Which place’s debt rules apply—and who can help?

SettleADebt J_GU PASS-01 — Guam

Debt-relief provider regulation and applicability gateways

Research dossier — not approved for publication or operational relianceResearch baseline: October 22, 2026, Pacific time Public-source verification: October 26, 2026, Pacific time Scope: Provider classification, authorization, fees, agreements, customer funds, enforcement, and territorial/federal applicability. The other six territory-dossier dimensions remain deferred.

Research provenance: Prepared in regular Chat using public web searches and opened primary-source text. No Deep Research, private records, account access, filings, contacts, or business operations. The interface does not independently expose a verifiable model/reasoning-tier identifier for this report, so no particular Pro tier is claimed.

1. Guam jurisdiction and source-authority map

Authorities: J_GU-P01-S001–S011, S029–S032; claims C001–C005, C017–C018. Ch. 1 The Laws of Guam+4

Currentness finding

A real version problem exists:

• The official Compiler's 14 GCA Chapter 7 PDF bears COL120106—a 2006 compilation marker.
• The Guam general business-license chapter bears COL 2025-12-23.
• The Consumer Protection Act PDF bears COL10/29/2021.
• The Compiler's 38th-Legislature table of affected code sections reaches Public Law 38-133.
• The Legislature's public-law index, checked October 26, lists enactments through Public Law 38-145, signed October 17, 2026. The Compiler's various update notices do not uniformly reach that point.

The descriptions of recent public laws do not identify a targeted amendment to Chapter 7, but neither an older PDF nor an index search establishes conclusively that every intervening enactment, uncodified provision, rule, or effective-date provision has been reconciled. The Chapter 7 findings below are therefore verified text, with a live-law reconciliation hold, not a certification of the law currently in force in every detail. An enactment date, page-update date, and statutory effective date are different things. The Chapter 7 text expressly traces its original enactment to Public Law 9-253, approved September 4, 1968, effective June 30, 1969. [C001–C002, C040] Uniform Consumer Credit Code+4

Federal geographic reach must be determined statute by statute:

• TSR statute: 15 U.S.C. § 6106(3) includes U.S. territories and possessions in its definition of “State”; the regulatory definition in 16 CFR § 310.2(ff) does likewise. TSR telemarketing requires a campaign involving more than one interstate telephone call. Guam's inclusion does not make every Guam debt-relief transaction a TSR transaction.
• FTC Act: 15 U.S.C. § 44 includes commerce within a U.S. territory in its commerce definition; its definition of “corporation” is relevant to bona fide nonprofit jurisdiction.
• CFPB Title X: 12 U.S.C. § 5481(27) expressly names Guam, and § 5481(15)(A)(viii) includes individual financial advice concerning debt management or settlement within a potentially covered financial-product/service category.
• CROA: 15 U.S.C. § 1679a applies its definition through interstate-commerce instrumentalities or the mails, not through an assumed Guam-equals-state provision in that section.
• Bankruptcy: The District Court of Guam exercises bankruptcy jurisdiction. U.S. Trustee approval of bankruptcy credit-counseling agencies is not authorization to operate a Guam credit-counseling business under 14 GCA Chapter 7. [C004–C005, C022, C028, C033] uscode.house.gov+5

2. The central Guam provider statute

14 GCA Chapter 7, “Nonprofit Consumer Credit Counseling Agencies,” is the decisive located territorial provider-specific enactment. It is not merely a licensing statute for entities voluntarily using the label “credit counselor.” Its definition covers three alternative forms of conduct:

1. Specialized counseling for members of the public suffering or potentially suffering economic hardship from credit.
2. Acting as an agent for those individuals to resolve their economic difficulties.
3. Receiving their money or other value for disbursement to creditors.

A paid service that negotiates existing consumer debts on the debtor's behalf has a substantial textual path into the second category. A DMP operator receiving monthly debtor payments has a substantial path into the third. The absence of the marketing term “debt settlement” from the statute is not a safe exclusion. Whether a purely commercial-debt engagement or a remote provider with no Guam establishment is covered requires a separate analysis of the statutory language, transaction facts, and territorial nexus. [C006, C043] Uniform Consumer Credit Code

Section 7103 prohibits engaging in, or holding oneself out as engaging in, the business of credit counseling, except for the statute's authorized agencies and specified persons.

Classification and exemption decision table

Sources and claims: S005; C006–C009, C041–C043. Uniform Consumer Credit Code+2

A separate, specifically named Guam debt-settlement-company act, debt-adjuster act, or credit-services-organization licensing act was NOT LOCATED in the bounded official search described in the evidence section. This is not a finding that such conduct is unregulated. Chapter 7 itself is substantial regulation, while the business-license, local telemarketing, deceptive-practices, and federal regimes can create additional obligations.

3. Authorization, registration, security, and oversight

Chapter 7 authorized-agency path

For an agency relying on § 7103(1), the located enacted text requires:

Do not describe this as an ordinary “$5,000 licensing fee.” The $5,000 is a surety-bond amount, not a statutory application fee and not a service-fee ceiling. Nor is advance notification alone an express grant of a proprietary “debt settlement license.” [C009–C010, C019–C020] Uniform Consumer Credit Code+1

Three other registration layers

Under the local telephonic-seller provision, solicitation from Guam or solicitation directed to prospective purchasers located in Guam supplies an express geographic connection. A non-Guam principal office triggers the additional designation of a Guam statutory agent for service under § 32306(c). Registrants must disclose organizational, location, principal, salesperson, script, and other required information. Material-change updates are subject to statutory timing, including a special quarterly process for salesperson changes. [C011–C018] Government Operations+5

Important statutory tension: Guam § 32304 states that a covered telemarketing sale of services is not final/enforceable until the consumer signs and delivers the agreement. But § 32301's definition of telemarketing excludes a transaction later reduced to a consumer-signed contract. These provisions must be read together before asserting that every telephone-negotiated, ultimately signed debt-relief contract requires § 32302 registration. No controlling reconciliation was established in this pass. Federal TSR coverage uses a different definition, so a Guam telemarketing exclusion is not necessarily a federal exclusion. [C013–C015, C022–C023]

The DRT's public website provides account-based business-license renewal, not evidence of a public, unauthenticated directory verifying Chapter 7 agency authorization or Attorney General telephonic-seller registration. A dedicated provider-status lookup was NOT LOCATED; no provider-specific search was undertaken. [C038] guamtax.com+1

Finally, 14 GCA Chapter 6 is an enforcement gateway requiring caution. Its official older PDF could be found in a Guam Judiciary search index but could not be opened as operative text here. The indexed § 6102 limits its Article 1 language to specified lenders/credit transactions and payment collection/enforcement; it is not safe to attach every Chapter 6 investigation or cease-and-desist power automatically to every Chapter 7 counseling intermediary. Its older procedural text also refers to appellate arrangements that require reconciliation with the later federal Organic Act. [C017–C018]

4. Provider charges and federal overlays

Guam fee law

Sections 7109(4) and 7111 allow an authorized nonprofit agency to charge reasonable fees under a schedule submitted to the Administrator and consistent with the agency's nonprofit nature. Section 7109 separately permits solicitation and acceptance of contributions.

The opened Chapter 7 text does not supply:

• A universal percentage of debt or savings that may be charged;
• A dollar maximum per debtor or debt;
• An express Chapter 7 settlement-success fee trigger;
• A standardized setup or monthly-fee allowance;
• A default, refund, or early-termination fee formula; or
• An across-the-board rule equating voluntary donations or creditor “fair-share” payments with permissible customer charges.

These are text-bounded absences, not findings that unrestricted charges are legal. Actual fee schedules and any further operative rules were not accessed. [C019, C021, C040]

Federal TSR: separate and sometimes much more restrictive

If a covered seller or telemarketer markets a service represented to alter debts owed to unsecured creditors or debt collectors, the TSR applies based on its own campaign, person, and exemption tests.

Under 16 CFR § 310.4(a)(5)(i), a covered seller/telemarketer cannot request or receive a debt-relief service fee until all three relevant conditions are satisfied:

1. At least one debt has actually been renegotiated, settled, reduced, or otherwise altered under a valid agreement executed by the customer.
2. The customer has made at least one payment under that new agreement to the creditor or debt collector.
3. For debts individually altered, the fee attributed to that debt follows one of two permitted allocation methods: proportional allocation based on enrolled balances, or a consistent percentage of actual savings.

Funding a reserve account alone does not satisfy the first-creditor-payment requirement. A success claim, verbal promise, or proposal not accepted and executed does not satisfy the first condition. A Guam agency's filed fee schedule cannot override these federal triggers. [C024–C026] ecfr.gov+1

When a covered provider requires a dedicated reserve account, § 310.4(a)(5)(ii) requires an insured financial institution, customer ownership and accrued interest, an independent account administrator with specified nonaffiliation/nonreferral conditions, and withdrawal without a penalty. On withdrawal, account funds other than lawfully earned fees must be returned within seven business days of the request. This is not an unrestricted seven-day right to cancel all Guam financial contracts. [C026]

The TSR also requires truthful pre-enrollment disclosures about the anticipated results and time, projected accumulation needed before settlement offers, risks arising from missed creditor payments, and account rights where applicable. Misrepresenting likely savings, completion periods, effects on creditors, or nonprofit status is separately restricted. [C024] ecfr.gov+1

Federal exclusions must be tested, not assumed. The rule treats unsolicited inbound calls, advertising-response calls, direct-mail responses, face-to-face presentations, and business-to-business transactions differently. Crucially, the ordinary advertising-response and direct-mail exemptions contain explicit debt-relief exceptions. A genuine nonprofit outside the FTC Act's corporate jurisdiction raises another distinct question; marketing by a for-profit vendor does not become exempt merely because its client is a nonprofit. An attorney is not categorically exempt from the TSR. [C022–C023, C042] ecfr.gov+1

Credit repair: overlapping but different product

If the marketed service expressly or implicitly offers, for compensation through interstate instrumentalities or the mails, to improve an individual's credit record/history/rating or provide advice for doing so, CROA classification must be tested separately. A debt-settlement label does not decide it. CROA excludes a qualifying 501(c)(3) tax-exempt organization, certain creditors restructuring their own debt, and specified depository institutions and credit unions. Merely filing Guam nonprofit articles is not equivalent to proven 501(c)(3) exemption. [C028, C042] uscode.house.gov

For an actual CROA-covered organization:

• 15 U.S.C. § 1679b(b): no money for promised credit-repair services before full performance.
• § 1679c: prescribed separate precontract consumer-rights disclosure and acknowledgment record.
• § 1679d: dated written contract stating payment terms, services, duration, and cancellation language; services cannot begin before the applicable three-business-day waiting period.
• § 1679e: cancellation without penalty before midnight of the third qualifying business day, with duplicate statutory notice forms and signed-document copies.
• § 1679f: noncompliant credit-repair service contracts are void; this is not a rule voiding the underlying card, loan, or other creditor balance.
• § 1679g: specified private damages, possible punitive relief, and attorney-fee consequences, on the statute's predicates.

For TSR-covered sales represented to remove adverse credit information or improve credit history, 16 CFR § 310.4(a)(2) imposes a separate stringent fee condition tied to completion of the represented time frame and a qualifying later consumer report. It must not be generalized to ordinary debt-settlement offers without the relevant credit-repair representation. [C027–C032] uscode.house.gov+5

Operational federal/territorial applicability matrix

Sources/claims: S005, S010, S012, S014–S022, S029; C006–C008, C011–C015, C022–C033, C041–C043.

5. Contracts, cancellation, disbursements, and creditor independence

Chapter 7 authorizes an agency to act as debtor's agent or trustee and to handle money. Section 7110 prohibits commingling debtor property with the agency's own property and requires an account holding debtor money intended for creditors until paid to the debtor or on the debtor's behalf, including lawful agency fees. This is an affirmative Guam rule even where the federal TSR reserve-account provision does not apply. [C020] Uniform Consumer Credit Code

The opened Chapter 7 provisions do not establish a complete mandatory form of consumer agreement, standardized budget review, ability-to-pay test, translated copy, creditor-notification requirement, cancellation form, settlement duration, missed-installment cure, or provider insolvency waterfall. Those questions remain unresolved pending further applicable authority and actual contract terms.

A debt-management plan and a negotiated reduction are not identical:

• DMP: usually a distribution/payment arrangement; its legality and fee treatment depend on whether the agency is acting as intermediary, holding funds, and whether the creditor has accepted changed terms.
• Settlement: proposed reduction or compromise; no provider agreement compels a creditor to accept a reduction.
• Customer-funds account: what the debtor deposited, what the provider lawfully earned, what the creditor received, and what the debtor still owes are four separate balances.

For applicable federal TSR accounts, withdrawal and return-of-funds conditions are specified. For applicable CROA credit-repair contracts, the three-business-day cancellation right is specified. Neither deadline can be copied wholesale into every Guam Chapter 7 counseling contract. No actual calendar due date is calculated here because execution, receipt, business-day, service, and holiday predicates are hypothetical or unspecified. [C020–C021, C026, C029–C031, C041]

6. Territorial and federal consequences

Guam's DTPA, 5 GCA Chapter 32, expressly reaches trade or commerce directly or indirectly affecting people of Guam. It defines “consumer” to include certain smaller business buyers, excluding specified business consumers with assets of $25 million or more or ownership/control by such an entity; however, its special unconscionability cause has narrower non-business-consumer limits. It separately prohibits knowingly offering services without the necessary authorization, material misrepresentations about results, and FTC-rule violations where applicable. [C034, C043] Government Operations+2

A private Guam DTPA damages claimant unrepresented by the Attorney General generally must provide a detailed written pre-suit notice at least 30 days before filing, subject to statutory distinctions and exceptions. That is not a 30-day right to cancel debt relief. A prevailing qualifying claimant may obtain actual and specified other damages, costs and attorney's fees; an additional award up to three times actual damages requires a finding of knowing conduct as a regular business practice. Depending on the claim, §§ 32111–32120 also address restitution, injunctions, and sales induced by prohibited practices. A provider service sale may be unenforceable on specified conditions, but that does not void the debtor's separate original creditor obligation. [C034–C036] Government Operations+2

Guam's Attorney General identifies its Consumer Protection Division as the public unit dealing with deceptive practices and displays a complaint-form resource. The Guam Judiciary and Guam Bar publish references to lawyer and civil legal-assistance resources, with eligibility restrictions. These are read-only informational paths, not evidence that any complaint has been accepted or that a provider is lawful or unlawful. [C038] guamattorneygeneral.org+2

7. Worked applicability examples

These are constructed examples, not findings about an actual provider or borrower. They assume ordinary unsecured consumer debt unless stated otherwise. They do not imply that a creditor must negotiate, stop collecting, or accept any proposed amount.

Example A — An out-of-state settlement company claims that its other-state license and attorney supervision are enough

Assumptions

• A for-profit company operates from a mainland state and offers to negotiate a Guam resident's $12,000 unsecured credit-card debt.
• Its campaign places three interstate sales calls to Guam residents.
• The company says it has a license in its home state and an attorney who supervises its sales staff.
• It does not establish that the service is rendered by an attorney within an applicable statutory exception. No settlement or payment has yet occurred.

Bounded conclusion: It is unsafe to label the arrangement either lawful or unlawful solely from the marketing claim. The decisive documents are the actual service agreement, who performs the work, the compensation and solicitation structure, where transactions are accepted, the attorney's role, and proof of any Guam-specific authority. A provider's claimed status does not establish an exception. Authorities: 14 GCA §§7102–7103; 11 GCA §§70103(e), 70130; 5 GCA §§32301–32302; 16 CFR §§310.2, 310.6; 15 USC §6106. Claims C006–C008, C011–C014, C022–C023, C042–C043.

Example B — The FTC debt-relief fee calculation

Assume, only for this calculation, that the debt-relief telemarketing transaction is covered by the FTC TSR and no exemption applies.

Three debts are enrolled:

Card A is the only debt settled. The creditor and consumer execute a valid agreement for the consumer to pay $2,400.00 to satisfy Card A, and the consumer has made the first $200.00 payment under that agreement. The agreement with the provider specifies either of these hypothetical alternative fee structures, not both:

Method 1 — Proportional total fee

• Hypothetical fee for resolving the full $20,000 enrolled balance: $4,000.00.
• Card A's fraction of enrolled balances: $4,000.00 ÷ $20,000.00 = 0.20.
• Permitted allocation to Card A under §310.4(a)(5)(i)(C)(1), assuming the other prerequisites hold: $4,000.00 × 0.20 = $800.00.

Method 2 — Uniform percentage of savings

• Hypothetical agreed fee rate: 20% of savings, unchanged across individual debts.
• Card A's statutory savings base: $4,000.00 enrolled balance − $2,400.00 actually paid to satisfy = $1,600.00.
• Allocation under §310.4(a)(5)(i)(C)(2): $1,600.00 × 0.20 = $320.00.

Both calculations are exact to the cent; no rounding adjustment is needed. Neither $4,000 nor 20% is a government-set Guam fee or a statutory fee cap. The TSR specifies when and how a chosen contractual fee can become payable; it does not itself establish that the chosen fee is otherwise lawful or reasonable under Guam law.

Before the executed settlement and the customer's first payment: allowable debt-relief-service fee under this TSR provision = $0.00. Once both occur, the applicable allocated fee may be charged for Card A, but no fee for unresolved Cards B or C is unlocked merely because Card A settled. Guam's nonprofit-agency reasonable-fee and schedule requirements, if applicable, still must be independently satisfied. Authority: 16 CFR §310.4(a)(5)(i)(A)–(C); 14 GCA §§7109(4), 7111. Claims C019, C025, C041, C044. ecfr.gov

Example C — Canceling a service with money in a dedicated account

Assumptions

• An individual has deposited $3,000.00 into an account that satisfies all five conditions of 16 CFR §310.4(a)(5)(ii).
• The account is at an insured financial institution, owned by the customer, and administered by a genuinely independent entity that receives no prohibited referral compensation.
• No debt has been settled or otherwise modified under an executed creditor agreement; the customer has made no payment under such an agreement.
• No account interest has accrued; no creditor payment or other authorized withdrawal has occurred.
• The customer requests withdrawal from the service and return of funds.

Calculation:

$3,000.00 balance − $0.00 TSR-compliant earned provider fee = $3,000.00 to return.

For this covered TSR account, withdrawal must be permitted without penalty, and the customer must receive the refundable account money within seven business days of the request. This example deliberately does not convert that period into a calendar date: the request time, business-day counting, and applicable holiday facts were not supplied. A different account arrangement would require a different analysis, including whether it was lawful in the first place.

Guam 14 GCA §7110 separately imposes a segregation requirement on a Chapter 7 agency handling client assets, but this research did not establish that its text creates the identical federal seven-business-day rule. The customer's original creditor has not agreed to forgive any debt merely because the customer deposited money or terminated the provider arrangement. If the original creditor balance is assumed to be $9,000.00 and there have been no creditor payments, credits, accruals, or separate legal events, the initial assumed creditor balance remains $9,000.00—not $6,000.00 or zero. Authority: 16 CFR §310.4(a)(5)(i)–(ii); 14 GCA §7110. Claims C020–C021, C025–C026, C041. ecfr.gov

Additional federal recordkeeping finding

A covered seller or telemarketer must assess the five-year recordkeeping framework in 16 CFR §310.5: material variants, call-level fields, customer information, consent evidence, certain employment records, and other listed records. The regulation has different retention triggers for certain materials, an exception for specified fields of manually dialed single-number calls, time-format requirements, a narrowly conditioned error defense, and rules assigning responsibility between sellers and telemarketers. An outsourcing contract does not necessarily relieve the seller of oversight. This is not a five-year Guam Chapter 7 record-retention rule: Chapter 7's own records requirement must be read separately. Claim C047. ecfr.gov ecfr.gov

Separate bankruptcy approval list—important distinction

The U.S. Trustee Program has a public Guam-specific list of approved pre-bankruptcy credit counseling agencies, including remote delivery methods. That federal bankruptcy-approval list is not evidence that every listed organization holds every authorization required for ordinary Guam debt-management or settlement services. Conversely, authorization under Guam Chapter 7 would not by itself establish U.S. Trustee approval. The list was opened on October 26, 2026, without a provider-specific inquiry. Claim C048. United States Department of Justice gud.uscourts.gov

8. Read-only evaluation checklist

For an individual comparing services, the research supports checking the following documents and representations, without enrolling, transmitting private records, or contacting any provider as part of this assignment:

1. Service identity: Is this an original lender making a new loan, a creditor collecting its own debt, a nonprofit DMP distributor, a negotiated-settlement firm, a credit-repair business, or some combination?
2. Legal identity and asserted exemption: Exact legal entity, place of operation, nonprofit status evidence if claimed, attorney's actual functions, claimed Guam business/license/Chapter 7 status, and whether any claimed exemption covers these exact services.
3. Solicitation history: Who initiated any telephone call, where each party was located, whether there was a prior relationship or in-person meeting, and how and when the contract was signed.
4. Full fee schedule: Enrollment, monthly, per-debt, success, cancellation, account-admin, donation, and creditor/fair-share payments, identifying who pays whom and what event triggers a charge.
5. Agreement and disclosures: Full signed agreement; all promised outcomes; expected timeframe; material risks of nonpayment; conditions for creditor participation; whether the provider can change fees; actual cancellation instructions.
6. Funds trail: Customer ownership, depository institution and insurance status, administrator affiliation, statements and disbursement ledger, provider withdrawals, and refund instructions.
7. Proof of actual creditor change: Written creditor or collector agreement and proof of required payments. A provider dashboard or enrollment receipt does not substitute for creditor consent.
8. Outcome if it fails: What happens if no creditor agrees, the consumer cannot keep saving, the service is terminated, or a promised credit-report improvement does not materialize?
9. Alternatives to compare: Reviewing the obligation directly with the original creditor, a genuinely qualified nonprofit counseling route, and independent legal assistance where rights or litigation exposure are uncertain. This is an information checklist, not a recommendation to enroll, settle, borrow, default, or contact anyone.

The documentary questions above implement the classification, fee, contract, funds, and enforcement distinctions in C006–C043 and C047–C048. The six unrelated debt-law dimensions remain expressly deferred.

9. Complete source register

Register convention. IDs use J_GU-P01-S###. Every entry below was checked or rechecked on October 26, 2026 (America/Los_Angeles); 26 Oct in each row means that date, not the source's publication date. “PDF P” is the zero-based PDF page index; “print p.” is the page number displayed in the document itself. “HTML” means no PDF page index applies. An opened, machine-extracted PDF was not pixel-reviewed. “Consolidated” describes the source's presentation; it does not independently prove inclusion of all later enactments.

Territorial statutes, rules, and official source gateways

Federal text and applicability gateways

Courts, complaints, and assistance sources

Source-search limitation: S007, portions of S011/S041, late-2026 public-law changes, and the local-court search interface were not independently verified as complete operative text. Searches and indexes are explicitly recorded as discovery or bounded negative results, not converted into substantive law. The full Chapter 7 body was read earlier in this pass; its later intermittent reopening failure is preserved in S005.

10. Claim register — A066 / Guam provider-regulatory pass

All claims below are scoped to A066 / J_GU PASS-01. The time marker is October 26, 2026, against the requested October 22 baseline. S### means the full direct URL and access qualifications in the source register above. “High” means the identified operative provision was read; it does not mean complete 2026 legislative-currentness verification or independent legal review. “Partial” or “hold” identifies a narrower evidentiary limitation.

Territorial authority, classification, and authorizations

Federal overlays and fees

Territorial/federal remedies, evidence limits, and examples

Arithmetic clarification to Example B / C044: Section 310.4(a)(5)(i)(C)(2) defines savings against the amount actually paid to satisfy the debt. For the illustrated $320 savings-based fee, assume the customer subsequently completes all agreed installments totaling $2,400.00 and thereby satisfies Card A before the final savings base is calculated. Immediately after only the first $200 installment, $2,400 actually paid would be inaccurate; a purported final savings amount must not be inferred solely from the remaining promise. The alternative $800 proportional-fee illustration uses the contractually specified total fee and the enrolled balances, subject to the other TSR fee-release requirements. This resolves the numerical sequencing distinction without inventing a different rate or entitlement.

A fresh opening of S005 through the official indexed result also succeeded after the intermittent direct-URL error recorded in the source register. It reaffirmed the entire five-page Chapter 7 body, including §§7102(2)(a)–(e), all five §7103 exceptions, the $5,000 §7107 bond, two-year §7108 retention, and §§7109–7113. This improves confidence in those textual claims but does not close the 2026 amendment-currentness hold. Uniform Consumer Credit Code

11. Granular coverage and gap register

Status meanings:

• Answered: The narrow rule or distinction identified in the row is supported by opened primary text, subject to the stated version limitation.
• Partial: A material part is established, but a necessary legal or operational branch remains unresolved.
• Unresolved: The requested proposition cannot be determined responsibly from the evidence obtained.
• Excluded_with_reason: Deliberately assigned to another A066 component, with only an essential intersection addressed here.

All C### references point to J_GU-P01-C###, tagged A066 above.

Item 1 — Territorial authority, hierarchy, and applicability

Item 2 — Provider classification

Item 3 — License, registration, exemptions, and supervision

Item 4 — Permitted services, fee amount and timing

Item 5 — Agreement, cancellation, creditor participation, and customer funds

Item 6 — Consequences, remedies, process and resources

Six deferred parent dimensions

12. Bounded official search and decision results

This table records what was actually examined. An unsuccessful or incomplete search is not affirmative proof that a law or decision does not exist.

Operational hold/allow matrix

The following is a research decision matrix, not permission to operate a debt-relief business.

13. Precise unresolved questions and publication holds

These are not minor editorial qualifications. They should remain visible in any coordinator handoff or draft intended to explain Guam legal requirements.

1. Amendment reconciliation: Have any laws through P.L. 38-145 altered Chapter 7, Chapter 6, the relevant 11 GCA provisions, or 5 GCA Chapter 32, directly or by broader reorganization? The older PDFs and table cutoff do not fully answer that.

2. Current UCCC Administrator: Who presently exercises the 14 GCA Chapter 6 Administrator's powers, under which current delegation, and through which legally prescribed process? S007 did not yield opened operative text. The historical 15 GAR identification should not be promoted to a conclusively current assignment.

3. Special registration practice: Does the Chapter 7 notice, corporation approval, and bond filing operate solely as the specified statutory prerequisites, or do current regulations require additional review/renewal, approvals or reporting? No specialist public application instructions were verified.

4. Remote reach: Does §7103 apply to every wholly off-island person servicing a Guam resident online, or only transactions meeting particular Guam nexus rules? The express reach of phone-seller §32302 is not by itself an answer to Chapter 7.

5. Telephonic-sale interpretive issue: Precisely when does §32301's later signed-contract exclusion apply, given §32304's separate written-contract requirement? A definitive operational statement needs full-text reconciliation and, preferably, an authoritative construction.

6. Nonprofit governance: Are the §7104 organization language and Judicial Council endorsement still administered exactly as originally enacted, including for nonresident nonprofits? What corporate-law amendments or administrative requirements matter?

7. Fee oversight: Does a submitted §7111 fee schedule require acceptance, approval or only filing, and what standard or formal procedure determines “reasonable” fees? No numeric Chapter 7 fee cap was identified in the full chapter; no alternative cap may be invented.

8. Financial assurances: Is there any current additional insurance, net-worth, bond-renewal, depository or audited-reporting requirement in unread current regulations? The demonstrated $5,000 Chapter 7 bond cannot answer all those questions.

9. Consumer contracts/cancellations: Beyond telephonic sales, CROA and TSR account withdrawal, what specific current Guam contractual, refund, translation or rescission rules apply to particular models? The lack of a comprehensive form in Chapter 7 is not a general exemption.

10. Customer money: For a Guam Chapter 7 agency outside the covered TSR reserve-account route, which law supplies exact disbursement cadence, ledger statements, reconciliation, insolvency priority and refund deadlines? Segregation alone does not settle them.

11. Exempt actors: What happens in combinations such as an independent sales company retaining a Guam lawyer, a creditor-paid nonprofit counseling program, a bank affiliate offering both lending and paid debtor negotiation, or a remote §501(c)(3) that has not completed Chapter 7 organization steps? Each needs predicate-by-predicate analysis.

12. Federal overlap and enforcement: Determine precise FTC jurisdiction for any true nonprofit arrangement; the applicable TSR campaign exclusions; and whether/how Guam's AG may use the distinct federal CROA §1679h and Telemarketing Act §6103 state-officer routes. Territorial DTPA authority should not be treated as proof of every federal route.

13. Court and administrative decisions: Accessible case indexes did not establish a square provider holding. Search completeness and any unpublished agency decisions remain unresolved. Adjacent bank/lease business-license annotations are not substitutes.

14. Current public lookups: No specialized public Chapter 7 roster or status-verification workflow was established. The DOJ bankruptcy list is a different approval system. No individual provider verification was attempted.

15. Calendar and remedy application: No contract execution date, consumer request, service method, holidays, actual creditor payment or lawsuit record exists in this assignment. Therefore, no live cancellation date, filing deadline, damages award, restitution amount, bond recovery or settlement discharge is calculated.

16. Commercial and secured arrangements: The exact business-consumer and secured-credit consequences under each adjacent statute may differ; broader product-specific analysis remains queued under the other A066 dimensions.

Publication decision by assertion type

14. Scoped researcher self-check

Final scoped assessment

The strongest Guam-specific finding is not a conventional for-profit debt-settlement license with a published fee cap. It is a broadly worded statutory prohibition and nonprofit credit-counseling structure in 14 GCA §§7102–7103, with detailed organizational, bond, recordkeeping, fee-schedule and segregation requirements in §§7104–7111. The applicability of that structure to a particular remote, attorney-operated, nonprofit, creditor-funded or mixed-service provider requires its exact statutory facts and presently unresolved territorial/administrative questions.

Independently, a service that satisfies the FTC Telemarketing Sales Rule's territorial, campaign, service and nonexemption tests faces substantive disclosure, fee-release, account and recordkeeping requirements. Guam's distinct telephonic-seller and deceptive-trade laws may also apply on their own definitions. A credit-repair representation can add CROA and the separate TSR credit-repair rule. No one layer replaces the others, and none guarantees creditor cooperation or debt cancellation.

Pass disposition: Focused research findings and all visible evidence tables delivered, with explicit holds. No Guam territory-dossier, provider-component, seven-dimension parent, A066, operational, legal-compliance or publication acceptance is asserted. Consequential authority, arithmetic and coverage remain subject to the coordinator's independent verification.

END J_GU PASS-01