA":"failedfreshcurrentroutes_explicitdatedbodyreuse_PL119120_notcurrentverification","no_component_acceptance":true},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"S_WY-P1-provider-fees-evidence-limits-20261027","status":"review_complete_with_remaining_evidence_and_components_held","at":"2026-10-27T18:09:41.030569+00:00"}]}